U. S. Department of Transportation

Federal Highway Administration

Fiscal Year 2020

MANAGEMENT

DIRECTIVE 715 

ANNUAL EEO PROGRAM 

STATUS REPORT
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 1 of 99

Table of Contents

Parts A – E. Identification, General Employment Totals, and Executive Summary ..................... 2

Part F. Certification of Establishment of Continuing EEO Programs ......................................... 27

Part G. Agency Self-Assessment Checklist Measuring Essential Elements................................ 28

Part H. EEO Plan to Attain the Essential Elements of a Model EEO Program........................... 60

Part I. EEO Plan to Eliminate Identified Barriers........................................................................ 69

Part J. Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of 

Persons with Disabilities............................................................................................................... 73
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MD-715 

Parts A Through E 

Part A - Department or Agency Identifying Information 

Agency Second Level 

Component Address City State Zip Code 

Agency

Code

FIPS 

Code

U.S. 

Department of 

Transportation 

Federal 

Highway 

Administration

1200 

New 

Jersey 

Avenue, 

SE

Washington DC 20590 TD04 11001

00001 

Part B - Total Employment 

Total Employment Permanent 

Workforce

Temporary 

Workforce Total Workforce 

Number of 

Employees 2759 8 2767 

Part C.1 - Head of Agency and Head of Agency Designee 

Agency 

Leadership Name Title

Head of Agency Stephanie Pollack Acting Administrator

Head of Agency 

Designee Stephanie Pollack Deputy Administrator 

Part C.2 - Agency Official(s) Responsible for Oversight of EEO Program(s) 

EEO Program 

Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number

Email 

Address

Principal EEO 

Director/ Official Irene Rico

Associate 

Administrator 

for Civil 

Rights

340 SES

202-

366-

0693

Irene.ric

o@dot.g

ov

Affirmative 

Employment 

Program 

Manager

Nikisha 

M. Pickett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

360 GS-14

202-

366-

3894

Nikisha.

pickett

@dot.go

v
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EEO Program 

Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number

Email 

Address

Complaint 

Processing 

Program 

Manager

Nikisha 

M. Pickett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

360 GS-14

202-

366-

3894

Nikisha.

pickett

@dot.go

v

Diversity & 

Inclusion Officer

Maisha 

Foskey 

Division 

Chief, HR 

Operations

201 GS-15

202-

366-

3103

Maisha.

Foskey

@dot.go

v

Hispanic 

Program 

Manager 

(SEPM)

Nikisha 

M. Pickett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

360 GS-14

202-

366-

3894

Nikisha.

pickett

@dot.go

v

Women's 

Program 

Manager 

(SEPM)

Nikisha 

M. Pickett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

360 GS-14

202-

366-

3894

Nikisha.

pickett

@dot.go

v

Disability 

Program 

Manager 

(SEPM)

Kirsten 

Poston 

Disability 

Policy 

Analyst

301 GS-13

202-

559-

5116

Kirsten.

poston

@dot.go

v

Special 

Placement 

Program 

Coordinator 

(Individuals with 

Disabilities)

Marlo 

Moises

Lead Human 

Resources 

Specialist

201 GS-14

202-

493-

0955

Marlo.m

oises@d

ot.gov

Reasonable 

Accommodation 

Program 

Manager

Kirsten 

Poston 

Disability 

Policy 

Analyst

301 GS-13

202-

559-

5116

Kirsten.

poston

@dot.go

v

Anti-Harassment 

Pilot Program 

Manager

Pamela 

McCormic

k

Program 

Analyst 343 GS-13

202-

366-

1607

Pamela.

mccormi

ck@dot.

gov
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EEO Program 

Staff Name Title Occupational 

Series

Pay 

Plan 

and 

Grade

Phone 

Number

Email 

Address

ADR Program 

Manager

Nikisha 

M. Pickett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

360 GS-14

202-

366-

3894

Nikisha.

pickett

@dot.go

v

Compliance 

Manager

Nikisha 

M. Pickett

Internal EEO 

and Special 

Emphasis 

Program 

Manager

360 GS-14

202-

366-

3894

Nikisha.

pickett

@dot.go

v

Principal MD715 PreparerKirsten 

Poston 

Disability 

Policy 

Analyst

301 GS-13

202-

559-

5116

Kirsten.

poston

@dot.go

v

Part D.1 – List of Subordinate Components Covered in this Report

 If the agency does not have any subordinate components, please check the box.

Subordinate Component

Division Office – The FHWA has a Division 

office in each of the 50 states, the District of 

Columbia and Puerto Rico. 

City State Agency 

Code

FPIS 

Code

Alabama Division Office Montgomery AL TD04 12130

101 

Alaska Division Office Juneau AK TD04 21130

110 

Arizona Division Office Phoenix AZ TD04 40370

013 

Arkansas Division Office Little Rock AR TD04 52320

119 

California Division Office Sacramento CA TD04 63150

067 

Colorado Division Office Lakewood CO TD04 81435

059 

Connecticut Division Office Glastonbury CT TD04 90255

003 

Delaware Division Office Dover DE TD04 10013

0001 

District of Columbia Division Office Washington DC TD04 11001

0001 
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Subordinate Component

Division Office – The FHWA has a Division 

office in each of the 50 states, the District of 

Columbia and Puerto Rico. 

City State Agency 

Code

FPIS 

Code

Florida Division Office Tallahassee FL TD04 12294

0073 

Georgia Division Office Atlanta GA TD04 13028

0089 

Hawaii Division Office Honolulu HI TD04 15240

0003 

Idaho Division Office Boise ID TD04 16016

0001 

Illinois Division Office Springfield IL TD04 17822

0167 

Indiana Division Office Indianapolis IN TD04 18221

0097 

Iowa Division Office Ames IA TD04 19023

0169 

Kansas Division Office Topeka KS TD04 20540

0177 

Kentucky Division Office Frankfort KY TD04 21122

0073 

Louisiana Division Office Baton Rouge LA TD04 22015

0033 

Maine Division Office Augusta ME TD04 23016

0011 

Maryland Division Office Baltimore MD TD04 24005

0510 

Massachusetts Division Office Cambridge MA TD04 25017

0017 

Michigan Division Office Lansing MI TD04 26270

0037 

Minnesota Division Office St. Paul MN TD04 27633

0123 

Mississippi Division Office Jackson MS TD04 28122

0049 

Missouri Division Office Jefferson City MO TD04 29404

0027 

Montana Division Office Helena MT TD04 30059

0049 

Nebraska Division Office Lincoln NE TD04 31283

0109 

Nevada Division Office Carson City NV TD04 32005

0510 
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Subordinate Component

Division Office – The FHWA has a Division 

office in each of the 50 states, the District of 

Columbia and Puerto Rico. 

City State Agency 

Code

FPIS 

Code

New Hampshire Division Office Concord NH TD04 33007

0013 

New Jersey Division Office West Trenton NJ TD04 34338

0021 

New Mexico Division Office Santa Fe NM TD04 35071

0049 

New York Division Office Albany NY TD04 36005

0001 

North Carolina Division Office Raleigh NC TD04 37375

0183 

North Dakota Division Office Bismarck ND TD04 38037

0015 

Ohio Division Office Columbus OH TD04 39180

0049 

Oklahoma Division Office Oklahoma City OK TD04 40355

0017 

Oregon Division Office Salem OR TD04 41181

0047 

Pennsylvania Division Office Harrisburg PA TD04 42350

0043 

Puerto Rico Division Office San Juan PR TD04 72-127 

Rhode Island Division Office Providence RI TD04 44019

0007 

South Carolina Division Office Columbia SC TD04 45052

0063 

South Dakota Division Office Pierre SD TD04 46216

0065 

Tennessee Division Office Nashville TN TD04 47176

0037 

Texas Division Office Austin TX TD04 48033

0453 

Utah Division Office Salt Lake City UT TD04 49170

0035 

Vermont Division Office Montpelier VT TD04 50038

0023 

Virginia Division Office Richmond VA TD04 51206

0760 

Washington Division Office Olympia WA TD04 53159

0067 
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Subordinate Component

Division Office – The FHWA has a Division 

office in each of the 50 states, the District of 

Columbia and Puerto Rico. 

City State Agency 

Code

FPIS 

Code

West Virginia Division Office Charleston WV TD04 54048

0039 

Wisconsin Division Office Madison WI TD04 55278

0025 

Wyoming Division Office Cheyenne WY TD04 56010

0021 

Federal Lands Highway Division Offices TD04 11001

0001 

Part D.2 – Mandatory and Optional Documents for this Report

In the table below, the agency must submit these documents with its MD-715 report.

Did the agency submit the following 

mandatory documents? 

Please 

respond

Yes or No

Comments

Organizational Chart YES

EEO Policy Statement YES

Strategic Plan YES

Anti-Harassment Policy and Procedures YES

Reasonable Accommodation Procedures YES

The Departmental Office of Civil 

Rights will be submitting this 

document on behalf of the 

Department.

Personal Assistance Services Procedures YES

The Departmental Office of Civil 

Rights will be submitting this 

document on behalf of the 

Department.

Alternative Dispute Resolution Procedures YES

The Departmental Office of Civil 

Rights will be submitting this 

document on behalf of the 

Department. 

In the table below, the agency may decide whether to submit these documents with its MD-715 

report.
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Did the agency submit the following 

optional documents? 

Please 

respond

Yes or No

Comments

Federal Equal Opportunity Recruitment 

Program (FEORP) Report YES

Disabled Veterans Affirmative Action 

Program (DVAAP) Report YES

Operational Plan for Increasing 

Employment of Individuals with 

Disabilities under Executive Order 13548 

YES

The Departmental Office of 

Civil Rights will provide this 

plan. 

Diversity and Inclusion Plan under 

Executive Order 13583 YES

Diversity Policy Statement YES

Human Capital Strategic Plan YES

The Departmental Office of 

Human Resource Management 

will provide this plan. 

EEO Strategic Plan YES

Results from most recent Federal 

Employee Viewpoint Survey or Annual 

Employee Survey 

YES

FHWA conducts an All 

Employee Survey every 2 years 

in addition to OPM’s Federal 

Employee Viewpoint Survey 

(FEVS).

Part E – Executive Summary

All agencies must complete Part E.1; however, only agencies with 199 or fewer employees in 

permanent FT/PT appointments are required to complete Part E.2 to E.5. Agencies with 200 or 

more employees in permanent FT/PT appointments have the option to complete Part E.2 to E.5.

Part E.1 - Executive Summary:

The Federal Highway Administration (FHWA) submission of the annual Equal Employment 

Opportunity Program Status Report for Fiscal Year 2020 (FY 20) Management Directive 715 

report and plan was prepared in accordance with the U.S. Equal Employment Opportunity 

Commission laws and authority governed under Section 717 of the Civil Rights Act of 1964, as 

amended; and Section 501 of the Rehabilitation Act of 1973, as amended. This report highlights 

FHWA’s accomplishments in establishing and maintaining a model Equal Employment 

Opportunity (EEO) Program for FY 20. 
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The FHWA is an Operating Administration within the U.S. Department of Transportation (DOT) 

that supports State and local governments in the design, construction, and maintenance of the 

Nation’s highway system (Federal-aid highway program) and various Federal and Tribal owned 

lands (Federal Lands Highway Program). Through financial and technical assistance to State 

departments of transportation, local governments, Federal agencies, Tribal governments, FHWA 

is responsible for ensuring that America’s roads and highways continue to be among the safest 

and most technologically sound in the world. 

The top-level official of FHWA is the Administrator, who reports directly to the Secretary of 

DOT. The FHWA organizational structure includes a Washington D.C., Headquarters with 14 

program offices, 3 Federal Lands Highway Division Offices, and 52 Federal-aid Division Offices 

(one in every State, the District of Columbia, and Puerto Rico). 

The FHWA’s mission is to “enable and empower the strengthening of a world-class highway 

system that promotes safety, mobility, and economic growth, while enhancing the quality of life 

of all Americans.”

Part E.2 - Executive Summary: Essential Element A – E 

Element A- Demonstrated Commitment from Agency Leadership

The FHWA continues to commit to the principles of EEO and maintaining a successful EEO 

Program. This commitment continues to be demonstrated throughout the Agency’s hierarchy 

from senior executives, managers and supervisors to all employees. Efforts to demonstrate this 

commitment includes the following:

• Status of the Agency’s MD-715 is provided to senior leadership on an annual and 

ongoing basis. 

• Senior leaders support, encourage and participate in monthly observances and events 

• Senior leadership participates in annual training sessions such as Anti-Harassment 

Training. 

The annual Administrator’s Awards Program has an award category, “Diversity and Inclusion 

Award” dedicated to giving recognition to individuals and/or teams for their significant 

contributions to EEO, Civil Rights, and Diversity and Inclusion while advancing the 

Administrator’s commitment to maintaining a high performing organization. 

On February 24, 2021, Stephanie Pollack was named Acting Administrator of FHWA. In this 

role, Ms. Pollack provides executive leadership and strategic direction within FHWA to advance 

goals and priorities of the Department as well as provide direction to a 2,700-person Agency and 

oversees an annual budget of $49 billion. 

The FHWA’s Executive Director Tom Everett selection was announced on October 22, 

2018. As Executive Director, Mr. Everett manages the Agency’s daily operations and its 

personnel, and advises the Administrator, Deputy Administrator and senior officials throughout 

DOT. 
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Senior Leadership demonstrates their commitment to advancing a model EEO Program through 

their participation in FHWA’s Diversity Management Committee Women’s Forum series, setting 

expectations for the Anti-Harassment Program, and supporting Special Emphasis programs. 

All Employee Survey Updates

Since the early 1990’s, FHWA has been conducting the “FHWA All Employee Survey (AES).” 

The FHWA AES was originally conducted on an annual basis, and when The Office of 

Personnel Management (OPM) began conducting the Federal Employee View Point Survey 

(FEVS) on an annual basis the FHWA AES started to be conducted only in the odd years. 

The FHWA AES had 2,128 employees who shared their thoughts and provided feedback. The 

division employees led the way with a 92% response rate overall; 34 division offices had a 

response rate of 90% or above, and 17 of those offices reported at 100%. The Office of the 

Administrator and the Directors of Field Services Office also reported 100% participation. The 

number of respondents and participation rates from primary groups in the Agency are shown 

below.

FHWA Headquarters 627/866 72% 

Office of Technical Services 112/138 81% 

Federal-aid Division Offices 926/1008 92% 

Federal Lands Highway 463/638 73% 

Based on the results of the survey, the Human Resources Management Committee (HRMC) 

created an action plan to address lower scoring items. The action plan includes objectives that 

address the needs across the Agency in different offices. Each objective has a champion and the 

HRMC compiles a status of the actions twice a year to present to Agency leadership. The 

HRMC action plan is released to Agency staff. The HRMC offers listening sessions to increase 

input on employee concerns. 

Element B- Integration of EEO in the Agency’s Strategic Mission

The FHWA Strategic Plan (2019-2022) outlines the goals and objectives of FHWA and 

supersedes the previous FHWA Performance Year 2018/19 Strategic Implementation Plan. This 

plan was developed to align FHWA efforts with the FY 2018-2022 DOT Strategic Plan and 

reflects the priorities of Agency leadership. In the DOT Strategic Plan, one of the Goals is 

Accountability, which has been adopted from the DOT Strategic Plan. 

Under Accountability: Management Objective 2- Mission Efficiency and Support. Strategies 

“Workforce: Attract, develop, and retain employees who have the capabilities and competencies 

to help the Department achieve its goals.” 

To improve the efficiency and effectiveness of the organization, FHWA/DOT continues to 

recruit, hire and retain employees from all segments of American society with the right skills, 

and provide the training and professional development opportunities they need to help DOT 

successfully achieve its goals. The Agency conducted a wide number of programs and activities 
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as outlined in the Unit Performance Plans during the reporting period that reflect leadership 

commitment:

• The Associate Administrator for the Office of Civil Rights has the authority and 

resources to effectively deliver a successful EEO Program and leads the day to day 

FHWA Civil Rights operations and reports to the Agency’s Executive Director. The 

FHWA Office of Civil Rights provides technical guidance in the implementation of EEO 

programs at the national level including the development of action plans as required by 

MD-715 and EEOC guidance. 

• In our effort to gather disability data, FHWA continued its efforts to resurvey the 

workforce resulting in an increased number of employees completing the revised SelfIdentification of the Workforce Standard Form (SF-256 form). All employees were 

encouraged to self-identify or update their information using descriptions from OPM’s 

Self-Identification of Disability through their Employee Express system account. All 

disability codes have been updated in the HR information system therefore increasing the 

Agency’s PWD and PWTD population. 

• Offices included Diversity and Inclusion (D & I) efforts within their Unit Performance 

Plans (UPP).

• The FHWA continued to implement and finalized FHWA’s pilot Anti-Harassment 

Process into a permanent Anti-Harassment Process. 

• Promoted programs that engage employee participation in committees that support efforts 

to improve FHWA as an organization. 

• Employees are encouraged in their technical field/discipline to enhance knowledge 

management throughout the Agency and support closing competency gaps through 

discipline learning and development. 

• The FHWA continues to promote a culture that recognizes employee contributions using 

informal and formal recognition programs at the local and national level. 

• Diverse pipeline recruitment initiatives included the Professional Development Program, 

Rotational Developmental Assignment Clearinghouse, and expanded Career 

Development Programs. 

Element C- Management and Program Accountability 

FHWA’s employees received updated training on EEO, Prevention of Harassment, and 

Reasonable Accommodations through the FHWA Office of Civil Rights. FHWA’s Office of 

Civil Rights Website includes details related to Anti-Harassment, EEO, and Prevention of 

Harassment. It provides an overview of each section, laws, points of contact, and other 

resources. https://www.fhwa.dot.gov/civilrights/.

The Office of Human Resources sponsored a Webinar on Federal Hiring Authorities including 

providing information on Schedule A hiring authorities in May of 2020 for its corporate 

recruiters, and over 100 FHWA employees attended. 
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The Human Resources Employee Relations staff and staff of the Office of Chief Counsel 

continued to work closely with both the FHWA Civil Rights Disability Program Manager to 

support the reasonable accommodations program throughout our workforce and the AntiHarassment Coordinator to respond to complaints of harassment. 

Reasonable Accommodations and Disability Program 

FHWA’s Disability Program Manager works collaboratively with the Departmental Disability 

Resource Center to process and track reasonable accommodation requests and provide technical 

assistance and training to Managers, Supervisors, and Team Leaders on the Reasonable 

Accommodation Process. In August 2020, the Office of Civil Rights presented at an Office of 

Human Resources sponsored Webinar for FHWA managers/supervisors on the Americans with 

Disabilities Act. More than 80 Managers/Supervisors participated in the Webinar. 

The FHWA along with other Operating Administrations sponsored mock interviews with 

undergraduate students who are deaf and hard of hearing from Gallaudet University in the spring 

and fall of 2020. The mock interviews were an opportunity for students to meet with hiring 

officials and learn about the many various pipeline programs and job opportunities at 

FHWA/DOT. More than 100 students participated, and the interviews were completed virtually 

over a 2-week period virtually with FHWA working in partnership with the Departmental Office 

of Human Resources. 

Special Emphasis Programs 

The FHWA Office of Civil Rights continues to utilize Special Emphasis Programs and continues 

to engage with Employee Resource Groups to increase employees’ awareness of the importance 

of diversity and to demonstrate the Agency’s commitment as a model EEO workplace. The 

Agency has continued to host a series of Webinars that were intended to educate the workforce 

about the different Employee Resource Groups within the Agency. 

In FY 20, FHWA distributed to staff, championed, and supported the delivery of the following 

DOT Special Emphasis Program Events: 

• African American History Month 

• National Hispanic Heritage Month

• Women’s History Month (note: the event was planned; however, it was cancelled due to 

the pandemic)

In addition, FHWA developed messaging and informational materials in support of the following 

FHWA Special Emphasis Program Events: 

• Asian and Pacific Islander Heritage Month: On May 14, 2020, the FHWA Office of 

Civil Rights invited FHWA employees to participate in Virtual DOT, 2020 Asian 

American and Pacific Islander Heritage Month celebration via zoom event that was held 

on Friday, May 22, 2020. 
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• National American Indian Heritage Month: A presentation on the FHWA’s Office of 

Tribal Transportation and the importance of this office when it comes to partnering with 

Tribal nations was delivered on December 11, 2019. 

• Gay and Lesbian Pride Month: In honor of Lesbian, Gay, Bisexual, Transgender and 

Queer (LGBTQ) Pride Month and the 50th Anniversary of Stonewall uprising, the 

FHWA, Office of Civil Rights shared information and resources about this observance on 

June 22, 2020. 

Targeted Recruitment and Outreach Efforts 

As a result of FY 2019 reporting, the FHWA has continued to build upon the revamped 

Corporate Recruitment efforts to address the low representation of women, Hispanic women and 

individuals with disabilities in the FHWA workforce. The FHWA attended recruitment and 

outreach events designed to provide access to targeted audiences from these populations and 

other underrepresented groups. The events included: (1) collaborating with FAA to implement a 

hiring event titled: Federal Opportunities for People with Disabilities (2) a Recruit Military 

hiring event (3) Careers and the Disabled Magazine's hiring event (4) Hiring events at Gallaudet 

University and the Rochester Institute of Technology, both diverse pools of talent for people 

with disabilities (5) Six hiring events organized by HBCUs (6) Three diversity themed hiring 

fairs (7) Four hiring fairs organized by Hispanic Affinity Groups (8) Three hiring events 

organized for females applicants (9) One hiring event organized for Asian Americans and one 

hiring event for Indian Americans. 

The FHWA utilized a variety of recruitment resources, including online services; social media; 

the Workforce Recruitment Program Database; OPM Shared List of People with Disabilities 

Database; State and local vocational rehabilitation agencies and employment offices; educational 

institutions, colleges and universities; and USAJOBS, to attract people with disabilities for 

FHWA job opportunities. The FHWA vacancy announcements continue to be marketed on free 

recruitment sites to increase the visibility in those specific communities.

Education/Outreach on Schedule A

FHWA’s Office of Human Resources continued to host several one-on-one consultative sessions 

with hiring managers to discuss various staffing and recruitment initiatives which included 

different hiring authorities. The database of Schedule A applicants was sorted by occupation to 

allow easier review by hiring managers. These hiring authorities (including Schedule A) 

continue to help hiring managers decrease time-to-hire and ensure that plans of action that place 

qualified applicants in the Agency’s positions are followed, including mission critical 

occupations. 

Addressing Generational Diversity

FHWA continues to employ an advisory group called the Innovation Exchange (iExchange), a 

multi-generational forum focused on exchanging ideas and inspiring innovation. While 

promoting and facilitating generational diversity, the iExchange creates an environment that 

welcomes members and encourages the overall diversity of the Agency. Sponsored by the 

Knowledge Management (KM) unit, the iExchange expanded its membership to over 250 
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employees. Over the course of FY 20, the advisory group held another virtual speed networking 

event, several crowdsource (brainstorm) sessions, and continued to work with FHWA offices, 

committees, and councils to provide ideas and a fresh perspective.

Element D- Proactive Prevention of Unlawful Discrimination 

Throughout FY 20, the Office of Civil Rights’ Internal EEO and the Reasonable 

Accommodations Program Managers delivered a series of virtual EEO and Reasonable 

Accommodations training sessions to the following FHWA offices: 

• Office of Research, Development, and Technology

• Arizona Division

• Nevada Division

• Illinois Division

• Texas Division

• New York Division Office

The training sessions’ aim was to ensure employees were familiar with the EEO and Reasonable 

Accommodation processes within FHWA. The virtual training sessions were well received and 

future plans to expand the sessions to cover all FHWA offices is currently in the works for FY 

21/22. 

In June 2020, the Office of Civil Rights recorded and delivered a virtual session training series 

on all of HCR programs (Anti-Harassment, EEO, Reasonable Accommodation, Title VI, 

Disadvantaged Business Enterprise and the Americans with Disabilities Act Program) to our 

Division Administrators. Staff of the Office of Chief Counsel participated in the virtual sessions. 

In December 2019, FHWA finalized the Anti-Harassment Process to comply with the DOT 

Policy Framework and rolled out the process to employees. As part of the rollout, the approved 

process was uploaded onto the Office of Civil Rights Website. A FHWA Anti-Harassment 

expectations memo was signed by our Executive Director and distributed to all employees and 

managers. 

The Office of Civil Rights held a total of 12 sessions to educate employees on the FHWA AntiHarassment process. Eight of those sessions included training of all FHWA management 

personnel on their role in the Anti-Harassment process as well as their rights and responsibilities. 

Staff from the Office of Human Resources and the Office of Chief Counsel participated in the 

development of these Anti-Harassment training sessions and along with the Office of Civil 

Rights served as subject matter experts during the question and answer segments of the training. 

Additionally, in FY 20, FHWA hosted an online virtual series of Prevention of Harassment 

training sessions with the topic being Effective Bystander. The purpose of this new course was 

to help participants better understand how to appropriately respond when witnessing harassment 

in the workplace. 
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Employees learned:

• The definition of a Bystander 

• The critical role of a Bystander 

• The 5 D’s of Bystander intervention 

• How to appropriately respond to harassment in the workplace 

A total of 9 session were held with a total of 585 FHWA employees participating in the sessions. 

The Office of Civil Rights in conjunction with the Office of Human Resources partnered with 

the DMC to provide training on the Anti-harassment, EEO, and Employee Relations processes 

during the February 2020 FHWA Diversity Management Committee Woman’s Forum session. 

Diversity Management Committee 

In support of the Agency’s strategic initiative to increase populations that currently have low 

representation at FHWA and foster a more inclusive organizational environment, FHWA 

continued to utilize its 19-member Diversity Management Committee (DMC or committee) to 

cultivate and advance several initiatives designed to improve organizational culture and raise 

awareness on the importance of having a diverse and inclusive organization. 

The committee selected and trained 32 new Diversity Champions to fill vacant slots for previous 

champions rotating off the program. With a goal to increase diversity, the DMC coordinated 

efforts to support the Agency’s recruitment efforts this year. The committee supported the 

Office of Human Resources and the Office of Civil Rights on the Agency’s HBCU 

competitiveness strategy, a White House initiative to increase and promote engagement between 

the Federal sector and HBCUs. The DMC leveraged internal employees, who are HBCU 

alumni, to create connections with their alma maters and assist with recruiting events and 

information sessions. In addition, the group helped identify resources and tips for diversity 

hiring. Furthermore, the committee collaborated with HR on the development of a Diversity 

Hiring Guide for Hiring Managers. The Diversity Hiring Guide for Hiring Managers is intended 

to offer consolidated tactics and strategies that can work to broaden the applicant pool for 

vacancies and reduce the effects of bias throughout the evaluation and selection process. 

The DMC also continued its Women’s Forum Webinar series which is designed to foster greater 

interaction among female employees at all levels of the Agency. The committee conducted two 

Webinars with the aim of providing a safe and engaging discussion platform for all employees to 

network with each other and address issues of common interest, such as career growth, 

mentoring, professional development, and identifying challenges in the workplace - especially 

those impacting women. 

With the Agency’s diversity education goals in mind, the DMC also identified several training 

modules available in DOT Learns that teach the principles of diversity and inclusion. The 

committee was able to identify two modules that address diversity and the benefits of inclusion, 

while providing a better understanding of how unconscious bias can undermine our efforts to be 

inclusive. The FHWA added the courses to all employees’ DOT Learns learning plans and 
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encouraged them to take the courses. Nearly a third of our workforce—have taken one or more 

of the training modules. 

In an effort to improve cultural awareness, the DMC also created a monthly Diversity Awareness 

newsletter which highlights a wide range of observances and traditions that acknowledge unique 

segments of our population. Furthermore, the DMC decided to build from last year’s effort to 

capture all of the Departmental Employee Resource Groups within a distribution list and added 

the listing to the New Employee Orientation Program. 

The DMC also continued its role in conducting diversity presentations at a large number of 

requesting program offices and one of the Discipline Support System Seminars. In a year 

marked by one of the greatest social justice movements in history, the DMC and its Diversity 

Program Manager conducted 14 conversations centered around race. Three of the sessions were 

agencywide corporate sessions that garnered attendee counts ranging from 250 to 300 

employees.

Element E- Efficiency 

In FY 20, FHWA timely submitted to the EEOC the Annual Federal EEO Statistical Report of 

Discrimination Complaints (EEOC Form 462). In addition, FHWA timely submitted to 

Congress the Annual Notification and Federal Employee Anti-discrimination and Retaliation Act 

of 2002 (No FEAR Act) report. Furthermore, FHWA submitted its annual FEEORP to OPM in 

December 2020.

The FHWA continues to ensure that all EEO policies were prominently posted in all personnel 

offices, employee bulletin boards, and on the FHWA Civil Rights Website. All policies related 

to anti-discrimination laws, Civil Rights, the EEO complaint process, Departmental Reasonable 

Accommodations policies and ADR have been posted on the FHWA Website. 

Element F- Responsiveness and Legal Compliance

The FHWA continues to maintain the goal of full compliance with all EEO statutes, regulations, 

policy guidance, and other written instructions. All Agency personnel are held accountable for 

timely compliance with orders issued by the EEOC. 

Plans for addressing newly identified gaps from prior fiscal years are further discussed in Part H 

of this report. 

Part E.3 - Executive Summary: Workforce Analyses

As of September 30, 2020, FHWA onboard strength showed a 

total of 2,767 employees, of whom 2,759 were permanent employees and 8 were temporary 

employees. 

The FHWA is starting to see improvements in targeted areas. In FY20, FHWA slightly 

exceeded its goal of 12% of hires of PWD and its 2% goal of PWTD onboard. In FY20, 

approximately 12.04% of all new hires were PWD, and 2.01% were PWTD. Overall, PWTD 

comprise 2.75% of the total FHWA workforce which was slightly lower than the 3.05% reported 
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for FY 19 (This number includes hires from other DOT modes, and therefore is not demonstrated 

by the workforce tables). 

Veterans with 30% or more disability represent 7.7% of all hires and make up 3.5% of the total 

workforce. 

The FHWA reports out the following regarding the overall diversity of its workforce between FY 

10 and FY 20: 

1) Hispanics in FHWA’s permanent workforce had a slight increase from 8.95% to 9.31% 

2) Black or African Americans in the permanent workforce had a slight increase from 

15.06% to 15.55%; and 

3) PWD stayed fairly consistent from 10.78% to 10.84% of the FHWA permanent 

workforce. 

4) PWTD had a slight decrease from 3.06% to 2.75% of the FHWA permanent workforce. 

* This number is inclusive of hires from other DOT modes, and not accounted for in the 

workforce tables.

Although FHWA continues to be successful in its efforts to diversify its workforce, the 

representation of persons with disabilities, White females and Hispanic females remain areas 

where FHWA needs to continue its efforts. In addition, FHWA will look to dive deeper into the 

workforce analysis in relation to hiring rate and separation rates of FHWA employees based 

upon race, gender, and disability demographics. These areas of improvement have been included 

in Part H and I of this report. 

In reviewing the FY 20 workforce tables Table B4P analyzing whether FHWA met 

EEOC’s 2% and 12% goal onboarding Persons with Disabilities and Persons with 

Targeted Disabilities at the GS-1-12 and GS13-SES the following information was 

captured:

Grade Level Person with Disabilities

(12%) 

Person with Targeted 

Disabilities (2 %)

GS 1-10 18.77% 5.80% 

GS 11-SES 9.85% 2.35% 

The FHWA’s FY 20 Ethnicity as it compares to the Civilian Labor Force: 
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FY 20 FHWA Total Workforce - Distribution by Race/Ethnicity and Sex (Table A1)

FHWA Total Workforce - Distribution by Disability (Table B1)

The following groups have participation rates that are above or equal to the Civilian Labor 

Force (CLF):

RNO/Disability FY 18 FY 19 FY 20 2010 CLF 

White Males 45.37% 44.63% 44.24% 38.33% 

Hispanic Males 5.23% 5.50% 5.75% 5.17% 

Black or African American Males 6.20% 6.28% 6.76% 5.49% 

Black or African American Females 8.81% 8.74% 8.78% 6.53% 

Asian Males 5.19% 5.32% 5.17% 1.97% 

Asian Females 2.50% 2.68% 2.86% 1.93% 

Native Hawaiian or Other Pacific 

Islander Males

0.15% 0.11% 0.11% 0.07% 

Two or More Races Females 0.37% 0.52% 0.51% 0.28% 

Persons with Targeted Disabilities* 2.88% 3.05% 2.75% 2.00 % 

(501 Goal) 

*Note: For Persons with Targeted Disabilities utilize the 501 Goal and not CLF. 

FHWA Total Workforce - Distribution by Race/Ethnicity and Sex (Table A1)

American

Indian or

Alaska

Native

Asian

Native

Hawaiian or

Other

Pacific

Islander

Black or

African

American

Hispanic or

Latino

Two or

More Races White NonSpecified

FHWA 1.00% 8.00% 0.10% 15.60% 9.30% 0.40% 65.20% 0.30%

CLF 0.40% 6.20% 0.40% 11.90% 17.50% 1.50% 62%

1.00%

8.00%

0.10%

15.60%

9.30%

0.40%

65.20%

0.40% 0.30%

6.20%

0.40%

11.90%

17.50%

1.50%

62%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

FHWA Workforce: Ethnicity Compared to Civilian Labor Force

FY 2020

FHWA CLF
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FHWA Total Workforce - Distribution by Disability (Table B1)

The following groups have a lower participation rate than the expected CLF:

RNO/Disability FY 2018 FY 2019 FY 2020 2010 CLF 

White Females 21.66% 21.53% 21.03% 34.03% 

Hispanic Females 3.25% 3.42% 3.54% 4.79% 

Native Hawaiian or Pacific 

Islander Female

0.04% 0.04% 0.00% 0.07% 

American Indian or Alaska Native 

Females

0.41% 0.52% 0.51% 0.53% 

American Indian or Alaska Native 

Males

0.52% 0.52% 0.51% 0.55% 

Two or More Races Males 0.15% 0.19% 0.25% 0.26% 

Persons with Disabilities* 9.97% 10.78% 10.84% 12.00% 

(501 Goal) 

*Note: For Persons with Disabilities utilize the 501 Goal and not the CLF. 

FHWA Total Workforce: Women Overall and White Women: Hiring and Separation 

In FY 19/20, the separation rate of white females is higher than the hiring rate for both 

fiscal years. The hiring rate of white females has trended down over the last 3 years.

Workforce Indicators

Females White Females

FY 2018 FY 2019 FY 

2020 

FY 2018 FY 2019 FY 

2020 

Total Workforce (A1) 37.12% 37.45% 37.22% 21.66% 21.53% 21.03% 

Civilian Labor Force (A1) 48.16% 34.03% 

Hiring Rate 

(A1: FY19/20; A8: FY18) 

38.30% 43.91% 36.79% 25.00% 20.00% 17.06% 

Separation Rate

(A1: FY19/20; A14: 

FY18) 

32.34% 41.82% 38.81% 20.00% 22.73% 20.09% 

Also, in FY 20 the separation rate of women is higher than the both the hiring rate and 

total workforce for women that fiscal year. 

FHWA Total Workforce: Women Overall and Hispanic Women: Hiring and Separation 

The hiring rate of Hispanic females is trending down over the last 3 years. 
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Workforce Indicators

Females Hispanic Females

FY 2018 FY 2019 FY 

2020

FY 2018 FY 2019 FY 

2020

Total Workforce (A1) 37.12% 37.45% 37.22% 3.25% 3.42% 3.54%

Civilian Labor Force (A1) 48.16% 4.79%

Hiring Rate

(A1: FY19/20; A8: FY18)

38.30% 43.91% 36.79% 5.32% 4.78% 4.01%

Separation Rate

(A1: FY19/20; A14: 

FY18)

32.34% 41.82% 38.81% 2.13% 1.82% 2.28%

Also, in FY 20 the separation rate of women is higher than both the hiring rate and the 

total workforce for women that fiscal year. 

Workforce Analysis Trends:

RNO FY 2017 FY 2018 FY 2019 FY 2020 FY 2010 CLF

Males 63.33% 

(1727)

62.88% 

(1684)

62.58%

(1679)

62.78%

(1737)

51.84%

Females 36.67% 

(1000)

37.12% 

(994)

37.42%

(1004)

37.22%

(1030)

48.16%

FHWA EEO Complaints Trends:

Over the past four years from FY17 to FY20, the informal/pre-complaint filing ebbs and 

flows.

Fiscal Year Informal Formal

2017 15 5

2018 11 11

2019 12 8

2020 15 14

Anti-Harassment cases identified FY18 to FY20

Fiscal Year Number of Anti-Harassment cases

2018 2

2019 3

2020 10

Top Five Bases Complaint Trends:

Top Five 

Bases FY 18 FY 19 FY 20

Sex 9 

(8 females, 1 male)

4 

(3 females, 1 LGBT)

3 

(2 females, 1 male)
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Top Five 

Bases FY 18 FY 19 FY 20

Disability 7 

(3 physical, 4 mental) 

8 

(4 mental, 4 physical) 

13 

(7 mental, 6 physical) 

Reprisal 5 4 10 

Race 5 

(4 Black, 1 White) 

5 

(4 Black, 1 White) 

5 

(4 Asian, 1 AA/Black) 

Age 4 4 

Religion 3 

Top Five Issues Complaint Trends:

Top Five Bases FY 17 FY 18 FY 19 FY 20

Harassment (Non-Sexual) 3 10 7 10 

Reasonable Accommodation 3 5 2 4 

Disciplinary Action 2 5 5 

Assignment of Duties 3 

Pay (Including overtime) 3 

Promotion/Non-Selection 2 5 

Performance 

Appraisal/Evaluation

2 2 5 

Time and Attendance 2 

Training 2 

Part E.4 - Executive Summary: Accomplishments

The FHWA makes EEO principles a fundamental part of its culture. Below is a summary of 

FHWA’s FY 20 accomplishments under the six essential elements 1) demonstrated commitment 

to equal employment opportunity, 2) integration of EEO into DOT’s strategic mission,3) 

management and program accountability, 4) proactive prevention of unlawful discrimination, 5) 

efficiency and responsiveness, and 6) legal compliance: 

• In FY 20, Office of Civil Rights requested nominations for four employees to serve as 

ancillary duty Equal Employment Opportunity (EEO) Counselors 

• All new and experienced EEO counselors received the required mandatory training. 

• FHWA had no findings of discrimination by the Equal Employment Opportunity 

Commission, the Merit Systems Protection Board, or the District Court in FY 2020. 
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• In FY 2020 FHWA hired 2.72% of people with targeted disabilities for the permanent

workforce which was a decrease from its FY 19 record of 4.35% hires.

• FHWA had 5 Schedule A Hires for Persons with Disabilities.

• FHWA had 1 Schedule A Hires for Persons with Targeted Disabilities.

• In FY 2020, FHWA continued to grow the activities of its corporate Diversity Committee

efforts. FHWA continued to expand the cadre of Diversity Champions throughout all its

units around the country.

• The FHWA has established an advisory group called the Innovation Exchange

(iExchange), a multi-generational forum focused on exchanging ideas, inspiring

innovation, raising awareness of generational diversity, and creating an environment that

embraces members of different generations. This advisory group is sponsored by the

FHWA’s Knowledge Management (KM) unit, the iExchange expanded its membership

to more than 240 employees in FY 2019. The advisory group hosted another virtual speed

networking event, several more crowdsource (brainstorm) sessions, and continued to

work with FHWA offices, committees, and councils to provide ideas and a fresh

perspective.

• In FY20, FHWA developed a web conferencing tool to demonstrate the conference tools

available to FHWA employees. Examples of web conferencing tools were MS Teams,

Adobe Connect, and other web conferencing tools. A supporting piece of the web

conferencing tool was the accessibility considerations. This tool was released to FHWA

staff to help them make an informed decision on which tool worked best for them.

• In FY20, FHWA established a Reasonable Accommodations working group. The group

consisted of program office and field managers and staff. The effort led to the

development of a handbook, checklists, and one page overviews so that employees and

managers can understand the roles, responsibilities, and timelines associated with

reasonable accommodations. Finalizing these tools was put on hold pending the release

of the new US DOT’s RA order.

• In September 2020, FHWA rolled out our draft 2020-2022 Competitiveness Strategy

Framework to DOT Employee Resource Groups and FHWA’s Diversity Management

Committee describing our strategies to strengthen the capacity of HBCUs to participate in

applicable Federal programs and initiatives. Out of this discussion several other

initiatives were born, the report was finalized and activities are underway to address each

tactic.

• In December 2019, FHWA finalized the Anti-Harassment Process to comply with the

DOT Policy Framework. As part of the rollout, the approved process was uploaded onto

the Office of Civil Rights Website. The Anti-Harassment process was rolled out to

employees and managers through a series of presentations, training sessions and

Webinars intended to educate all employees of the new process. As part of the rollout the

following documents were distributed to FHWA employees:

o FHWA Anti-Harassment Expectations Memorandum;

o FHWA Anti-Harassment Process and Procedures; and
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o The U.S. Department of Transportation Policy Framework for the Prevention of

Harassment.

• In FY 20, FHWA hosted an online virtual series of Prevention of Harassment training

sessions with the topic being Effective Bystander. A total of 9 sessions were held with a

total of 585 FHWA employees participating in the sessions. The purpose of this new

course was to help participants better understand how to appropriately respond when

witnessing harassment in the workplace.

• In FY 20, the Office of Civil Rights requested nominations for six FHWA employees to

serve as Fact Finders for the Anti-Harassment process. The FHWA’s Fact Finders serve

as the neutral party who conducts inquiries into allegations of harassment.

• The FHWA employees serving as collateral duty Fact Finders were required to attend a

mandatory 32-hour Workplace Investigator’s training. The training was attended by Fact

Finders, Employee Relations Staff, and the Office of Chief Counsel Staff.

• The Office of Civil Rights in conjunction with the Office of Human Resources partnered

with the DMC to provide training on the Anti-harassment, EEO, and Employee Relations

processes during the February 2020 Woman’s Forum session.

• Provided orientation to the Hispanic recruiter volunteers to update them on planned

activities, and received their feedback.

• Replaced sponsors rotating off the Hispanic Outreach initiative with new sponsors.

• Recruited additional members to the AMIGO Outreach Team with a focus on those

located in areas with large Hispanic populations – This team consists of existing

recruiters as well as new volunteers with a common goal of recruiting Hispanic

candidates. They are tasked with participating in job fairs and conferences, among other

recruiting opportunities, to scout and recruit Hispanics for the Agency. They will reach

out to highly qualified Hispanic candidates and spark their interest in the Agency by

providing information and guidance on the Federal job application process. The

Outreach Team could also provide personal career road maps as examples of their career

path within the Agency. For this, the Outreach Team will have materials such as

presentations, brochures, links, etc., available in the SharePoint site for recruiting events.

• The Office of Human Resources established interaction with the DMC and appointed a

liaison to serve on both committees (the DMC and the Hispanic Recruitment) with the

goal to increase communication and collaboration.

• Developed and/or updated drafts of these documents to reflect feedback from recruitment

sponsors and workgroup members:

o Hispanic 2020 Plan: This plan was updated in 2020. It builds upon the efforts of

the document titled “Increasing the Representation of Hispanics in FHWA.” This

document will accomplish the following steps: 1) summarize and utilize the data

from the Federal Highway Administration FY 18 Workforce Plan as it relates to

Hispanics, 2) conduct a gap analysis, and 3) identify opportunities that exist to
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positively influence FHWA’s Strategic Plan and ensure alignment with DOT’s 

Strategic Plan. It will provide the Agency with an effective tool to enhance 

engagement in recruiting, developing, and retaining Hispanics in FHWA. 

o AMIGO Strategy Charter: This document was updated in 2020. It establishes a 

platform focusing efforts in improving the recruitment, integration, and retention 

of qualified Hispanics. 

o AMIGO Hispanic Outreach Action Plan: This document was updated in 2020. It 

outlines a process established by the AMIGO (Assist, Motivate, Integrate, Guide, 

and Orient) Strategy to work in coordination with the FHWA Human Resources 

(HR) Office.

o AMIGO Standard Operating Procedures (SOP) – This document was drafted in 

2020. It provides specific information on delivering the AMIGO Strategy and 

details the processes and procedures for developing, implementing, and managing 

the different work products such as the AMIGO Strategy and AMIGO Team 

Charter, AMIGO Member List, AMIGO External Website, AMIGO SharePoint 

site and AMIGO Accomplishment Report. 

o AMIGO Members List – This searchable document was updated in 2020. It lists 

all Agency employee volunteers (or AMIGO members) recruited to work in the 

AMIGO Strategy as part of the outreach team, mentors or both. It includes 

names, locations, job titles, and areas of expertise. The document also includes 

specific information and products for recruiting and retaining Hispanic staff. 

o AMIGO External FHWA Webpage – This Webpage will be included as part of 

FHWA’s external/public Website to provide an easily accessible space for the 

public to learn about FHWA’s workforce diversity policies. The Webpage will 

focus on marketing FHWA as a place of work to potential Hispanic candidates. 

The Webpage will include links to existing Agency job vacancy postings, articles 

by Hispanic employees in the Agency, links to hiring resources, and links to other 

appropriate USDOT professional awareness and Hispanic business associations’ 

Websites.

o AMIGO SharePoint Site & Internal Networking Platform – This site will provide 

the main platform for implementing and managing the AMIGO Strategy. The 

SharePoint site will serve as the main Hispanic network site within FHWA. 

Interested Agency employees would be able to access specific Hispanic 

workforce information, contact AMIGO Members, post questions, research 

information. The SharePoint site will also allow AMIGO Members to promote 

and coordinate professional development activities and opportunities among the 

Hispanic workforce such as brown bag lunch activities, resume reviews, mock 

interview sessions, and interview/shadowing activities with Hispanic senior 

leaders in the Agency.
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Part E.5 - Executive Summary: Planned Activities

The following list identifies emphasis areas, activities and/or planned initiatives to address 

and/or correct program deficiencies in Parts H, I and J: 

• FHWA will revamp its Strategic Plan to continue to address equity, diversity, and 

inclusion. In addition, FHWA will revamp its Organizational Manual to reflect the 

Administration’s priorities in relation to equity, diversity, and inclusion. 

• FHWA will enhance its workforce analysis on participation rates for permanent 

workforce (i.e. senior grade level, compensation and awards, management positions) 

through focus groups, surveys, policy reviews, and educational awareness. 

• FHWA will continue to roll out its technical assistance and training on EEO, Reasonable 

Accommodations, Anti- Harassment, and Diversity & Inclusion to program and field 

offices. 

• FHWA Virtual EEO Awareness Symposium started preparations in July 2020. The 

symposium’s purpose was to educate FHWA Management and Staff with a focus on 

EEO, Conflict Resolution, Prevention of Harassment, and Effective Communication. 

The symposium was held over a 3-day time span from February 22-25, 2021. 

• FHWA developed a draft Reasonable Accommodations Handbook that will be a tool for 

Managers to understand their role and responsibilities. We also drafted checklists, 

sample letters, and one-page summaries for managers and employees. These resources 

will be reevaluated based upon the new Departmental DOT Reasonable Accommodation 

order. 

• FHWA will continue to partner within DOT to recognize and identify monthly 

observances and host various events to educate employees on cultural differences, 

accomplishments, and contributions. 

• FHWA plans to continue to revamp its recruitment efforts to support targeted outreach to 

increase the number of women and Hispanic women as well as persons with targeted 

disabilities at all grade levels.

• FHWA will continue to create an inclusive organization environment by performing 

outreach and remaining in close contact in working with our recruitment partners from 

various associations and organizations that target or serve underrepresented groups, and 

schools with targeted populations to tap in to a diversified applicant pool for all job 

vacancies while working with these organizations to ensure the success of our 

recruitment program. 

• FHWA will continue to develop new resources and programs for hiring managers that 

highlight how to find diverse pools of talent for FHWA vacancy announcements as well 

as how to communicate vacancy announcements to those diverse talent pools. 

• FHWA will develop and distribute a “Diversity Hiring Guide” for hiring managers. This 

guide will provide recommendations that aim to mitigate bias and offer resources that 
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help broaden applicant pools for job vacancies. The guide will also make diverse resume 

review panels and interview panels a standard practice.

• FHWA will continue its partnership with universities with a large disability population to

provide mock interview experiences for students who may be seeking employment

opportunities within FHWA’s Pipeline programs.

• In partnership with the DOT Disability Resource Center, FHWA will offer education and

training about the DOT Disability Resource Center and how their services benefit

FHWA’s workforce.

• FHWA will continue to be proactive in its efforts to market the Summer Transportation

Internship Program for Diverse Groups (STIPDG) as well as the Professional

Development Program (PDP) amongst colleges and universities.

• FHWA will continue to examine and review its recruitment and hiring practices to further

identify if there are barriers to underrepresented groups, particularly within the nine

mission critical occupations.

• FHWA’s goal is to have a Diversity Champion for each unit, and the DMC will continue

its efforts towards having a champion for each unit. Additionally, the DMC will continue

to partner with Employee Resource Groups and will deploy new training modules on the

subjects of diversity awareness and unconscious bias.
. �� 

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CFORM U.S. Equal Employment Opportunity Commission 

715-01 FEDERAL AGENCY ANNUAL 

PARTF EEO PROGRAM STATUS REPORT 

CERTIFICATION of ESTABLISHMENT of CONTINUING 

EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS 

I, Irene Rico, Associate Administrator for Civil Rights am the 

(Insert name above) (Insert official 

title/series/grade above) 

Principal EEO Director/Official for Federal Highway Administration 

(Insert Agency/Component Name above) 

The Agency has conducted an annual self-assessment of Section 717 and Section 501 programs against the essential elements 

as prescribed by EEO MD-715. If an essential element was not fully compliant with the standards of EEO MD-715, a further 

evaluation was conducted and, as appropriate, EEO Plans for Attaining the Essential Elements of a Model EEO Program, are 

included with this Federal Agency Annual EEO Program Status Report. 

The Agency has also analyzed its work force profiles and conducted barrier analyses aimed at detecting whether any 

management or personnel policy, procedure or practice is operating to disadvantage any group based on race, national origin, 

gender or disability. EEO Plans to Eliminate Identified Barriers, as appropriate, are included with this Federal Agency Annual 

EEO Program Status Report. 

I certify that proper documentation of this assessment is in place and is being maintained for EEOC review upon request. 

Digitally signed by IRENE RICO IRENE RICO Date: 2021.07.27 18:58:08 -04'00'

Signature of Principal EEO Director/Official Date 

Certifies that this Federal Agency Annual EEO Program Status Report is in compliance with EEO MD-715 . 

Signature of Agency Head or Agency Head Designee Date 

Page 27 of99 
Page 28 of 99 

MD-715 - PART G

Agency Self-Assessment Checklist

Essential Element A: Demonstrated Commitment From Agency Leadership

This element requires the agency head to communicate a commitment to equal employment opportunity and a discriminationfree workplace.

Measures

Compliance Indicator

A.1 - The agency issues an effective, up-to-date

EEO policy statement.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.1.a

Does the agency annually issue a signed and dated 

EEO policy statement on agency letterhead that 

clearly communicates the agency's commitment to 

EEO for all employees and applicants? If "yes", 

please provide the annual issuance date in the 

comments column. [see MD-715, II(A)]

YES

The Departmental Office of 

Civil Rights issued the annual 

DOT EEO Policy statements on 

behalf of the Department.

A.1.a.2

A.1.b

Does the EEO policy statement address all protected 

bases (age, color, disability, sex (including 

pregnancy, sexual orientation and gender identity), 

genetic information, national origin, race, religion, 

and reprisal) contained in the laws EEOC enforces? 

[see 29 CFR § 1614.101(a)] 

YES New

Measures

Compliance Indicator 

A.2 - The agency has communicated EEO policies

and procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.2.a Does the agency disseminate the following policies 

and procedures to all employees:

A.2.a.1 Anti-harassment policy? [see MD 715, II(A)] YES New

A.2.a.2 Reasonable accommodation procedures? [see 29 

C.F.R § 1614.203(d)(3)] YES

FHWA uses the Department’s 

Reasonable Accommodation 

Policy. 

New
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Measures

Compliance Indicator 

A.2 - The agency has communicated EEO policies

and procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

A.2.b

Does the agency prominently post the following 

information throughout the workplace and on its 

public website: 

A.2.b.1

The business contact information for its EEO 

Counselors, EEO Officers, Special Emphasis 

Program Managers, and EEO Director? [see 29 C.F.R 

§ 1614.102(b)(7)]

YES https://www.fhwa.dot.gov/civilr

ights/ New

A.2.b.2

Written materials concerning the EEO program, laws, 

policy statements, and the operation of the EEO 

complaint process? [see 29 C.F.R § 1614.102(b)(5)] 

YES https://www.fhwa.dot.gov/civilr

ights/programs/eeo/ A.2.c

A.2.b.3

Reasonable accommodation procedures? [see 29 

C.F.R. § 1614.203(d)(3)(i)] If so, please provide the

internet address in the comments column.

YES

https://www.transportation.gov/

civil-rights/civil-rightsawarenessenforcement/proceduresprocessing-reasonableaccommodation

A.3.c

A.2.c Does the agency inform its employees about the 

following topics: 

A.2.c.1

EEO complaint process? [see 29 CFR §§ 

1614.102(a)(12) and 1614.102(b)(5)] If "yes", please 

provide how often. 

YES Annually A.2.a

A.2.c.2 ADR process? [see MD-110, Ch. 3(II)(C)] If "yes", 

please provide how often. YES Annually New

A.2.c.3

Reasonable accommodation program? [see 29 CFR § 

1614.203(d)(7)(ii)(C)] If "yes", please provide how 

often. 

YES Annually New

A.2.c.4 Anti-harassment program? [see EEOC Enforcement 

Guidance on Vicarious Employer Liability for YES

Annually. 

FHWA has an Anti-Harassment 

Program that was established 

New
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 30 of 99

Measures

Compliance Indicator 

A.2 - The agency has communicated EEO policies

and procedures to all employees.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

Unlawful Harassment by Supervisors (1999), § 

V.C.1] If "yes", please provide how often.

October 10, 2017, and 

updated/finalized on December 

13, 2019. 

https://www.fhwa.dot.gov/civilr

ights/programs/antiharassment/resources.cfm

A.2.c.5

Behaviors that are inappropriate in the workplace and 

could result in disciplinary action? [5 CFR § 

2635.101(b)] If "yes", please provide how often. 

YES

Annually via mandatory 

harassment training. Also, 

continuously via the FHWA 

Table of Offenses and Penalties, 

which is posted on FHWA’s 

internal intranet site.

https://staffnet.fhwa.dot.gov/hr/

regulations/handbook/appendix

_a.htm#d

A.3.b
EEOC FORM 

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Measures

Compliance Indicator 

A.3 - The agency assesses and ensures EEO

principles are part of its culture.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

A.3.a

Does the agency provide recognition to employees, 

supervisors, managers, and units demonstrating 

superior accomplishment in equal employment 

opportunity? [see 29 CFR § 1614.102(a) (9)] If "yes", 

provide one or two examples in the comments section.

YES

The Agency established a 

Diversity & Inclusion award in 

2017 as a part of the 

Administrator’s Awards 

Program. The Department also 

has a Secretary’s Awards 

Program, which recognizes 

employees for accomplishments 

in EEO and the Agency has 

consistently nominated FHWA 

employees for those honors.

New

A.3.b

Does the agency utilize the Federal Employee 

Viewpoint Survey or other climate assessment tools to 

monitor the perception of EEO principles within the 

workforce? [see 5 CFR Part 250] 

YES Annually for FEVS and Every 2 

years for FHWA’s All 

Employee Survey. 

New

Essential Element B: Integration of EEO into the agency’s Strategic Mission 

This element requires that the agency’s EEO programs are structured to maintain a workplace that is free from 

discrimination and support the agency’s strategic mission.
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 32 of 99

Measures

Compliance Indicator

B.1 - The reporting structure for the EEO

program provides the principal EEO official with

appropriate authority and resources to effectively

carry out a successful EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.1.a

Is the agency head the immediate supervisor of the 

person ("EEO Director") who has day-to-day control 

over the EEO office? [see 29 CFR §1614.102(b)(4)]

NO

The Associate Administrator 

for Civil Rights Reports to the 

Agency Executive Director who 

is the Agency’s top career 

employee. The Executive 

Director is responsible for all 

workforce matters in the 

Agency.

B.1.a

B.1.a.1

If the EEO Director does not report to the agency 

head, does the EEO Director report to the same 

agency head designee as the mission-related 

programmatic offices? If "yes," please provide the 

title of the agency head designee in the comments.

YES

The Associate Administrator 

for Civil Rights Reports to the 

Executive Director. The 

Executive Director is 

responsible for all workforce 

matters in the Agency. 

New

B.1.a.2

Does the agency's organizational chart clearly define 

the reporting structure for the EEO office? [see 29 

CFR §1614.102(b)(4)] 

YES B.1.d

B.1.b

Does the EEO Director have a regular and effective 

means of advising the agency head and other senior 

management officials of the effectiveness, efficiency, 

and legal compliance of the agency's EEO program? 

[see 29 CFR §1614.102(c)(1); MD-715 Instructions, 

Sec. I]

YES B.2.a
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 33 of 99

Measures

Compliance Indicator 

B.1 - The reporting structure for the EEO

program provides the principal EEO official with

appropriate authority and resources to effectively

carry out a successful EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.1.c

During this reporting period, did the EEO Director 

present to the head of the agency, and other senior 

management officials, the "State of the agency" 

briefing covering the six essential elements of the 

model EEO program and the status of the barrier 

analysis process? [see MD-715 Instructions, Sec. I)] If 

"yes", please provide the date of the briefing in the 

comments column. 

YES

The Associate Administrator 

presented to agency leadership 

the “State of the Agency” 

briefing on June 16, 2020. 

B.2.b

B.1.d

Does the EEO Director regularly participate in seniorlevel staff meetings concerning personnel, budget, 

technology, and other workforce issues? [see MD715, II(B)]

YES New

Measures

Compliance Indicator 

B.2 - The EEO Director controls all aspects of the

EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

B.2.a

Is the EEO Director responsible for the 

implementation of a continuing affirmative 

employment program to promote EEO and to identify 

and eliminate discriminatory policies, procedures, 

and practices? [see MD-110, Ch. 1(III)(A); 29 CFR 

§1614.102(c)]

YES B.3.a

B.2.b

Is the EEO Director responsible for overseeing the 

completion of EEO counseling [see 29 CFR 

§1614.102(c)(4)]

YES New
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 34 of 99

Measures

Compliance Indicator 

B.2 - The EEO Director controls all aspects of the

EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

Current 

Part G 

Questions

B.2.c

Is the EEO Director responsible for overseeing the 

fair and thorough investigation of EEO complaints? 

[see 29 CFR §1614.102(c)(5)] [This question may 

not be applicable for certain subordinate level 

components.] 

N/A

FHWA is a sub-reporting Unit 

and are not responsible for 

investigations. Investigations 

are handled at the Departmental 

Office of Civil Rights. 

New

B.2.d

Is the EEO Director responsible for overseeing the 

timely issuing final agency decisions? [see 29 CFR 

§1614.102(c)(5)] [This question may not be

applicable for certain subordinate level components.] 

N/A

FHWA is a sub-reporting Unit 

and are not responsible for 

investigations. Issuance of final 

agency decisions occurs at the 

Departmental Office of Civil 

Rights. 

New

B.2.e

Is the EEO Director responsible for ensuring 

compliance with EEOC orders? [see 29 CFR §§ 

1614.102(e); 1614.502] 

YES F.3.b

B.2.f

Is the EEO Director responsible for periodically 

evaluating the entire EEO program and providing 

recommendations for improvement to the agency 

head? [see 29 CFR §1614.102(c)(2)]

YES New

B.2.g

If the agency has subordinate level components, does 

the EEO Director provide effective guidance and 

coordination for the components? [see 29 CFR §§ 

1614.102(c)(2) and (c)(3)] 

N/A

This function is handled by the 

Departmental Office of Civil 

Rights. 

New
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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Measures

Compliance Indicator 

B.3 - The EEO Director and other EEO

professional staff are involved in, and consulted 

on, management/personnel actions.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.3.a

Do EEO program officials participate in agency 

meetings regarding workforce changes that might 

impact EEO issues, including strategic planning, 

recruitment strategies, vacancy projections, 

succession planning, and selections for training/career 

development opportunities? [see MD-715, II(B)]

YES B.2.c &

B.2.d

B.3.b

Does the agency's current strategic plan reference 

EEO / diversity and inclusion principles? [see MD715, II(B)] If "yes", please identify the EEO 

principles in the strategic plan in the comments 

column. 

YES

FHWA strategic and 

performance planning efforts 

are aligned to the DOT 

Strategic Plan. In addition, 

FHWA has provided a list of 

objectives that include 

EEO/diversity and inclusion 

principles through INPUT 

performance tracking system. 

(This information is provided as 

supplemental documentation to 

this report)

New

Measures

Compliance Indicator 

B.4 - The agency has sufficient budget and staffing

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.a

Pursuant to 29 CFR §1614.102(a)(1), has the agency 

allocated sufficient funding and qualified staffing to 

successfully implement the EEO program, for the 

following areas:

B.4.a.1 to conduct a self-assessment of the agency for 

possible program deficiencies? [see MD-715, II(D)] YES B.3.b
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 36 of 99

Measures

Compliance Indicator 

B.4 - The agency has sufficient budget and staffing

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.a.2 to enable the agency to conduct a thorough barrier 

analysis of its workforce? [see MD-715, II(B)] YES B.4.a

B.4.a.3

to timely, thoroughly, and fairly process EEO 

complaints, including EEO counseling, 

investigations, final agency decisions, and legal 

sufficiency reviews? [see 29 CFR § 1614.102(c)(5) & 

1614.105(b) - (f); MD-110, Ch. 1(IV)(D) & 5(IV); 

MD-715, II(E)]

YES E.5.b

B.4.a.4

to provide all supervisors and employees with 

training on the EEO program, including but not 

limited to retaliation, harassment, religious 

accommodations, disability accommodations, the 

EEO complaint process, and ADR? [see MD-715, 

II(B) and III(C)] If not, please identify the type(s) of 

training with insufficient funding in the comments 

column. 

YES B.4.f &

B.4.g

B.4.a.5

to conduct thorough, accurate, and effective field 

audits of the EEO programs in components and the 

field offices, if applicable? [see 29 CFR 

§1614.102(c)(2)]

YES E.1.c

B.4.a.6

to publish and distribute EEO materials (e.g., 

harassment policies, EEO posters, reasonable 

accommodations procedures)? [see MD-715, II(B)]

YES B.4.c

B.4.a.7

to maintain accurate data collection and tracking 

systems for the following types of data: complaint 

tracking, workforce demographics, and applicant 

flow data? [see MD-715, II(E)]. If not, please identify 

the systems with insufficient funding in the 

comments section.

YES New
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 37 of 99

Measures

Compliance Indicator 

B.4 - The agency has sufficient budget and staffing

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.a.8

to effectively administer its special emphasis 

programs (such as, Federal Women's Program, 

Hispanic Employment Program, and People with 

Disabilities Program Manager)? [5 USC § 7201; 38 

USC § 4214; 5 CFR § 720.204; 5 CFR § 213.3102(t) 

and (u); 5 CFR § 315.709] 

YES

B.3.c,

B.3.c.1,

B.3.c.2, &

B.3.c.3

B.4.a.9

to effectively manage its anti-harassment program? 

[see MD-715 Instructions, Sec. I); EEOC 

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(1999), § V.C.1] 

YES New

B.4.a.10 to effectively manage its reasonable accommodation 

program? [see 29 CFR § 1614.203(d)(4)(ii)] YES B.4.d

B.4.a.11 to ensure timely and complete compliance with 

EEOC orders? [see MD-715, II(E)] YES New

B.4.b

Does the EEO office have a budget that is separate 

from other offices within the agency? [see 29 CFR § 

1614.102(a)(1)] 

YES New

B.4.c

Are the duties and responsibilities of EEO officials 

clearly defined? [see MD-110, Ch. 1(III)(A), 2(III), 

& 6(III)]

YES B.1.b

B.4.d

Does the agency ensure that all new counselors and 

investigators, including contractors and collateral 

duty employees, receive the required 32 hours of 

training, pursuant to Ch. 2(II)(A) of MD-110? 

YES Investigators are overseen at the 

Departmental level. E.2.d
EEOC FORM 

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Measures

Compliance Indicator 

B.4 - The agency has sufficient budget and staffing 

to support the success of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

B.4.e YES Investigators are overseen at the 

Departmental level. E.2.e

Measures

Compliance Indicator 

B.5 - The agency recruits, hires, develops, and

retains supervisors and managers who have 

effective managerial, communications, and 

interpersonal skills.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

B.5.a

Pursuant to 29 CFR § 1614.102(a)(5), have all 

managers and supervisors received training on 

their responsibilities under the following areas 

under the agency EEO program:

B.5.a.1 EEO Complaint Process? [see MD-715(II)(B)] YES New

B.5.a.2 Reasonable Accommodation Procedures? [see 29 

C.F.R. § 1614.102(d)(3)] YES A.3.d

B.5.a.3 Anti-Harassment Policy? [see MD-715(II)(B)] YES New

B.5.a.4

Supervisory, managerial, communication, and 

interpersonal skills in order to supervise most 

effectively in a workplace with diverse employees 

and avoid disputes arising from ineffective 

communications? [see MD-715, II(B)]

YES New

B.5.a.5

ADR, with emphasis on the federal government's 

interest in encouraging mutual resolution of 

disputes and the benefits associated with utilizing 

ADR? [see MD-715(II)(E)]

YES E.4.b

Pursuant to 29 CFR §1614.102(a)(1), has the agency 

allocated sufficient funding and qualified staffing to 

successfully implement the EEO program, for the 

following areas: 
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 39 of 99

Measures

Compliance Indicator 

B.6 - The agency involves managers in the

implementation of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

B.6.a

Are senior managers involved in the 

implementation of Special Emphasis Programs? 

[see MD-715 Instructions, Sec. I]

YES New

B.6.b

Do senior managers participate in the barrier 

analysis process? [see MD-715 Instructions, Sec. 

I]

YES D.1.a

B.6.c

When barriers are identified, do senior managers 

assist in developing agency EEO action plans 

(Part I, Part J, or the Executive Summary)? [see 

MD-715 Instructions, Sec. I]

YES D.1.b

B.6.d

Do senior managers successfully implement EEO 

Action Plans and incorporate the EEO Action 

Plan Objectives into agency strategic plans? [29 

CFR § 1614.102(a)(5)] 

YES D.1.c

Essential Element C: Management and Program Accountability 

This element requires the agency head to hold all managers, supervisors, and EEO officials responsible for the effective 

implementation of the agency’s EEO Program and Plan. 

Measures

Compliance Indicator 

C.1 - The agency conducts regular internal

audits of its component and field offices.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.1.a

Does the agency regularly assess its component and 

field offices for possible EEO program 

deficiencies? [see 29 CFR §1614.102(c)(2)] If 

"yes", please provide the schedule for conducting 

audits in the comments section.

YES

FHWA periodically on an 

annual basis assesses its field 

offices for possible EEO 

deficiencies.

New
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 40 of 99

Measures

Compliance Indicator 

C.1 - The agency conducts regular internal

audits of its component and field offices.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.1.b

Does the agency regularly assess its component and 

field offices on their efforts to remove barriers from 

the workplace? [see 29 CFR §1614.102(c)(2)] If 

"yes", please provide the schedule for conducting 

audits in the comments section.

YES

FHWA annually conducts 

assessments on the agency’s 

efforts to remove barriers from 

the workplace. 

New

C.1.c

Do the component and field offices make 

reasonable efforts to comply with the 

recommendations of the field audit? [see MD-715, 

II(C)]

YES New

Measures 

Compliance Indicator 

C.2 - The agency has established procedures to

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.a

Has the agency established comprehensive antiharassment policy and procedures that comply with 

EEOC's enforcement guidance? [see MD-715, II(C); 

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(Enforcement Guidance), EEOC No. 915.002, § 

V.C.1 (June 18, 1999)]

YES

FHWA Anti-Harassment policy 

and procedures have been 

updated.

New

C.2.a.1

Does the anti-harassment policy require corrective 

action to prevent or eliminate conduct before it rises 

to the level of unlawful harassment? [see EEOC 

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(1999), § V.C.1]

YES New
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 41 of 99

Measures

Compliance Indicator 

C.2 - The agency has established procedures to

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.a.2

Has the agency established a firewall between the 

Anti-Harassment Coordinator and the EEO 

Director? [see EEOC Report, Model EEO Program 

Must Have an Effective Anti-Harassment Program 

(2006]

YES New

C.2.a.3

Does the agency have a separate procedure (outside 

the EEO complaint process) to address harassment 

allegations? [see Enforcement Guidance on 

Vicarious Employer Liability for Unlawful 

Harassment by Supervisors (Enforcement 

Guidance), EEOC No. 915.002, § V.C.1 (June 18, 

1999)]

YES New

C.2.a.4

Does the agency ensure that the EEO office informs 

the anti-harassment program of all EEO counseling 

activity alleging harassment? [see Enforcement 

Guidance, V.C.]

YES . New

C.2.a.5

Does the agency conduct a prompt inquiry 

(beginning within 10 days of notification) of all 

harassment allegations, including those initially 

raised in the EEO complaint process? 

[see Complainant v. Dep't of Veterans Affairs, 

EEOC Appeal No. 0120123232 (May 21, 2015); 

Complainant v. Dep't of Defense (Defense 

Commissary Agency), EEOC Appeal No. 

0120130331 (May 29, 2015)] If "no", please provide 

the percentage of timely-processed inquiries in the 

comments column.

YES New
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 42 of 99

Measures

Compliance Indicator 

C.2 - The agency has established procedures to

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.a.6

Do the agency's training materials on its antiharassment policy include examples of disabilitybased harassment? [see 29 CFR 1614.203(d)(2)]

YES New

C.2.b

Has the agency established disability reasonable 

accommodation procedures that comply with 

EEOC's regulations and guidance? [see 29 CFR 

1614.203(d)(3)]

YES FHWA currently follows the 

Department’s RA procedures. New

C.2.b.1

Is there a designated agency official or other 

mechanism in place to coordinate or assist with 

processing requests for disability accommodations 

throughout the agency? [see 29 CFR 

1614.203(d)(3)(D)]

YES E.1.d

C.2.b.2

Has the agency established a firewall between the 

Reasonable Accommodation Program Manager 

and the EEO Director? [see MD-110, Ch. 1(IV)(A)] 

YES . New

C.2.b.3

Does the agency ensure that job applicants can 

request and receive reasonable accommodations 

during the application and placement processes? [see 

29 CFR 1614.203(d)(1)(ii)(B)] 

YES New

C.2.b.4

Do the reasonable accommodation procedures 

clearly state that the agency should process the 

request within a maximum amount of time (e.g., 20 

business days), as established by the agency in its 

affirmative action plan? [see 29 CFR 

1614.203(d)(3)(i)(M)] 

YES New
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 43 of 99

Measures

Compliance Indicator 

C.2 - The agency has established procedures to

prevent all forms of EEO discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.2.b.5

Does the agency process all accommodation 

requests within the time frame set forth in its 

reasonable accommodation procedures? [see MD715, II(C)] If "no", please provide the percentage of 

timely-processed requests in the comments column. 

YES E.1.e

C.2.c

Has the agency established procedures for 

processing requests for personal assistance services 

that comply with EEOC's regulations, enforcement 

guidance, and other applicable executive orders, 

guidance, and standards? [see 29 CFR 

1614.203(d)(6)] 

YES FHWA currently follows the 

Department’s procedures. New

C.2.c.1

Does the agency post its procedures for processing 

requests for Personal Assistance Services on its 

public website? [see 29 CFR § 1614.203(d)(5)(v)] If 

"yes", please provide the internet address in the 

comments column. 

YES

https://www.transportation.gov/

drc/personal-assistance-asreasonable-accommodationNew

Measures 

Compliance Indicator 

C.3 - The agency evaluates managers and

supervisors on their efforts to ensure equal

employment opportunity.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.3.a

Pursuant to 29 CFR §1614.102(a)(5), do all managers 

and supervisors have an element in their performance 

appraisal that evaluates their commitment to agency 

EEO policies and principles and their participation in 

the EEO program?

YES New

C.3.b

Does the agency require rating officials to evaluate 

the performance of managers and supervisors based 

on the following activities:
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 44 of 99

Measures

Compliance Indicator 

C.3 - The agency evaluates managers and

supervisors on their efforts to ensure equal

employment opportunity.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.3.b.1

Resolve EEO problems/disagreements/conflicts, 

including the participation in ADR proceedings? [see 

MD-110, Ch. 3.I]

YES A.3.a.1

C.3.b.2

Ensure full cooperation of employees under his/her 

supervision with EEO officials, such as counselors 

and investigators? [see 29 CFR §1614.102(b)(6)] 

YES A.3.a.4

C.3.b.3

Ensure a workplace that is free from all forms of 

discrimination, including harassment and retaliation? 

[see MD-715, II(C)]

YES A.3.a.5

C.3.b.4

Ensure that subordinate supervisors have effective 

managerial, communication, and interpersonal skills 

to supervise in a workplace with diverse employees? 

[see MD-715 Instructions, Sec. I]

YES A.3.a.6

C.3.b.5

Provide religious accommodations when such 

accommodations do not cause an undue hardship? 

[see 29 CFR §1614.102(a)(7)] 

YES A.3.a.7

C.3.b.6

Provide disability accommodations when such 

accommodations do not cause an undue hardship? [ 

see 29 CFR §1614.102(a)(8)] 

YES A.3.a.8

C.3.b.7

Support the EEO program in identifying and 

removing barriers to equal opportunity. [see MD-715, 

II(C)]

YES New

C.3.b.8

Support the anti-harassment program in investigating 

and correcting harassing conduct. [see Enforcement 

Guidance, V.C.2] 

YES A.3.a.2
EEOC FORM 

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Measures

Compliance Indicator 

C.3 - The agency evaluates managers and

supervisors on their efforts to ensure equal

employment opportunity.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

C.3.b.9

Comply with settlement agreements and orders issued 

by the agency, EEOC, and EEO-related cases from 

the Merit Systems Protection Board, labor arbitrators, 

and the Federal Labor Relations Authority? [see MD715, II(C)]

YES New

C.3.c

Does the EEO Director recommend to the agency

head improvements or corrections, including remedial 

or disciplinary actions, for managers and supervisors 

who have failed in their EEO responsibilities? [see 29 

CFR §1614.102(c)(2)] 

N/A

Investigations are handled at the 

Department. The 

recommendations for 

corrections are handled at the 

Departmental Office of Civil 

Rights level. 

New

C.3.d

When the EEO Director recommends remedial or 

disciplinary actions, are the recommendations 

regularly implemented by the agency? [see 29 CFR 

§1614.102(c)(2)]

N/A Investigations are handled at the 

Department. The remedial or 

disciplinary actions are handled 

at the Departmental Office of 

Civil Rights level. No 

recommendations have been 

issued during this reporting 

period.

New

Measures

Compliance Indicator 

C.4 - The agency ensures effective

coordination between its EEO programs and 

Human Resources (HR) program.

Masure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.4.a

Do the HR Director and the EEO Director meet 

regularly to assess whether personnel programs, 

policies, and procedures conform to EEOC laws, 

YES New
EEOC FORM 

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Page 46 of 99

Measures

Compliance Indicator 

C.4 - The agency ensures effective

coordination between its EEO programs and 

Human Resources (HR) program.

Masure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

instructions, and management directives? [see 29 

CFR §1614.102(a)(2)]

C.4.b

Has the agency established timetables/schedules 

to review at regular intervals its merit promotion 

program, employee recognition awards program, 

employee development/training programs, and 

management/personnel policies, procedures, and 

practices for systemic barriers that may be 

impeding full participation in the program by all 

EEO groups? [see MD-715 Instructions, Sec. I] 

YES C.2.a, C.2.b,

& C.2.c

C.4.c

Does the EEO office have timely access to 

accurate and complete data (e.g., demographic 

data for workforce, applicants, training programs, 

etc.) required to prepare the MD-715 workforce 

data tables? [see 29 CFR §1614.601(a)] 

YES New

C.4.d

Does the HR office timely provide the EEO 

office have timely access to other data (e.g., exit 

interview data, climate assessment surveys, and 

grievance data), upon request? [see MD-715, 

II(C)]

YES New

C.4.e Pursuant to Section II(C) of MD-715, does the 

EEO office collaborate with the HR office to:

C.4.e.1

Implement the Affirmative Action Plan for 

Individuals with Disabilities? [see 29 CFR 

§1614.203(d); MD-715, II(C)]

YES New

C.4.e.2 Develop and/or conduct outreach and recruiting 

initiatives? [see MD-715, II(C)] YES New
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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Measures

Compliance Indicator 

C.4 - The agency ensures effective

coordination between its EEO programs and 

Human Resources (HR) program.

Masure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.4.e.3 Develop and/or provide training for managers 

and employees? [see MD-715, II(C)] YES New

C.4.e.4 Identify and remove barriers to equal opportunity 

in the workplace? [see MD-715, II(C)] YES New

C.4.e.5 Assist in preparing the MD-715 report? [see MD715, II(C)] YES New

Measures

Compliance Indicator 

C.5 - Following a finding of discrimination, the

agency explores whether it should take a 

disciplinary action.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.5.a

Does the agency have a disciplinary policy and/or 

table of penalties that covers discriminatory 

conduct? 29 CFR § 1614.102(a)(6); see 

also Douglas v. Veterans Administration, 5 

MSPR 280 (1981)

YES

http://staffnet.fhwa.dot.gov/hr/r

egulations/handbook/appendix_

a.htm

C.3.a.

C.5.b

When appropriate, does the agency discipline or 

sanction managers and employees for 

discriminatory conduct? [see 29 CFR 

§1614.102(a)(6)] If "yes", please state the number

of disciplined/sanctioned individuals during this

reporting period in the comments.

YES

Although the Agency takes 

appropriate action, there were 

no reported actions this year. 

C.3.c

C.5.c

If the agency has a finding of discrimination (or 

settles cases in which a finding was likely), does 

the agency inform managers and supervisors 

about the discriminatory conduct? [see MD-715, 

II(C)]

N/A

No findings of discrimination or 

settlements due to likely finding 

during this reporting period. 

New
EEOC FORM 

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Measures

Compliance Indicator 

C.6 - The EEO office advises

managers/supervisors on EEO matters.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

C.6.a

Does the EEO office provide 

management/supervisory officials with regular 

EEO updates on at least an annual basis, 

including EEO complaints, workforce 

demographics and data summaries, legal updates, 

barrier analysis plans, and special emphasis 

updates? [see MD-715 Instructions, Sec. I] If 

"yes", please identify the frequency of the EEO 

updates in the comment’s column.

YES This is discussed annually 

within FHWA. C.1.a

C.6.b

Are EEO officials readily available to answer 

managers' and supervisors' questions or concerns? 

[see MD-715 Instructions, Sec. I]

YES New

Essential Element D: Proactive Prevention

This element requires that the agency head make early efforts to prevent discrimination and to identify and eliminate barriers 

to equal employment opportunity.

Measures

Compliance Indicator 

D.1 - The agency conducts a reasonable

assessment to monitor progress towards

achieving equal employment opportunity

throughout the year.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

D.1.a

Does the agency have a process for identifying 

triggers in the workplace? [see MD-715 

Instructions, Sec. I]

YES New
EEOC FORM 

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Measures

Compliance Indicator 

D.1 - The agency conducts a reasonable

assessment to monitor progress towards

achieving equal employment opportunity

throughout the year.

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

D.1.b

Does the agency regularly use the following 

sources of information for trigger identification: 

workforce data; complaint/grievance data; exit 

surveys; employee climate surveys; focus groups; 

affinity groups; union; program evaluations; 

special emphasis programs; reasonable 

accommodation program; anti-harassment 

program; and/or external special interest groups? 

[see MD-715 Instructions, Sec. I]

YES New

D.1.c

Does the agency conduct exit interviews or 

surveys that include questions on how the agency 

could improve the recruitment, hiring, inclusion, 

retention and advancement of individuals with 

disabilities? [see 29 CFR 1614.203(d)(1)(iii)(C)] 

YES New

Measures

Compliance Indicator 

D.2 - The agency identifies areas where

barriers may exclude EEO groups (reasonable 

basis to act.)

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

D.2.a

Does the agency have a process for analyzing the 

identified triggers to find possible barriers? [see 

MD-715, (II)(B)]

YES New

D.2.b

Does the agency regularly examine the impact of 

management/personnel policies, procedures, and 

practices by race, national origin, sex, and 

disability? [see 29 CFR §1614.102(a)(3)] 

YES B.2.c.2
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Measures

Compliance Indicator 

D.2 - The agency identifies areas where

barriers may exclude EEO groups (reasonable 

basis to act.)

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

D.2.c

Does the agency consider whether any group of 

employees or applicants might be negatively 

impacted prior to making human resource 

decisions, such as re-organizations and 

realignments? [see 29 CFR §1614.102(a)(3)] 

YES B.2.c.1

D.2.d

Does the agency regularly review the following 

sources of information to find barriers: 

complaint/grievance data, exit surveys, employee 

climate surveys, focus groups, affinity groups, 

union, program evaluations, anti-harassment 

program, special emphasis programs, reasonable 

accommodation program; anti-harassment 

program; and/or external special interest groups? 

[see MD-715 Instructions, Sec. I] If "yes", please 

identify the data sources in the comments column. 

YES

Complaint/grievance data, exit 

surveys, employee climate 

surveys, focus groups, affinity 

groups, anti-harassment 

program, special emphasis 

programs, and the reasonable 

accommodation program. 

New

Measures

Compliance Indicator 

D.3 - The agency establishes appropriate

action plans to remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

D.3.a.

Does the agency effectively tailor action plans to 

address the identified barriers, in particular 

policies, procedures, or practices? [see 29 CFR 

§1614.102(a)(3)]

YES New

D.3.b

If the agency identified one or more barriers 

during the reporting period, did the agency 

implement a plan in Part I, including meeting the 

target dates for the planned activities? [see MD715, II(D)] 

YES New
EEOC FORM 

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Measures

Compliance Indicator 

D.3 - The agency establishes appropriate 

action plans to remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

Current 

Part G 

Questions

D.3.c Does the agency periodically review the 

effectiveness of the plans? [see MD-715, II(D)] YES New

Measures 

Compliance Indicator 

D.4 - The agency has an affirmative action

plan for people with disabilities, including

those with targeted disabilities

Measure 

Met?

(Yes/No/NA)

Comments

Current 

Part G 

Questions

D.4.a

Does the agency post its affirmative action plan 

on its public website? [see 29 CFR 

1614.203(d)(4)] Please provide the internet 

address in the comments.

YES www.fhwa.dot.gov/civilrights/ New

D.4.b

Does the agency take specific steps to ensure 

qualified people with disabilities are aware of and 

encouraged to apply for job vacancies? [see 29 

CFR 1614.203(d)(1)(i)]

YES New

D.4.c

Does the agency ensure that disability-related 

questions from members of the public are 

answered promptly and correctly? [see 29 CFR 

1614.203(d)(1)(ii)(A)] 

YES New

D.4.d

Has the agency taken specific steps that are 

reasonably designed to increase the number of 

persons with disabilities or targeted disabilities 

employed at the agency until it meets the goals? 

[see 29 CFR 1614.203(d)(7)(ii)] 

YES New

Essential Element E: Efficiency

This element requires the agency head to ensure that there are effective systems for evaluating the impact and effectiveness of 

the agency's EEO programs and an efficient and fair dispute resolution process.
EEOC FORM 

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Measures

Compliance Indicator 

E.1 - The agency maintains an efficient, fair, 

and impartial complaint resolution process.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.1.a Does the agency timely provide EEO counseling, 

pursuant to 29 CFR §1614.105? YES E.3.a.1

E.1.b

Does the agency provide written notification of 

rights and responsibilities in the EEO process 

during the initial counseling session, pursuant to 

29 CFR §1614.105(b)(1)? 

YES E.3.a.2

E.1.c

Does the agency issue acknowledgment letters 

immediately upon receipt of a formal complaint, 

pursuant to MD-110, Ch. 5(I)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

E.1.d

Does the agency issue acceptance letters/dismissal 

decisions within a reasonable time (e.g., 60 days) 

after receipt of the written EEO Counselor report, 

pursuant to MD-110, Ch. 5(I)? If so, please 

provide the average processing time in the 

comments.

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

E.1.e

Does the agency ensure all employees fully 

cooperate with EEO counselors and EEO 

personnel in the EEO process, including granting 

routine access to personnel records related to an 

investigation, pursuant to 29 CFR 

§1614.102(b)(6)?

YES New

E.1.f Does the agency timely complete investigations, 

pursuant to 29 CFR §1614.108? N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.3
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Measures

Compliance Indicator 

E.1 - The agency maintains an efficient, fair, 

and impartial complaint resolution process.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.1.g

If the agency does not timely complete 

investigations, does the agency notify 

complainants of the date by which the 

investigation will be completed and of their right 

to request a hearing or file a lawsuit, pursuant to 

29 CFR §1614.108(g)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

E.1.h

When the complainant does not request a hearing, 

does the agency timely issue the final agency 

decision, pursuant to 29 CFR §1614.110(b)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.4

E.1.i

Does the agency timely issue final actions 

following receipt of the hearing file and the 

administrative judge's decision, pursuant to 29 

CFR §1614.110(a)? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.7

E.1.j

If the agency uses contractors to implement any 

stage of the EEO complaint process, does the 

agency hold them accountable for poor work 

product and/or delays? [See MD-110, Ch. 

5(V)(A)] If "yes", please describe how in the 

comments column. 

N/A

FHWA does not use 

contractors for its stages of 

the EEO process. To the 

extent contractors are used 

for other stages, this is 

handled by the Departmental 

Office of Civil Rights.

E.2.c

E.1.k

If the agency uses employees to implement any 

stage of the EEO complaint process, does the 

agency hold them accountable for poor work 

product and/or delays during performance 

review? [See MD-110, Ch. 5(V)(A)] 

YES New

E.1.l

Does the agency submit complaint files and other 

documents in the proper format to EEOC through 

the Federal Sector EEO Portal (FedSEP)? [See 29 

CFR § 1614.403(g)] 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 54 of 99

Measures Compliance Indicator 

E.2 - The agency has a neutral EEO process.

Measure Met?

(Yes/No/NA)

Comments

Revised Indicator

Current 

Part G 

Questions

E.2.a

Has the agency established a clear separation 

between its EEO complaint program and its 

defensive function? [see MD-110, Ch. 1(IV)(D)]

YES New

E.2.b

When seeking legal sufficiency reviews, does the 

EEO office have access to sufficient legal 

resources separate from the agency 

representative? [see MD-110, Ch. 1(IV)(D)] If 

"yes", please identify the source/location of the 

attorney who conducts the legal sufficiency 

review in the comments column. 

N/A

Legal sufficiency reviews 

are handled at the 

Departmental level.

E.6.a

E.2.c

If the EEO office relies on the agency's defensive 

function to conduct the legal sufficiency review, 

is there a firewall between the reviewing attorney 

and the agency representative? [see MD-110, Ch. 

1(IV)(D)]

N/A

Legal sufficiency reviews 

are handled at the 

Departmental level.

New

E.2.d

Does the agency ensure that its agency 

representative does not intrude upon EEO 

counseling, investigations, and final agency 

decisions? [see MD-110, Ch. 1(IV)(D)] 

YES E.6.b

E.2.e

If applicable, are processing time frames 

incorporated for the legal counsel's sufficiency 

review for timely processing of complaints? 

EEOC Report, Attaining a Model Agency 

Program: Efficiency (Dec. 1, 2004) 

N/A

Legal sufficiency reviews 

are handled at the 

Departmental level.

E.6.c
EEOC FORM 

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Measures

Compliance Indicator 

E.3 - The agency has established and

encouraged the widespread use of a fair 

alternative dispute resolution (ADR) program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.3.a

Has the agency established an ADR program for 

use during both the pre-complaint and formal 

complaint stages of the EEO process? [see 29 

CFR §1614.102(b)(2)]

YES E.4.a

E.3.b

Does the agency require managers and 

supervisors to participate in ADR once it has been 

offered? [see MD-715, II(A)(1)]

YES

Mandatory participation is 

required of managers and 

supervisors once offered 

and Aggrieved Person 

elects.

E.4.c

E.3.c

Does the agency encourage all employees to use 

ADR, where ADR is appropriate? [see MD-110, 

Ch. 3(IV)(C)]

YES D.2.a

E.3.d

Does the agency ensure a management official 

with settlement authority is accessible during the 

dispute resolution process? [see MD-110, Ch. 

3(III)(A)(9)]

YES New

E.3.e

Does the agency prohibit the responsible 

management official named in the dispute from 

having settlement authority? [see MD-110, Ch. 

3(I)]

YES E.4.d

E.3.f

Does the agency annually evaluate the 

effectiveness of its ADR program? [see MD-110, 

Ch. 3(II)(D)]

N/A This assessment is handled 

at the Departmental level. New
EEOC FORM 

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Measures

Compliance Indicator 

E.4 - The agency has effective and accurate

data collection systems in place to evaluate its 

EEO program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.4.a

Does the agency have systems in place to 

accurately collect, monitor, and analyze the 

following data:

E.4.a.1

Complaint activity, including the issues and bases 

of the complaints, the aggrieved 

individuals/complainants, and the involved 

management official? [see MD-715, II(E)]

YES E.5.a

E.4.a.2 The race, national origin, sex, and disability status 

of agency employees? [see 29 CFR §1614.601(a)] YES E.5.c

E.4.a.3 Recruitment activities? [see MD-715, II(E)] YES E.5.f

E.4.a.4

External and internal applicant flow data 

concerning the applicants' race, national origin, 

sex, and disability status? [see MD-715, II(E)]

YES New

E.4.a.5 The processing of requests for reasonable 

accommodation? [29 CFR § 1614.203(d)(4)] YES New

E.4.a.6

The processing of complaints for the antiharassment program? [see EEOC Enforcement 

Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), § 

V.C.2]

YES New

E.4.b

Does the agency have a system in place to resurvey the workforce on a regular basis? [MD715 Instructions, Sec. I] 

YES New
EEOC FORM 

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Measures

Compliance Indicator 

E.5 - The agency identifies and disseminates

significant trends and best practices in its EEO 

program.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

E.5.a

Does the agency monitor trends in its EEO 

program to determine whether the agency is 

meeting its obligations under the statutes EEOC 

enforces? [see MD-715, II(E)] If "yes", provide 

an example in the comments.

YES

Reviews Annual Federal 

Equal Employment 

Opportunity Statistical 

Report of Discrimination 

Complaints (EEOC Form 

462) to develop and provide

training in EEO areas.

E.5.e

E.5.b

Does the agency review other agencies' best 

practices and adopt them, where appropriate, to 

improve the effectiveness of its EEO program? 

[see MD-715, II(E)] If "yes", provide an example 

in the comments.

YES

Adopted a best practice 

from GSA. EEO counselors 

provide initial contact form 

to Aggrieved Persons to 

review for accuracy of EEO 

allegations.

E.5.g

E.5.c

Does the agency compare its performance in the 

EEO process to other federal agencies of similar 

size? [see MD-715, II(E)]

YES E.3.a

Essential Element F: Responsiveness and Legal Compliance

This element requires federal agencies to comply with EEO statutes and EEOC regulations, policy guidance, and other written 

instructions.
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 58 of 99

Measures

Compliance Indicator 

F.1 - The agency has processes in place to

ensure timely and full compliance with EEOC

Orders and settlement agreements.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.1.a

Does the agency have a system of management 

controls to ensure that its officials timely comply 

with EEOC orders/directives and final agency 

actions? [see 29 CFR §1614.102(e); MD-715, 

II(F)]

YES F.1.a

F.1.b

Does the agency have a system of management 

controls to ensure the timely, accurate, and 

complete compliance with resolutions/settlement 

agreements? [see MD-715, II(F)]

YES E.3.a.6

F.1.c

Are there procedures in place to ensure the timely 

and predictable processing of ordered monetary 

relief? [see MD-715, II(F)]

YES F.2.a.1

F.1.d Are procedures in place to process other forms of 

ordered relief promptly? [see MD-715, II(F)] YES F.2.a.2

F.1.e

When EEOC issues an order requiring 

compliance by the agency, does the agency hold 

its compliance officer(s) accountable for poor 

work product and/or delays during performance 

review? [see MD-110, Ch. 9(IX)(H)] 

N/A Compliance Officer is at the 

Departmental Level. F.3.a.

Measures

Compliance Indicator 

F.2 - The agency complies with the law,

including EEOC regulations, management 

directives, orders, and other written

instructions.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.2.a

Does the agency timely respond and fully comply 

with EEOC orders? [see 29 CFR §1614.502; MD715, II(E)]YES C.3.d
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

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Measures

Compliance Indicator 

F.2 - The agency complies with the law,

including EEOC regulations, management 

directives, orders, and other written

instructions.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.2.a.1

When a complainant requests a hearing, does the 

agency timely forward the investigative file to the 

appropriate EEOC hearing office? [see 29 CFR 

§1614.108(g)]

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

E.3.a.5

F.2.a.2

When there is a finding of discrimination that is 

not the subject of an appeal by the agency, does 

the agency ensure timely compliance with the 

orders of relief? [see 29 CFR §1614.501] 

YES

FHWA notes, however, that 

there have not been any such 

findings in recent years. 

E.3.a.7

F.2.a.3

When a complainant files an appeal, does the 

agency timely forward the investigative file to 

EEOC's Office of Federal Operations? [see 29 

CFR §1614.403(e)] 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

New

F.2.a.4

Pursuant to 29 CFR §1614.502, does the agency 

promptly provide EEOC with the required 

documentation for completing compliance? 

N/A

This function is handled by 

the Departmental Office of 

Civil Rights.

F.3.d (1 to

9) 

Measures

Compliance Indicator 

F.3 - The agency reports to EEOC its program

efforts and accomplishments.

Measure Met?

(Yes/No/NA) Comments

Current 

Part G 

Questions

F.3.a

Does the agency timely submit to EEOC an 

accurate and complete No FEAR Act report? 

[Public Law 107-174 (May 15, 2002), §203(a)]

YES New

F.3.b

Does the agency timely post on its public 

webpage its quarterly No FEAR Act data? [see 29 

CFR §1614.703(d)]

YES New
Page 60 of 100

MD-715 – Part H

Part H1

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program. 

 If the agency did not address any deficiencies during the reporting period, please check the 

box. 

Statement of Model Program Essential Element Deficiency 

Type of Program Deficiency Brief Description of Program Deficiency

The Agency has not trained all 

employees (supervisory and 

non-supervisory) on DOT’s 

anti-harassment policies

The Agency has trained all employees (supervisory and nonsupervisory) on DOT’s anti-harassment policies. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

12/1/2016 

To ensure that all 

managers/supervisors are 

trained on anti-harassment 

policies.

12/1/2016 09/30/2017 

09/30/2018 

09/30/2017 

09/30/2018 

09/30/2019 

09/30/2020 

Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Associate Administrator for Civil Rights Irene Rico YES

Planned Activities Toward Completion of Objective 
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Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

09/30/2017 

Identify available training 

module and/or develop and 

implement a training module 

for anti-harassment policies

YES 09/30/2021 

09/30/2017

04/30/2018 

09/30/2019 

09/30/2020

09/30/2017 

Present webinars, in person 

training and/ or web-based 

sessions to be delivered 

and/or offered to managers, 

supervisors and employees

YES 09/30/2021 

09/30/2017 

09/30/2018 

09/30/2019 

09/30/2020 

Report of Accomplishments 

Fiscal Year Accomplishments

2018 

The mandatory training began in FY 18 and will continue each FY that follows, 

via a series of webinars and in person sessions. Proactive prevention is the best 

tool to prevent harassment in the workplace. Therefore, FHWA’s training 

focuses on prevention and employee involvement in creating a civil and 

inclusive culture within the workplace.

2019 

On June 21, 2019, the Department issued its Policy Framework for the 

Prevention of Harassment, which, among other things, requires each mode to 

develop an anti-harassment process incorporating certain parameters, and 

submit that process for OST review within 90 days. The FHWA pilot process 

already met many of the Framework’s requirements but did not meet others. 

Since the issuance of the Framework, the workgroup has been working to revise 

the FHWA pilot process to conform to the Framework’s requirements. Similar 

to the Pilot process, the proposed FHWA Anti-Harassment Process addresses 

allegations of any type of harassment in or relating to (FHWA) workplace. 

Based on the Policy Framework FHWA submitted the updated procedures to 

OST for approval on September 19, 2019. On November 19, 2019, FHWA 

received final approval for its process. The FHWA communicated the approval 

and the new process to all employees on December 18, 2019, via email. 

Training

FHWA secured a contract for FY 2020 Anti-Harassment Training. This 

contract will provide harassment training to all FHWA employees. 
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Fiscal Year Accomplishments

2020 

Training

FY2020 Anti-Harassment Training of Managers/Supervisors (Agency Leaders, 

HQs Management, and Field Management) was delivered with a total of eight 

sessions conducted both in person and virtually. 

In addition, FHWA developed and released the Anti-Harassment Toolkit for 

Managers that is a comprehensive resource to managers to understand their 

roles and responsibilities. 
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MD-715 – Part H

Part H2

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the 

box. 

Statement of Model Program Essential Element Deficiency 

Type of Program Deficiency Brief Description of Program Deficiency

Agency does not conduct trend 

analysis on workforce data 

The FHWA has not completed a 3-year trend analyses for 

the workforce compensation and reward system by race, 

national origin, sex, and disability. 

Objective(s) and Dates for EEO Plan

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

12/15/2005 

To conduct trend 

analyses for workforce 

compensation and 

reward system by race, 

national origin, sex, and 

disability.

09/30/2017 

09/302017 

09/30/2020 

09/30/2021 

03/02/2017 

Ongoing 

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Director of Human Resources David Lewis YES

Operations Team Leader Tanya Emam YES

Planned Activities Toward Completion of Objective 
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Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

09/30/2017 

HCR in continued 

partnership with HR will 

conduct annual barrier 

analyses by race, national 

origin and sex on 

workforce compensation 

and awards for the last 3 

to 5 years.

YES 09/30/2017 

09/30/2021 

09/30/2017 

HCR in continued 

partnership with HR will 

conduct annual trend 

analyses by disability on 

workforce compensation 

and awards for the last 3 

to 5 years.

YES

09/30/2017 

09/30/2020 9/30/2021 

Report of Accomplishments

Fiscal 

Year Accomplishments

2018 

The FHWA “At-A-Glance” workforce analysis report for FY 18 was completed 

and presented to the Agency in February 2019. On an annual basis, this 

workforce analysis is presented as a snapshot of the FHWA’s workforce by 

Gender, Ethnicity, Disability, Grade Dispersion, Awards and Recognition. 

FHWA continues to monitor and conduct an annual trend analysis by race, 

national origin and sex on workforce compensation and awards. 
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Fiscal 

Year Accomplishments

2019 

The FHWA continues to examine and review its recruitment trends in an effort 

to bolster the Agency’s corporate recruitment plan. It will be utilizing the Data 

Visualization Center to continue to identify new ways to improve its recruitment 

and onboarding efforts. As part of this new plan a focus was put on increasing 

outreach and diversity in FHWA’s workforce with a particular focus on 

women. A 30+ page recruitment plan that created 5 year benchmarks of 

FHWA’s applicant pool, aligned with previous workforce plans, identified 

underrepresented populations and hiring targets for each as well as predictions 

for mission critical turnover was developed. Hiring fairs and outreach events 

were identified to align with the data to create a strategic approach to 

organizational outreach and recruitment. FHWA worked with FHWA leadership 

to develop a designated team for recruitment and outreach. The result was the 

creation of the Recruitment Outreach And Diversity (ROAD) Team. The ROAD 

team created new promotional materials including brochures and a banner for 

display and distribution. In addition, FHWA recognized a need to understand 

how to advertise its careers in urban areas. FHWA conducted market research 

on brand awareness and specifically looked at the effectiveness of transit 

advertising in multiple metropolitan areas. The information was later used to 

identify a vendor and advertising package to pursue billboard advertising to 

promote the Agency’s very own career fair in Q2 of FY 2020. To further 

support the ROAD team and the Agency’s recruitment efforts, FHWA enhanced 

its Ambassador’s program, which is an initiative to select and train Division 

Office recruiters all over the Agency. The ROAD team updated the list of 

approximately 100 recruiters and grew the list with support from senior 

leadership to approximately 180 ambassadors. New recruiters were selected 

with an emphasis on creating as much diversity as possible. A 1-day training 

was created for Ambassadors to teach them how to be effective recruiters, or 

Ambassadors, for FHWA. Two separate 1-day trainings were offered in FY 

19. Post-course feedback was very positive with the course receiving 

overwhelmingly positive reviews. FHWA now has a larger pool of diverse 

recruiters nationwide to attend hiring fairs, professional conferences, and career 

info sessions while visiting colleges and universities. A list of universities as 

well as points of contact was compiled. Each university was contacted via email 

or phone to ensure that FHWA’s contact list was up to date. Utilizing 

Handshake, US News and World Report’s annual list of top engineering schools, 

and lists of Minority Serving Institutions, Historically Black Colleges and 

Universities, all female universities, Hispanic Serving Institutes and Asian 

Serving Institutes as well as large universities with diverse student bodies. 

FHWA now has a list of 239 universities with specific points of contact that its 

recruiters have access to. Many have already used the list to begin outreach 

efforts and conduct presentations at universities.
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Fiscal 

Year Accomplishments

2020 

The FHWA “At-A-Glance” workforce analysis report for FY 20 was completed 

and presented to the Agency on April 8, 2021. On an annual basis, this 

workforce analysis is presented as a snapshot of the FHWA’s workforce by 

Gender, Ethnicity, Disability, Grade Dispersion, Awards and Recognition. 

FHWA continues to monitor and conduct an annual trend analysis by race, 

national origin and sex on workforce compensation and awards. 

FHWA has analyzed the RNO over a 3 year trend in relation to compensation 

and awards. The next steps is to utilize a Barrier Analysis Team to identify 

triggers, determine if there are barriers, and develop an action plan. 
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MD-715 – Part H

Part H3

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in 

the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the 

box.

Statement of Model Program Essential Element Deficiency 

Type of Program Deficiency Brief Description of Program Deficiency

Tracking recruitment efforts and 

using this data to identify 

potential barriers in accordance 

with MD-715 standards. 

The FHWA does not track the effectiveness of our 

targeted outreach recruitment efforts and analyze resulting 

data to identify potential barriers in accordance with MD715 standards. 

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

12/15/2011

To track and analyze the 

effectiveness of our 

targeted recruitment 

outreach efforts to 

determine whether the 

FHWA is yielding a 

sufficient number of 

applications from the 

targeted recruitment 

activities conducted 

throughout the year. 

09/30/2017

Target date 

extended: 

09/30/2019 

09/30/2020

Complete

9/30/2020

Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Director of Human Resources David Lewis YES
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Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

09/30/2017 

FHWA will work to 

identify the best approach 

to gathering and tracking 

data on recruitment 

resources. 

YES 09/30/2020 

09/30/2017 

Complete

9/30/2020 

09/30/2017 Analyze Data. YES 09/30/2020 

09/30/2017 

Complete

9/30/2020 

Report of Accomplishments 

Fiscal Year Accomplishments

2018 

In FY 18 recruitment efforts were not as expected due to additional 

processes built into the vetting approval process of new positions by FHWA. 

The Department approves all vacancies. This adds an additional layer to the 

process. A modified plan is still in developmental stages with the target date 

of 09/30/2020 so that multiple year trend analyses can be 

performed. Recruitment activities will continue to be monitored for hiring 

trends for FY 19/20. 

2019 

The FHWA continues to examine and review its recruitment trends. It will 

be utilizing the Data Visualization Center to continue to identify ways to 

improve its recruitment and onboarding efforts. This will be an ongoing 

effort for FY 2020.

2020 

FHWA consistently participates in recruitment events also making it a 

priority to attend virtual events as well. FHWA then does an assessment 

using event evaluation forms for attendees to assess the success of the event. 

This routine will continue going forward. 
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MD-715 Part I: 

Agency EEO Plan to Eliminate Identified Barrier

Please describe the status of each plan that the agency implemented to identify possible barriers 

in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the 

box. 

Statement of Condition That Was a Trigger for a Potential Barrier: 

Source of the 

Trigger

Specific 

Workforce 

Data Table 

Narrative Description of Trigger

Workforce Data 

Tables A/1, B/1

Groups with lower than expected participation rates

when comparing workforce indicators such as onboard 

representation, the CLF, hiring, and/or separation rates. 

EEO Group(s) Affected by Trigger

EEO Group Affected by Trigger (Yes/No)

All Men NO

All Women YES

Hispanic or Latino Males NO

Hispanic or Latino Females YES

White Males NO

White Females YES

Black or African American Males NO

Black or African American Females NO

Asian Males NO

Asian Females NO

Native Hawaiian or Other Pacific Islander 

Males YES

Native Hawaiian or Other Pacific Islander 

Females YES
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EEO Group Affected by Trigger (Yes/No)

American Indian or Alaska Native Males YES

American Indian or Alaska Native Females YES

Two or More Races Males YES

Two or More Races Females NO

Barrier Analysis Process 

Sources of Data Source Reviewed?

(Yes or No) Identify Information Collected

Workforce Data Tables YES

Complaint Data (Trends) YES

Grievance Data (Trends) NO

Findings from Decisions (e.g., 

EEO, Grievance, MSPB, 

Anti-Harassment Processes) 

YES

Climate Assessment Survey 

(e.g., FEVS) YES

Exit Interview Data NO

Focus Groups NO

Interviews NO

Reports (e.g., Congress, 

EEOC, MSPB, GAO, OPM) NO

Other (Please Describe) NO

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

YES YES

Statement of Identified Barrier(s)
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Description of Policy, Procedure, or Practice

The Agency is in the process of conducting a barrier analysis of recruitment and hiring 

practices, and the separation factors. The DOT has not identified the causes of the condition 

at the time of reporting.

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy) Objective Target Date (mm/dd/yyyy) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

03/30/2018

FHWA will continue to 

implement its focus 

outreach efforts to 

recruit qualified female 

applicants and applicants 

from groups with lower 

than expected 

participation rates. 

FHWA will leverage its 

resources to increase 

recruitment efforts, 

through the 2019-2022 

Strategic Plan.

09/30/2022

04/30/2021

FHWA will continue to 

implement and perform 

workforce analysis on a 

biennial basis as it 

relates to hiring rate and 

separation rates over a 3-

year trend. As well as 

further analysis at the 

higher-grade levels. 

Once analysis is 

complete, FHWA will 

look to perform: 1) 

Focus Groups; 2) Exit 

Interviews; and 3) 

Target Group Surveys 

on any identified triggers 

to further analyze 

barriers if necessary.

9/30/2023
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Responsible Official(s) 

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Associate Administrator for Civil 

Rights Irene Rico YES

Director of Human Resources David Lewis YES

Report of Accomplishments

2020 

FY 20 Accomplishments for recruiting women:110 or 36.8% of the permanent hires 

were women – an 11% increase from the 99 women hired in FY 2019. With the 

improvements in hiring, women still separated. It is noted that in FY 20 the separation 

rate of women is higher than the participant rate of women in the total workforce. 

FHWA excelled in improving the number of females in the applicant pools of the 

following two occupational series: 0810 (Civil Engineering) which is a hard to fill 

occupation where the talent pool is overwhelmingly male and 0020 (Community 

Planning) which saw the largest spike in the number of female applicants. 

0810 Civil Engineering saw an increase from 245 in 2019 to 286 female applicants in 

2020, a 114% increase in the number of female applicants.

0020 Community Planning saw an increase from 68 in 2019 to 114 female applicants 

in 2020, a 141% increase in the number of female applicants 

 
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MD-715 – Part J 

Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of Persons 

with Disabilities

To capture agencies’ affirmative action plan for persons with disabilities (PWD) and persons 

with targeted disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 

require agencies to describe how their plan will improve the recruitment, hiring, advancement, 

and retention of applicants and employees with disabilities. All agencies, regardless of size, 

must complete this Part of the MD-715 report. 

Section I: Efforts to Reach Regulatory Goals 

EEOC regulations (29 C.F.R. § 1614.203(d)(7)) require agencies to establish specific numerical 

goals for increasing the participation of persons with reportable and targeted disabilities in the 

federal government. 

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving 

PWD by grade level cluster in the permanent workforce? If “yes”, describe the trigger(s) 

in the text box. 

a. Cluster GS-1 to GS-10 (PWD) Yes 0 No X

b. Cluster GS-11 to SES (PWD) Yes X No 0

Source: Table B4P: In FY20, PWD in GS 1-10 Cluster of the permanent workforce 

participate at 18.77%, a higher rate than the expected 12% benchmark, indicating no 

trigger. 

PWD in the GS 11 to SES Cluster participate at 9.85%, a lower rate than the expected 

12% benchmark, indicating a trigger. (Source: Table B4P) 

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving 

PWTD by grade level cluster in the permanent workforce? If “yes”, describe the 

trigger(s) in the text box. 

a. Cluster GS-1 to GS-10 (PWTD) Yes 0 No X

b. Cluster GS-11 to SES (PWTD) Yes 0 No X

Source Table B4P: In FY20, PWTD in GS 1-10 Cluster of the permanent 

workforce participate at 5.80%, a higher rate than the expected 2% benchmark, 

indicating no trigger. 

PWTD in the GS 11 to SES Cluster participate at 2.35%, a rate equal to the 

expected 2% benchmark, indicating no trigger. (Table B4P) 
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3. Describe how the agency has communicated the numerical goals to the hiring managers

and/or recruiters.

Through FY 20, the Agency’s numerical goals for hiring person with disabilities was

shared via the Agency’s quarterly Leadership Team Dashboard. This was specifically

targeted toward managers and supervisors and is posted on the Agency’s internal Website

to provide access to all employees. In addition, the annual FHWA At-A-Glance report

and All Employee Webinar briefing are used to share information on the Agency’s

workforce including the status of persons with disabilities. Also, all senior leadership

members receive the Office Profile for their organization biannually which includes

information on the numerical representation of persons with disabilities and persons with

targeted disabilities in their organizations. The Agency’s annual Workforce Plan

includes a section on “Employment of Persons with Disabilities” that identifies the

numerical goals and how the Agency did in meeting those goals.

Section II: Model Disability Program 

Pursuant to 29 C.F.R. §1614.203(d)(1), agencies must ensure sufficient staff, training and 

resources to recruit and hire persons with disabilities and persons with targeted disabilities, 

administer the reasonable accommodation program and special emphasis program, and oversee 

any other disability hiring and advancement program the agency has in place. 

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR THE

DISABILITY PROGRAM

1. Has the agency designated sufficient qualified personnel to implement its

disability program during the reporting period? If “no”, describe the agency’s plan

to improve the staffing for the upcoming year.

Yes X No 0

Not applicable.

2. Identify all staff responsible for implementing the agency’s disability employment

program by the office, staff employment status, and responsible official.

Disability Program Task 

# of FTE Staff by 

Employment Status Responsible Official

(Name, Title, Office, 

Email) Full 

Time

Part 

Time

Collateral 

Duty

Processing applications from PWD 

and PWTD 1 Steven Graham, Human Resources Specialist

Answering questions from the public 

about hiring authorities that take 

disability into account 

1 

Steven Graham, Human 

Resources Specialist
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Disability Program Task 

# of FTE Staff by 

Employment Status Responsible Official

(Name, Title, Office, 

Email) Full 

Time

Part 

Time

Collateral 

Duty

Processing reasonable accommodation 

requests from applicants and 

employees

1 

Kirsten Poston, 

Disability Program 

Manager

Section 508 Compliance 

1 

Michelle Cribbs,

Section 508 Program 

Manager 

Architectural Barriers Act Compliance

1 

Jeffrey Baxter, 

Associate Director of 

Facilities, Office of the 

Secretary (OST)

Special Emphasis Program for PWD 

and PWTD 1 

Kirsten Poston, 

Disability Program 

Manager

3. Has the agency provided disability program staff with sufficient training to carry

out their responsibilities during the reporting period? If “yes”, describe the

training that disability program staff have received. If “no”, describe the training

planned for the upcoming year.

Yes X No 0

All Human Resources Specialists and hiring managers are required to complete 

the Veteran Employment Training for Human Resource Professionals which also 

includes information on the use of Schedule A hiring authorities. This 

information is tracked via the USDOT’s Learning Management System. 

B. Plan to Ensure Sufficient Funding for the Disability Program

1. Has the agency provided sufficient funding and other resources to successfully

implement the disability program during the reporting period? If “no”, describe

the agency’s plan to ensure all aspects of the disability program have sufficient

funding and other resources.

Yes X No 0

Not applicable.

Section III: Plan to Recruit and Hire Individuals with Disabilities

Pursuant to 29 C.F.R. § 1614.203(d)(1)(i) and (ii), agencies must establish a plan to increase the 

recruitment and hiring of individuals with disabilities. The questions below are designed to 

identify outcomes of the agency’s recruitment program plan for PWD and PWTD. 

A. Plan to Identify Job Applicants with Disabilities
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1. Describe the programs and resources the agency uses to identify job applicants

with disabilities, including individuals with targeted disabilities. S

The FHWA has a multipronged approach to identify potential applicants with

disabilities. This includes:

• Participating in recruitment and outreach events that focus on the

employment of persons with disabilities. In FY 20, FHWA participated in

51 in-person and 34 virtual recruitment events nationally. Of those seven

events were related to disability hiring.

• Developing and maintaining relationships with disability organizations

and colleges with disability offices. This allows FHWA to share

information related to job opportunities which can be shared with their

community. In some instances, these organizations have helped FHWA to

post job announcements on their recruitment sites to be more visible.

FHWA is using Handshake and Simplicity to post job opportunities.

• The FHWA implements a Recruitment, Outreach and Diversity plan that

focuses on increasing the number of applicants with disabilities within

FHWA's overall applicant pool. To achieve this outcome the Agency

attends hiring events that are marketed toward or attract people with

disabilities. In FY 20 FHWA attended seven hiring events that were

marketed toward people with a disability.

• The DOT Executive Agent has a standard list of professional

organizations, and academic institutions that automatically receive a copy

of all job announcements posted via USAJobs. More specifically, FHWA

has used the following recruitment sources as part of its outreach to have

persons with disabilities apply for vacancies:

• OPM’s Shared List of People with Disabilities; the Workforce

Recruitment Program (WRP) database; State and local vocational

rehabilitation agencies and employment offices; the Department of

Veterans Affairs, Wounded Warrior Office and Vets 2 Feds; Military

installations and transition offices.

• FHWA created a database of People with Disabilities and Disabled

Veterans with a disability rating of 30% or higher. Resumes are

categorized by occupation. Classification and Staffing Specialists have

access to this database and provide resumes for hiring managers to review

prior to determining if they would like to pursue a USAJobs vacancy

announcement.
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This list is not all encompassing but provides a broad view of the Agency’s 

ongoing efforts. 

2. Pursuant to 29 C.F.R. § 1614.203(a)(3), describe the agency’s use of hiring 

authorities that take disability into account (e.g., Schedule A) to recruit PWD and 

PWTD for positions in the permanent workforce. 

The FHWA utilizes appointing authorities to include Schedule A, Excepted 

Service, Veterans Recruitment Appointment (VRA) and 30% or more Disabled 

Veterans. FHWA continues to work with the DOT Office of the Secretary on the 

establishment of the Warriors to the DOT program. FHWA was one of a just a 

few Agencies within DOT to make a selection in support of this program. 

HR specialists provide information on these hiring flexibilities when contacted by 

hiring managers to fill a vacancy. The HR Specialist identifies which authority 

may meet the needs of the office and provides information on how to use the 

authorities if deemed appropriate.

3. When individuals apply for a position under a hiring authority that takes disability 

into account (e.g., Schedule A), explain how the agency (1) determines if the 

individual is eligible for appointment under such authority and (2) forwards the 

individual's application to the relevant hiring officials with an explanation of how 

hand when the individual may be appointed. 

At FHWA, the HR Specialists work directly with hiring managers to use the noncompetitive excepted service hiring authorities, including Schedule A. If a 

manager determines that a hiring authority that takes disability into account may 

be used, the HR Specialists provides specific information related to how 

applications are received and reviewed. This may include requesting resumes 

from the Agency’s Selection Placement Coordinator assigned to collect and share 

this information. In addition, Agency recruiters from around the country may be 

asked for points of contacts for Veteran organizations to facilitate resume 

collection. 

FHWA receives and reviews resumes and determines whether the applicants are 

qualified for the position and whether the applicants submitted the necessary 

supplemental documents including Schedule A letters. Resumes and 

supplemental documents are then forwarded to the hiring manager. After the 

hiring manager completes interviewing of qualified candidates, he/she decides if 
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the applicant can perform the job duties. The applicant must meet the 

qualification requirements, including specialized experience, for the position. 

4. Has the agency provided training to all hiring managers on the use of hiring 

authorities that take disability into account (e.g., Schedule A)? If “yes”, describe 

the type(s) of training and frequency. If “no”, describe the agency’s plan to 

provide this training. 

Yes X No 0 N/A 0

In FY20, the FHWA Office of Human Resources conducted webinars on hiring 

veterans, disabled veterans and persons with disabilities for the HR Community as 

well as for the hiring managers. 

The FHWA Selective Placement Program Coordinator advised the HR Specialists 

on the Goals for FY 20, as well as addressing workforce/succession planning 

needs. As positions become vacant, HR Specialists discussed the hiring 

flexibilities and options with hiring managers to reinforce the Agency's 

commitment for employing a diverse workforce. 

B. Plan to Establish Contacts with Disability Employment Organizations 

1. Describe the agency’s efforts to establish and maintain contacts with 

organizations that assist PWD, including PWTD, in securing and maintaining 

employment. 

The FHWA has branded their recruitment strategy ROAD and it implements a 

comprehensive strategy focused on the recruitment of a highly talented diverse 

workforce for entry level, mid-career, and hard to fill positions. The plan centers 

on creating “brand awareness” of FHWA as a preferred employer with students, 

veterans, and mid-career professionals through relationships and ongoing 

education about the mission and the vast array of positions available across 

FHWA. As part of this strategy organizations whose members are people with 

disabilities are contacted and provided information about the FHWA, as well as 

the name and email of a dedicated resource to contact. The ROAD team has also 

participated in outreach to disability employment organizations and outreach 

sources as well as conducting meetings with them to update resource information 

and to explore potential future partnerships. 

In FY 20, FHWA attended seven recruitment events at colleges, universities, 

academic institutions, and professional associations that support populations of 

diverse recruitment candidates.
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C. Progression Towards Goals (Recruitment and Hiring) 

1. Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do 

triggers exist for PWD and/or PWTD among the new hires in the permanent 

workforce? If “yes”, please describe the triggers below.

a. New Hires for Permanent Workforce (PWD) Yes 0 No X

b. New Hires for Permanent Workforce (PWTD) Yes 0 No X

Source: Table B-1-1. 

In FY20, the new hire rate for FHWA PWD in the permanent workforce was 

12.04%, a slightly higher rate than the expected 12% benchmark, indicating no 

trigger.

The new hire rate for FHWA PWTD in the permanent workforce is 2.01%, a 

slightly higher rate than the expected 2% benchmark, indicating no trigger. 

2. Using the relevant applicant pool as the benchmark, do triggers exist for PWD 

and/or PWTD among the qualified internal applicants for any of the missioncritical occupations (MCO)? If “yes”, please describe the triggers below.

a. Qualified Applicants for MCO (PWD) Yes X No 0

b. Qualified Applicants for MCO (PWTD) Yes X No 0

Source: Table B6-P Applicants for Internal Competitive Promotions for 

Major Occupations by Disability PWD qualified as applicants at a rate lower 

than the relevant applicant pool within the Financial Specialist, Civil Engineering, 

Realty Specialist, and Transportation Specialist series indicating triggers. PWTD 

qualified as applicants at a lower rate than the relevant applicant pool within the 

Financial Specialist, Engineering Technician, Civil Engineering, and 

Transportation Specialist series indicating triggers.

MCO

PWD Triggers PWTD Triggers

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

(0020) 

Community 

Planner

6.96% 16.67% No 3.48% 16.67% No

(0028) 

Environmental 

Specialist

7.89% 9.30% No 0.88% 9.30% No
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 80 of 99

MCO

PWD Triggers PWTD Triggers

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

(0501/0505) 

Financial 

Specialist

12.18% 6.0% Yes 2.56% 2.0% Yes

(0802) 

Engineering 

Technician

12.20% 18.18% No 3.66% 0.0% Yes

(0810) Civil 

Engineering 7.68% 7.58% Yes 1.81% 0.0% Yes

(1170) Realty 

Specialist 8.12% 0.0% Yes 0.00% 0.0% No

(2101) 

Transportation 

Specialist

8.55% 4.82% Yes 3.29% 2.41% Yes

3. Using the qualified applicant pool as the benchmark, do triggers exist for PWD 

and/or PWTD among employees promoted to any of the mission-critical 

occupations (MCO)? If “yes”, please describe the triggers below. 

a. Promotions for MCO (PWD) Yes X No 0

b. Promotions for MCO (PWTD) Yes X No 0

Source: Table B6-P SELECTIONS FOR INTERNAL COMPETITIVE 

PROMOTIONS for MAJOR Occupations by Disability PWD were selected at 

a rate lower than the qualified internal applicant pool within the Community 

Planner, Engineering Technician, and Civil Engineering series indicating triggers. 

PWTD were selected at a lower rate than the qualified internal applicant pool 

within the Community Planner, Environmental Specialist, and Financial Specialist 

series indicating triggers.

MCO

PWD Triggers PWTD Triggers

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

(0020) 

Community 

Planner

16.67% 0.0% Yes 16.67% 0.0% Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 81 of 99

MCO

PWD Triggers PWTD Triggers

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

Table 

Relevant 

Applicant 

Pool 

Table B6-P 

Qualified 

Internal 

Applicants

Yes/No

(0028) 

Environmental 

Specialist

9.30% 33.3% No 9.30% 0.0% Yes

(0501/0505) 

Financial 

Specialist

6.0% 42.86% No 2.00% 0.0% Yes

(0802) 

Engineering 

Technician

18.18% 0.0% Yes 0.0% 0.0% No

(0810) Civil 

Engineering 7.58% 

0.0%

0.0%

Yes 0.0% 0.0% No

(1170) Realty 

Specialist 0.00% 0.0% No 0.0% 0.0% No

(2101) 

Transportation 

Specialist

4.82% 7.14% No 2.41% 3.57% No

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities

Pursuant to 29 C.F.R §1614.203(d)(1)(iii), agencies are required to provide sufficient 

advancement opportunities for employees with disabilities. Such activities might include 

specialized training and mentoring programs, career development opportunities, awards 

programs, promotions, and similar programs that address advancement. In this section, agencies 

should identify, and provide data on programs designed to ensure advancement opportunities for 

employees with disabilities.

A. Advancement Program Plan

1. Describe the agency’s plan to ensure PWD, including PWTD, have sufficient

opportunities for advancement.

FHWA employees, including PWD and PWTD, are provided equal access to

career development opportunities for advancement. Promotion opportunities are

posted on FHWA’s internal StaffNet site, USAJOBS, and emails are sent to all

employees with a link to the vacancy announcement on USAJOBS.

The opportunity for advancement is the same for all employees. Career ladders

are established based on the position and the needs of the office. This reduces any

negative impact on PWD and PWTD.
EEOC FORM 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 82 of 99

B. Career Development Opportunities

1. Please describe the career development opportunities that the agency provides to

its employees.

The FHWA encourages and provides training and career development

opportunities for all employees, including PWD and PWTD. Within the Office of

Human Resources, the Agency has staff dedicated to the development of a catalog

of professional and leadership opportunities. There is a focus on the leadership

pipeline that includes all grade levels and across all job series. FY 2020-2021

webinars and trainings focused on employee engagement to help employees

function in a quarantine environment. The team recrafted many training programs

to allow employee to take ownership of their personal development while

understanding how their supervisors can assist them in reaching their goals in a

virtual environment. The FHWA also institutes a number of career development

programs that support and prepare our Agency’s employees for enhanced

performance and career advancement. These programs target employees at all

levels in a variety of ways and have been recrafted to be offered in a virtual

environment. The programs are as follows: The PDP, FHWA 360 Degree

Leadership Assessment, Discipline Support System, Is Supervision for Me?,

Building the Foundation for Visionary Leadership, DMC Women’s Forum

Webinar Series, Critical Human Resources Skills, Formal Mentoring Program,

Launch Point, Leadership Competency Certificate Program, Leadership

Development Academy (LDA), Management and Supervision Forum Webinar

Series, Transportation Operations Academy Senior Management Program and

several American University Leadership programs.

2. In the table below, please provide the data for career development opportunities

that require competition and/or supervisory recommendation/approval to

participate.

Career 

Development 

Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees

(%)

Internship 

Programs 26 26 23.1 23.1 11.5 11.5 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

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Page 83 of 99

Career 

Development 

Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees

(%)

Fellowship 

Programs 0 0 0.0 0.0 0.0 0.0 

Mentoring 

Programs 38 38 13.2 13.2 2.6 2.6 

Coaching 

Programs 0 0 0.0 0.0 0.0 0.0 

Training 

Programs 496 425 7.3 7.8 2.2 2.4 

Detail Programs 10 5 0.0 0.0 0.0 0.0 

Other Career 

Development 

Programs

37 37 13.5 13.5 2.7 2.7 

3. Do triggers exist for PWD among the applicants and/or selectees for any of the

career development programs? (The appropriate benchmarks are the relevant

applicant pool for the applicants and the applicant pool for selectees.) If “yes”,

describe the trigger(s) in the text box.

a. Applicants (PWD) Yes 0 No X

b. Selections (PWD) Yes 0 No X

Not applicable.

4. Do triggers exist for PWTD among the applicants and/or selectees for any of the

career development programs identified? (The appropriate benchmarks are the

relevant applicant pool for applicants and the applicant pool for selectees.) If

“yes”, describe the trigger(s) in the text box.

a. Applicants (PWTD) Yes 0 No X

b. Selections (PWTD) Yes 0 No X

For all career development programs, PWTD’s were selected at the same or 

higher rate indicating no trigger. 

C. Awards
EEOC FORM 

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1. Using the inclusion rate as the benchmark, does your agency have a trigger

involving PWD and/or PWTD for any level of the time-off awards, bonuses, or

other incentives? If “yes”, please describe the trigger(s) in the text box.

a. Awards, Bonuses, & Incentives (PWD) Yes X No 0

b. Awards, Bonuses, & Incentives (PWTD) Yes X No 0

Source: Table B9 When analyzing award categories separately, Cash Awards 

indicated YES triggers for both PWD/PWTD when compared to their inclusion 

rates. Additionally, the Time-off Awards analysis indicated no trigger for PWTD. 

(See table below)

PY20 FHWA 

Awards

Persons 

without 

Disability 

(Pw/oD)

Inclusion Rate 

for PWD & 

PWTD Group 

FHWA Total 

Permanent 

Workforce 

Inclusion 

Rate/Benchmark

Trigger

Formula

[Subtract the 

Total # of 

Persons with 

Disability 

(PWD) 

recipients 

from the Total 

# of 

Recipients]

Inclusion Rate

[Divide the Total 

# of PWD and 

Persons with 

Targeted 

Disabilities 

(PWTD) 

recipients by 

their total # in 

the permanent 

workforce] 

BenchmarkInclusion Rate

[Divide the Pw/oD 

# receiving awards 

into their 

respective # in 

permanent 

workforce] 

[Triggers exist 

if Inclusion 

Rate for PWD 

or PWTD is 

less than 

Inclusion rate 

for Pw/oD]

PWD Cash 2305-242 = 

2063

179/300= 

59.67% 2063/2467 = 

83.62% 

Yes

PWTD Cash 63/76= 82.89% Yes

PWD Time-Off 1590-174 = 

1416

128/300= 

42.67% 1416/2467= 

57.40%

Yes

PWTD Time-Off 46/76= 60.52% No

2. Using the inclusion rate as the benchmark, does your agency have a trigger

involving PWD and/or PWTD for quality step increases or performance-based

pay increases? If “yes”, please describe the trigger(s) in the text box.

a. Pay Increases (PWD) Yes X No 0 

b. Pay Increases (PWTD) Yes X No 0
EEOC FORM 

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Page 85 of 99

Source: Table B9 When analyzing the quality step increase award category 

separately, there were triggers for both PWD and PWTD when compared to its 

inclusion rates. (See the table below)

PY20 FHWA 

Awards

Persons 

without 

Disability 

(Pw/oD)

Inclusion Rate 

for PWD & 

PWTD Group 

FHWA Total 

Permanent 

Workforce Inclusion 

Rate/Benchmark

Trigger

PWD QSI

47-5 = 42

4/300 = 1.67%

42/2331 = 1.80%

Yes

PWTD QSI 1/76 = 1.31% Yes

3. If the agency has other types of employee recognition programs, are PWD and/or

PWTD recognized disproportionately less than employees without disabilities?

(The appropriate benchmark is the inclusion rate.) If “yes”, describe the employee

recognition program and relevant data in the text box.

a. Other Types of Recognition (PWD) Yes X No 0 N/A 0

b. Other Types of Recognition (PWTD) Yes X No 0 N/A

Source: Table B9 When analyzing the Honorary award category separately, there 

was a trigger indicated for PWD and PWTD when compared to their inclusion 

rate. There was no trigger for SES awards. (See the table below) 

PY20 FHWA 

Awards

Persons without 

Disability 

(Pw/oD)

Inclusion 

Rate for 

PWD & 

PWTD 

Group

FHWA Total 

Permanent 

Workforce Inclusion 

Rate/Benchmark

Trigger

PWD SES 46-4 = 42 4/4 = 100% 42/48 = 87.50% No

PWTD SES 0/0 = N/A No

PWD Honorary 

Awards 83-8 = 75

6/244 = 

2.68% 75/2684 = 2.79%

Yes

PWTD Honorary 

Awards

2/76 = 

2.63% Yes

PWD All Awards

2431-260 = 2171

193/208 = 

92.79%

2171/2684 = 80.89%

No

PWTD All Awards 67/82 = 

81.71% No

D. Promotions
EEOC FORM 

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Page 86 of 99

1. Does your agency have a trigger involving PWD among the qualified internal

applicants and/or selectees for promotions to the senior grade levels? (The

appropriate benchmarks are the relevant applicant pool for qualified internal

applicants and the qualified applicant pool for selectees.) For non-GS pay plans,

please use the approximate senior grade levels. If “yes”, describe the trigger(s) in

the text box.

a. SES

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X

b. Grade GS-15

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes X No 0

c. Grade GS-13/14

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X

Source: Table B-7 INTERNAL SELECTIONS FOR SENIOR LEVEL (GS 

13/14, GS 15, and SES) POSITIONS by PWD

The Agency used Table B-7 to analyze the applicant flow of internal applicants 

and/or selections for promotions by grade and PWD to the senior level (analysis 

included grades 13-15, SES). PWD applicants qualify at rates lower than they 

apply for the GS 13/14, GS 15 and SES grade levels. Of those qualified, PWD are 

internally selected at rates lower than they are qualified for the GS-15 indicating 

Internal Selection triggers. Analysis to identify triggers using Table B-7 are 

displayed below: 

Senior 

Grade Level

PWD

REVELANT 

APPL POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTION

Triggers 

Yes/No

GS-13/14 10.01% 4.96% Yes 8.49% No

GS-15 6.77% 6.06% Yes 5.88% Yes

SES 8.60% 0.00% Yes 0.00% No

2. Does your agency have a trigger involving PWTD among the qualified internal

applicants and/or selectees for promotions to the senior grade levels? (The

appropriate benchmarks are the relevant applicant pool for qualified internal

applicants and the qualified applicant pool for selectees.) For non-GS pay plans,

please use the approximate senior grade levels. If “yes”, describe the trigger(s) in

the text box.

a. SES
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i. Qualified Internal Applicants (PWTD) Yes X No 0

ii. Internal Selections (PWTD) Yes 0 No X

b. Grade GS-15

i. Qualified Internal Applicants (PWTD) Yes 0 No X

ii. Internal Selections (PWTD) Yes 0 No X

c. Grade GS-13/14

i. Qualified Internal Applicants (PWTD) Yes X No 0 

ii. Internal Selections (PWTD) Yes 0 No X

Source: Table B-7 INTERNAL SELECTIONS FOR SENIOR LEVEL (GS 

13/14, GS 15, and SES) POSITIONS by PWTD 

The Agency used Table B-7 to analyze the applicant flow of internal applicants 

and/or selections for promotions by grade and PWTD to the senior level (analysis 

included grades 13-15, SES). PWTD applicants qualify at rates lower than they 

apply at the GS-13/14 and SES level. Analysis to identify triggers using Table 

B-7 are displayed below:

Senior 

Grade Level

PWTD

RELEVANT 

APPL POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTIONS

Triggers 

Yes/No

GS-13/14 2.39% 2.04% Yes 2.08% No

GS-15 1.93% 3.03% No 5.88% No

SES 3.23% 0.00% Yes 0.00% No

3. Using the qualified applicant pool as the benchmark, does your agency have a

trigger involving PWD among the new hires to the senior grade levels? For nonGS pay plans, please use the approximate senior grade levels. If “yes”, describe

the trigger(s) in the text box.

a. New Hires to SES (PWD) Yes X No 0

b. New Hires to GS-15 (PWD) Yes X No 0

c. New Hires to GS-13/14(PWD) Yes 0 No X

Source: B7 New Hires for Senior Level (GS 13/14, GS 15 and SES Positions 

by Disability 

The Agency used a datamart table to analyze the applicant flow of qualified 

applicants and/or selections for promotions by grade and PWD to the senior level 

(analysis included grades 13-15, SES). Of those qualified, PWD are selected at 

rates lower than the rate of those qualified for the GS 15 and SES levels, 

indicating selection triggers. Analysis to identify triggers using Table are 

displayed below: 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 88 of 99

Senior 

Grade Level

PWD

QUAL APPL POOL SELECTIONS Triggers 

Yes/No

GS-13/14 5.14% 9.55% No

GS-15 2.77% 0.00% Yes

SES 3.17% 0.00% Yes

4. Using the qualified applicant pool as the benchmark, does your agency have a

trigger involving PWTD among the new hires to the senior grade levels? For nonGS pay plans, please use the approximate senior grade levels. If “yes”, describe

the trigger(s) in the text box.

a. New Hires to SES (PWTD) Yes X No 0

b. New Hires to GS-15 (PWTD) Yes X No 0

c. New Hires to GS-13/14(PWTD) Yes X No 0

Source: B7-1 New Hires for Senior level (GS 13/14, GS 15 and SES Position 

by Disability.

When analyzing the applicant flow of qualified applicants and/or selections for 

New Hires by grade and PWTD to the senior level (analysis included grades 13-

15, SES). Of those qualified, PWTD are selected at rates lower than they are 

qualified at the SES level indicating a selection trigger. Analysis to identify 

triggers using Table are displayed below: 

Senior 

Grade Level

PWTD

QUAL APPL POOL SELECTIONS Triggers 

Yes/No

GS-13/14 2.79% 0.00% Yes

GS-15 1.38% 0.00% Yes

SES 2.26% 0.00% Yes

5. Does your agency have a trigger involving PWD among the qualified internal

applicants and/or selectees for promotions to supervisory positions? (The

appropriate benchmarks are the relevant applicant pool for qualified internal

applicants and the qualified applicant pool for selectees.) If “yes”, describe the

trigger(s) in the text box.

a. Executives

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes 0 No X

b. Managers

i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes X No 0

c. Supervisors
EEOC FORM 

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i. Qualified Internal Applicants (PWD) Yes X No 0

ii. Internal Selections (PWD) Yes X No 0

Source: Table B8 PWD were selected at rates lower than the qualified applicant 

pool within the Manager and Supervisor ranks indicating a trigger. 

Supervisory 

Positions 

PWD

RELEV 

APPL 

POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTIONS

Triggers 

Yes/No

Executive 8.70% 0.00% Yes 0.00% No

Managers 6.77% 2.38% Yes 0.00% Yes

Supervisors 9.99% 3.56% Yes 0.00% Yes

6. Does your agency have a trigger involving PWTD among the qualified internal

applicants and/or selectees for promotions to supervisory positions? (The

appropriate benchmarks are the relevant applicant pool for qualified internal

applicants and the qualified applicant pool for selectees.) If “yes”, describe the

trigger(s) in the text box.

a. Executives

i. Qualified Internal Applicants (PWTD) Yes X No 0

ii. Internal Selections (PWTD) Yes 0 No X

b. Managers

i. Qualified Internal Applicants (PWTD) Yes X No 0

ii. Internal Selections (PWTD) Yes 0 No X

c. Supervisors

i. Qualified Internal Applicants (PWTD) Yes X No 0

ii. Internal Selections (PWTD) Yes X No 0

Source: Table B8 Internal Selections of New Supervisors by Positions by 

Disability

PWTD were selected at rates lower than the qualified applicant pool within the 

Supervisor ranks indicating a trigger. 

Supervisory 

Positions 

PWTD

RELEV 

APPL POOL

QUAL 

INTERNAL 

APPL

Triggers 

Yes/No

INTERNAL 

SELECTIONS

Triggers 

Yes/No

Executives 3.91% 0.00% Yes 0.00% No

Managers 1.93% 0.00% Yes 0.00% No

Supervisors 2.33% 1.78% Yes 0.00% Yes
EEOC FORM 

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Page 90 of 99

7. Using the qualified applicant pool as the benchmark, does your agency have a

trigger involving PWD among the selectees for new hires to supervisory

positions? If “yes”, describe the trigger(s) in the text box.

a. New Hires for Executives (PWD) Yes X No 0

b. New Hires for Managers (PWD) Yes X No 0

c. New Hires for Supervisors (PWD) Yes X No 0

Source: Table B8 New Supervisors by Positions by Disability 

PWD were selected at rates lower than the qualified applicant pool within the 

Executive, Manager and Supervisor ranks indicating triggers. 

Supervisory 

Positions 

PWD

QUAL APPL POOL SELECTIONS Triggers 

Yes/No

Executives 3.17% 0.00% Yes

Managers 2.84% 0.00% Yes

Supervisors 6.21% 0.00% Yes

8. Using the qualified applicant pool as the benchmark, does your agency have a

trigger involving PWTD among the selectees for new hires to supervisory

positions? If “yes”, describe the trigger(s) in the text box.

a. New Hires for Executives (PWTD) Yes X No 0 

b. New Hires for Managers (PWTD) Yes 0 No X

c. New Hires for Supervisors (PWTD) Yes 0 No X

Source: Table B8 New Supervisors by Positions by Disability 

PWTD were selected at rates lower than the qualified applicant pool within the 

Executive ranks indicating a trigger. 

Supervisory 

Positions 

PWTD

QUAL APPL POOL SELECTIONS Triggers 

Yes/No

Executives 2.26% 0.00% Yes

Managers 0.00% 0.00% No

Supervisors 0.00% 0.00% No

Section V: Plan to Improve Retention of Persons with Disabilities

To be a model employer for persons with disabilities, agencies must have policies and programs 

in place to retain employees with disabilities. In this section, agencies should: (1) analyze 

workforce separation data to identify barriers retaining employees with disabilities; (2) describe 

efforts to ensure accessibility of technology and facilities; and (3) provide information on the 

reasonable accommodation program and workplace personal assistance services.
EEOC FORM 

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A. Voluntary and Involuntary Separations

1. In this reporting period, did the agency convert all eligible Schedule A employees

with a disability into the competitive service after two years of satisfactory service

(5 C.F.R. § 213.3102(u)(6)(i))? If “no”, please explain why the agency did not

convert all eligible Schedule A employees.

Yes 0 No X N/A 0

All but one Schedule A employee was converted after 2 years of satisfactory 

service. Conversion is still being considered for the remaining employee, but has 

been delayed in an effort to resolve conduct and performance concerns prior to 

conversion. 

2. Using the inclusion rate as the benchmark, did the percentage of PWD among

voluntary and involuntary separations exceed that of persons without disabilities?

If “yes”, describe the trigger below.

a. Voluntary Separations (PWD) Yes X No 0

b. Involuntary Separations (PWD) Yes X No 0 

Based on the inclusion rate, in FY 20, the voluntary separation rate for PWD 

(9.74%) was higher to that of employees without a disability (7.35%). The PWD 

involuntary separation rate (1.01%%) exceeded the non-PWD involuntary 

separation rate (0.20%) in FY 2020. (Table B1-2) 

FY20 Separations Inclusion Rate for

EEO Group

FHWA Total

Permanent

Workforce 

Inclusion

Rate/Benchmark

Trigger

Formula

Inclusion Rate

[Divide the Total # of 

PWD or PWD 

separations by their 

total # in the FHWA 

permanent 

workforce] 

BenchmarkInclusion Rate

[Divide the Pw/oD 

separations into their 

respective # in Perm 

Workforce]

[Triggers exist if 

Inclusion rate for 

PWD is higher than 

Inclusion rate for 

Pw/oD]

PWD

Voluntary 

(32-3)/298 = 9.74% (186-5)/2461 = 

7.35% 

Yes

PWD

Involuntary 

3/298 = 1.01% 5/2461 = 0.20% Yes

*Internal to FHWA Note only for MD 715: Calculate Voluntary Separations by

subtracting the Removal Separtions from the Total Separtions
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

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Page 92 of 99

3. Using the inclusion rate as the benchmark, did the percentage of PWTD among

voluntary and involuntary separations exceed that of persons without targeted

disabilities? If “yes”, describe the trigger below.

a. Voluntary Separations (PWTD) Yes X No 0

b. Involuntary Separations (PWTD) Yes X No 0

Table B-1 - Separations by Type of Separation - Distribution by PWD - 

Permanent Workforce 

Source: FHWA Datamart database 

The Agency used Table B-1 to analyze the Separations by Type 

(voluntary/involuntary) by distribution of PWTD. PWTD separated at a slightly 

higher rate when compared to their inclusion rate/benchmark for voluntary 

separations indicating a trigger. Analysis to identify triggers using Table B-1 are 

displayed below: 

FY 20 Inclusion Rate for EEO 

Group

FHWA Total 

Permanent Trigger

Formula

Inclusion Rate [Divide the 

Total # of PWTD 

separations by their total # 

in the FHWA permanent

workforce]

Benchmark-Inclusion

Rate [Divide the 

Pw/oTD separations into

their respective # in

Perm Workforce]

[Triggers exist if Inclusion 

rate for PWTD is higher 

than Inclusion rate for

Pw/oTD]

PWTD

Voluntary (13-1)/75 = 16.00% (186-5)/2461 = 7.35% Yes

PWTD

Involuntary 1/75 = 1.33% 5/2461 = 0.20% Yes

*Internal to FHWA Note only for MD 715: Calculate Voluntary Separations by

subtracting the Removal Separtions from the Total Separtions

4. If a trigger exists involving the separation rate of PWD and/or PWTD, please

explain why they left the agency using exit interview results and other data

sources.

In analyzing the exit interview results and other data sources, the large majority of

reasons why PWD and/or PWTD employees who left the Agency cited was for

family reasons, health reasons including medical hardships, and career

promotional opportunities. A good number of employees also left the Agency

due to retirement.

B. Accessibilty of Technology and Facilities
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Page 93 of 99

Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform 

applicants and employees of their rights under Section 508 of the Rehabilitation Act of 

1973 (29 U.S.C. § 794(b), concerning the accessibility of agency technology, and the 

Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility 

of agency facilities. In addition, agencies are required to inform individuals where to file 

complaints if other agencies are responsible for a violation. 

1. Please provide the internet address on the agency’s public Website for its notice

explaining employees’ and applicants’ rights under Section 508 of the

Rehabilitation Act, including a description of how to file a complaint.

The internet address on the Agency’s public Website regarding Section 508 of the

Rehabilitation Act of 1973, including a description of how to file a complaint is

https://www.fhwa.dot.gov/508/.

2. Please provide the internet address on the agency’s public Website for its notice

explaining employees’ and applicants’ rights under the Architectural Barriers Act,

including a description of how to file a complaint.

The internet address on the Agency’s public Website regarding Architectural

Barriers Act is https://www.fhwa.dot.gov/accessibility/.

3. Describe any programs, policies, or practices that the agency has undertaken, or

plans on undertaking over the next fiscal year, designed to improve accessibility

of agency facilities and/or technology.

The FHWA has outlined for Agency employees an expectations memo in relation

to Accessibility. This memo provides roles and responsibilities for staff to follow

if they are hosting an virtual event. Also, the Agency has made modifications to

the MS TEAMs webconferencing format to allow for audio/bridge lines to ensure

video relay services can connect into meetings.

C. Reasonable Accommodation Program

Pursuant to 29 C.F.R. § 1614.203(d)(3), agencies must adopt, post on their public

Website, and make available to all job applicants and employees, reasonable

accommodation procedures.

1. Please provide the average time frame for processing initial requests for

reasonable accommodations during the reporting period. (Please do not include
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previously approved requests with repetitive accommodations, such as 

interpreting services.) 

In FY 20, The Agency complies with the policy of processing requests within the 

25-business day policy as set forth by the Department’s Order 1101.1A. FHWA

processes reasonable accommodations requests within this time frame unless

extenuating circumstances prevent it from doing so. Requests are processed

through the department’s Reasonable Accommodations Online Tracking System

(RAMS). (note: The Department’s Order 1011.1B was updated in January

2021).

2. Describe the effectiveness of the policies, procedures, or practices to implement

the agency’s reasonable accommodation program. Some examples of an effective

program include timely processing requests, timely providing approved

accommodations, conducting training for managers and supervisors, and

monitoring accommodation requests for trends.

During FY 20 the Agency worked with the Departmental Office of Civil Rights to

revise and update DOT Order 1011.1B. The Agency hosted several sessions of

training on Reasonable Accommodations during FY 20. The Agency Disability

Program Manager provided a training overview of the Reasonable

Accommodations process to FHWA Leadership, and to several division offices.

The Agency has completed a draft of the Reasonable Accommodations Handbook

which is currently under internal review and was placed on hold to reflect the

updated DOT Order 11011.1B.

D. Personal Assistance Services Allowing Employees to Participate in the Workplace

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative

action, are required to provide personal assistance services (PAS) to employees who need

them because of a targeted disability, unless doing so would impose an undue hardship

on the agency.

1. Describe the effectiveness of the policies, procedures, or practices to implement

the PAS requirement. Some examples of an effective program include timely

processing requests for PAS, timely providing approved services, conducting

training for managers and supervisors, and monitoring PAS requests for trends.

This is handled at the Departmental level.

Section VI: EEO Complaint and Findings Data

A. EEO Complaint Data Involving Harassment
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1. During the last fiscal year, did a higher percentage of PWD file a formal EEO

complaint alleging harassment, as compared to the government-wide average?

Yes X No 0 N/A 0

2. During the last fiscal year, did any complaints alleging harassment based on

disability status result in a finding of discrimination or a settlement agreement?

Yes X No 0 N/A 0

3. If the agency had one or more findings of discrimination alleging harassment

based on disability status during the last fiscal year, please describe the corrective

measures taken by the agency.

FHWA had no EEOC or Departmental findings of discrimination or harassment

in FY 20. FHWA settled cases involving, among other claims, those of

harassment based on disability status. These cases were not considered to be ones

where there was a substantial risk of an adverse finding on the harassment issue,

and the cases were resolved without any admission of liability. Accordingly, no

corrective measures were required on these claims.

B. EEO Complaint Data Involving Reasonable Accommodation

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO

complaint alleging failure to provide a reasonable accommodation, as compared

to the government-wide average?

Yes X No 0 N/A 0

2. During the last fiscal year, did any complaints alleging failure to provide

reasonable accommodation result in a finding of discrimination or a settlement

agreement?

Yes X No 0 N/A 0

3. If the agency had one or more findings of discrimination involving the failure to

provide a reasonable accommodation during the last fiscal year, please describe

the corrective measures taken by the agency.

FHWA had no findings of discrimination in FY 20. FHWA settled cases

involving, among other claims, those of reasonable accommodation. These cases

were not considered to be ones where there was a substantial risk of an adverse

finding on the reasonable accommodation issue, and the cases were resolved

without any admission of liability. Accordingly, no corrective measures were

required on the reasonable accommodation claims.
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Section VII: Identification and Removal of Barriers 

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests 

that a policy, procedure, or practice may be impeding the employment opportunities of a 

protected EEO group. 

1. Has the agency identified any barriers (policies, procedures, and/or practices) that

affect employment opportunities for PWD and/or PWTD?

Yes X No 0

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or

PWTD?

Yes X No 0 N/A 0

3. barrier(s), objective(s), responsible official(s), planned activities, and, where

applicable, accomplishments.

Trigger 1 Individuals with targeted disabilities (PWTD) have a low participation rate 

in the FHWA workforce in grades GS13-SES.

Barrier(s) Recruitment Practices; FHWA focuses recruitment on distributing 

competitive vacancy announcements. 

Reasonable Accommodation; FHWA needs to develop and market its 

written procedures for Reasonable Accommodations for FHWA employees 

Objective(s)

Increase hiring managers’ and HR Specialists’ awareness and knowledge of 

how to use non-competitive hiring authorities for individuals with 

disabilities (Schedule A; “On-the-Spot”). Increased awareness of this 

hiring flexibility will assist the Agency in reaching the EEOC hiring goal 

that 2% of all new hires at GS 1-10 and GS 11-SES should be PWTD. 

The purpose of developing and implementing FHWA-specific reasonable 

accommodation procedures is to provide employees as well as supervisors 

and managers with an easy-to-understand, step-by-step explanation of the 

Reasonable Accommodation process. These procedures outline the steps 

for requesting or responding to requests for Reasonable Accommodation at 

FHWA.

Responsible Official(s) Performance Standards Address the Plan?

(Yes or No)

David Lewis, Director, Office of Human 

Resources YES

Irene Rico, Associate Administrator for Civil 

Rights YES
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Sources of Data Sources Reviewed?

(Yes or No)

Identify Information 

Collected

Workforce Data Tables YES

Complaint Data (Trends) YES

Grievance Data (Trends) NO

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

NO

Climate Assessment Survey (e.g., FEVS) NO

Exit Interview Data NO

Focus Groups NO

Interviews NO

Reports (e.g., Congress, EEOC, MSPB, 

GAO, OPM) NO

Other (Please Describe)

Target Date 

(mm/dd/yyyy) Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

Ongoing 

Educate hiring managers 

and HR Specialists on 

available hiring 

flexibilities to include 

Schedule A through the 

revamped and userfriendly hiring tool kit.

YES 09/30/2021 

Ongoing 

The FHWA will analyze 

data regarding disability 

status reporting of 

preference eligible 

veterans to determine 

what, if any, outreach 

education should be 

developed to encourage 

identifying as a 

PWD/PWTD.

YES 09/30/2021 

Ongoing 

Develop step by step 

procedures on the 

Reasonable 

Accommodations process 

in easy to use format for 

employees. 

YES 09/30/2021 
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Fiscal Year Accomplishments

2018 FHWA will report out updates and accomplishments in the FY 2019 and FY 

2020 MD-715 report. 

2019 

Draft Reasonable Accommodations handbook developed. It is currently 

undergoing internal review. Further progress will be reported out on in the FY 

2020 report. 

In 2019, FHWA conducted a two-part Webinar on Schedule A Hiring and 

Reasonable Accommodations within the Agency’s Management and 

Supervisory Forum Webinar Series. The Management & Supervision Forum is 

a monthly Webinar series that provides learning opportunities for individuals 

who serve as supervisors, team leaders, and managers. It is part of the Office of 

Human Resources' ongoing effort to give all employees the tools and 

information they need to chart their own course for performance improvement, 

learning, career development, as well as personal growth. The session provided 

participants with information that was designed to help them to: 

• Understand how Schedule A works and the benefits of using this hiring

authority.

• Use available hiring tools to find qualified Schedule A candidates with

disabilities.

• Cite manager’s responsibilities in engaging the Reasonable

Accommodations process

• Recall the steps in the Reasonable Accommodations process

• Follow the right order and appropriate steps in the Reasonable

Accommodations process.

FHWA also conducts biannual Workforce planning conversations. Workforce 

Planning conversations are scheduled meetings between servicing HR 

specialists and organizational unit leaders (Division Administrators), which 

focus on workforce planning at the unit level rather than agencywide. The 

conversations provide an opportunity to discuss anticipated vacancies, possible 

separations and retirements, and hiring flexibilities, especially those that align 

with the Strategic Workforce Assessment. These strategic conversations are 

used to educate and highlight the Schedule A hiring flexibility. This process 

occurs every 2 year and last took place in 2018. The program will continue in 

FY2020.
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Fiscal Year Accomplishments

2020 

The Agency continued efforts by conducting webinars in support of Schedule A 

Hiring and Reasonable Accommodations as part of the Agency’s Hot off the 

HR Desk series as well as the Management & Supervision Forums. The 

Agency had established a Reasonable Accommodation Working Group to 

develop materials in support of the US DOT Reasonable Accommodations. 

The draft documents were not finalized due to the anticipated revisions of the 

Departmental RA order. 

4. Please explain the factor(s) that prevented the agency from timely completing any

of the planned activities.

FHWA has modified its target date to 09/30/2021 as a completion date for the

objectives listed above. This will ensure that we update policies and procedures

to reflect the latest DOT Reasonable Accommodation Order signed in January

2021.

5. For the planned activities that were completed, please describe the actual impact

of those activities toward eliminating the barrier(s).

FHWA will report out progress and updates for the upcoming FY 21 MD-715

report.

6. If the planned activities did not correct the trigger(s) and/or barrier(s), please

describe how the agency intends to improve the plan for the next fiscal year.

FHWA will report out progress and updates for the upcoming FY 21 MD-715

report.