`

Management Directive 715 

(MD-715) 

Report 

FY2022 

Defense Finance and 

Accounting Service 

Diversity 

Equity 

Inclusion 

Accessibility 
 

 

 

 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Defense Finance and Accounting Service 

Management Directive (MD) 715 Report, FY 2022 

Table of Contents 

Page 

Parts A-C............................................................................................................................ 2 

Part D ................................................................................................................................. 4 

Part E – Detailed Executive Summary............................................................................... 6 

Part E.1 – DFAS Mission................................................................................................... 6 

Part E.2 – The Six Elements of a Model EEO Program .................................................... 6 

E.2.A-F Essential Elements for a Model EEO Program

E.2.A Demonstrated Commitment from Agency Leadership............................ 7 

E.2.B Integration of EEO into the Agency’s Strategic Mission ........................ 7 

E.2.C Management and Program Accountability.............................................. 8 

E.2.D Proactive Prevention of Unlawful Discrimination .................................. 8 

E.2.E Efficiency................................................................................................. 9 

E.2.F Responsiveness and Legal Compliance................................................. 10 

Part E.3 – Workforce Analysis ........................................................................................ 10 

Part E.4 – Accomplishments............................................................................................ 26 

Part E.5 – Planned Activities ........................................................................................... 32 

Part F – Certification of Establishment of Continuing EEO Programs ........................... 34 

Part G – Agency Self-Assessment Checklist................................................................... 35 

Part H – Agency Plans to Attain the Essential Elements of a Model EEO Program....... 63 

Part I – Agency EEO Plan to Eliminate Identified Barrier...............................................72 

Part J – Special Program Plan for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities.................................................................99 
 

 

 

 

 

 

 

 

Part A – Department or Agency Identifying Information 

Agency 

Second 

Level Component Address City State 

Zip 

Code 

(xxxxx) 

Agency Code 

(xxxx) 

FIPS Code 

(xxxx) 

Department of 

Defense (DoD) 

Defense Finance and 

Accounting Service 

(DFAS) 

8899 East 

56th Street 

Indianapolis IN 46249 DD35 18-097 

Part B – Total Employment 

Total Employment 

Permanent Workforce Temporary 

Workforce 

Total Workforce 

Number of Employees 10,719 19 10,738 

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

Agency Leadership Name Title 

Head of Agency Ms. Audrey Davis Agency Director 

Head of Agency Designee Mr. Jonathan Witter Principal Deputy Director 

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

EEO Program 

Staff 

Name Title Occupational 

Series (xxxx) 

Pay Plan 

and Grade 

(xx-xx) 

Phone 

Number 

(xxx-xxxxxxx) 

Email Address 

Principal EEO 

Director/Official 

William 

Bryson 

Director, Office 

of Equal

Opportunity

Programs 

(OEOP) 

0260 GS-15 317-212-

7962 

william.l.bryson4

.civ@mail.mil 

Affirmative 

Employment 

Program

Manager 

Michelle Lugo OEOP Program

Manager 

0260 GS-13 317-212-

7362 

michelle.m.lugobonet.civ@mail. 

mil 

2 
 

Complaint

Processing

Program

Manager 

Ali 

Mohammed 

Fawaz 

Inquiry and 

Resolution 

Division Program

Manager 

0260 GS-14 317-212- 5438 

mohamed.a.fawaz 

2.civ@mail.mil 

Diversity and 

Inclusion 

Officer 

Cynthia IceBones Deputy Director, 

OEOP 

0260 GS-14 317-212-

2170 

cynthia.g.icebones.civ@mail.m 

il 

Hispanic Michelle Lugo OEOP Program 0260 GS-13 317-212- michelle.m.lugoProgram Manager 7362 bonet.civ@ 

Manager mail.mil 

(SEPM) 

Women’s Cynthia Deputy Director, 0260 GS-14 317-212- cynthia.g.iceProgram Ice-Bones OEOP 2170 bones.civ@mail. 

Manager mil 

(SEPM) 

Disability Lauren Aggen Disability 0260 GS-13 317-212- lauren.a.aggen.ci 

Program Employment 8141 v@mail.mil 

Manager Program 

(SEPM) Manager 

(DEPM) 

Special 

Placement 

Program 

Coordinator 

(Individuals 

with 

Disabilities) 

Lauren Aggen DEPM 0260 GS-13 317-212-

8141 

lauren.a.aggen.ci 

v@mail.mil 

Reasonable Lauren Aggen DEPM 0260 GS-13 317-212- lauren.a.aggen.ci 

Accommodation 

Program 

Manager 

8141 v@mail.mil 

Anti- Katherine Human 0201 GS-14 317-212- katherine.m.murra 

Harassment 

Program

Manager 

Murray Resources 

Specialist 

4526 y16.civ@mail.mil 

ADR Program 

Manager 

Doug Hess ADR 

Director 

0905 GS-14 317-212-

0818 

douglas.a.hess4.ci 

v@mail.mil 

Compliance Ali Mohamed Inquiry and 0260 GS-14 317-212- mohamed.a.fawa 

Manager Fawaz Resolution 5438 z2.civ@mail.mil 

Division 

Program 

Manager 

3 
 

 

 

 

 

 

 

 

 

 

 

 

Principal MD715 Preparer Michelle LugoBonet Diversity and 

Inclusion (D&I) 

Program 

Manager 

0260 GS-13 317-212-

7362 

michelle.m.lugobonet.civ@ 

mail.mil 

Other EEO Tim Foster Data Analyst 0301 GS-12 317-212- timothy.b.foster4. 

Staff 3832 civ@mail.mil 

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

Please identify the subordinate components within the Agency (e.g., bureaus, regions, etc.). 

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

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 

Personal Assistance Services Procedures Yes 

Alternative Dispute Resolution Procedures Yes 

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

report. 

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 No 

While the Agency does 

not have a specific plan in 

response to the E.O., 

DFAS produces a yearly 

4 
 

 

“Affirmative Action Plan 

for the Recruitment, 

Hiring, Advancement, and 

Retention of Persons with 

Disabilities.” As a result, 

we are significantly 

exceeding federal, DoD, 

and DFAS established 

goals. The DFAS 

Diversity and Inclusion 

Operating Plan further 

supports our efforts. 

D&I Plan under Executive Order (E.O.) 13583 Yes 

Diversity Policy Statement Yes 

Human Capital Strategic Plan Yes 

EEO Strategic Plan Yes 

Results from most recent Federal Employee Viewpoint 

Survey or Annual Employee Survey Yes 

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U.S. EEO Commission

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT

Part E – Executive Summary 

Defense Finance and Accounting Service (DFAS) Fiscal Year 2022 (FY22) Highlights 

 DFAS scored 80% on the Employee Engagement Index (EEI) in the 2022 Federal

Employment View Survey (FEVS). This exceeds the government threshold of 67% set by

the Office of Management and Budget (OMB). DFAS ranked 4th in the EEI among the 24

Defense Agencies, an improvement from 5th place in 2021.

 DFAS tied for 3rd place in the EEI “Leaders Lead” category among Defense Agencies.

This category reflects employee perception of senior leadership.

 The Grow Mission-Integrated Diversity (GMID) team developed a Leadership Dashboard

that will simplify workforce data analysis and will provide metrics for diversity, equity,

inclusion and accessibility (DEIA) efforts.

 DFAS scored 79% in overall DEIA scores, exceeding Department of Defense (DoD) and

Office of the Secretary of Defense scores.

 DFAS was recognized as the outstanding mid-sized DoD component supporting Workforce

Recruitment Program (WRP) efforts in 2022.

 DFAS employee, Ms. Amy Umhoefer, was recognized with the 2022 Outstanding Employee

with a Disability Award in the 42nd Annual Secretary of Defense Disability Awards

Ceremony. Another DFAS employee, Mr. Devid Brodsky, was recognized in the 2022

Workforce Recruitment Program Awards Ceremony.

 DFAS Office of Equal Opportunity Programs (OEOP) further shortened complaint and

investigation completion times. The average number of days in investigation decreased by

57 days, from 185 days in FY21 to 128 days in FY22.

 In FY22 the first Agency-wide Employee Resource Group (ERG) was established. The

Leading Employees as Advocates for Disabilities (LEAD) ERG focuses on enhancing the

understanding and inclusion of employees with disabilities and targeted disabilities.

 The percentage of employment for people with disabilities (PWD) is at 19.69%, exceeding

the DoD goal of 12%. The employment of people with target disabilities (PWTD) at DFAS

was 4.21%, more than doubling the federal goal of 2% and exceeding the DFAS goal of 3%.

Part E.1 – Mission 

DFAS is one of the world’s largest finance and accounting operations. Its mission is to 

deliver financial excellence and quality pay services to its customers. Its vision is to be a 

valued partner in financial management by consistently delivering first-class service and 

products. The Agency is committed to continuous improvement supporting the men and 

women who defend our nation and striving to achieve the Six Essential Elements of a Model 

Equal Employment Opportunity (EEO) Program. 

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Part E.2 – The Six Essential Elements of a Model EEO Program 

The six essential elements of a model EEO program include 1) Demonstrated commitment from 

Agency leadership; 2) Integration of EEO into the Agency’s strategic mission; 3) Management 

and program accountability; 4) Proactive prevention of unlawful discrimination; 5) Efficiency; 

and 6) Responsiveness and legal compliance. To determine how the Agency is performing in 

each of these six elements, DFAS compared Model EEO Program data for FY21 to FY22, 

reviewed barrier analyses, examined issues, and created action plans supporting the Agency’s 

employees and applicants. DFAS also examined current EEO Program status, compared it to the 

Model EEO Program Self-Assessment Checklist in Part G, and identified four deficiencies 

within its EEO Program. Based on those results, DFAS developed plans to address deficiencies, 

as covered in Part H, and workforce triggers related to participation rates for certain groups, 

discussed in Parts I and J. In FY22, the Agency’s Office of Equal Opportunity Programs 

(OEOP) engaged in significant activities dedicated to advancing EEO practices for the DFAS 

workforce. Accomplishments, improvements, specific work, and planned activities associated 

with each of the six elements follow. 

Part E.2.A – Demonstrated Commitment from Agency Leadership 

In FY22, the DFAS Director and senior leaders demonstrated a strong and continued 

commitment to EEO policies and procedures to include DEIA in the workplace. Examples 

include: 

 Senior leaders were instrumental in the development of several DEIA initiatives, like the

GMID component of the Agency’s strategy, which was developed to integrate a broad range of

flexibilities and best practice processes and policies to inform, recruit, develop, and retain a

talented workforce in ways that increasingly value diversity and accelerate DFAS mission

success.

 Senior Executive Service (SES) and senior leaders served in key roles supporting the Agency’s

DEIA efforts. They sponsored and participated in Special Emphasis Programs (SEPs), served

as barrier team members and ERG champions, identified employees to join SEP committees,

completed the eCornell DEIA Certificate program, and encouraged employees to attend DEIA

agency-wide sponsored events, to include twelve live, virtual observances which featured

keynote speakers and panels of speakers.

 DFAS is also committed to providing a work environment that values the inclusion of PWD.

In FY22, the Agency’s PWD employment activities included strategic participation in

recruitment and outreach events, as well as the development of an agency-wide PWD ERG.

Part E.2.B – Integration of EEO into the Agency’s Strategic Mission 

The OEOP Director had responsibility for all aspects of the Model EEO Program. DFAS 

ensured independence and neutrality in its EEO mission. The OEOP Director worked to ensure 

the Agency timely complied with EEOC orders, EEO program evaluations, and improvements. 

DFAS continues to commit to a model workplace and a workforce that is both diverse and 

inclusive in all dimensions. The Agency’s Director expects leaders at all levels to make equal 

opportunity, diversity, and inclusion priorities. The Agency’s Diversity and Inclusion Operating 

Plan (DIOP), the DFAS Strategic Plan, and the DFAS Human Capital Strategic Plan each 

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identify DEIA components to cultivate a diverse, results-oriented, high performing workforce by 

fostering a flexible, inclusive work environment and addressing any gaps or challenges related to 

those efforts. Also, senior leaders are active members of the Diversity and Inclusion Leadership 

Council as part of their roles as Enterprise Business Council (EBC) members. 

DFAS leadership also ensured effective coordination and collaboration between EEO programs 

and Human Resources (HR) programs to strengthen and enhance merit promotion processes and 

external recruiting. The Agency continues to proactively prevent and address discrimination and 

harassment through its Harassment Prevention and Responses Instruction, DFAS 1020.2-I. This 

guidance provides employees avenues beyond the EEO complaint process to voice concerns and 

report harassing behaviors. It provides specific timelines and responsibilities for supervisors and 

inquiry officials to address employees’ concerns. Additionally, DFAS surveyed the workforce 

and provided mandatory training to supervisors and employees on the topic. 

Part E.2.C – Management and Program Accountability 

DFAS senior leaders, managers, and supervisors are held accountable in their performance plans 

and appraisals for advancing the Agency’s EEO and DEIA plans, initiatives, and practices. SES 

performance plans include EEO and DEIA standards in a critical performance element. 

The DFAS Harassment Prevention and Responses Instruction also provides a firewall separating 

the Agency’s harassment function from the processing of EEO complaints with a procedure 

outside the EEO complaint process. It requires initiating an inquiry of all harassment allegations 

within 10 calendar days from the time the harassing behavior is first reported. DFAS trained a 

diverse cadre of Inquiry Officials (IOs) to perform the inquiries and report their findings. 

The OEOP is responsible for briefing senior leaders on workforce demographics, EEO concerns 

or deficiencies, and developing plans to address issues. In FY22, an emphasis on strategic 

alignment continued to increase, and the OEOP Director served as the key EEO advisor to the 

DFAS Director. For example, OEOP briefings in FY22 to the DFAS Director and her Board of 

Directors included: 

 Model program corrective action plans, complaints trends, diversity and inclusion initiatives,

policies, and key information.

 Regular need-to-know information on merit-based final agency decision corrective actions

and findings.

 Details and compliance requirements on executive orders, laws, Office of Personnel

Management governing issuances, EEOC and DoD-level reports, advisories, and supporting

documents.

The OEOP Director continued as a voting member of the EBC, a formal governance body 

comprised of SES and GS-15 Directors that is chartered to fulfill statutory as well as regulatory 

requirements, and serves as the Diversity and Inclusion Leadership Council. 

Part E.2.D – Proactive Prevention of Unlawful Discrimination 

In FY22, the DFAS Director continued to communicate strong commitment to the appropriate 

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execution of all aspects of the EEO program, from training to final agency actions. The OEOP 

Director continued to regularly coordinate EEO training and programs with senior leaders. 

The GMID team developed a Leadership Dashboard that will simplify workforce data analysis 

and will provide metrics for DEIA efforts. This will allow the Agency to identify triggers in the 

workplace and track the status of identified barriers. 

To proactively prevent unlawful discrimination, the OEOP staff continuously provided virtual 

training on a wide variety of EEO topics (e.g., Avoiding Reprisal for Supervisors, Reasonable 

Accommodations, DEIA, Inclusive Leadership, Unconscious Bias, and Diversity of Thought). 

In FY22, managers, supervisors, and employees received formal DEIA training. This included 

232 supervisors and employees who attended the Inclusive Leadership – Understanding 

Unconscious Bias training and 177 supervisors who attended the Diversity of Thought – 

Fostering an Inclusive Workplace training. A total of 219 supervisors attended the New 

Supervisor Training (which includes a dedicated DEIA module), 55 employees attended 

Avoiding Reprisal, and 58 attended Reasonable Accommodations training. OEOP also provided 

all new employees with comprehensive EEO, DEIA, and Harassment training on 45 occasions. 

Part E.2.E – Efficiency 

DFAS continues to work primarily in a virtual environment, and in FY22, senior leaders and 

supervisors supported a culture of inclusion in the virtual workplace. Through the Mature 

Digital Workplace strategic initiative, the Agency committed to addressing feedback that 

supported the workforce’s ability to operate and contribute to the mission. This included training 

on the tools and capabilities that would support collaboration, regardless of environment, and 

enhancing virtual or hybrid leadership skills for supervisors to ensure connection and inclusion 

remained an area of importance. 

Furthermore, DFAS actively addressed workforce needs and proactively provided services and 

accommodations, like closed-caption availability, Communication Access Real-Time Translation 

(CART), videophone interpreting services, certified sign-language interpreters, ergonomic 

assessments and equipment, and an Employee Assistance Program. 

In FY22, DFAS performed virtual and on-site ergonomic assessments, employee consultation/ 

follow-ups, equipment distribution and installation. A majority of the equipment issued was 

acquired from storage and included items such as chairs, keyboards, height adjustable tables, and 

ergo mice. The Computer Electronic Accommodations Program (CAP) was also used to provide 

equipment when applicable. In FY22, CAP provided 46 accommodations to DFAS. 

The Agency updated its Reasonable Accommodation Instruction and published it on the DFAS 

public-facing website. Supervisors were trained on their responsibilities and the process to 

address employee requests. 

DFAS enhanced processes for timeliness and full compliance with EEOC orders and settlement 

agreements, and timely filed the FY22 No-Fear and Annual Federal EEO Statistical Report of 

Discrimination Complaints (Form 462 Reports). In FY22, DFAS OEOP further shortened 

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U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

complaint and investigations completion times. The team provided timely EEO counseling to 

the workforce and provided written notification to complainants about their rights and 

responsibilities in the EEO process. 

DFAS strives to ensure the workplace is free from harassment and discrimination by 

investigating all complaints immediately and taking appropriate action. In FY22, DFAS EEO 

complaints investigative time-frames decreased by 57 days, from 185 days in FY21 to an average 

of 128 days in FY22. 

To further integrate EEO principles and support diversity and inclusion, DFAS leadership sent 

employees DEIA related messages via email, articles, and newsletters. Twenty-six stories were 

published in the online DFAS Business Journal, 18 messages were sent via email to the 

workforce, 16 event marketing banners were published on the DFAS intranet and a fixed-side 

panel that by itself generated 23,457 clicks by DFAS employees. The OEOP Celebrate Diversity 

and Inclusion webpage included content for 14 observances and continues to be one of the most 

visited websites in the DFAS intranet portal. 

All of the agency-wide observance programs were recorded and are available to the workforce 

for on-demand replay. The Agency also aligned them with leadership competencies, to allow 

attendees to earn continuing education and training (CET) credits. 

In FY22, the Agency continued to make progress in ongoing barrier analysis plans for lowerthan-expected Hispanic and Asian participation rates. DFAS representatives participated in 

several targeted recruiting events. The Hispanic Asian Barrier Inclusion Team (HABIT) 

facilitated outreach sessions at universities with higher populations of Hispanic and Asian 

students to provide information about DFAS career opportunities and diversity initiatives. The 

representatives also shared advice and guidance on resume writing and interview techniques with 

potential applicants. 

Part E.2.F – Responsiveness and Legal Compliance 

The significant timeliness accomplishments referenced in the efficiencies section were achieved 

by enhancing the processes. The EEO Complaints Manager promptly reviews all EEO formal 

complaints, drafts and signs acceptance letters within an average of 11 calendar days. Likewise, 

when we receive Reports of Investigations (ROIs), the Complaints Manager promptly reviews 

the ROI for sufficiency, and signs the Election Memorandum, expediting the process. Likewise, 

EEO Counselors are responsible for following up on all signed settlement agreements to ensure 

timely compliance. Within two business days of individuals contacting our office, EEO 

Counselors are required to contact the individual and begin the EEO process. 

Part E.3 – Workforce Analysis 

Data presented are from the FY22 year-end report. 

1. Distribution by Race/Ethnicity and Sex. The DFAS workforce analysis includes the 

permanent employee workforce. Relevant tables provide a consolidated snapshot of gender, 

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U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

race, ethnicity, and targeted disability to convey how hiring, promotion, awards, separation, and 

corresponding workforce participation compared to established benchmarks for the National 

Civilian Labor Force (NCLF) and Occupational Civilian Labor Force (OCLF), as applicable. 

The following analysis presumes that, ideally, all groups should move through the employment 

life cycle in proportion to their relative availability in the labor force. In the tables below, parity 

would be assumed if the Agency numbers matched the N/OCLF numbers for each race/ethnicity 

and sex group. If not, the resulting trigger suggests a possible EEO barrier. OEOP reviews two 

years of data to assess annual changes for each race, gender, ethnic group, and for employees 

who report a disability or a targeted disability. During FY22, the DFAS workforce included a 

total of 10,719 permanent GS or Wage Grade (WG) employees. The DFAS permanent 

workforce rounds up to 41% male and 59% female employees, with no change from FY21. 

Table A-1.1: Total Workforce – Distribution by Race/Ethnicity and Sex 

2. Participation by Race/Ethnicity and Sex. From FY21 to FY22, DFAS saw slight increases 

in the participation rate of White females and in Two or More Races (2+R) males and females. 

Hispanic males and females, White males, Asian males, Native Hawaiian and Pacific Islander 

(NH/PI) males and females participation rates stayed the same as FY21. DFAS saw a slight 

decrease in the participation rate of Black males and females, Asian American females, and 

American Indian and Alaskan Native (AI/AN) males and females. 

Similar to last year, in FY22 DFAS had significantly lower-than-expected rates of participation 

among Hispanic males and females and White males. DFAS had a lower-than-expected 

participation rate for Asian males and females and AI/AN males and females. Please note that 

some numbers and percentages shown in workforce data tables are the results of first-level 

rounding. 

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3. Participation of Males and Females by Grade. While females comprised 58.9% of the 

permanent workforce, they were not represented proportionally at GS-13 through GS-15 levels, 

whereas males represented 41.1% of the permanent workforce and exceeded this rate from GS13 through GS-15 levels. However, in the SES positions, female participation rates increased to 

54.5%, which shows a slight improvement from the previous year. 

In FY22, White males occupied 43.7 % of the GS-15 level positions, an increase from 42.4% in 

FY21. White male participation rates at the GS-14 slightly decreased from 52.4% to 52.2%. 

White female participation at the GS-15 level increased from 37.6% to 39.1% and had a slight 

increase at the GS-14 level from 32.9% to 33.9%. Black male participation rates at the GS-15 

level decreased from 8.2% to 6.9% and at the GS-14 level they slightly decreased from 5.5% to 

5%. Black female representation decreased at the GS-15 level from 7.1% to 5.7% and had a 

slight decrease at the GS-14 level from 5.9% to 5.6%. 

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FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Table A4-2P Compared to Table A-1.1: Total Workforce Table Males and Females 

FY22 Total 

Employees Males 

Percentage of MALES in the permanent workforce 

by grade level 

2+ AI ASIAN BLK HISP NH WHI 

Grade 

Levels 10,718 41.1% 0.7% 0.2% 1.3% 6.4% 1.3% 0.1% 31.1% 

GS-01 - GS08 4448 31.5% 0.5% 0.2% 0.7% 6.3% 0.9% 0.0% 23.0% 

GS-09 492 35.4% 0.6% 0.0% 1.8% 5.9% 2.0% 0.2% 24.8% 

GS-11 1673 44.4% 0.9% 0.2% 1.7% 8.2% 1.3% 0.1% 32.0% 

GS-12 2536 48.5% 1.0% 0.2% 1.9% 6.2% 1.8% 0.1% 37.3% 

GS-13 1159 53.4% 0.6% 0.0% 1.3% 5.4% 1.8% 0.2% 44.1% 

GS-14 301 59.1% 1.0% 0.0% 0.7% 5.0% 0.3% 0.0% 52.2% 

GS-15 87 55.2% 0.0% 0.0% 1.1% 6.9% 3.4% 0.0% 43.7% 

SES 22 45.5% 0.0% 0.0% 4.5% 4.5% 0.0% 0.0% 36.4% 

FY22 Total 

Employees Females 

Percentage of FEMALES in the permanent workforce 

by grade level 

2+ AI ASIAN BLK HISP NH WHI 

Grade 

Levels 10,718 58.9% 0.8% 0.2% 1.5% 14.5% 1.5% 0.1% 40.3% 

GS-01 - GS08 4448 68.5% 0.9% 0.2% 1.0% 17.2% 1.4% 0.1% 47.7% 

GS-09 492 64.6% 1.4% 0.4% 2.2% 15.7% 2.2% 0.2% 42.5% 

GS-11 1673 55.6% 0.8% 0.1% 2.2% 16.7% 1.7% 0.0% 34.1% 

GS-12 2536 51.5% 0.8% 0.3% 2.2% 12.2% 1.4% 0.0% 34.6% 

GS-13 1159 46.6% 0.5% 0.0% 1.3% 8.8% 1.9% 0.0% 34.1% 

GS-14 301 40.9% 0.0% 0.0% 0.3% 5.6% 1.0% 0.0% 33.9% 

GS-15 87 44.8% 0.0% 0.0% 0.0% 5.7% 0.0% 0.0% 39.1% 

SES 22 54.5% 0.0% 0.0% 0.0% 4.5% 0.0% 0.0% 50.0% 

*Permanent employees excluding Wage Grade. 

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Hispanic male participation rates increased from 2.4% to 3.4% at the GS-15 level but remained 

at 0.3% at the GS-14 level. Asian males had a slight decrease in participation rates at the GS-15 

level, from 1.2% to 1.1%. Similarly, at the GS-14 level, their participation rate decreased from 

1.0% to 0.7%. Hispanic females had no representation at the GS-15 level. Their participation 

rate went from 1.2% to 0% and remained the same at the GS-14 level with 1%. Asian female 

participation rates also remained the same as last year with no representation (0%) at the GS-15 

level and stayed the same at the GS-14 level with 0.3%. 

AI/AN males and females at the GS-15 and GS-14 levels stayed the same with no representation 

(0%). 

NH/PI males and females at the GS-15 and GS-14 levels stayed the same with no representation 

(0%). 

2+R males remained the same at the GS-15 level with no representation (0%) and at the GS-14 

the group saw an increase from 0% to 1%. For 2+R females, there was a decrease from 0.3% to 

0% at the GS-15 level the group stayed the same at the GS-14 level (0%). 

4. Participation in the Senior Executive Service. In FY22, the SES positions were occupied 

by 10 males (45.5%) and 12 females (54.5%). White females made up 50.0% (11 positions) at 

this level, followed by White males with 36.4% (8 positions). There was 4.5% representation for 

Black males and females, and Asian males with 1 position each. At the SES level, there were no 

Hispanic males and females, Asian females, NH/PI males and females, AI/AN males and 

females, or 2+R males and females. 

5. Participation Rates by Sex in MCOs. DFAS identifies the following as “mission-critical” 

occupations: Human Resources (0201), Financial Administration (0501), Accountant (0510), 

Auditor (0511), and Information Systems (2210). These mission-critical occupations (MCOs) 

are those typically leading to senior leader positions. 

Table A6: Participation Rates for Mission-Critical Occupations 

0201 0501 0510 0511 2210 

Human Resources Financial 

Administration Accounting Auditor 

Information 

Systems 

FY21 FY22 FY21 FY22 FY21 FY22 FY21 FY22 FY21 FY22 

Male 34.7% 32.9% 44.4% 43.5% 41.5% 40.6% 61.7% 66.2% 70.3% 70.9% 

OCLF 38.7% 38.7% 54.2% 54.2% 39.0% 40.1% 39.0% 39.0% 70.9% 70.9% 

Female 65.3% 67.1% 55.6% 56.5% 58.5% 58.2% 38.3% 33.9% 29.7% 29.1% 

OCLF 61.2% 61.2% 45.8% 45.8% 60.9% 59.9% 60.9% 60.9% 29.1% 29.1% 

Hispanic Male 2.1% 1.4% 1.3% 1.3% 1.0% 1.0% 0.0% 0.0% 2.6% 3.1% 

OCLF 4.7% 4.7% 3.9% 3.9% 2.8% 2.8% 2.8% 2.8% 4.5% 4.5% 

Hispanic

Female 

2.6% 1.4% 1.9% 2.1% 1.5% 1.4% 0.0% 0.0% 0.5% 0.4% 

OCLF 6.7% 6.7% 4.7% 4.7% 5.1% 5.1% 5.1% 5.1% 1.6% 1.6% 

White Male 26.4% 25.7% 33.7% 33.1% 31.7% 30.6% 56.7% 61.5% 56.8% 56.9% 

OCLF 28.1% 28.1% 44.1% 44.1% 29.8% 29.8% 29.8% 29.8% 54.3% 54.3% 

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White Female 42.0% 43.8% 37.2% 37.7% 39.0% 39.8% 30.0% 30.8% 20.8% 20.4% 

OCLF 43.5% 43.5% 32.8% 32.8% 42.9% 42.9% 42.9% 42.9% 21.7% 21.7% 

Black Male 5.7% 5.2% 7.5% 8.3% 6.7% 6.4% 5.0% 4.6% 6.8% 5.8% 

OCLF 3.3% 3.3% 3.0% 4.7% 2.7% 2.7% 2.7% 2.7% 3.6% 3.6% 

Black Female 19.7% 19.5% 14.3% 14.7% 14.8% 14.4% 6.7% 3.1% 6.6% 6.3% 

OCLF 7.0% 7.0% 4.9% 7.5% 5.7% 5.7% 5.7% 5.7% 2.5% 2.5% 

Asian Male 0.5% 0.5% 1.2% 1.1% 1.7% 1.7% 0.0% 0.0% 3.4% 3.5% 

OCLF 1.9% 1.9% 2.3% 1.6% 3.1% 3.1% 3.1% 3.1% 7.0% 7.0% 

Asian Female 1.0% 1.4% 1.6% 1.4% 2.7% 2.9% 1.7% 0.0% 1.4% 1.4% 

OCLF 2.4% 2.4% 2.3% 3.1% 5.8% 5.8% 5.8% 5.8% 2.6% 2.6% 

NH/PI Male 0.0% 0.0% 0.1% 0.1% 0.1% 0.2% 0.0% 0.0% 0.1% 0.1% 

OCLF 0.2% 0.2% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

NH/PI Female 0.5% 0.0% 0.1% 0.1% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 

OCLF 0.3% 0.3% 0.2% 0.2% 0.3% 0.3% 0.3% 0.3% 0.1% 0.1% 

AI/AN Male 0.0% 0.0% 0.5% 0.0% 0.3% 0.2% 0.0% 0.0% 0.5% 0.1% 

OCLF 0.0% 0.0% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

AI/AN Female 0.5% 0.0% 0.3% 0.1% 0.4% 0.2% 0.0% 0.0% 0.4% 0.2% 

OCLF 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.0% 0.0% 

2+R Male 0.0% 0.0% 0.2% 0.8% 0.0% 0.5% 0.0% 0.0% 0.2% 1.4% 

OCLF 0.7% 0.7% 0.8% 0.8% 0.6% 0.6% 0.6% 0.6% 1.3% 1.3% 

2+R Female 0.0% 1.0% 0.3% 1.0% 0.0% 0.8% 0.0% 0.0% 0.0% 0.4% 

OCLF 1.2% 1.2% 0.9% 0.9% 1.1% 1.1% 1.1% 1.1% 0.7% 0.7% 

PWTD 5.2% 4.3% 3.5% 4.1% 3.9% 3.9% 0.0% 1.5% 5.2% 4.5% 

The workforce participation rate for males at DFAS exceeded the OCLF in two (same as FY21) 

of the five mission-critical occupations (0510 and 0511), stayed at par in 2210s, and was below 

the OCLF in 0201 and 0501. Females exceeded availability in two (one less than FY21) 

mission-critical occupations (0201, 0501), stayed at par in 2210s, and was below in 0510 and 

0511 occupational series. 

In FY22, the overall male participation rate in the 0201 occupational series decreased from FY21 

and fell below the OCLF by almost 6%. In the 0501 occupational series the male participation 

rate decreased from FY21 and was significantly below the OCLF by 10.7%. In the 0510 

occupational series, the male participation rate decreased slightly from FY21 but was above the 

OCLF by 1.6%. In the 0511 occupational series, the male participation rate increased from 

FY21 and was significantly higher than the 27.2% OCLF benchmark, and in the 2210 

occupational series the male participation rate slightly increased from FY21 and was at par with 

the OCLF benchmark. 

In FY22, the overall female participation rate in the 0201 and 0501 occupational series increased 

from FY21 and were above the OCLF. On the 0510 occupational series there was an increase in 

participation from FY21 but were below the OCLF. On the 0511 occupational series there was a 

decrease in participation from FY21 and were significantly below the OCLF by 27%. On the 

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2210 occupational series, there was a decrease in participation from FY21 but stayed at par with 

the OCLF benchmark. 

6. Participation Rates by Race and National Origin (RNO) and Sex in MCOs. In FY22, the 

RNO participation rates were as follows: White males had higher participation rates than the 

OCLF in the 0510, 0511 and 2210 occupational series and fell below the OCLF benchmark in 

the 0201 and 0501 occupational series, same as FY21. White females had higher participation 

rates in 0201, 0501 and had less-than-expected participation rates in 0510, 0511 (significantly), 

and 2210 occupational series. 

Black males exceeded their availability in the OCLF in all MCOs. Black females significantly 

exceeded their availability in the OCLF in the 0201, 0501, and 0510 occupational series. They 

were above the OCLF in 2210 and below the OCLF in 0511. 

Conversely, Hispanic and Asian males and females had less-than-expected participation in all 

mission-critical occupations. Hispanic males and females and Asian males had no representation 

in the 0511 occupational series (same as FY21). 

NH/PI males were above the OCLF participation rate in the 0510 occupational series, at parity 

with the OCLF participation rates in the 0501 and 2210 occupational series, and were below the 

OCLF in the 0201 and 0511 occupational series with no representation. NH/PI females were 

below the OCLF in all MCOs and only had representation at the 0501 series (0.1%). 

AI/AN males were above the OCLF in the 0510 occupational series, at par in the 2210 series, 

and below in 0201, 0501, 0511 with no representation. AI/AN females were above participation 

rates in the 0510 and 2210 occupational series, were at par in 0501 and had lower-than-expected 

participation rates in the 0201 and 0511 occupational series with no representation. 

Two or More Races males were above OCLF participation rates in the 0501 occupational series, 

had no representation in the 0511 series, and were below in all other occupational series. Two or 

More Races females were above their OCLF participation rate in the 0501 occupational series, 

fell below the OCLF participation rate in all MCOs, and had no representation in the 0511 series. 

7. Participation Rates by RNO, Sex, and Grade Level in Mission-Critical Occupations. 

Black males and females constituted 6.43% and 14.51% respectively of the permanent GS 

workforce, a slight decrease from 6.88% and 15.39% respectively from FY21. 

Black males occupied positions in senior grades GS-13 (5.4%), GS-14 (5.0%), and SES (4.55%) 

at rates lower than their overall workforce participation rate. In GS-15 (6.9%), their rate of 

participation exceeded the overall workforce participation rate. 

In the 0201 occupational series, Black males exceeded OCLF participation at the GS-7, 11, 12, 

and 13 grade levels but fell below their benchmark with no representation at the GS-9, 14, and 

15 grade levels. In the 0501occupational series, Black males exceeded OCLF participation at all 

levels, especially at the GS-7, 11, 15, and SES grade levels, where they significantly exceeded 

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the benchmark. In the 0510 occupational series, they exceeded OCLF participation at all levels, 

except at the SES level, in which they fell below the benchmark with no representation. In the 

0511 occupational series, they exceeded workforce participation at the GS-12 and 13 grade 

levels and fell below their participation benchmark at all other grade levels with no 

representation. In the 2210 occupational series, they were above the workforce participation rate 

at the GS-7, 11, 12, 13 grade levels, fell below their benchmark at the GS-14 level, and had no 

representation at the GS-9, 15, and SES grade levels. 

In the 0201 occupational series, Black females significantly exceeded the OCLF workforce 

participation rate at all levels, except at the GS-15 grade level (no representation). In the 0501 

occupational series, Black females exceeded their OCLF participation rates at all grade levels, 

except at the GS-15 level and had no representation at the SES level. In the 0510 occupational 

series, they exceeded their OCLF participation rate at all levels, significantly exceeding at the 

GS-7, 9, 11, 12, 13 and SES levels. In the 0511 occupational series, Black females significantly 

exceeded OCLF participation rates at the GS-13 and fell below the benchmark at all other grade 

levels with no representation. In the 2210 occupational series, Black females exceeded the 

workforce participation rate at the GS-11, 12, 13 and 14 grade levels, and they had no 

representation at all other grade levels. 

Regarding the participation of Hispanics, males and females represented 1.3% and 1.5%, 

respectively, and their participation was consistently below the OCLF for all mission-critical 

occupations. Hispanic males were above the benchmark at GS-13 and at the GS-15 grade level 

and below the benchmark at the GS-14 and SES levels (no representation). Hispanic females 

were slightly above the OCLF benchmark at the GS-13 level but fell below the benchmark at the 

GS-14 level, and had no representation at the GS-15 and SES levels. 

Regarding the participation of Hispanics in mission-critical occupations, Hispanic males in the 

0201 occupational series were below OCLF benchmarks at all levels and had no representation at 

the GS-7, 9, 13, 14, and 15 grade levels. In the 0501 occupational series, they fell below the 

benchmark at all levels, with no representation at the GS-7, 14, 15, and SES level. In the 0510 

occupational series, they fell below the benchmark at all levels, except the GS-15 level. They 

had no representation at the SES level. In the 0511 series, they had no representation at any 

level. In the 2210 occupational series, they fell below the benchmark at all levels with no 

representation at the GS-7, 9, 14, 15, and SES levels. 

Hispanic females in the 0201 occupational series were below the OCLF benchmark at all levels 

and had no representation at the GS- 7, 11, 13, 14, and 15 levels. In the 0501 occupational 

series, they fell below the benchmark at all levels, with no representation at the GS-14, 15, and 

SES levels. In the 0510 occupational series, they fell below the benchmark at all levels and had 

no representation at the GS-14, 15, and SES levels. In the 0511 occupational series, they had no 

representation at any level. In the 2210 occupational series, they fell below the benchmark at all 

levels, except the GS-7. They had no representation at the GS-9, 11, 14, 15, and SES levels. 

Asian males fell below the OCLF participation rate in the 0201, 0510, and 0511 occupational 

series at all grade levels. In the 0201 occupational series, Asian males fell below the OCLF 

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benchmark at all levels. They only had representation at the GS-11 level. In the 0501 

occupational series, they only exceeded workforce participation at the SES level and fell below 

OCLF workforce participation benchmarks at all other grade levels (no representation at the GS15 level). In the 0510 series they fell below the OCLF benchmark at all levels and had no 

representation at the GS-13, 15, and SES levels. In the 0511 occupational series, they had no 

representation at any level. In the 2210 occupational series the fell below the OCLF benchmark 

at all levels, except at the GS-9 level in which they significantly exceeded the benchmark. They 

had no representation at the GS-14, 15, and SES levels. 

Asian females fell below the OCLF participation rate in all mission-critical occupations, except 

at the 0201 GS-12 level and at the 0501 GS-9 level. They had no representation at the GS-14 to 

SES level, except at the 0501 GS-14 level, in which they still fell below the OCLF benchmark. 

They also had no representation at any levels in the 0511 occupational series. 

NH/PI males only exceeded the OCLF participation rate in the 0501 GS-9 and 13 levels, in the 

0510 GS-11, 12, and 13 levels, and in the 2210 occupational series at the GS-12 level. They had 

no representation in all other grade levels in the 0501, 0510, and 2210 occupational series. They 

also had no representation in any grade level in the 0201 and 0511 occupational series. 

NH/PI females only exceeded the OCLF participation rate in the 0501 occupational series at the 

GS-9 level and fell below the benchmark with no representation at all other levels in all major 

critical occupations. 

AI/AN males only exceeded the OCLF participation rate in the 0510 occupational series at the 

GS-11 and 12 levels and in the 2210 occupational series at the GS-12 level. They fell below the 

benchmark at all other levels due to no representation. 

Two or More Races males had no representation at any grade level in the 0201 and 0511 

occupational series. There were no SES positions in the 0201 occupational series. They 

exceeded the OCLF benchmark in the 0501 occupational series at the GS-11 and GS-14 levels 

and fell below the benchmark at all other levels. In the 0501 series, Two or More Races males 

had no representation at the GS-7, 15, and SES levels. In the 0510 occupational series, they 

exceeded the OCLF benchmark at the GS-12, 13, and 14 grade levels and fell below the 

benchmark at all other levels, with no representation at the GS-7, 9, 15, and SES levels. In the 

2210 occupational series they exceeded the OCLF benchmark at the GS-11 and 12 grade levels. 

They fell below the benchmark at all other levels with no representation at the GS-7, 9, 14, 15, 

and SES levels. 

Two or More Races females had no representation at any grade level in the 0511 occupational 

series. They exceeded the OCLF benchmark in the 0201 occupational series at the GS-11 and 12 

levels and fell below the benchmark with no representation at the other levels. In the 0501 

occupational series, they exceeded the OCLF benchmark at the GS-9, 11, 12, and 13 grade levels 

and fell below the benchmark with no representation at the other levels. In the 0510 series, they 

exceeded the OCLF benchmark at the GS-7 and 9 grade levels and fell below the benchmark at 

the GS-11, 12, and 13 levels, and had no representation at the other levels. In the 2210 series, 

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they exceeded the OCLF benchmark at the GS-12 and 13 levels and fell below the benchmark 

with no representation at the other levels. 

DFAS Analysis, Opportunities, and Actions 

Some trends identified in prior years continued in FY22. DFAS worked to address hiring needs 

for Hispanics and Asians and barriers for Black females and other females reaching higher 

grades leading to the SES level. Work is progressing with high-level action plans identified. 

Participation of Hispanic and Asian Workforce 

Table A1 

FY22 All Hispanic Asian 

Male Female Male Female 

Permanent 

Workforce 

# 10,719 140 162 136 165 

% 100% 1.31% 1.51% 1.27% 1.54% 

CLF 2018 % 6.82% 6.16% 2.19% 2.18% 

Hiring # 1274 14 10 25 21 

% 100% 1.10% 0.78% 1.96% 1.65% 

Separations # 1093 7 10 15 6 

% 100% 0.64% 0.91% 1.37% 0.55% 

FY21 All Hispanic Asian 

Male Female Male Female 

Permanent 

Workforce 

# 10,778 137 159 145 169 

% 100% 1.29% 1.48% 1.35% 1.57% 

CLF 2010 % 6.82% 6.16% 2.19% 2.18% 

Hiring # 915 14 9 17 17 

% 100% 1.53% 0.98% 1.86% 1.86% 

Separations # 1605 40 74 22 49 

% 100% 2.49% 4.61% 1.37% 3.05% 

*Permanent employees including Wage Grade. 

Hiring and Separations – Hispanics and Asians 

Hispanic permanent employees self-identified at a rate of 2.82% compared to the NCLF rate of 

12.98%. Asian permanent employees self-identified at a rate of 2.81% compared to the NCLF 

rate of 4.37%. 

A review of the FY22 workforce data indicated that the overall participation rate for Hispanic 

males and females stayed almost the same (from 1.27% and 1.48% in FY21 to 1.31% and 1.51% 

in FY22, respectively). Asian males and females had decreases in participation rates (from 

1.35% and 1.57% in FY21 to 1.27% and 1.54% in FY22, respectively). Hispanic and Asian 

males and females fell below the NCLF benchmark for the third year in a row. 

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Hispanics continued to show the most significant disparity in participation rates among DFAS 

employees, as compared to the NCLF. Asian employees also continued to be represented at 

lower-than-expected levels in the workforce, as compared to the NCLF. 

During this period, the total hires for DFAS increased (from 915 in FY21 to 1,274 in FY22), 

with less turnover (from 1,605 separations in FY21 to 1,093 in FY22). 

The percentage of Hispanic males hired decreased from 1.53% in FY21 to 1.10% in FY22. That 

said, their separation rate in FY22 was lower than FY21. The hiring of Hispanic females also 

decreased from 0.98% in FY21 to 0.78% in FY22. However, their separation rate in FY22 was 

also lower than FY21. The Hispanic male and female participation rates were also lower-thanexpected as compared to the OCLF in all five mission-critical occupational series. 

The percentage of Asian males hired slightly increased from 1.86% in FY21 to 1.96% in FY22. 

The hiring of Asian females decreased from 1.86% in FY21 to 1.65% in FY22. The separation 

rate of males in FY22 stayed the same as FY21, but for Asian females it was lower than FY21. 

The Asian male and female participation rates were also lower-than-expected as compared to the 

OCLF in all five mission-critical occupational series. 

In summary, while taking important steps in increasing the hiring of Hispanic and Asian 

employees, the separation of these underrepresented groups continues to be high. DFAS has 

taken steps toward increasing Hispanic and Asian participation in its workforce and is taking 

proactive actions to avoid additional disparities in these under-represented groups. Increasingly 

focused strategic recruitment and outreach activities continue. 

Females in Leadership Pipeline Participation 

In FY22, females comprised 58.9% of the DFAS workforce. While 62.83% of the supervisory 

workforce are female, the proportion of female managers and executives is at 45.4% and 47.2%, 

respectively. The pipeline to senior positions in the Agency (SES and GS-15) has not seen 

significant change since FY20. The proportion of GS-15 positions occupied by females 

decreased from 45.9% in FY21 to 44.8% in FY22, while males comprised 55.2%. In GS-14 

positions, females comprised 40.9%, as compared to males who comprised 59.1%. In GS-13 

positions, females comprised 46.6%, as compared to males who comprised 53.4%. 

Most females occupying positions at or above the GS-13 grade level were White. In FY22, 

33.1% of GS-13’s were White females, followed by Black females at 8.8%, then Hispanic 

females at 1.9%, followed by Asian females at 1.3%. The representation of females in 

leadership positions for all categories fell below their representation in the overall DFAS 

population. 

For 0201 occupational series positions, Black and White females were selected less than 

expected, given representation in the hiring pipeline (applied, qualified, and referred). However, 

White females held a larger portion of GS-13 and higher graded positions in the 0201 series (GS13 was 50%, GS-14 was 38.5%, and GS-15 was 42.9%) as compared to Black females (GS-13 

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was 13.9%, GS-14 was 7.69%, and GS-15 was 0%) and Hispanic and Asian females, who had no 

representation at the GS-13 and higher levels. 

For 0501 occupational series positions, White and Black females were selected more than 

expected, given their representation in the hiring pipeline (applied, qualified, and referred). 

White females held a larger portion of GS-13 and higher graded positions in the 0501 series (GS13 was 34%, GS-14 was 40%, and GS-15 was 36.4%) as compared to Black females (GS-13 was 

9.62%, GS-14 was 5.1%, and GS-15 was 3.03%), Asian females (GS-13 was 0.1%, GS-14 was 

1%, and GS-15 was 0%), and Hispanic females (GS-13 was 2.9%, GS-14 was 2%, and GS-15 

was 0%). 

For 0510 occupational series positions, Black females were selected more often than expected, 

given their representation in the hiring pipeline (applied, qualified, and referred). White females 

held a larger portion of GS-13 and higher graded positions in the 0510 occupational series (GS13 was 47%, GS-14 was 36.6%, and GS-15 was 42.3%) as compared to Black females (GS-13 

was 10.5 %, GS-14 was 8.6 %, and GS-15 was 7.7%), Asian females (GS-13 was 1%, GS-14 

was 0.%, and GS-15 was 0%), and Hispanic females (GS-13 was 1.2%, GS-14 was 0.%, and GS15 was 0%). 

For 0511 occupational series positions, females were selected less than expected, given their 

representation in the hiring pipeline (applied, qualified, and referred). There was no 

representation of Hispanic, Asian, or any other race in this occupational series. White females 

held a larger portion of GS-13 and higher graded positions in the 0511 series (GS-13 was 27.8%, 

GS-14 was 0%, and GS-15 was 0%) as compared to Black females (GS-13 was 11.1%, GS-14 

was 0 %, and GS-15 was 0%). 

For 2210 occupational series positions, Black females were selected more often than expected, 

given their representation in the hiring pipeline (applied, qualified, and referred). White females 

still maintained a larger portion of those GS-13 and higher graded positions (GS-13 was 16.9%, 

GS-14 was 21.6%, and GS-15 was 50%) as compared to Black females (GS-13 was 4.9%, GS-14 

was 2.7%, and GS-15 was 0%), Asian females (GS-13 was 2.2%, GS-14 and GS-15 were 0%), 

and Hispanic females (GS-13 was 0.9%, GS-14 and GS-15 were 0%). 

As in prior years, in FY22, GS-14 and 15 graded employees were considered the most likely 

applicant pool for competitive promotions to the SES within DFAS. Females remained 

consistent at the SES level, occupying 12 of the 22 positions. 

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Participation in Career Development Programs FY22 

Table A1.2 

Table A1.2 reflects the participation of employees in grades GS-5 through 12 in the DFAS 

Career Acclimation Program (DCAP) and Pathways program. Employees hired into these “slide

positions” (i.e., generally GS-7/9/11) participate in a two-year program to develop employees to

advance to journey-level professional, administrative, and technological career fields. 

In FY22, DCAP and Pathways participants continued to receive opportunities to build career and 

leadership, team building, project management, and process improvement skills through on-thejob assignments, cross-training, rotational assignments or job exposures, and formal training. 

Participants also developed professional relationships through group projects, social functions, 

community service activities, networking, and working with mentors. 

From FY21 to FY22, participation in career development programs by White females, Black 

males and females, Hispanic females, Asian males, and 2+R males and females increased. 

AI/AN male and female participation stayed the same, while White males, Hispanic males, Asian 

females, NH/PI males and females, and AI/AN females decreased. 

The “Relevant Pool” data in Table A1.2 is based on participation of grade levels included in the 

program at DFAS. The NCLF is relevant for comparison because external applicants selected 

for these positions are also entered into the program. Because the program application process is 

directly tied to selections from vacancy announcements across the Agency, the “Applied” and 

“Participated” percentages reflect the same data. 

In FY22, the participation of Black females in career development programs was significantly 

above the NCLF participation rate. White females and Black males were above the NCLF 

participation rates. Meanwhile, NH/PI stayed at parity with the NCLF, Hispanic males and

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females, White males, AI/AN males and females, and 2+R males and females were below the 

NCLF participation rates. Hispanic males and females had the largest delta between their 

participation rate and the NCLF participation rate. 

Employee Recognition: Awards Distribution by Race/Ethnicity and Sex 

In FY22, monetary and time-off awards were distributed to employees in the workforce at all 

grade levels, in all occupations, and at all locations. DFAS analyzed award distribution and 

amount by RNO, sex, and disability for purposes of identifying possible barriers. The 

triggers identified will be examined further to identify the specificity of the disparity between 

grades. It is possible existing grade-related barriers may represent a probable root cause as 

opposed to a primary issue. Since rating-based awards are often partially calculated based on 

employee salary, the grade distribution within race, ethnicity, and gender may play a significant 

role in the average award amount. Additional analysis will focus on these factors relative to the 

workforce analysis below. 

In FY22, the Agency distributed a total of $21,659,017 in monetary awards. Of these awards, 

the Agency distributed $18,480,647 in cash awards of $501 or more, which represents 

approximately 85% of monetary awards, up 2% from FY21. Awards were primarily associated 

with individual performance ratings. 

The Agency distributed $3,178,343 in cash awards in the $500 or less amount category, which 

includes special act awards, suggestion awards, and performance awards. 

The Agency distributed Quality Step Increases (QSIs) to employees in recognition of outstanding 

performance. There was no significant difference in the number of QSIs issued to employees by 

RNO or gender based on their overall representation in the DFAS population. 

In average award amounts for both FY21 and FY22, White employees received higher award 

amounts than Black employees. In addition, Black employees received fewer award dollars than 

Asian and Hispanic employees. The award amount differences between Black employees and 

Asian and Hispanic employees from FY21 continued in FY22. 

Male employees received significantly higher award amounts than female employees in the 0510 

occupational series. In the 0201, 0501, 0511, and 2210 occupational series, there was no 

significant difference in award amounts between males and females. 

In FY22, the Agency continued its analysis of barriers to female participation in grade levels GS11 to SES and examined the impact this phenomenon has on their participation in the awards 

program. Additional work and plans regarding the granting of awards at less-than-expected rates 

are being further considered in FY23. 

In average award amounts for FY21 and FY22, there were significant differences in the award 

amounts received by grade, with higher grades (>GS-12) receiving larger award amounts than 

lower grades (<GS-12) on average. These differences applied to all occupational series. 

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Agency Program for People with Targeted Disabilities Participation 

Overall, the Agency saw an increase in the percentage of the permanent workforce that identified 

as PWD. The percentage of PWD at the end of FY22 stood at 19.69%. This was an increase 

from 19.54% in FY21. DFAS exceeds the federal 12% goal for employment of PWD. DFAS 

also exceeded the federal 2% goal for employment of PWTD. The B6 Tables below reflect the 

participation rate of PWTD in mission-critical occupations. In FY22, there was an increase of 

0.44% for PWD in the 0201 mission-critical occupation. For PWD in the 0501 mission-critical 

occupation, there was an increase of 1.12% and 0.60% for PWTD from FY21 to FY22. For the 

510s, there was a 0.51% increase for PWD and a minimal increase for PWTD. There was a 

minimal decrease for PWD and PWTD in the 2210s. 

Table B6 – Participation Rates for Mission-Critical Occupations (FY22) 

Job Title/Series Total 

Total by Disability Status 

(05) No 

Disability 

(01) Not 

Identified 

(06-94) 

Disability 

Targeted 

Disability 

201 – HR Managers # 210 154 17 39 9 

% 100.00% 73.33% 8.10% 18.57% 4.29% 

501 – Financial 

Management 

# 2035 1533 101 401 84 

% 100.00% 75.33% 4.96% 19.71% 4.13% 

510 – Accounting # 2379 1872 102 405 92 

% 100.00% 78.69% 4.29% 17.02% 3.87% 

511 – Auditor # 65 54 3 8 1 

% 100.00% 83.08% 4.62% 12.31% 1.54% 

2210 – Information 

Systems 

# 1130 822 70 238 51 

% 100.00% 72.74% 6.19% 21.06% 4.51% 

Distribution by Grade Grouping 

The Agency exceeded the 2% federal goal in the employment of PWTD in the grade groupings 

of GS-10 and below (4.65%) and GS-11 and above (4.00%). Additionally, DFAS exceeded the 

federal benchmark of 12% for PWD in both grade groupings, GS-10 and below (15.72%) and 

GS-11 and above (14.87%). 

Table B4 – Workforce Distribution by Grade Grouping 

Disability GS-1 - GS-10 GS-11 - SES Grand Total 

Disability 785 15.72% 859 14.87% 1644 15.26% 

No Disability 3600 72.09% 4406 76.28% 8006 74.34% 

Targeted Disability 232 4.65% 231 4.00% 463 4.30% 

Unknown 377 7.55% 280 4.85% 657 6.10% 

Grand Total 4994 100.00% 5776 100.00% 10770 100.00% 

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Employment of People with Disabilities 

Employment of PWD increased from 19.54% to 19.69%, exceeding the DoD goal of 12%. 

Employment of PWTD was 4.21% in FY22, exceeding the DFAS goal of 3%. 

Hiring and Separations for PWTD 

Table B1 – (Permanent) Distribution – Hiring and Separations for PWTD 

FY22 All No 

Disability 

Not 

Identified 

Disability Targeted 

Disability 

Total Workforce 

Table B1 

# 10738 7934 682 2114 452 

% 100% 74.02% 6.35% 19.69% 4.21% 

Hiring 

Table B1 

# 1293 1039 160 94 25 

% 100% 80.36% 12.37% 7.27% 1.93% 

Separations 

Table B1 

# 1102 730 108 264 60 

% 100% 66.24% 9.80% 23.96% 5.44% 

FY21 All No 

Disability 

Not 

Identified 

Disability Targeted 

Disability 

Total Workforce 

Table B1 

# 10803 8030 662 2111 462 

% 100% 74.33% 6.13% 19.54% 4.28% 

Hiring 

Table B1 

# 928 688 144 96 17 

% 100% 74.14% 15.52% 10.34% 1.83% 

Separations 

Table B1 

# 1614 1056 204 354 75 

% 100% 65.43% 12.64% 21.93% 4.65% 

* Total workforce to include Permanent, Temp and Wage Grade employees 

Separations: Separations percentage increased from FY21 to FY22. In FY22, 5.44% (60) of all 

separations were PWTD. In FY21, that percentage was 4.65% (75). 

Hiring: Hiring of PWTD in FY22 was at 1.93% (25) of all new hires; this was an increase from 

FY21 when 1.83% (17) of all new hires was a PWTD. 

An area of concern continues to be the number of new hires (160) who chose not to identify a 

disability status. These individuals represented 12.37% of all new hires. To increase the DFAS 

percentage of PWD and PWTD, the Agency continues to promote verifying self-identification 

during the onboarding process for new hires. 

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Agency Recognition and Awards: Distribution by Disability 

Table B9 – Employee Recognition and Awards 

FY22 Recognition 

and Awards Total No Disability 

(05) 

Not 

Identified 

(01) 

Disability 

(02-03, 

06-99) 

Persons 

With 

Targeted 

Disability 

Cash Awards: $500 

and Under 

# 8733 6536 542 1655 352 

% 100.00 74.84 6.21 18.95 4.03 

Total Amount $ 3176343 2385050 195632 595661 125462 

Average Amount $ 363.72 364.91 360.94 359.92 356.43 

Cash Awards: $501 -

$999 

# 3039 2331 182 526 106 

% 100.00 76.70 5.99 17.31 3.49 

Total Amount $ 2285950 1749643 136594 399713 80201 

Average Amount $ 752.20 750.60 750.52 759.91 756.61 

Cash Awards: $1000 

- $1999 

# 4845 3714 223 908 182 

% 100.00 76.66 4.60 18.74 3.76 

Total Amount $ 6427782 4925385 294019 1208378 244232 

Average Amount $ 1326.68 1326.17 1318.47 1330.81 1341.93 

Cash Awards: $2000 

- $2999 

# 2001 1520 98 383 71 

% 100.00 75.96 4.90 19.14 3.55 

Total Amount $ 4785272 3631952 236486 916834 165885 

Average Amount $ 2391.44 2389.44 2413.12 2393.82 2336.41 

Cash Awards: $3000 

- $3999 

# 674 544 27 103 14 

% 100.00 80.71 4.01 15.28 2.08 

Total Amount $ 2251932 1822845 89596 339491 45407 

Average Amount $ 3341.15 3350.82 3318.37 3296.03 3243.36 

Cash Awards: $4000 

- $4999 

# 303 250 7 46 9 

% 100.00 82.51 2.31 15.18 2.97 

Total Amount $ 1323928 1092566 30100 201262 39622 

Average Amount $ 4369.40 4370.26 4300.00 4375.26 4402.44 

Cash Awards: $5000 

or more 

# 174 142 4 28 6 

% 100.00 81.61 2.30 16.09 3.45 

Total Amount $ 1375121 1084591 34355 256175 60637 

Average Amount $ 7902.99 7637.96 8588.75 9149.11 10106.17 

Table B9 reflects the distribution of $18,449,985 in monetary awards of $501 and up. In FY22, 

1,994 employees with non-targeted disabilities received monetary awards of $501 and up. A 

total of 388 employees with targeted disabilities received monetary awards of $501 and up. 

Part E.4 – Accomplishments 

• In the 2022 FEVS, the Agency scored 80% on the EEI, which exceeds the government 

threshold of 67% (set by OMB) by 13%. DFAS ranked 4th in EEI among the 24 Defense 

Agencies, an improvement from 5th place in 2021. 

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• DFAS tied for 3rd place in the Leaders Lead category under the EEI. This category reflects 

employee perception of senior leadership. 

• The Agency’s FEVS results also show that DFAS scored 79% in Overall DEIA, exceeding 

DoD scores. 

• Senior leaders developed the GMID strategy to enhance DEIA efforts. GMID includes 

initiatives related to merit promotion and mentoring, which includes a DFAS instruction with 

examples and templates for hiring managers, a supervisor tool kit explaining hiring strategies 

and authority, and deployment of a mentoring module within the success factors. In 

mentoring, GMID: 

 Matched 100% of GS-14 succession cycle participants with a mentor. 

 Provided mentorship trainings to more than 230 attendees and 30 mentors. 

 Established collaborative approaches with process partners to generate, analyze, and 

deliver accurate reporting to senior leaders. 

• Senior leaders and executives continue to serve in key roles in supporting Agency DEIA 

efforts related to the Black Female Barrier Analysis work, the HABIT initiative, the GMID, 

ERGs, SEPs, and DEIA committees. 

• The Agency provided portfolio management for the OEOP by facilitating initiative alignment 

to the DIOP. 

• Senior leaders approved the development of the first agency-wide DEIA Award, the La Mont 

Johnson DEIA Award, designed to recognize DEIA above and beyond contributions from 

employees and supervisors. 

• Agency site leaders met with newly hired employees after onboarding to discuss the 

importance of the EEO program, professional development, teamwork, site wellness, and 

being an exemplary public servant. 

• In FY22, DFAS hired 19 Schedule-A appointees, totaling 2% of external hires [up from 14 

hires (1.3% of external hires) in FY21]. DFAS also hired a total of 186 veterans in FY22, 

representing 17% of all hires. Of those hired, 102 veterans had a 30% or higher disability 

rating (up from 87 in FY21), which represented 55% of all veterans hired (up 2% from 

FY21). 

• OEOP worked in conjunction with HR, Office of General Counsel (OGC), and senior 

management to update and streamline the civil liberties, harassment prevention, and 

accommodation programs and instructions. 

• Leadership/supervisors promptly addressed employee allegations of harassment or 

discrimination in the workplace. 

• Agency leaders established a cadre of IOs to promptly investigate claims of harassment. All 

IOs received detailed training on the DFAS Harassment Prevention Instruction, investigative 

process and techniques, and their investigative role and responsibilities. 

• OEOP regularly briefed senior leaders regarding barrier analysis, DEIA initiatives, agency 

demographics, complaint posture, and training data. OEOP also briefed senior leaders on the 

Agency’s progress toward a model EEO program and addressed any existing or emerging 

challenges. 

• OEOP proactively avoided conflicts of interest in complaint processing and ensured legal 

compliance in the EEO Program by working with the OGC, while maintaining a firewall 

between litigation and final agency action staff. OEOP also encouraged early resolution by 

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offering mediation to participants in the EEO complaint process 100% of the time, through 

the DFAS Dispute Resolution Office. 

• To promote diversity and inclusion and cultural awareness, DFAS site directors encouraged 

employees to participate in the Agency’s SEP virtual observances. 

• DFAS celebrated 14 observances with keynote speakers and panels. Observances included 

Disability Awareness Month, American Indian and Alaskan Native Heritage Month, Martin 

Luther King, Jr. Observance, Black History Month, Women’s History Month, Holocaust 

Remembrance Observance, Asian American Heritage Month, Native Hawaiian and Pacific 

Islander Heritage Month, LGBTQ+ Pride Month, Juneteenth Observance, Military and 

Veterans Appreciation Observance, Women’s Equality Day, Hispanic Heritage and European 

American Heritage Month. These observances enhanced the workforce cultural awareness 

and promoted diversity and inclusion. 

 In FY22, in an effort to increase workforce participation at observance events, Agency 

leaders extended a “Road to 15% Challenge” to supervisors and managers. As a result, 

workforce participation significantly increased at all events. 

 DFAS provided CET credit based on leadership competencies to observance event 

attendees. 

• DFAS continued to make progress in the action items identified in prior years’ barrier 

analyses regarding lower-than-expected participation rates of Hispanics and Asians. The 

HABIT successfully supported DFAS to: 

 Perform applicant flow data analysis. 

 Provide recommendations to HR on educational institutions and affinity organizations 

with a higher Hispanic and Asian demographic to include in their recruitment plan. 

 Participate in targeted recruiting events with the goal of attracting talent from multiple 

demographics. 

 Prepare, schedule, and facilitate targeted outreach events and facilitate one-on-one and 

group sessions to provide job candidates information about the DFAS mission, 

application process, and career opportunities upon graduation. 

 Translate recruitment materials and presentations to Spanish and distribute them in 

Hispanic Serving Institutions. 

 Expand targeted recruitment efforts to one-grade level interval positions. 

• DFAS leadership supported effective coordination and collaboration to strengthen and 

enhance the merit promotion processes and external recruiting, to include increasing the use 

of direct hire authorities as a strategic recruitment tool to acquire a more diverse workforce. 

• To enhance retention of the PWD workforce and enhance inclusion, teams received peer-topeer Deaf Awareness classes on working and communicating with deaf and hard of hearing 

employees, understanding cultural interaction, and interacting with the Interpreting 

Department. 

• DFAS supervisors and employees are required to complete Harassment Prevention and 

Responses training. 

• DFAS used centralized training dollars to pay the tuition of 15 workforce representatives 

from all levels to obtain a Diversity and Inclusion certification from Cornell University. 

• DFAS encouraged employees to verify their disability status and RNO within the Defense 

Civilian Personnel Data System’s MyBiz+ application to improve agency data collection. 

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• The Agency promptly considered employees’ requests for adaptive equipment and/or 

reasonable accommodation. DFAS also provided employees with continued 

accommodations and opportunities to take home additional equipment and furniture to 

enhance their telework environment. 

• To meet the needs of deaf and hard of hearing employees, DFAS used Telecommunications 

Relay Service, CART, DFAS interpreters, and CAP services. DFAS also provided iPads and 

video phones to deaf employees. 

• DFAS ensured virtual collaboration team members attended training and reviewed guidance 

on ensuring virtual events were 508-compliant. This helped ensure that registration 

procedures were compliant, web-conferencing platforms were tested with DFAS 

environment and security considerations, presenters submitted 508-compliant materials, and 

closed captions and/or other accommodations were considered for each event. 

• To promote inclusion of the agency’s deaf community, DFAS offered Peer-to-Peer Deaf 

Awareness classes to deaf and hard of hearing teammates and/or process partners. The 

training provided information to teams on working and communicating with deaf and hard of 

hearing employees, and understanding cultural interaction. The training raised awareness 

while educating and encouraging sound methods of professional practice. DFAS also 

provided an agency-wide virtual American Sign Language class. Topics included deaf 

history, the signed alphabet, and common words and phrases. It also focused on increasing 

awareness about cultural differences and the availability of services and resources DFAS 

offers for those who are or work with deaf and hard of hearing employees, as well as those 

who may need other accommodations. 

• The interpreting team briefed new employees to create awareness and provide an overview 

on working with deaf and hard of hearing employees and interpreters at DFAS. They offered 

the DFAS interpreting team resources and links to provide technical support and 

accommodations to the agency’s deaf community and individuals, when needed. They also 

advocated for the deaf and hard of hearing employees to resolve issues. 

• DFAS interpreters mentored two students from the interpreting program at Columbus State 

Community College. These relationships help increase interest in the interpreting profession 

and future job opportunities at DFAS as the Agency continues to provide accessibility for the 

deaf and hard of hearing population. 

• To support Executive Order 13548 (Increasing Federal Employment of Individuals with 

Disabilities) in FY22, recruiters from the DFAS Hire a Hero Program participated in 

outreach events and job fairs targeting veterans and veterans with disabilities to assist them 

with the federal application process, resume writing, and coaching services. As part of the 

program, veterans were considered for DFAS jobs outside the typical hiring process by 

applying through the Hire a Hero Program Applicant Supply File. 

 DFAS proactively used Hire a Hero and Schedule-A and the Veterans Employment 

Opportunities Act (VEOA) listings in hiring efforts of veterans, PWD and PWTD. In 

FY22, DFAS hired 19 Schedule-A appointees, totaling 2.0% of total external hires [up 

from 14 hires (1.3% of external hires) in FY21]. DFAS also hired a total of 186 veterans 

in FY22, representing 17% of all hires. Of those hired, 102 veterans had a 30% or higher 

disability rating (up from 87 in FY21), which represented 55% of all veterans hired (up 

2% from FY21). Also, 15% of FY22 promotions were of veterans, 52% of which were 

30% or more disabled veterans. 

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• DFAS employee, Ms. Amy Umhoefer, was recognized with the 2022 Outstanding Employee 

with a Disability Award in the 42nd Annual Secretary of Defense Disability Awards 

Ceremony, and DFAS employee, Mr. Devid Brodsky, was recognized in the 2022 Workforce 

Recruitment Program Awards Ceremony. 

• The Agency’s Disability Program Manager provided a presentation on DFAS, Schedule-A, 

and WRP to colleges such as the Rochester Institute of Technology and non-profit 

organizations such as Opportunities for Ohioans with Disabilities that have a high percentage 

of PWDand. She also provided a presentation on best practices during the DoD’s WRP 

Forum, as well as a presentation on work/life balance and disability to the entire DoD 

workforce. 

• In FY22, through the DFAS Careers for Americans with Disabilities Program, DFAS 

continued to use a repository database of Schedule-A applicants that allowed for the 

“matching” of applicants against recruitment actions. 

• To enhance the recruitment opportunities of PWD, the Agency attended eight virtual 

recruiting events with participants who identified as PWTD. DFAS collaborated with the 

Gallaudet School of the Deaf, Rochester Institute of Technology, the National Technical 

Institute for the Deaf, and the Bender Virtual Career Fair for PWD. 

• DFAS participated in the WRP, a program designed to provide internships and permanent 

positions for emerging professionals with disabilities. DFAS used the WRP in compliance 

with Executive Order (EO) 14035, which specifically directs agencies to use the WRP more 

extensively in its recruitment efforts. 

 DFAS was recognized as the outstanding mid-sized component within DoD supporting 

WRP efforts in 2022. In FY22, the Agency hired 11 WRP candidates for summer 

internships and three WRP interns from FY21 had their internship extended into FY22. 

A total of five interns were hired as permanent employees. 

• To enhance diversity in the Agency’s applicant pool, DFAS posted job opportunity 

announcements to the career services offices of multiple Hispanic Serving Institutions 

(HSIs), Historically Black Colleges and Universities (HBCUs), and Minority Serving 

Institutions (MSIs). The Agency also attended seven virtual recruitment events that were 

targeted towards veterans, minority groups, and disabled candidates. 

• DFAS encouraged having diverse background hiring panel members in order to promote 

DEIA throughout the selection process and has also developed a Making a Selection Training 

Guide, to provide additional guidance to selecting officials during the hiring process. 

• Agency senior leaders and managers provided regular virtual mission area All Hands to 

encourage workforce recognition and morale. Virtual awards were presented to employees 

to recognize their accomplishments to enhance employee morale and engagement. 

• DFAS facilitated a robust Site Wellness Program to ensure work/life balance for employees. 

• The Agency continues to support the development of ERGs as they align with the goals of 

the Agency’s DIOP. In FY22, senior leaders and supervisors were briefed on the importance 

and benefits of ERGs. The OEOP created a comprehensive guide with instructions to 

develop and establish an ERG, and provided charter and memorandum of agreement 

templates. 

 The Agency established the first Agency-wide ERG: LEAD. LEAD conducted events to 

educate the DFAS workforce about disabilities and reasonable accommodation. They 

provided American Sign Language training, CAP training, articles on accessibility and 

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virtual platforms, ataxia awareness, a disability etiquette information sheet, and tools and 

resources to address challenges with recruitment, retention, advancement, training and 

development for PWD. They also shared resources and offered assistance to new DFAS 

employees to help them acclimate to their new workplace; leadership and mentorship 

opportunities for DFAS employees, supervisors, and managers; collaboration with DFAS 

management to overcome barriers for individuals with disabilities; and a Schedule-A 

questionnaire and step-by-step guide for recruitment efforts. 

 In FY22, the DFAS Veterans Employment Program became the Veterans ERG. This 

ERG focuses on fostering DEIA in the workplace by embracing the proud community of 

employee veterans and those still serving to support, encourage and connect them with 

other organizations and resources that improve their lives and the community. 

• DFAS administered the Defense Equal Opportunity Climate Survey (DEOCS). Participation 

exceeded the 25% goal, and enough data was collected from a third of the DFAS community 

to make assessments and identify problem areas. DEOCS version 5.0 was released in 

January 2021 and contains approximately 100 questions designed to assess 19 protective and 

risk factors that can impact an organization’s command climate. The objective is to assist 

agencies with collecting data that reflects workforce perceptions of their organization’s equal 

opportunity climate. 

 DEOCS Factors: A protective factor is an attitude, belief, and behavior associated with 

positive outcomes for organizations. Examples of these protective factors include 

cohesion, fairness, morale, and work-life balance. On the opposite end of the spectrum, a 

risk factor is an attitude, belief, and behavior associated with negative outcomes. Risk 

factors can include stress, toxic leadership, and workplace hostility. 

 DFAS received very high ratings for Connectedness, Work-Life Balance, Leadership 

Support from Immediate Supervisors, and Cohesion. 

 There were opportunities for improvement in Morale, Fairness, and Transformational 

Leadership. 

o There were double digit results for the presence of racially and sexually harassing 

behaviors. 

o One third of employees reported moderate to high stress. 

• In addition to celebrating with virtual observances, the Agency maintained a Celebrate 

Diversity and Inclusion website which provided the workforce with history, profiles, cultural 

learning, and entertainment information to celebrate observances at their leisure. The 

website also provided the workforce with recordings of observance programs held 

throughout the year. The website had up to 1,700 hits within a month and continues to 

remain a popular source for cultural awareness and inclusion. 

• DFAS extended observance programs to other DoD organizations and components to 

establish partnerships and enhance collaboration. DFAS also provided keynote speakers and 

had employees attend several federal government organization conferences. 

• DFAS sites in Japan and Europe developed additional DEIA programs designed to promote 

the objectives of the agency’s DIOP and customized them to the needs of the workforce. For 

instance, DFAS-Japan developed a Cultural Diversity and Inclusion Program, to maximize 

the benefits of their diverse workforce and host training and events that included a diversity 

panel titled “Creating a Culture of Inclusion, Fairness, and Relationships,” to increase 

employee awareness of DEIA. They also developed an English-to-Japanese common use 

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terms and phrases document for all new employees to build and improve connections, and an 

Employee Engagement Team to improve employee communication, engagement, 

participation. The team focused on cultural awareness, communication, and team building 

across the DFAS civilian and local national workforce. For the Holocaust Remembrance, 

DFAS-Europe conducted training focused on cultural enhancement at the Hinzert Memorial 

Concentration Camp. Employees were provided the opportunity to learn about the camp and 

those who were a part of its history. This event provided employees with a unique team 

building experience. 

• DFAS provided new employees with presentations on equal opportunity programs, DEIA, 

Alternate Dispute Resolution (ADR), quality of work/life balance, deaf/hard of hearing 

culture, and mentoring/coaching as part of the Agency’s onboarding program. 

• Agency leaders participated in training designed to stay abreast of important DFAS policies 

and procedures, including but not limited to EEO, ADR, quality of work/life balance, 

deaf/hard of hearing culture, and mentoring/coaching, among other topics. 

• Aside from the DEIA trainings the OEOP provided, several supervisors attended Leadership 

Foundations Program courses (e.g., Leading Diversity Coaching Sessions and Leading 

Diversity Mentoring Sessions). 

• DFAS also provided robust and comprehensive training for all new supervisors. The training 

covered topics such as workforce planning, recruiting, selecting and staffing, the hiring 

process, mentoring, reasonable accommodations, harassment and discrimination, and DEIA. 

• DFAS New Supervisor Training also included topics such as the Supervisor Manager 

Assimilation Program (SMAP), the Leadership Foundations Program, the Management 

Advancement for the Public Service seminars, the Institute for Management Studies 

seminars, and the Enterprise Leadership Program requirements. These six specialized 

training programs provide supervisors with the tools and skills they need and thus ensure the 

best interaction possible between supervisor and their employees. 

Part E.5 – Planned Activities 

DFAS is proud of its progress toward a Model EEO Program. There is, however, more to be 

accomplished in the upcoming years. Related plans and accomplishments (Part E.4) are at Parts 

H, I, and J of this report. In addition, the following list summarizes initiatives either planned, 

ongoing or completed in FY22, based on the annual MD-715 program assessment. 

• Further strengthen reporting relationship. 

• Enhance EEO and DEIA information in the Agency’s public website. 

• Implement the GMID Strategic Plan. 

 Implement DEIA reporting and communication, and build accountability. 

 Continue to implement efforts on mentoring, career counseling, professional 

development, and succession. 

• Continue to train supervisors and leaders on the benefits of a diverse workforce and an 

inclusive environment. 

• Continue to enhance the Agency’s mentorship program. 

• Continue to improve Agency’s anti-harassment complaints response timeliness. 

• Continue to perform applicant flow data analysis and remove any barriers identified. 

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• Continue to promote the development of ERGs Agency-wide. 

• Enhance the SEPs and continue to develop plans to increase workforce attendance at 

observances. 

• Continue to expand targeted recruitment efforts to increase diversity in applicant pools. 

• HABIT will continue to: 

 Collaborate with HR and site support offices to enhance recruitment efforts and increase 

the diversity of applicant pools. 

 Work on the “Engage” phase focused on solidifying structure and enhancing 

relationships with Hispanic and Asian communities close to DFAS sites. 

 Attract candidates into DFAS entry-level technician occupations, as well as two-grade 

interval positions. 

 Explore retention actions focused on targeted populations. 

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PART F

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DFAS FY22 MD-715 – Part G 

Agency Self-Assessment Checklist 

The Part G Self-Assessment Checklist is a series of questions designed to provide federal 

agencies with an effective means for conducting the annual self-assessment required in Part F of 

MD-715. This self-assessment permits EEO Directors to recognize, and to highlight for their 

senior staff, deficiencies in their EEO program that the agency must address to comply with MD715's requirements. Nothing in Part G prevents agencies from establishing additional practices 

that exceed the requirements set forth in this checklist. 

All agencies will be required to submit Part G to EEOC. Although agencies need not submit 

documentation to support their Part G responses, they must maintain such documentation on file 

and make it available to EEOC upon request. 

The Part G checklist is organized to track the MD-715 essential elements. As a result, a single 

substantive matter may appear in several different sections, but in different contexts. For 

example, questions about establishing an anti-harassment policy fall within Element C 

(Management and Program Accountability), while questions about providing training under the 

anti-harassment policy are found in Element A (Demonstrated Commitment from Agency 

Leadership). 

For each MD-715 essential element, the Part G checklist provides a series of “compliance 

indicators.” Each compliance indicator, in turn, contains a series of “yes/no” questions, called 

“measures.” To the right of the measures, there are two columns, one for the agency to answer 

the measure with “Yes”, “No”, or “NA”, and the second column for the agency to provide 

“comments”, if necessary. Agencies should briefly explain any “N/A” answer in the comments. 

For example, many of the sub-component agencies are not responsible for issuing final agency 

decisions (FADs) in the EEO complaint process, so it may answer questions about FAD 

timeliness with “NA” and explain in the comments column that the parent agency drafts all 

FADs. 

A “No” response to any measure in Part G is a program deficiency. For each such “No” 

response, an agency will be required in Part H to identify a plan for correcting the identified 

deficiency. If one or more sub-components answer “No” to a particular question, the agencywide/parent agency’s report should also include that “No” response. 

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MD-715 – Part G 

Agency Self-Assessment Checklist 

Compliance 

Indicator 

Measures 

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

statement. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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 EEO Policy Statement 

issued on January 13, 

2022. 

A.1.b Does the EEO policy statement address all protected bases (age, 

color, disability, sex, pregnancy, sexual orientation, gender 

identity, genetic information, national origin, race, religion, and 

reprisal) contained in the laws EEOC enforces? [see 29 CFR § 

1614.101(a)] 

Yes 

Compliance 

Indicator 

Measures 

A.2 – The agency has communicated EEO policies and 

procedures to all employees. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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 

A.2.a.2 Reasonable accommodation procedures? [see 29 C.F.R § 

1614.203(d)(3)] 

Yes 

A.2.b Does the agency prominently post the following information 

throughout the workplace and on its public website: 

36 
 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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.dfas.mil/ 

nofearact.html 

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.dfas.mil/ 

nofearact.html 

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 1020.1-I, Providing 

Reasonable 

Accommodations for 

Individuals with 

Disabilities (dfas.mil) 

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 Included in mandatory 

training for new 

employees and every 

two years thereafter. 

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

how often. 

Yes Included in mandatory 

training for new 

employees and every 

two years thereafter. 

A.2.c.3 Reasonable accommodation program? [see 29 CFR § 

1614.203(d)(7)(ii)(C)] If “yes”, please provide how often. 

Yes In FY22, there were 

three reasonable 

accommodation 

trainings for 

supervisors and 

training for the entire 

workforce on the 

Computer/Electronic 

Accommodations 

Program. 

37 
 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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

Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1] If “yes”, please provide how often. 

Yes Included in mandatory 

training for new 

employees and every 

two years thereafter. 

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 Included in mandatory 

training for new 

employees and every 

two years thereafter. 

Compliance 

Indicator 

Measures 

A.3 – The agency assesses and ensures EEO principles are part 

of its culture. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Compliance 

Indicator 

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 SEPMs and 

committee members 

by their managers and 

OEOP. Nominations 

and selection of 

DFAS Outstanding 

Employee with a 

Disability. 

Accomplishments are 

also published in the 

Agency’s MD-715 

Report. 

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 Both FEVS and 

Defense 

Organizational 

Climate Survey 

(DEOCS) are used to 

monitor the perception 

38 
 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

of EEO principles, 

determine workplace 

climate, and identify 

potential issues that 

can be resolved 

proactively. 

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. 

Compliance 

Indicator 

Measures 

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 

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 Reporting 

relationships have not 

changed since 

FY20. DFAS is a 

subordinate agency of 

the Department of 

Defense with 

implementation of the 

Elijah Cummings Act 

pending direction 

from the Department 

level. DFAS is a 

subordinate agency of 

the Department of 

Defense with the 

implementation of the 

Elijah Cummings Act 

39 
 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

pending direction 

from the Department 

level. 

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. 

No In FY22, the EEO 

Director provided 

updates to the DFAS 

board of Directors 

regularly; this 

included the top four 

DFAS senior 

executives, including 

the DFAS Director. 

The EEO Director 

also had monthly oneon-one sessions, as 

needed, and attended 

the Director’s weekly 

staff meetings. The 

EEO process 

examines impacts of 

personnel actions and 

decisions; the OEOP 

Director had free rein 

and provided 

dissenting opinions 

and maintained the 

integrity of the EEO 

investigative and 

decision-making 

process. Reporting 

level is not a negative 

factor in this work. 

40 
 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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.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.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 April 7, 2022 

B.1.d Does the EEO Director regularly participate in senior-level staff 

meetings concerning personnel, budget, technology, and other 

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

Yes 

Compliance 

Indicator 

Measures 

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

program. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Compliance 

Indicator 

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.2.b Is the EEO Director responsible for overseeing the completion of 

EEO counseling? [see 29 CFR §1614.102(c)(4)] 

Yes 

B.2.c Is the EEO Director responsible for overseeing the fair and 

thorough investigation of EEO complaints? [see 29 CFR 

Yes 

41 
 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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

subordinate level components.] 

B.2.d Is the EEO Director responsible for overseeing the timely issuing 

of final agency decisions? [see 29 CFR §1614.102(c)(5)] [This 

question may not be applicable for certain subordinate level 

components.] 

Yes 

B.2.e Is the EEO Director responsible for ensuring compliance with 

EEOC orders? [see 29 CFR §§ 1614.102(e); 1614.502] 

Yes 

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 

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)] 

NA 

No sub-components 

Compliance 

Indicator 

Measures 

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 

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.3.b Does the agency’s current strategic plan reference EEO/diversity 

and inclusion principles? [see MD-715, II(B)] If “yes”, please 

identify the EEO principles in the strategic plan in the comments 

column. 

Yes Please see the Human 

Capital Strategic Plan 

in the Federal Sector 

EEO Portal (FedSep) 

supporting documents 

section. 

42 
 

 

 

 

 

 

 

 

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U.S. Equal Employment Opportunity Commission 

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Compliance 

Indicator 

Measures 

B.4 - The agency has sufficient budget and staffing to support 

the success of its EEO program. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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.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.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 

B.4.a.4 to provide all supervisors and employees with training on the EEO 

Yes 

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. 

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)] 

NA No field offices 

B.4.a.6 to publish and distribute EEO materials (e.g. harassment policies, Yes 

EEO posters, reasonable accommodations procedures)? [see MD715, II(B)] 

B.4.a.7 to maintain accurate data collection and tracking systems for the 

following types of data: complaint tracking, workforce 

Yes 

43 
 

 

 

EEOC FORM 

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demographics, and applicant flow data? [see MD-715, II(E)]. If 

not, please identify the systems with insufficient funding in the 

comments section. 

B.4.a.8 to effectively administer its special emphasis programs (such as, Yes 

Federal Women’s Program, Hispanic Employment Program, and 

People with Disabilities Program)? [5 USC § 7201; 38 USC § 

4214; 5 CFR § 720.204; 5 CFR § 213.3102(t) and (u); 5 CFR § 

315.709] 

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] 

No Currently the AntiHarassment Program 

(AHP) is managed by 

several individuals 

and groups as a 

collateral duty. A full 

analysis and 

examination of AHP 

and its processes and 

resources is planned 

for the next fiscal 

year. Please see Part 

H of this report. 

B.4.a.10 to effectively manage its Reasonable Accommodation Program? 

[see 29 CFR § 1614.203(d)(4)(ii)] 

Yes 

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

[see MD-715, II(E)] 

Yes 

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 

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.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 

44 
 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

B.4.e Does the agency ensure that all experienced counselors and 

investigators, including contractors and collateral duty employees, 

receive the required 8 hours of annual refresher training, pursuant 

to Ch. 2(II)(C) of MD-110? 

Yes 

Compliance 

Indicator 

Measures 

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 

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: 

For these topics, 

training for all new 

supervisors is 

mandatory, and the 

Agency offers training 

on reasonable 

accommodation, antiharassment, and a 

variety of DEIA 

classes. 

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

B.5.a.2 Reasonable Accommodation Procedures? [see 29 C.F.R. § 

1614.102(d)(3)] 

Yes 

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

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 

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 

45 
 

 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures 

B.6 – The agency involves managers in the implementation of 

its EEO program. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Indicator 

B.6.a Are senior managers involved in the implementation of special 

emphasis programs? [see MD-715 Instructions, Sec. I] 

Yes 

B.6.b Do senior managers participate in the barrier analysis process? 

[see MD-715 Instructions, Sec. I] 

Yes 

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 

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 

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. 

Compliance 

Indicator 

Measures 

C.1 – The agency conducts regular internal audits of its 

component and field offices. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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. 

NA no component or field 

offices 

C.1.b Does the agency regularly assess its component and field offices 

on their efforts to remove barriers from the workplace? [see 29 

NA no component or field 

offices 

46 
 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

CFR §1614.102(c)(2)] If “yes”, please provide the schedule for 

conducting audits in the comments section. 

C.1.c Do the component and field offices make reasonable efforts to 

comply with the recommendations of the field audit? [see MD715, II(C)] 

NA no component or field 

offices 

Compliance 

Indicator 

Measures 

C.2 – The agency has established procedures to prevent all 

forms of EEO discrimination. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Indicator 

C.2.a Has the agency established comprehensive anti-harassment 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 

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 

C.2.a.2 Has the agency established a firewall between the AntiHarassment Coordinator and the EEO Director? [see EEOC 

Report, Model EEO Program must have an Effective AntiHarassment Program (2006)] 

Yes 

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 

47 
 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

C.2.a.4 Does the agency ensure that the EEO office informs the antiharassment program of all EEO counseling activity alleging 

harassment? [see Enforcement Guidance, V.C.] 

Yes 

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. 

No A total of 55% were 

completed timely. 

C.2.a.6 Do the agency’s training materials on its anti-harassment policy 

include examples of disability-based harassment? [see 29 CFR 

1614.203(d)(2)] 

Yes 

C.2.b Has the agency established disability reasonable accommodation Yes 

procedures that comply with EEOC’s regulations and guidance? 

[see 29 CFR 1614.203(d)(3)] 

C.2.b.1 Is there a designated agency official or other mechanism in place Yes 

to coordinate or assist with processing requests for disability 

accommodations throughout the agency? [see 29 CFR 

1614.203(d)(3)(D)] 

C.2.b.2 Has the agency established a firewall between the Reasonable Yes 

Accommodation Program Manager and the EEO Director? [see 

MD-110, Ch. 1(IV)(A)] 

C.2.b.3 Does the agency ensure that job applicants can request and receive Yes 

reasonable accommodations during the application and placement 

processes? [see 29 CFR 1614.203(d)(1)(ii)(B)] 

C.2.b.4 Do the reasonable accommodation procedures clearly state that the Yes within 15 days 

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)] 

48 
 

 

 

 

 

 

 

 

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U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

C.2.b.5 Does the agency process all accommodation requests within the 

time frame set forth in its reasonable accommodation procedures? 

[see MD-715, II(C)] If “no”, please provide the percentage of 

timely-processed requests in the comments column. 

Yes average 17.17 

calendar days for 

decisions 

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 

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.dfas.mil/ 

nofearact.html 

Compliance 

Indicator 

Measures 

C.3 - The agency evaluates managers and supervisors on their 

efforts to ensure equal employment opportunity. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Indicator 

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 

C.3.b Does the agency require rating officials to evaluate the 

performance of managers and supervisors based on the following 

activities: 

C.3.b.1 Resolve EEO problems/disagreements/conflicts, including the 

participation in ADR proceedings? [see MD-110, Ch. 3.I] 

Yes 

49 
 

 

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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 

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 

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 

C.3.b.5 Provide religious accommodations when such accommodations do 

not cause an undue hardship? [see 29 CFR §1614.102(a)(7)] 

Yes 

C.3.b.6 Provide disability accommodations when such accommodations 

do not cause an undue hardship? [ see 29 CFR §1614.102(a)(8)] 

Yes 

C.3.b.7 Support the EEO program in identifying and removing barriers to 

equal opportunity. [see MD-715, II(C)] 

Yes 

C.3.b.8 Support the anti-harassment program in investigating and 

correcting harassing conduct. [see Enforcement Guidance, V.C.2] 

Yes 

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 MD-715, II(C)] 

Yes 

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)] 

Yes 

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)] 

Yes 

50 
 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures 

C.4 – The agency ensures effective coordination between its 

EEO and HR programs. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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, instructions, and management directives? [see 29 

CFR §1614.102(a)(2)] 

Yes 

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.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 

C.4.d Does the HR office timely provide the EEO office timely access to 

other data (e.g., exit interview data, climate assessment surveys, 

and grievance data), upon request? [see MD-715, II(C)] 

Yes 

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 

C.4.e.2 Develop and/or conduct outreach and recruiting initiatives? [see 

MD-715, II(C)] 

Yes 

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

[see MD-715, II(C)] 

Yes 

51 
 

 

 

 

 

 

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

workplace? [see MD-715, II(C)] 

Yes 

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

Compliance 

Indicator 

Measures 

C.5 – Following a finding of discrimination, the agency 

explores whether it should take a disciplinary action. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

C.5.a Does the agency have a disciplinary policy and/or table of 

penalties that covers discriminatory conduct? [see 29 CFR § 

1614.102(a)(6); see also Douglas v. Veterans Administration, 5 

MSPR 280 (1981)] 

Yes 

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. 

NA 

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)] 

NA no findings 

Compliance 

Indicator 

Measures 

C.6 – The EEO office advises managers/supervisors on EEO 

matters. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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 

Yes Varies among Agency 

management officials 

from annually to 

quarterly to monthly. 

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U.S. Equal Employment Opportunity Commission 

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identify the frequency of the EEO updates in the comments 

column. 

C.6.b Are EEO officials readily available to answer managers’ and 

supervisors’ questions or concerns? [see MD-715 Instructions, 

Sec. I] 

Yes 

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. 

Compliance 

Indicator 

Measures 

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 

D.1.a Does the agency have a process for identifying triggers in the 

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

Yes 

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; antiharassment program; and/or external special interest groups? [see 

MD-715 Instructions, Sec. I] 

Yes 

D.1.c Does the agency conduct exit interviews or surveys that include Yes 

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)] 

53 
 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures 

D.2 – The agency identifies areas where barriers may exclude 

EEO groups (reasonable basis to act.) 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Indicator 

D.2.a Does the agency have a process for analyzing the identified 

triggers to find possible barriers? [see MD-715, (II)(B)] 

Yes 

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 

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 

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, antiharassment 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 data, 

employee climate 

surveys (FEVS and 

DEOCS) 

Compliance 

Indicator 

Measures 

D.3 – The agency establishes appropriate action plans to 

remove identified barriers. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Indicator 

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 

54 
 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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 MD-715, 

II(D)] 

Yes 

D.3.c Does the agency periodically review the effectiveness of the 

plans? [see MD-715, II(D)] 

Yes 

Compliance 

Indicator 

Measures 

D.4 – The agency has an affirmative action plan for people 

with disabilities, including those with targeted disabilities 

Measure 

Met? 

(Yes/No/NA) 

Comments 

New Indicator 

D.4.a 

Does the agency post its affirmative action plan on its public Yes https://www.dfas.mil/ 

nofearact/ website? [see 29 CFR 1614.203(d)(4)] Please provide the internet 

address in the comments. 

D.4.b 

Does the agency take specific steps to ensure qualified people with Yes 

disabilities are aware of and encouraged to apply for job 

vacancies? [see 29 CFR 1614.203(d)(1)(i)] 

D.4.c 

Does the agency ensure that disability-related questions from Yes 

members of the public are answered promptly and correctly? [see 

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

D.4.d 

Has the agency taken specific steps that are reasonably designed to Yes 

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)] 

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. 

Compliance 

Indicator 

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

complaint resolution process. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

55 
 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Measures 

E.1.a Does the agency timely provide EEO counseling, pursuant to 29 

CFR §1614.105? 

Yes 

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.1.c Does the agency issue acknowledgment letters immediately upon 

receipt of a formal complaint, pursuant to MD-110, Ch. 5(I)? 

Yes 

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. 

Yes In FY22, acceptance 

letters/dismissal 

decisions were 

completed in an 

average of 10 days, a 

decrease of 3 days 

from FY21. 

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 

E.1.f Does the agency timely complete investigations, pursuant to 29 

CFR §1614.108? 

Yes In FY22, the Agency 

further shortened 

complaint and 

investigations 

completion times. 

The average number 

of investigation days 

decreased by 57 days, 

from an average of 

185 days in FY21 to 

128 days in FY22. 

All investigations 

56 
 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

were completed 

within 180 days. The 

18 investigations 

represent 15 less than 

the 33 completed in 

FY21. 

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)? 

Yes 

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)? 

Yes 

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)? 

Yes 

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. 

NA The Agency did not 

use contractors in this 

reporting period, but 

when used, DFAS 

does hold them to 

standards of quality 

through a review of 

work products. 

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 

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)] 

Yes 

57 
 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures 

E.2 – The agency has a neutral EEO process. Measure 

Met? 

(Yes/No/NA) 

Comments 

Revised Indicator 

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 

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. 

Yes Office of General 

Counsel: 

Administrative and 

Employment Law 

Team 

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 MD110, Ch. 1(IV)(D)] 

Yes All legal sufficiency 

reviews are performed 

by a unit separate 

from the Litigation 

Team. 

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.2.e If applicable, are processing time frames incorporated for the legal 

counsel’s sufficiency review for timely processing of complaints? 

[see EEOC Report, Attaining a Model Agency Program: 

Efficiency (Dec. 1, 2004)] 

Yes 

Compliance 

Indicator 

Measures 

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 

58 
 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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.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 

E.3.c Does the agency encourage all employees to use ADR, where 

ADR is appropriate? [see MD-110, Ch. 3(IV)(C)] 

Yes 

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 

E.3.e Does the agency prohibit the responsible management official 

named in the dispute from having settlement authority? [see MD110, Ch. 3(I)] 

Yes 

E.3.f Does the agency annually evaluate the effectiveness of its ADR 

program? [see MD-110, Ch. 3(II)(D)] 

Yes 

Compliance 

Indicator 

Measures 

E.4 – The agency has effective and accurate data collection 

systems in place to evaluate its EEO program. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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

employees? [see 29 CFR §1614.601(a)] 

Yes 

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

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 

59 
 

 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

E.4.a.5 The processing of requests for reasonable accommodation? [29 

CFR § 1614.203(d)(4)] 

Yes 

E.4.a.6 The processing of complaints for the anti-harassment program? 

[see EEOC Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors (1999), § 

V.C.2] 

Yes 

E.4.b Does the agency have a system in place to re-survey the workforce 

on a regular basis? [MD-715 Instructions, Sec. I] 

Yes 

Compliance 

Indicator 

Measures 

E.5 – The agency identifies and disseminates significant trends 

and best practices in its EEO program. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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 The Agency reviews 

complaints metrics on 

a monthly basis and 

that data is reported to 

the Deputy Director, 

Strategy and Support. 

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 The Agency 

participates in DoD 

EEO and DEIA 

related meetings 

where best practices 

are shared. DFAS 

adopts some of those 

practices to enhance 

its programs. 

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 

60 
 

 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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. 

Compliance 

Indicator 

Measures 

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 

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.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 

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

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

Yes 

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)] 

Yes 

Compliance 

Indicator 

Measures 

F.2 – The agency complies with the law, including EEOC 

regulations, management directives, orders, and other written 

instructions. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

Indicator moved 

from E-III Revised 

F.2.a Does the agency timely respond and fully comply with EEOC 

orders? [see 29 CFR §1614.502; MD-715, II(E)] 

Yes 

61 
 

 

 

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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)] 

Yes 

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 

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)] 

Yes 

F.2.a.4 Pursuant to 29 CFR §1614.502, does the agency promptly provide 

EEOC with the required documentation for completing 

compliance? 

Yes 

Compliance 

Indicator 

Measures 

F.3 – The agency reports to EEOC its program efforts and 

accomplishments. 

Measure 

Met? 

(Yes/No/NA) 

Comments 

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 

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 

62 
 

 

 

 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715 – Part H 

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 Brief Description of Program Deficiency Deficiency 

The Director, Office of Equal Opportunity Programs (OEOP) is 

Element B.1.a not a direct report to the Agency Head. 

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) 

9/30/2020 

Ensure compliance with Elijah 

Cummings Act. 9/30/2022 9/30/2023 

Responsible Official(s) 

Title Name 

Performance 

Standards 

Address the 

Plan? 

(Yes or No) 

Director, Office of Equal Opportunity 

Programs 

William Bryson Yes 

63 
 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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) 

09/30/2022 

DFAS continues to review its reporting 

structure. For now, they will continue to 

further strengthen reporting relationship, 

while maintaining benefits of current 

structure. DFAS is a 4th estate Department 

of Defense agency under the Office of the 

Secretary of Defense. The Agency Head 

reports directly to the Office, Under 

Secretary of Defense Comptroller. DFAS 

will follow Departmental direction for 

implementing any required changes IAW 

Elijah Cummings Act and the relevant 

National Defense Authorization Act. 

Yes 9/30/2023 

Report of Accomplishments 

Fiscal Year Accomplishments 

2022 

The EEO Director attends the Agency Head’s weekly staff meeting and meets with 

the Agency Head on a one-on-one basis monthly. They also regularly connect to 

discuss EEO complaints, findings, and final agency decisions. 

64 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715 – Part H 

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 Brief Description of Program Deficiency Deficiency 

The OEOP Director is not a direct report to the Agency Head. EEO 

Element B.1.a.1 director reporting relationship is to the Deputy Director, Strategy and 

Support (DDSS), the same director who leads Human Resources, 

Human Capital, Corporate Communications, Information and 

Technology, and other strategy and enterprise program offices. 

Objective(s) and Dates for EEO Plan 

Date 

Initiated Objective Target 

Date 

Modified 

Date 

Date 

Completed 

10/1/2018 

Ensure the DFAS reporting structure for the 

EEO program provides the principal EEO 

official with independence, resources, and 

appropriate authority to effectively carry out a 

successful EEO program. Ensure work and 

communication with Strategy and Support 

organizations is clear and support is fully 

provided by mission-related programmatic 

partners to not only promote the independence 

of the office but to also assist in all matters 

relevant to enhancing efforts for the Model EEO 

Program. 

Continue to ensure a clear separation of duties 

between EEO and HR to prevent a conflict of 

interest. In addition, the DFAS director will 

continue deliberate approach to releasing 

messages on the importance of EEO and DEIA 

principles. This will ensure employees clearly 

understand her commitment and expectations for 

all leaders and employees. 

Also, importantly, while the senior executive 

9/30/2022 9/30/2022 

65 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

over the EEO office does also have HR as a 

direct report, he is not included in any 

conversations on specific EEO Complaints 

process items. In essence, OEOP has a 

protective “firewall” which limits discussion in 

these areas of the office mission to minimize 

conflict of interest concerns. 

Responsible Official(s) 

Title Name 

Performance 

Standards 

Address the 

Plan? 

(Yes or No) 

Director, Office of Equal Opportunity 

Programs 

William Bryson Yes 

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) 

09/30/2022 

DFAS will follow DoD guidance and 

direction regarding reporting relationship 

for OEOP Director to Agency Head. 

Yes 9/30/2023 

Report of Accomplishments 

Fiscal Year Accomplishments 

• The DFAS structure provides monthly direct and “whenever needed” 

access to the DFAS Director. This provides the principal EEO official 

with appropriate authority. It also provides the Agency Head with a clear 

understanding of EEO factors when making organizational decisions. 

• Coordination and discussion on final agency actions go directly from the 

OEOP Director to the Agency Director, providing a strong level of 

independence. 

• The OEOP Director continues to be a key member of the DFAS formal 

governance body chartered for discussion and vetting of enterprisewide programs, identifying opportunities for improvement, evaluating 

alternatives, assessing risk, and making recommendations for projects, 

priorities, and initiatives. OEOP also briefed EEO/D&I actions/issues 2022 of concern to executives/leaders every month. 

• The reporting structure to the DDSS is providing significant advantages 

and a proactive way to acquire additional resources to augment the 

66 
 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

OEOP staff and effectively carry out and support all facets of a 

successful model EEO program. 

• The DDSS, who provides oversight to other critical mission-related 

programmatic offices, has afforded the opportunity for significant 

collaboration, support, resources, and expertise from other Strategy and 

Support organizations such as Enterprise Management Services (EMS), 

Information and Technology, Human Resources, and Human Capital. 

• Project Management Professionals and Black Belts from EMS have 

provided significant resourcing and support to the OEOP in completing 

numerous EEO and DEIA related projects. 

67 
 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715 – Part H 

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 

Element B.4.a.9 

Pursuant to 29 CFR §1614.102(a)(1), the agency has not allocated 

sufficient funding and qualified staffing to successfully implement 

the EEO program, to effectively manage its anti-harassment 

program. 

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) 

06/01/2022 

To allocate sufficient funding and 

resources (qualified staff) to complete 

harassment inquires in a 10-day 

deadline. 

09/30/2024 

Responsible Official(s) 

Title Name 

Performance 

Standards Address 

the Plan? 

(Yes or No) 

Director, Office of Equal 

Opportunity Programs 

William Bryson Yes 

Director, Human Resources Kathy Hendrickson Yes 

68 
 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

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) 

9/30/2023 Conduct survey aiming to measure 

inefficiencies, gage the causes of delays 

or complexities. 

Yes 

9/30/2023 Continue to train Inquiry Officials on 

their role and responsibilities in the 

harassment investigation process. 

Yes 

9/30/2024 Develop a business case for at least two 

designated full-time inquiry officials. 

Yes 

Report of Accomplishments 

Fiscal Year Accomplishments 

2022 

Formed an anti-harassment working group consisting of GS-14s and 15s, 

including the chiefs of staff, EEO Director, Labor and Employee Relations 

Chief, Agency attorney supporting the Anti-Harassment Program, Deputy 

EEO Director, EEO Complaints Manager, and Dispute Resolution Office 

Director. 

The working group pinned down the causes of the delays (i.e., conflicts of 

interest, inquiry official replacement during the inquiry, complex 

allegations, determining complaints alleging harassment, insufficient 

training, inexperienced inquiry officials, and other causes). 

69 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715 – Part H 

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 

Element 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. 

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) 

9/30/2022 Improve timeliness of harassment case 

processing and investigations. 9/30/2023 

Responsible Official(s) 

Title Name 

Performance 

Standards 

Address the 

Plan? 

(Yes or No) 

Director, Office of Equal Opportunity 

Programs 

William Bryson Yes 

Chief, Labor, Management and 

Employee Relations Policy Office 

Amber Kennedy-Miller 

Yes 

70 
 

 

 

 

 

EEOC Form 

U.S. EEO Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

Planned Activities toward Completion of Objective 

Target Date Planned Activities (mm/dd/yyyy) 

The Agency plans to revise its anti- 9/30/2022 harassment instruction to provide 

clarification and guidance concerning 

these issues. 

The Agency will adjust its Inquiry 

9/30/2022 Official (IO) training on a regular basis 

to address challenges of this nature that 

may come up. 

Develop a working group to discuss 9/30/2022 these issues as they arise. The working 

group will include multiple high-level 

officials at the GS14 and 15 levels 

Sufficient Modified Completion Funding Date Date & (mm/dd/yyyy) (mm/dd/yyyy) 

Staffing? 

(Yes or No) 

Yes 9/30/2023 

Yes 9/30/2023 

Yes 9/30/2023 

Report of Accomplishments 

Fiscal Year Accomplishments 

2022 

In FY22, the Agency successfully met the 10-day deadline to initiate an inquiry 

into allegations of harassment in 65% of the cases. This is largely due to the 

fact that some allegations are not, in fact, allegations of harassment, even 

though they are labeled as such. Therefore, in some cases, it took the Agency 

longer than 10 days before deciding to conduct an inquiry into some allegations. 

Another reason is when the alleged victim claimed that they do not want an 

inquiry into their allegation, thus, creating confusion. 

71 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 

Accommodations 

in Virtual 

Platforms 

462 Report There are areas of concern addressed regarding accommodations 

in virtual platform settings. 

EEO Group(s) Affected by Trigger 

EEO Group 

All Men 

All Women 

Hispanic or Latino Males 

Hispanic or Latino Females 

White Males 

White Females 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

Native Hawaiian or Other Pacific Islander 

Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

Two or More Races Females 

72 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  

 

Individuals with Disabilities X 

Individuals with Targeted Disabilities X 

Barrier Analysis Process 

Sources of Data 

Source 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables No 

Complaint Data (Trends) Yes 462 Report 

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) Yes 

Customers were confused about host responsibilities 

when obtaining accommodation needs for individuals 

during virtual events. 

Status of Barrier Analysis Process 

Barrier Analysis Process Completed? 

(Yes or No) 

Barrier(s) Identified? 

(Yes or No) 

Yes Yes 

73 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Statement of Identified Barrier(s) 

Description of Policy, Procedure, or Practice 

No procedure exists to ensure employees’ accommodation needs are considered prior to hosting a 

virtual event within the Agency. Individuals can make reasonable accommodation requests for 

virtual events, but hosts may not be aware of procedures to get accommodations for their event. 

Objective(s) and Dates for EEO Plan 

Objective 

Date 

Initiated 

(mm/dd/yyyy) 

Target 

Date 

(mm/dd/yyyy) 

Sufficient 

Funding & 

Staffing? 

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

Educate the workforce on the 

procedure for hosting virtual 

events to make them more 

accessible (to include, but not 

limited to closed captioning, 

requesting a live sign 

language interpreter, or 

making slides 508 compliant). 

1/15/2022 9/30/2022 Yes 4/19/2022 

Responsible Official(s) 

Title Name 

Performance Standards 

Address the Plan? 

(Yes or No) 

Disability Employment Program 

Manager (DEPM) 

Lauren A. Aggen Yes 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

1/15/2022 The DEPM will publish an article within DFAS detailing 

options for hosting virtual events. This article will 

have a list of POCs for accommodation requests to 

include captioning or making PowerPoint slides 

508 compliant. 

4/19/2022 4/19/2022 

74 
 

 

 

 

 

 

 

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

1/15/2022 

The DEPM will add details on hosting virtual 

events during future reasonable 

accommodation trainings to supervisors. 

9/30/2023 

9/01/2022 

The DFAS Advocacy PWD ERG will develop 

an information sheet for all supervisors 

regarding accommodation matters for virtual 

platforms. 

4/19/2022 

Report of Accomplishments 

Fiscal Year Accomplishments 

FY22 An article on accessibility in virtual platforms was published for the 

workforce to include supervisors on 4/19/2022. 

75 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 

SelfIdentification B1 

Self-Identification of Disability – A total of 682 employees did not 

self-identify their disability. The percentage of those who did not 

self-identify increased from FY21 to FY22 by 0.22%. 

EEO Group(s) Affected by Trigger 

EEO Group 

All Men 

All Women 

Hispanic or Latino Males 

Hispanic or Latino Females 

White Males 

White Females 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

Native Hawaiian or Other Pacific Islander Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

76 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  

 

 

 

 

 

EEO Group 

Two or More Races Females 

Individuals with Disabilities X 

Individuals with Targeted Disabilities X 

Barrier Analysis Process 

Sources of Data 

Source 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes Table B1 

Complaint Data (Trends) No 

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) 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) 

Description of Policy, Procedure, or Practice 

Some employees with disabilities do not see a benefit in self-reporting a disability. This appears to 

be an attitudinal barrier. There is also confusion that MyBiz+ only allows self-identification of one 

disability but not more. Therefore, people who have multiple disabilities are not sure how to 

respond to the prompt. 

77 
 

 

 

 

 

 

 

 

 

 

Objective(s) and Dates for EEO Plan 

Objective 

Date 

Initiated 

(mm/dd/yyyy) 

Target 

Date 

(mm/dd/yyyy) 

Sufficient 

Funding & 

Staffing? 

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

The DEPM will send mass 

emails to the workforce 

regarding the importance of 

self-identification of 

disabilities. 

9/01/2021 9/30/2022 9/30/2023 

Responsible Official(s) 

Title Name 

Performance Standards 

Address the Plan? 

(Yes or No) 

Disability Employment Program 

Manager 

Lauren A. Aggen Yes 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

9/01/2022 The DEPM will publish an article to the 

workforce regarding the benefits of selfidentification. 

9/30/2023 

Report of Accomplishments 

Fiscal Year Accomplishments 

FY22 

The DEPM sent a mass e-mail to the workforce on self-identification. 

There was also information on how to self-identify a disability under 

MyBiz+ during monthly Reasonable Accommodation Training to 

supervisors. 

78 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 

Lower-thanLower-than-expected participation rate of Hispanics and 

Asians in Workforce 

There continues to be low participation rates of Hispanic 

and Asian males and females in the DFAS workforce. 

Hispanic males and females fell below the NCLF 

benchmark by 5.51%, and 4.65%, respectively. Asian 

males and females also fell below the NCLF benchmark 

expected 

participation A1, by 0.92% and 0.64%, respectively. 

rate of 

Hispanics and 

Asians in 

Workforce, 

MissionCritical 

Occupations 

and High rate 

of separations 

A4, 

A6 Lower-than-expected participation rate of Hispanics and 

Asians males and females in Mission-Critical Occupations 

Hispanic and Asian male and female participation rates 

were lower-than-expected when compared to the OCLF 

in all five mission-critical occupational series: 0201 

(Human Resources), 0501 (Financial Administration), 

0510 

(Accounting), 0511 (Auditing), and 2210 (Information 

Technology). 

High rate of separation compared to new hire and 

participation rates for Hispanic and Asian males and 

females 

While the participation rate of Hispanic males and females 

in the total workforce falls below their availability, their rate 

of voluntary separation continues to be high. 

EEO Group(s) Affected by Trigger 

EEO Group 

All Men 

All Women 

Hispanic or Latino Males 

72 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Hispanic or Latino Females 

White Males 

White Females 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

Native Hawaiian or Other Pacific Islander 

Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

Two or More Races Females 

Individuals with Disabilities X 

Individuals with Targeted Disabilities X 

73 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Barrier Analysis Process 

Sources of Data 

Source 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes 

The Agency reviewed Tables A1, A4, and A6 to 

examine the participation of Hispanics and 

Asians in the workforce and in mission-critical 

occupations by grade level, and to examine rates 

of entry and separation to assess progress. 

Complaint Data (Trends) No 

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) Yes 

Hispanic Representation in the Department of 

Defense Civilian Workforce: Trend and Barrier 

Analysis, Santa Monica, Calif.: RAND Corp., RR1699-OSD, 2017. As of January 16, 2018: 

https://www.rand.org/pubs/researchreports/RR1699.html 

EEOC’s Report on Hispanic Employment Challenge 

in the Federal Government (October 2008). 

Other (Please Describe) Yes 

 Prior MD-715 Reports 

 FEORP and DVAAP Reports 

Root Cause Analysis Tree 

Status of Barrier Analysis Process 

Barrier Analysis Process 

Completed? 

(Yes or No) 

Barrier(s) 

Identified? 

(Yes or No) 

Yes Yes (2015) 

74 
 

 

 

 

 

 

 

 

 

 

 

 

 

Statement of Identified Barrier(s) 

Description of Policy, Procedure, or Practice 

The Agency EEO Plan was initiated based on the triggers identified and barrier analysis 

conducted as reported in prior year MD-715 assessments, and it spans multiple reporting periods. 

Also, as noted in the summary of accomplishments, in FY22 the HABIT continued executing 

portions of their structured outreach and recruitment plan. Remaining planned activities, related 

to Hispanic and Asian population engagement and retention of the Hispanic and Asian workforce, 

continue to be valid and will be carried over into ensuing years with modifications, as appropriate, 

to reflect changes needed based on what is learned during follow-up analysis. 

Objective 

Date Initiated 

(mm/dd/yyyy) 

Target

Date 

(mm/dd/yyyy) 

Sufficient 

Funding 

& 

Staffing? 

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

Implement strategies to 

recruit, hire, and retain 

Hispanics and Asians to 

increase their participation 

rate in the DFAS workforce 

and mission-critical 

occupations. 

02/01/2021 9/30/2022 Yes 9/30/2023 

Responsible Officials 

Title Name 

Performance 

Standards Address the 

Plan? 

(Yes or No) 

Director, OEOP William Bryson Y 

Deputy Director, OEOP Cynthia Ice-Bones Y 

Diversity and Inclusion 

Program Manager 

Michelle Lugo Y 

Director, Human Resources Kathy Hendrickson Y 

Director, Human Capital Shante Jones Y 

75 
 

 

 

 

 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) 

Planned Activities Modified Date Completion Date 

(mm/dd/yyyy) 

9/30/2021 Develop and implement a formal outreach 

and recruitment plan to increase 

participation of Hispanics and Asians in 

mission-critical occupations and technician 

levels 

9/30/2023 

9/30/2022 Monitor and analyze applicant flow data of 

Agency’s mission-critical occupations 

9/30/2023 

9/30/2023 Conduct additional barrier analysis 

9/30/2023 Develop a strategic plan to enhance retention 

of the targeted population in the workforce 

9/30/2023 Add a diversity and inclusion 

statement in job announcements 

76 
 

 

 

 

 

 

Report of Accomplishments 

Fiscal Year Accomplishments 

2022 

In FY22, HABIT continued to partner with internal stakeholders 

to develop a strategic recruitment and outreach plan designed to 

target Hispanic and Asian populations. The team analyzed 

Applicant Flow Data, provided Human Resources a list of 

recommended educational institutions and H&A affinity 

organizations to include in their yearly recruitment plan, 

developed and provided outreach presentations in Spanish and 

English to better reach the targeted populations and also 

translated Agency recruitment materials to Spanish to reach out 

to Hispanic applicants and promote a more inclusive 

environment. HABIT also published a Daily Business Journal 

(DBJ) article for the workforce to show the diversity of 

Hispanics, their professional journey and how they feel included 

at DFAS. 

The Agency continued to post direct-hire authority job 

announcements on the one-grade interval series positions to open 

additional recruitment opportunities and expand the applicant 

pool. 

In FY22, there was a slight increase in Hispanic male and female 

participation from 1.27% and 1.48% in FY21 to 1.31% and 

1.51% in FY22, respectively. 

77 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 

Awards and 

recognition 

disparities 

by RNO. 

Lower-than-expected dollar amount received in Cash 

Awards of 501+ compared to White males and females. 

This award category is primarily performance-based and 

calculated using a percentage of base pay. Black males and 

females have comparatively lower participation in highergraded positions than White males and females and as such 

have lower base pay as compared to White males and 

females, who occupy more positions at higher grade levels 

and therefore receive higher award amounts. There is a 

disparity in award amounts by race in some of the missioncritical occupations. 

EEO Group(s) Affected by Trigger 

EEO 

Group 

All Men 

All Women 

Hispanic or Latino Males 

Hispanic or Latino Females 

White Males 

White Females 

Black or African American Males X 

Black or African American Females X 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

78 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Native Hawaiian or Other Pacific Islander Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

Two or More Races Females 

Barrier Analysis Process 

Sources of Data 

Source 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes The Agency reviewed Tables A1, A3, A4, A6, 

A8, and A9 to examine the participation of 

Black males and females in the workforce and 

in mission-critical occupations by grade level as 

well as their participation in the Awards 

Program. 

Complaint Data (Trends) No 

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 Yes DFAS recognized the need for 

enhancement of exit interview data 

upon further review. 

Focus Groups Yes FY18 

Interviews Yes Surveys completed in 2020 

Reports (e.g., Congress, 

EEOC, MSPB, GAO, OPM). Yes Applicant Data 

Other (Please Describe) Yes 

Prior year MD-715 reports and review of 

demographic information 

79 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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) 

Description of Policy, Procedure, or Practice 

DFAS identified barriers to senior grade levels (GS-12 to SES) based on an analysis of 

workforce data, and anecdotal data received from focus groups and interviews with Black 

males and females. 

As of FY22, DFAS has not yet identified a specific policy, procedure or practice that has 

been determined to be a barrier or cause for Black males and females receiving cash 

awards at the same rates as other RNOs. However, the triggers identified will be

examined further to identify the specificity of the disparity between grades. It is possible 

existing grade-related barriers may represent a probable root cause as opposed to a 

primary issue. Because rating-based awards are often partially calculated based on 

employee salary, the grade distribution within race, ethnicity and gender may play a 

significant role in the average award amount. Additional analysis and plans regarding the 

granting of awards at less-than-expected rates will focus on these factors in FY23. 

Objective(s) and Dates for EEO Plan 

Objective 

Date 

Initiated 

(mm/dd/yyyy) 

Target 

Date 

(mm/dd/yyyy) 

Sufficient 

Funding & 

Staffing? 

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed

(mm/dd/yyyy) 

Analyze workforce data and 

remove barriers for Black 

males and females related to 

awards and its disparities by 

RNO. 

12/20/2022 9/30/2024 Yes 

Responsible Official(s) 

Title Name 

Performance 

Standards Address 

the Plan? 

(Yes or No) 

Director, OEOP William Bryson Yes 

Deputy Director, OEOP Cynthia Ice-Bones Yes 

80 
 

 

 

 

 

 

 

Diversity and Inclusion 

Program Manager 

Michelle Lugo Yes 

Director, Human Resources Kathy Hendrickson Yes 

Director, Human Capital Shante Jones Yes 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) 

Planned Activities 

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

9/30/2023 Further analyze workforce data related to 

disparity in Black male and female 

awards. 

9/30/2024 Develop action plans to address barriers 

identified. 

Report of Accomplishments 

Fiscal 

Year 

Accomplishments 

2022 N/A 

81 
 

 

 

 

 

 

 

 

 

 

 

 

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 

Lower-than-expected participation rate in nonsupervisory and managerial GS-13 to GS-15 

positions. 

In FY22, females comprised 58.9% of the DFAS workforce. 

While 62.83% of the supervisory workforce are female, the 

proportion of female managers and executives are at 45.4% and 

47.2%, respectively. The pipeline to senior positions in the 

Agency (SES and GS-15) has not seen significant change since 

FY20. The proportion of GS-15 positions occupied by females 

Workforce A1, A4, decreased from 45.9% in FY21 to 44.8%, while males 

Data A6, comprised 55.2%. In GS-14 positions, females comprised 

Tables A7, A8 40.9%, as compared to males that comprised 59.1% In GS-13 

positions, females comprised 46.6%, as compared to males that 

comprised 53.4%. 

Lower-than-expected dollar amount received in Cash 

Awards of 501+ compared to males. 

The awards category at issue is performance based and 

calculated by percentage of base pay. In FY22, male 

employees received higher award amounts than female 

employees, in the 0510 occupational series. In the 0201, 0501, 

0511 and 2210 series, there was no significant difference in 

award amounts between males and females. 

EEO Group(s) Affected by Trigger 

EEO Group 

All Men 

All Women X 

Hispanic or Latino Males 

Hispanic or Latino Females 

White Males 

White Females 

82 
 

 

 

 

 

 

 

 

 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

Native Hawaiian or Other Pacific Islander Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

Two or More Races Females 

Barrier Analysis Process 

Sources of Data Source Reviewed? 

(Yes or No) Identify Information Collected 

Workforce Data Tables Yes 

The Agency reviewed Tables A1, A4, A6, 

A7, and A8 to examine the participation of 

females and their participation rates in the 

workforce and in mission-critical 

occupations by grade level as well as their 

participation in the Awards Program. 

Complaint Data 

(Trends) 

No 

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) 

Yes EEOC Women’s Working Group Report 

(Dec 2013) 

Other (Please Describe) Yes Prior MD-715 reports 

83 
 

 

 

 

 

 

 

 

 

Status of Barrier Analysis Process 

Barrier Analysis Process 

Completed?

(Yes or No) 

Barrier(s) Identified? 

(Yes or No) 

No No (further analysis pending) 

Statement of Identified Barrier(s) 

Description of Policy, Procedure, or Practice 

DFAS has not yet identified the specific policy, procedure, or practice determined to be the 

barrier or cause of lower-than-expected representation of females in non-supervisory and 

managerial GS-13 to GS-15 level positions. 

Objective(s) and Dates for EEO Plan 

Objective 

Date Initiated 

(mm/dd/yyyy) 

Target Date 

(mm/dd/yyyy) 

Sufficient 

Funding 

& 

Staffing? 

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

The Agency will 

identify priorities 

for development 

of solutions and 

interventions and 

will establish 

them through the 

barrier analysis 

process. 

1/29/2016 9/30/2018 Yes 9/30/2023 

84 
 

 

 

 

 

 

 

 

 

 

 

 

Responsible Official(s) 

Title Name 

Performance 

Standards Address 

the Plan? 

(Yes or No) 

Director, OEOP William Bryson Yes 

Deputy Director, OEOP Cynthia Ice-Bones Yes 

Diversity and Inclusion 

Program Manager 

Michelle Lugo Yes 

Director, Human Resources Kathy Hendrickson Yes 

Director, Human Capital Shante Jones Yes 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities 

Modified 

Date 

(mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

9/30/2021 

Address Merit Promotion and Professional 

Development elements to enhance 

diversity. DFAS leadership, OEOP, and 

Human Resources will partner to seek 

opportunities and encourage panel member 

diversity as a part of the existing interview 

and selection process for promotion and 

professional development (especially 

important for GS-13 and up positions). 

The Agency is also considering further 

review to strengthen transparency of 

communication and enhance applicant/ 

selecting official feedback opportunities. 

9/30/2023 

9/30/2022 

Barrier Analysis Implementation Plan: 

• Provide enhanced guidance and 

support to panel members and 

selecting officials on diversity 

in selection process. 

• Provide supervisors integrated toolkits 

to gain access to expanded recruiting 

pools. 

• Provide guidance to supervisors on 

biases, reprisal and discrimination that 

may affect the decision making process. 

9/30/2023 

85 
 

 

 

 

 

 

Report of Accomplishments 

Fiscal 

Year 

Accomplishments 

2022 

In FY22, senior leaders led and championed initiatives like the 

Grow-Mission Integrated Diversity, which focused on creating and 

identifying actionable goals focused on mentoring and networking, 

equity in professional development, diversity in merit promotion, 

and communication (internal and external). 

In FY22, GMID HR partners developed a supervisor tool kit 

explaining hiring strategies and authority, and deploy a mentoring 

module within the Success Factors. 

GMID also matched 100% of GS-14 succession cycle participants with 

a mentor, provided mentorship trainings to more than 230 attendees 

and 30 mentors and established documented and collaborative 

approach with process partners to generate, analyze and deliver 

accurate reporting to senior leaders. 

The Agency is also developing a dashboard that will simplify 

workforce data analysis and will assist in identifying triggers, and 

barriers in order to address them promptly. 

In FY22, OEOP provided training to supervisors, leaders, and HR 

Specialists on Inclusive Leadership: Understanding Unconscious 

Bias, Diversity of Thought: Fostering an Inclusive Environment, and 

Avoiding Reprisal. 

86 
 

 

 

 

 

 

 

 

 

 

 

 

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 

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

box. 

Source of the Trigger Specific Workforce Data Table Narrative Description of Trigger 

Lack of new hires in the 0511 

occupational series for PWD and 

PWTD. Also, trigger existed for 

PWD in the 0510 occupational 

series. 

B Tables 

The application rate for PWD 

and PWTD fell below the 12% 

and 2% recruitment goal for 

mission-critical occupation 

series of 0511 and for 0510 

for PWD. 

EEO Group(s) Affected by Trigger 

EEO Group 

All Men 

All Women X 

Hispanic or Latino Males 

Hispanic or Latino Females 

White Males 

White Females 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

Native Hawaiian or Other Pacific Islander Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

Two or More Races Females 

Individuals with Disabilities X 

Individuals with Targeted Disabilities X 

87 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Barrier Analysis Process 

Sources of Data 

Source 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes B Tables for Mission Critical Occupations 

Complaint Data (Trends) No 

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) No 

Status of Barrier Analysis Process 

Barrier Analysis Process Completed? (Yes or No) Barrier(s) Identified? 

(Yes or No) 

No Yes 

Statement of Identified Barrier(s) 

Description of Policy, Procedure, or Practice 

No procedure exists to ensure that the hiring and recruitment of PWD a PWTD exceed the DoD 

goal for the 0510 and 0511 occupational series. 

Objective(s) and Dates for EEO Plan 

Objective 

Date 

Initiated 

(mm/dd/yyyy) 

Target Date 

(mm/dd/yyyy) 

Sufficient 

Funding & 

Staffing?

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

Monitor DFAS data to keep 

track of how many PWD and 

PWTD are hired for series 0201 

and 0511. Advise HR they can 

ask the DEPM to provide 

Schedule-A resumes. 

12/20/2022 9/30/2023 Yes 

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Objective(s) and Dates for EEO Plan 

Objective 

Date 

Initiated 

(mm/dd/yyyy) 

Target Date 

(mm/dd/yyyy) 

Sufficient 

Funding & 

Staffing?

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

Monitor DFAS data to keep 

track of how many PWD and 

PWTD are hired for series 0201 

and 0511. Advise HR they can 

ask the DEPM to provide 

Schedule-A resumes. 

12/20/2022 9/30/2023 Yes 

Responsible Official(s) 

Title Name 

Performance Standards 

Address the Plan? 

(Yes or No) 

Disability Employment Program 

Manager 

Lauren A. Aggen Yes 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

9/30/2022 The DEPM will continue to meet with HR to 

discuss PWD and PWTD recruitment data and 

identify barriers. 

9/30/2022 

9/30/2022 

OEOP will advise HR they can ask the DEPM to 

provide Schedule-A resumes. For 0201 and 

0511 positions, we will endeavor to train these 

departments on the use of the Schedule-A hiring 

authority, and we will advise them they can ask 

the DEPM for resumes from the Schedule-A 

database when they have a vacancy. We will 

educate these departments they can request 

Schedule-A resumes and add them to the pool of 

applicants for further evaluation and interviews. 

We will also educate these departments that 

obtaining Schedule-A resumes does not mean 

they must select a candidate without conducting 

interviews and a resume evaluation. 

9/30/2022 

9/30/2022 OEOP and HR will deploy the DFAS dashboard to 

simplify the data analysis. 

9/30/2023 

9/30/2023 The DEPM will review and analyze the dashboard 

data and recommend actions. 

Report of Accomplishments 

Fiscal Year Accomplishments 

FY22 The DEPM met with HR to go over the dashboard along with information 

pertaining to Schedule-A. 

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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. 

box. 

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

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

Source of the Trigger Specific Workforce Data Table Narrative Description of 

Trigger 

There is a lack of PWD and 

PWTD at higher grades and 

PWD/PWTD don’t get as many 

cash awards as compared to 

those with no disability. 

B Tables 

Triggers exist for PWD and/or 

PWTD for internal selections 

for promotion to senior grade 

levels and new hires to the 

senior grade levels. Triggers 

exist for PWD and PWTD in 

cash awards under $500 and 

$501 - $5,000. 

EEO Group(s) Affected by Trigger 

EEO Group 

All Men 

All Women 

Hispanic or Latino Males 

Hispanic or Latino Females 

White Males 

White Females 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Native Hawaiian or Other Pacific Islander Males 

Native Hawaiian or Other Pacific Islander 

Females 

American Indian or Alaska Native Males 

American Indian or Alaska Native Females 

Two or More Races Males 

Two or More Races Females 

Individuals with Disabilities X 

Individuals with Targeted Disabilities X 

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Barrier Analysis Process 

Sources of Data 

Source 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes B Tables 

Complaint Data (Trends) No 

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) No 

Status of Barrier Analysis Process 

Barrier Analysis Process Completed? Barrier(s) Identified? 

(Yes or No) (Yes or No) 

No Yes 

Statement of Identified Barrier(s) 

Description of Policy, Procedure, or Practice 

Amount of cash awards are tied to employees’ grade levels. The award issue and employees with 

disabilities at the senior leadership level are intertwined. To resolve this issue, we will be advocating 

for the Agency to create a mentorship program, mentoring individuals with disabilities at the GS-13 

level and above on how to apply for and get selected for senior level positions. 

Objective(s) and Dates for EEO Plan 

Objective 

Date 

Initiated 

(mm/dd/yyyy) 

Target 

Date 

(mm/dd/yyyy) 

Sufficient 

Funding & 

Staffing?

(Yes or No) 

Modified 

Date 

(mm/dd/yyyy) 

Date 

Completed 

(mm/dd/yyyy) 

We will be advocating for the 

Agency to create a mentorship 

program, mentoring individuals 

with disabilities at the GS-13 

level and above on how to apply 

for and get selected for senior 

level positions. We will also 

educate senior leadership on the 

use of the Schedule-A hiring 

authority to select managers at 

the GS-13 level and above. 

1/15/2022 9/30/2023 Yes 

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Responsible Official(s) 

Title Name 

Performance Standards 

Address the Plan? 

(Yes or No) 

Disability Employment Program 

Manager 

Lauren A. Aggen Yes 

Planned Activities toward Completion of Objective 

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy) 

Completion 

Date 

(mm/dd/yyyy) 

9/30/2023 

The Disabilities ERG will host a workshop 

with a guest speaker who will speak about the 

importance of having a mentor. A senior leader 

will also speak at the workshop on mentoring. 

9/30/2023 The DEPM will provide briefings to site directors 

about promoting and hiring PWD/PWTD at 

higher grade levels by using Schedule-A. 

Report of Accomplishments 

Fiscal Year Accomplishments 

FY22 Recruited a guest speaker to present at DFAS in March 2023 pertaining to 

the importance of mentorship and disability inclusion. 

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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. 

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 0 No X 

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 

2. Describe how the agency has communicated the numerical goals to the hiring managers 

and/or recruiters. 

The numerical goals are communicated in variety of ways, from various leadership briefings to 

the Agency SES team to new supervisors during new supervisory training. On a one-to-one 

basis, the DEPM briefed supervisors regarding goals and opportunities. The DEPM also 

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informed and counseled recruiters on goals and procedures to facilitate hiring of PWD/PWTD. 

The DEPM sent an email message to the entire DFAS workforce that communicated the 3% 

PWTD inclusion goal and asked that employees verify their disability status in their personnel 

file. Step-by-step directions how to verify disability status in MyBiz+. 

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 

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 

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 

Full (Name, Title, Office, Email) 

Time 

Part 

Time 

Collateral 

Duty 

Processing applications from 

PWD and PWTD 

1 Kara Board, HR Specialist, HR 

Shared Services, 

kara.m.board.civ@mail.mil 

Answering questions from the 

public about hiring authorities 

that take disability into account 

1 Lauren A. Aggen, Disability 

Employment Program Manager, 

Office of Equal Opportunity 

Programs, 

lauren.a.aggen.civ@mail.mil 

Processing reasonable 

accommodation requests from 

applicants and employees 

1 Connie Hoeferkamp, Labor and 

Employee Relations Specialist, 

HR Shared Services, 

connie.s.hoeferkamp.civ@mail.mil 

Section 508 Compliance 1 Jaye Miller, DFAS Section 508 

Coordinator, Information and 

Technology, 

jaye.p.miller.civ@mail.mil 

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Architectural Barriers Act 

Compliance 

1 Lauren A. Aggen, Disability 

Employment Program Manager, 

Office of Equal Opportunity 

Programs, 

lauren.a.aggen.civ@mail.mil 

Special Emphasis Program for 

PWD and PWTD 

5 Cynthia Ice-Bones, Deputy 

Director, Office of Equal 

Opportunity Programs, 

cynthia.g.ice-bones.civ@mail.mil 

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 

EEOC Workshop: Employer Challenges and Pitfalls with the ADA, EEOC Workshop: The Great 

Resignation: Why Are Workers Quitting Their Jobs?, Federally Employed Women Conference, 

PDF Accessibility Training, Computer Electronic Accommodations Program Training, EEOC 

Workshop: Creating Equity in the Workplace: LGBTQI+ Discussion with the EEOC 

B. Plan to Ensure Sufficient Funding for the Disability Program 

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 

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 

Describe the programs and resources the agency uses to identify job applicants with disabilities, 

including individuals with targeted disabilities. 

DFAS participates in the WRP and provides recruiters to conduct interviews with students. 

DFAS hired eleven WRP candidates for a summer internship in 2022. In addition, three WRP 

interns from FY21 had their internship extended into FY22. A total of five WRP interns 

accepted a permanent position within DFAS. The DEPM provided an overview about best 

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practices at the WRP forum in July 2022. DFAS was recognized as outstanding mid-component 

within DoD supporting WRP efforts in 2022. 

DFAS established the Hire a Hero Program because the Agency is committed to providing 

employment opportunities for men and women who have honorably served in the U.S. Armed 

Forces. To support this commitment, DFAS uses an applicant supply file that includes 10-point 

veteran’s preference eligible applicants. After a preliminary qualification determination is made, 

the Agency places applicants in this file as a match for all DFAS specialties and grades for which 

they are likely qualified. As vacancies occur in these specialties and grades, we can use this file 

and these possible matches as a means of recruitment using streamlined hiring authorities. 

DFAS has also established an applicant supply file for Schedule-A eligible applicants. After a 

preliminary qualification determination is made, the Agency places applicants in this file as a 

match for all DFAS specialties and grades for which they are likely qualified. As vacancies 

occur in these specialties and grades, we can use this file and these possible matches as a means 

of recruitment using streamlined hiring authorities. 

DFAS representatives (including the DEPM) participated in virtual career fairs. The Agency 

hosted personal chat rooms to connect virtually with candidates. 

In FY22, DFAS attended to several virtual recruiting events: 

DFAS representatives (including the DEPM) participated in virtual career fairs. The Agency 

hosted personal chat rooms to connect virtually with candidates. An RIT/NTID Career Fair was 

held on October 6, 2021 where the DPM interviewed 13 candidates. A Bender Virtual Career 

Fair took place on November 16, 2021 and there was 1018 participants. At the Gallaudet Career 

Fair on February 23, 2022, the DPM interviewed 3 candidates. On March 3, 2022 there was 285 

participants at the State of Indiana Collegiate Talent Search Virtual Career fair. On March 16, 

2022 the Diversity and Inclusion Virtual Career Fair was held where there was 1474 participants. 

The Bender Virtual Career Fair on April 13, 2022 had 1180 participants. DPM interviewed a 

few candidates at the Institute of Management Accountants (IMA) Career Fair on September 9, 

2022. On September 13, 2022 the DPM interviewed a few candidates during the Indiana 

University- Bloomington Career Fair. There were 689 participants at the Diversity and Inclusion 

Virtual Career Fair on September 22, 2022. 

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. 

DFAS participates in the WRP and provides recruiters to conduct interviews with students. The 

Agency hired 11 WRP interns in 2022 and hired five WRP candidates for a full-time position. 

Additionally, DFAS established a project team consisting of members from OEOP, HR, and 

Human Capital to increase WRP hiring. The project team conducted outreach and provided 

informational meetings to key site staff to encourage hiring via WRP. The project team also 

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conducted searches of the WRP database and provided resumes to site staff with the resumes of 

highly qualified candidates appropriate to supervisors needs for consideration. 

DFAS established the Hire a Hero Program because the Agency is committed to providing 

employment opportunities for men and women who have honorably served in the U.S. Armed 

Forces. To support this commitment, DFAS uses an applicant supply file that includes 10-point 

veteran’s preference eligible applicants. After a preliminary qualification determination is made, 

the Agency places applicants in this file as a match for all DFAS specialties and grades for which 

they are likely qualified. As vacancies occur in these specialties and grades, we can use this file 

and these possible matches as a means of recruitment using streamlined hiring authorities. 

DFAS has also established an applicant supply file for Schedule A eligible applicants. As with 

the Hire a Hero Program, after a preliminary qualification determination is made, we place 

applicants in this file as a match for all our specialties and grades for which they are likely 

qualified. As vacancies occur in these specialties and grades, we use this file and these possible 

matches as a means of recruitment to streamline hiring. 

DFAS also participates in the bi-annual “Bender Virtual Career Fair” for people with disabilities. 

DFAS hosts personal chat rooms to connect virtually with candidates. Agency representatives 

chat with many potential candidates during this career fair. 

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 and when the individual may be appointed. 

HR Staffing performs a preliminary qualification review. Eligibility documentation (e.g., 

Schedule-A) is also reviewed. Applicants are then placed in an applicant supply file as potential 

matches for all the specialties (series) and grades for which they are likely qualified. 

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 

The DEPM incorporated Schedule-A information during the monthly Reasonable 

Accommodation Training for supervisors. The DEPM also deployed online mandatory training 

for hiring managers to take on special hiring authorities for people with disabilities that includes 

information on Schedule-A. 

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B. Plan to Establish Contacts with Disability Employment Organizations 

Describe the agency’s efforts to establish and maintain contacts with organizations that assist 

PWD, including PWTD, in securing and maintaining employment. 

We maintain contact information with the Social Security Administration for the Ticket toWork Program; State Vocational Rehabilitation Agencies and State Disability Service Agencies; 

the Department of Labor’s Veterans’ Employment and Training; and Veteran’s Administration 

Vocational Rehabilitation and Employment Service. 

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 X No 0 

b. New Hires for Permanent Workforce (PWTD) Yes X No 0 

New hires of PWD were 6.99% of all new appointments in FY22. New hires of PWTD were 

1.88% of all new appointments in FY22. 

2. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or 

PWTD among the new hires for any of the mission-critical occupations (MCO)? If 

“yes”, please describe the triggers below. 

a. New Hires for MCO (PWD) Yes X No 0 

b. New Hires for MCO (PWTD) Yes X No 0 

A trigger exists for PWD for new hires in the mission-critical occupation of 0510 and 0511. 

A trigger exists for PWTD for new hires in the mission-critical occupation of 0511. 

3. 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 mission-critical 

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 

Triggers exist for PWD in the mission-critical occupations of 0501 and 0510. 

A trigger exists for PWTD in the mission-critical occupations of 0501and 0510. 

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4. 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 0 No X 

Triggers exist for promotions of PWD in the mission-critical occupations 2210. 

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 

Describe the agency’s plan to ensure PWD, including PWTD, have sufficient opportunities for 

advancement. 

The DFAS Succession program is intended to safeguard the DFAS mission, building leadership 

continuity and talent from within the Agency. This is accomplished with an annual review of 

leadership talent through an assessment of leadership competencies, work experience, 

performance, and professional credentials. The program is now open to all GS-12 supervisors 

and all GS-13 and above employees. The DFAS Mentoring Program provides career broadening 

opportunities that are available to employees. 

B. Career Development Opportunities 

Please describe the career development opportunities that the agency provides to its employees. 

The Agency’s primary career development program is the DFAS Career Acclimation 

Program (DCAP). DCAP is a two-year formal developmental training program for nonsupervisory, entry-level personnel into professional and analytical positions typically targeted to 

GS-9 or GS-11. 

The program completion date ends two years from the entry date in the program. Participants 

are expected to complete the mandatory program requirements within this two-year period. In 

rare circumstances, if course work and assignments are not completed within two years, the 

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participant will be granted an extension until their program is successfully completed. 

The goal of this program is to enhance technical skills, broaden Agency and organizational 

awareness, and develop process improvement skills to make mission area improvements by 

focusing development on learning the job and gaining exposure to related processes and 

functions. 

DFAS also offers the Aspiring Leader Program (ALP). The ALP is as a 2-year, cohort-based 

program that develops critical leadership competencies for candidates at the GS-11 and GS-12 

level. Unlike the DCAP or LIM programs, this program is a competitive program where 

interested candidates must apply and are selected to be a part of the program. 

The basic framework of the ALP includes a training curriculum focused on specific competencies 

that align with the DoD leadership continuum and address skill gaps that have emerged from 

interviews with senior agency leaders. Additionally, participants will have learning experiences 

such as rotations dictated by DFAS needs/mission (with possible rotations to different sites) and 

exposure to the strategic elements within the Agency, with the goal of preparing the participants 

for an enterprise-wide perspective. ALP participants will also be required to obtain their Green 

Belt Certification. 

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 

Fellowship 

Programs 

Mentoring Programs 

Coaching Programs 

Training Programs 

Detail Programs 

Other Career 

Development 

Programs 

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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 

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 

C. Awards 

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 

Triggers exist for PWD in time-off awards of 1-10 time-off awards. 

Triggers exist for PWD in time-off awards of 31-40 time-off awards. 

Triggers exist for PWD and PWTD in cash awards 500 and under, cash awards $501-$5000, and 

$5000 or more. 

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 0 No X 

b. Pay Increases (PWTD) Yes 0 No X 

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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 0 No 0 N/A X 

b. Other Types of Recognition (PWTD) Yes 0 No 0 N/A X 

D. Promotions 

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. 

ii. 

Qualified Internal Applicants (PWTD) 

Internal Selections (PWTD) 

Yes 0 

Yes 0 

No X 

No X 

b. Grade GS-15 

i. Qualified Internal Applicants (PWTD) 

ii. Internal Selections (PWTD) 

Yes 0 

Yes X 

No X 

No 0 

c. Grade GS-14 

i. Qualified Internal Applicants (PWTD) 

ii. Internal Selections (PWTD) 

Yes 0 

Yes X 

No X 

No 0 

d. Grade GS-13 

i. Qualified Internal Applicants (PWTD) 

ii. Internal Selections (PWTD) 

Yes 0 

Yes 0 

No X 

No X 

GS-15: This comparison is deceiving because while the number of internal selections was 0 for 

PWD, there was in total only one grade 15 internal selection. 

GS-14: The comparison is deceiving because while the number of internal selections was 0 for 

PWD, there was in total only three grade 14 internal selection. 

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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 

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

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 X No 0 

c. Grade GS-14 

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

ii. Internal Selections (PWTD) Yes X No 0 

d. Grade GS-13 

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

ii. Internal Selections (PWTD) Yes 0 No X 

GS-15: This comparison is deceiving because while the number of internal selections was 0 for 

PWTD, there was in total only one grade 15 internal selection. 

GS-14: The comparison is deceiving because while the number of internal selections was 0 for 

PWTD, there was in total only three grade 14 internal selection. 

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 non-GS 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 0 No X 

b. New Hires to GS-15 (PWD) Yes 0 No X 

c. New Hires to GS-14 (PWD) Yes 0 No X 

d. New Hires to GS-13 (PWD) Yes 0 No X 

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 non-GS pay plans, 

please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the box. 

a. New Hires to SES (PWTD) Yes 0 No X 

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b. New Hires to GS-15 (PWTD) Yes 0 No X 

c. New Hires to GS-14 (PWTD) Yes 0 No X 

d. New Hires to GS-13 (PWTD) Yes X No 0 

At the GS-13 level, no qualified PWTD applicants were selected as compared to those with no 

disability at 77.42% selection rate. 

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 0 No X 

ii. Internal Selections (PWD) Yes X No 0 

b. Managers 

i. Qualified Internal Applicants (PWD) Yes 0 No X 

ii. Internal Selections (PWD) Yes 0 No X 

c. Supervisors 

i. Qualified Internal Applicants (PWD) Yes 0 No X 

ii. Internal Selections (PWD) Yes 0 No X 

Executives: Four executives were promoted but none were PWD. 

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) 

ii. Internal Selections (PWTD) 

Yes 0 

Yes X 

No X 

No 0 

b. Managers 

i. Qualified Internal Applicants (PWTD) 

ii. Internal Selections (PWTD) 

Yes 0 

Yes X 

No X 

No 0 

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c. Supervisors 

i. Qualified Internal Applicants (PWTD) Yes 0 No X 

d. Executives 

iii. Qualified Internal Applicants (PWTD) 

iv. Internal Selections (PWTD) 

Yes 0 

Yes X 

No X 

No 0 

e. Managers 

iii. Qualified Internal Applicants (PWTD) 

iv. Internal Selections (PWTD) 

Yes 0 

Yes X 

No X 

No 0 

f. Supervisors 

ii. Qualified Internal Applicants (PWTD) 

iii. Internal Selections (PWTD) 

Yes 0 

Yes 0 

No X 

No X 

Executives: Four executives were promoted but none were PWTD. 

Managers: Eleven managers with no disability were promoted but zero PWTD managers were 

promoted. 

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 0 No X 

b. New Hires for Managers (PWD) Yes 0 No X 

c. New Hires for Supervisors (PWD) Yes X No 0 

There was one PWD hired for supervisory position compared to five employees who were hired 

with no disability. 

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 0 No X 

b. New Hires for Managers (PWTD) Yes 0 No X 

c. New Hires for Supervisors (PWTD) Yes X No 0 

Section V: Plan to Improve Retention of Persons with Disabilities 

There were no PWTD hired for supervisory position compared to five employees who were hired 

with no disability. 

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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. 

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 X No 0 N/A 0 

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 0 No X 

b. Involuntary Separations (PWD) Yes 0 No X 

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 0 No X 

Possibly related to difficulty getting to work or medical complications, there was a higher 

number of PWTD choosing to separate voluntary. 

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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. 

PWD and PWTD left due to personal reasons according to exit surveys. 

B. Accessibility of Technology and Facilities 

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. 

http://dodcio.defense.gov/DoDSection508/Std_Stmt.aspx 

An individual experiencing difficulties accessing content on a DFAS website may submit a DoD 

Section 508 Form at the website below. 

http://dodcio.defense.gov/DoDSection508/Section508Form.aspx 

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. 

https://www.dfas.mil/nofearact/ 

This link is to the DFAS Reasonable Accommodation instructions. These instructions contain 

guidance on how to initiate an EEO discrimination complaint with the Agency. 

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. 

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The DEPM and Section 508 Program Coordinator attended Change Control Board (CCB) 

meetings in a proactive attempt to ensure matters related to accessibility were considered when 

making changes to the IT infrastructure. The CCB is the approval authority for all proposed 

change requests pertaining to the Agency’s IT infrastructure. DFAS established a Section 508 

ICT Accessibility Team. The purpose of this team is: 

• To assist the Accessibility Team Chair in implementing 508 standards through the 

maintenance of the Section 508 policy by keeping abreast of industry best practices and 

considering them during the revision of the policy. 

• To provide governance for the DFAS Section 508 program. 

• To be a liaison for each Agency directorate or section by bringing issues, complaints, or 

problems into the limelight and to disseminate information to management. 

The DEPM is engaged in meetings regarding updated changes that will be made to the main 

entrance at the Indianapolis site. 

DFAS will recruit members for the DFAS Advocacy PWD ERG. This ERG will advise 

management on matters affecting employment of PWD, to include accessibility of 

Agency facilities and technology. 

DFAS will try to obtain a contract to cover JAWS scripting and a centralized CART services 

contract (real-time captioning for deaf and hard of hearing employees). 

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 previously approved 

requests with repetitive accommodations, such as interpreting services.) 

The average processing time for reasonable accommodation requests in FY22 was 21.44 

calendar days. 

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. 

DFAS continues to maintain a full-time ASL interpreting staff at 4 of its 5 main sites. 

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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. 

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. 

The process for requesting PAS was included in the revised DFAS Reasonable Accommodation 

Instruction, DFAS 1020.1-I. No requests for PAS were made in FY22. 

Section VI: EEO Complaint and Findings Data 

A. EEO Complaint Data involving Harassment 

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. 

Total of 23 complaints filed in FY 22 at DFAS. Out of the 23 cases, 8 PWD filed alleging 

harassment (34.78%). 

Removal of Letter of Warning. 

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 governmentwide average? 

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Yes 0 No X 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. 

Monetary Settlement Agreement 

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 0 No X 

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. Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), 

objective(s), responsible official(s), planned activities, and, where applicable, 

accomplishments. 

Trigger 1 There are 0 PWTD in series 0511 

Barrier(s) An examination of established Agency regulations does not reflect that the 

existing policy creates a barrier for individuals with disabilities. 

Objective(s) Analyze avenues to increase PWTD in series 0511. 

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Responsible Official(s) 

Performance Standards Address the 

Plan? 

(Yes or No) 

Lauren A. Aggen, Disability Employment Program 

Manager No 

Barrier Analysis Process Completed? 

(Yes or No) 

Barrier(s) Identified? 

(Yes or No) 

Yes No 

Sources of Data 

Sources 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes 

Looked at data of the employees at 

issue. Range in grade from GS-07 to 

SES. Analyze which sites the employees 

are at. 

Complaint Data (Trends) 

Grievance Data (Trends) 

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

Climate Assessment Survey (e.g., 

FEVS) 

Exit Interview Data 

Focus Groups 

Interviews 

Reports (e.g., Congress, EEOC, 

MSPB, GAO, OPM) 

Other (Please Describe) Yes 

Reviewed requirements for 0511 series. 

Read the Schedule-A listing and 0511 

roadmap. 

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Target Date Planned Activities Sufficient 

Staffing & 

Funding 

(Yes or No) 

Modified 

Date 

Completion 

Date 

9/30/2022 Send self-identification email to 0511 

management to target their area. 

Reach out to the GS-15s and SES at 

said department and encourage them to 

make use of Schedule A or/and WRP. 

Yes 09/30/2022 

Fiscal 

Year 

Accomplishments 

2022 Percentage of PWTD in series 0511 increased from FY21 to FY22. 

4. Please explain the factor(s) that prevented the agency from timely completing any of the 

planned activities. 

Not applicable 

5. For the planned activities that were completed, please describe the actual impact of those 

activities toward eliminating the barrier(s). 

In FY 23, there has been an increase of PWTD in series 0511. 

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. 

Not applicable. 

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