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

Persons with Disabilities

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

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

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

of applicants and employees with disabilities. All agencies, regardless of size, must complete this Part 

of the MD-715 report.

Section I: Efforts to Reach Regulatory Goals

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

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

government. 

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

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

box.

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

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

Table B4 shows:

GS 11-SES/SL: 399 total employees, 33 (8.2%) PWD. In FY 22, DFC had 342 total employees, 

22 (6.4%) PWD. Although this is still below the 12% benchmark, we saw improvement from the 

prior FY. This is still a trigger.

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

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

box.

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

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

Table B4 shows:

GS 11-SES/SL: 399 total employees, six (1.5%) PWTD. This is an increase from FY 2021 when 

DFC had 342 total employees, three (0.9%) PWTD. We are still below the 2% benchmark, 

therefore there is a trigger.

3. Describe how the agency has communicated the numerical goals to the hiring managers 

and/or recruiters.

The EEO Director began making strides to communicate the numerical goals to hiring managers 

and recruiters. We will heighten communication in FY 23, incorporating strategic recruitment efforts 

to target applicants with targeted disabilities. 

Section II: Model Disability Program

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

to recruit and hire persons with disabilities and persons with targeted disabilities, administer the 
reasonable accommodation program and special emphasis program, and oversee any other 

disability hiring and advancement program the agency has in place. 

A. Plan to Provide Sufficient & Competent Staffing for the Disability Program

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

during the reporting period? If “no”, describe the agency’s plan to improve the staffing for the 

upcoming year.

Yes No X

During the FY, we found that current EEO staffing, i.e., one EEO Director, was insufficient to 

proactively build a model EEO program. The EEO Office added collateral duty staff; however, 

they were only utilized for the EEO complaints process. During FY 2023, the agency will focus on 

building resources (permanent and collateral duty) to ensure adequate staffing is available for 

barrier analysis and to fulfill a Disability Program Manager role.

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

the office, staff employment status, and responsible official.

Disability Program Task

# of FTE Staff by 

Employment Status Responsible Official

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

Processing applications from PWD 

and PWTD 

1 0 0 Samantha Miller, Selective 

Placement Coordinator/ 

Human Resources Specialist

Samantha.miller@dfc.gov

Answering questions from the public 

about hiring authorities that take 

disability into account

5 0 0 Todd Morris, Director, Talen 

Acquisition, Office of Human 

Resources Management 

todd.morris@dfc.gov

Processing reasonable 

accommodation requests from 

applicants and employees

0 3 0 Patrick Browne, 

Director, Workforce Relations 

Patrick.Browne@dfc.gov

Section 508 Compliance 0 1 0 Office of Information 

Technology

Architectural Barriers Act Compliance 0 1 0 Charles von Goins, 

Supervisory Facilities 

Specialist 

charles.vongoins@dfc.gov

Special Emphasis Program for PWD 

and PWTD

1 0 0 Samantha Miller, Selective 

Placement Coordinator/ 

Human Resources Specialist

Samantha.miller@dfc.gov

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

responsibilities during the reporting period? If “yes”, describe the training that disability 

program staff have received. If “no”, describe the training planned for the upcoming year. 

Yes No X
During FY 2022, there was insufficient resourcing for the EEO program to ensure training occurred. 

A training plan will be developed for FY 2023.

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 No X

In FY 2023, the agency will hire a Chief Diversity and Inclusion Officer to increase awareness, 

outreach, and assist the EEO Director with barrier analysis.

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

1. Describe the programs and resources the agency uses to identify job applicants with 

disabilities, including individuals with targeted disabilities. 

Over the last fiscal year, DFC utilized a variety of recruitment strategies designed to increase the 

number of qualified applicants with disabilities and applicants with targeted disabilities within the 

major occupations. DFC utilized the following resources to identify job applicants with disabilities, 

including targeted disabilities: 

• OPM’s Shared Register of Candidates with Disabilities (Bender List); and 

• Websites geared towards veterans

• Virtual Career Fairs at Universities

• Updating Selective Placement Program Coordinator information on OPM’s Directory.

• Workforce Recruitment Program

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

take disability into account (e.g., Schedule A) to recruit PWD and PWTD for positions in the 

permanent workforce. 

DFC used Schedule A appointing authority (5 C.F.R. 213.310(2)) and 30% or More Disabled 

Veteran appointing authority (5 U.S.C. 3112; C.F.R. 316.302, 316.402, and 315.707) to proactively 

hire PWD/ expeditiously. DFC job announcements contain information explaining how to apply 

under Schedule A and other excepted service hiring authorities. During FY 22, four Schedule A 

hires were made. All Schedule A hires were appointed to GS-11 to SES positions, and three of the 

four were in mission critical occupations.
3. When individuals apply for a position under a hiring authority that takes disability into account 

(e.g., Schedule A), explain how the agency (1) determines if the individual is eligible for 

appointment under such authority and (2) forwards the individual's application to the relevant 

hiring officials with an explanation of how and when the individual may be appointed. 

To determine if an applicant is eligible under Schedule A, OHRM reviews the application package 

to determine if the required documentation was provided (as described in the vacancy 

announcement from OPM’s Disability Employment Page). The documentation is reviewed for 

eligibility under the hiring authority. This is applied when a candidate applies through USAJOBS 

and/or directly to OHRM. If the documentation submitted is unclear, OHRM gives tentative 

consideration under this hiring authority. In this case, if the individual is selected, HRM asks the 

selectee to furnish the appropriate documentation. When an applicant applies through USAJOBS, 

OHRM reviews the package for qualifications and eligibility. Those eligible and qualified under noncompetitive hiring authorities are placed on a certificate of eligible applicants that is separate from 

those competitively eligible. Additionally, OHRM searches OPM’s list of Persons with Disabilities 

(Bender) and/or any resumes on file. If qualified candidates are found, the resumes are forwarded 

to the hiring official via email for consideration.

4. Has the agency provided training to all hiring managers on the use of hiring authorities that 

take disability into account (e.g., Schedule A)? If “yes”, describe the type(s) of training and 

frequency. If “no”, describe the agency’s plan to provide this training.

Yes No X N/A 

DFC plans to provide mandatory annual training for senior leadership, hiring managers, and HR 

specialists to: 

• Promote and support employment of PWD/PWTD for all employment opportunities in the 

agency. 

• Use Schedule A authority for people with disabilities. 

• Use other tools available to assist hiring managers to identify qualified applicants with 

disabilities; and 

• Remain versed on DFC’s procedures for providing reasonable accommodation to job 

applicants and employees with disabilities.

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. 

The Selective Placement Coordinator (SPC) utilizes the Workforce Recruitment Program to identify 

job applicants with disabilities, including individuals with targeted disabilities. Although the SPC 

made referrals under the WRP and served as a recruiter during FY 22, no WRP hires were made. 

During FY 23, the EEO Office plans to significantly increase marketing and promotion of the WRP 

program. Additionally, the EEO Director will provide recommendations to the recruiting team that 

would increase the applicant pool for PWTD.

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 No X

b. New Hires for Permanent Workforce (PWTD) Yes No X

During FY22, 11 new hires (12.79%) were PWD and 2 (2.33%) were PWTD.

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 No X

b. New Hires for MCO (PWTD) Yes X No 

Of the 107 new hires in FY 2022, 14 (13.1% of 107 new hires) were PWDs and two (14.3% of the 

14 PWDs) were in mission critical occupations (1 in 1101 series, and 1 in 301 series). 

Of the 107 new hires in FY 2022, two (1.9% of 107 hires) had targeted disabilities, but none were 

in MCOs. This is a trigger.

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 No X

b. Qualified Applicants for MCO (PWTD) Yes No X

Relevant applicant pool data is not available. The data provided by USA Staffing does not identify 

which current DFC employees qualify for a job series they are not currently in. The HR Office does 

not adjudicate applicant qualifications until an applicant applies for a specific position, and the 

applicant may qualify based on experience obtained prior to entry into their current job series, or 

into DFC. DFC has not attempted to develop an estimate for job series-relevant applicant pools or 

to tabulate relevant applicant pools for this reporting cycle. 

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 No X

b. Promotions for MCO (PWTD) Yes No X

Due to agency size, DFC is not required to analyze Table A – B 6. We plan to review and analyze 

this data in FY 2023.

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.

DFC HR Specialists will continue to encourage and implement strategic prerecruitment discussions 

among hiring officials and HR professionals that includes detailed information about available hiring 

options and flexibilities, including programs that build education to career pipelines for applicants with 

disabilities. Additionally, while not a regulatory mandate, DFC promotes the use of individual 

development plans (IDPs) as a tool for monitoring. 

The EEO Director will seek to appoint a Disability Program Manager (DPM) to ensure DFC is a model 

employer for people with disabilities. The DPM will partner with DFC SPC to build a pipeline of 

Schedule A applicants, encourage the use of the Workforce Recruitment Program, ensure an effective 

and efficient Reasonable Accommodation program, and develop a community outreach plan. 

Additionally, the DPM will analyze data from the agency’s Federal Employees Viewpoint Survey 

(FEVS) to identify areas of concern for employees and develop action plans for improvement.

B. Career Development Opportunities

1. Please describe the career development opportunities that the agency provides to its 

employees. 

DFC provides both formal and informal training opportunities to employees via external organizations 

that host courses on finance, law and other practices deemed essential to meeting the DFC mission. 

Additional courses around project/time management, soft skills, and professional development are 

provided by Graduate School USA or other external entities such as Skillsoft. DFC does not collect 

data relative to employees in these training opportunities.

2. In the table below, please provide the data for career development opportunities that require 

competition and/or supervisory recommendation/approval to participate. 

Career Development 

Opportunities

Total Participants PWD PWTD

Applicant

s (#)

Selectees 

(#)

Applicant

s (%)

Selectees 

(%)

Applicant

s (%)

Selectees 

(%)

Internship Programs 294 7 6.8% 14.3% 3.1% 14.3%

Fellowship Programs NA NA NA NA NA NA

Mentoring Programs NA NA NA NA NA NA

Coaching Programs NA NA NA NA NA NA

Training Programs NA NA NA NA NA NA

Detail Programs NA NA NA NA NA NA

Other Career 

Development Programs

NA NA NA NA NA NA
3. Do triggers exist for PWD among the applicants and/or selectees for any of the career 

development programs? (The appropriate benchmarks are the relevant applicant pool for the 

applicants and the applicant pool for selectees.) If “yes”, describe the trigger(s) in the text 

box.

a. Applicants (PWD) Yes No X N/A X

b. Selections (PWD) Yes No X N/A X

Not applicable

4. Do triggers exist for PWTD among the applicants and/or selectees for any of the career 

development programs identified? (The appropriate benchmarks are the relevant applicant 

pool for applicants and the applicant pool for selectees.) If “yes”, describe the trigger(s) in 

the text box.

a. Applicants (PWTD) Yes No X N/A X

b. Selections (PWTD) Yes No X N/A X

Not applicable

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 No X

b. Awards, Bonuses, & Incentives (PWTD) Yes No X

Due to agency size, DFC is not required to analyze Tables 9.1 and 9.2. We plan to review and 

analyze this data in FY 2023.

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 No X

b. Pay Increases (PWTD) Yes No X

Due to agency size, DFC is not required to analyze Tables 9.1 and 9.2. We plan to review and 

analyze this data in FY 2023.
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 No N/A X

b. Other Types of Recognition (PWTD) Yes No N/A X

Due to agency size, DFC is not required to analyze Tables 9.1 and 9.2. We plan to review and 

analyze this data in FY 2023.

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. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

b. Grade GS-15 g 

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

c. Grade GS-14 

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

d. Grade GS-13 

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

Due to agency size, DFC is not required to analyze Tables 6. We plan to review and analyze this 

data in FY 2023.
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 No X

ii. Internal Selections (PWTD) Yes No X

b. Grade GS-15

i. Qualified Internal Applicants (PWTD) Yes No X

ii. Internal Selections (PWTD) Yes No X

c. Grade GS-14 

i. Qualified Internal Applicants (PWTD) Yes No X

ii. Internal Selections (PWTD) Yes No X

d. Grade GS-13 

i. Qualified Internal Applicants (PWTD) Yes No X

ii. Internal Selections (PWTD) Yes No X

Due to agency size, DFC is not required to analyze Tables 6. We plan to review and analyze this 

data in FY 2023.

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 No X

b. New Hires to GS-15 (PWD) Yes No X

c. New Hires to GS-14 (PWD) Yes No X

d. New Hires to GS-13 (PWD) Yes No X

Due to agency size (<500 employees), DFC is not required to analyze Tables 6. We plan to review 

and analyze this data in FY 2023.

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 text box.

a. New Hires to SES (PWTD) Yes No X

b. New Hires to GS-15 (PWTD) Yes No X

c. New Hires to GS-14 (PWTD) Yes No X

d. New Hires to GS-13 (PWTD) Yes No X 
Due to agency size (<500 employees), DFC is not required to analyze Tables 6. We plan to review 

and analyze this data in FY 2023.

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 No X

ii. Internal Selections (PWD) Yes No X

b. Managers

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

c. Supervisors 

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

Due to agency size (< 500 employees), DFC is not required to analyze Tables 6. We plan to 

review and analyze this data in FY 2023.

6. Does your agency have a trigger involving PWTD among the qualified internal applicants 

and/or selectees for promotions to supervisory positions? (The appropriate benchmarks are 

the relevant applicant pool for qualified internal applicants and the qualified applicant pool for 

selectees.) If “yes”, describe the trigger(s) in the text box. 

a. Executives

i. Qualified Internal Applicants (PWTD) Yes No X

ii. Internal Selections (PWTD) Yes No X

b. Managers

i. Qualified Internal Applicants (PWTD) Yes No X

ii. Internal Selections (PWTD) Yes No X

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Yes No X

ii. Internal Selections (PWTD) Yes No X

Due to agency size (< 500 employees), DFC is not required to analyze Tables 6. We plan to 

review and analyze this data in FY 2023.

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 No X 

b. New Hires for Managers (PWD) Yes No X

c. New Hires for Supervisors (PWD) Yes No X

Due to agency size (< 500 employees), DFC is not required to analyze Tables 6. We plan to 

review and analyze this data in FY 2023.

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 No X 

b. New Hires for Managers (PWTD) Yes No X

c. New Hires for Supervisors (PWTD) Yes No X 

Due to agency size, DFC is not required to analyze Tables 6. We plan to review and analyze this 

data in FY 2023.

Section V: Plan to Improve Retention of Persons with Disabilities

To be a model employer for persons with disabilities, agencies must have policies and programs in 

place to retain employees with disabilities. In this section, agencies should: (1) analyze workforce 

separation data to identify barriers retaining employees with disabilities; (2) describe efforts to ensure 

accessibility of technology and facilities; and (3) provide information on the reasonable 

accommodation program and workplace personal assistance services.

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 No N/A x

N/A

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 No X

b. Involuntary Separations (PWD) Yes No X

N/A

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 No X

b. Involuntary Separations (PWTD) Yes No X

N/A

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. 

N/A

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. 

The internet address is https://www.dfc.gov/accessibility-statement.

2. Please provide the internet address on the agency’s public website for its notice explaining 

employees’ and applicants’ rights under the Architectural Barriers Act, including a description 

of how to file a complaint.

The internet address is https://www.dfc.gov/accessibility-statement.

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.

In FY 2022, DFC continued to enable and allow all employees the flexibility to telework. In March 

2022, DFC workforce returned to onsite work and launched its remote work policy. The agency 

analyzed the workforce to determine positions that were available for total remote work. As of FY 

22, approximately 25% of DFC employees are remote and more than 95% have telework 
agreements and are able to telework. 

DFC will continue to ensure their internal and external websites comply with all facility and 

technological guidance. During FY 2023, the agency will conduct an architectural barriers survey 

to ensure all facilities are accessible for PWD and PWTD. The agency will also survey publicfacing webpages to ensure compliance with ADA regulations.

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.)

During FY 2022, DFC received 25 requests for Reasonable Accommodation. The average time to 

respond to requests was 1 day. The average time to provide a request was 52 days. In addition to 

processing RA requests, the agency proactively provides high volume accommodation solutions 

outside of the RA process (e.g., sit-stand stations, ergonomic chairs, etc.).

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.

In FY 2022, new staff were assigned the responsibility of processing RA requests. Training was 

provided to staff in late FY 2022. In FY 2023, the RA program effectiveness will be reviewed to 

determine ways to streamline the process and improve efficiencies. Employee education and 

training will be provided in FY 2023. The EEO office will recommend changes to the RA policy.

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.

DFC did not receive any PAS requests in FY 2022.

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 No N/A X

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 No X N/A 

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.

DFC had no findings of discrimination.

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? 

Yes No N/A X

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 No N/A X

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.

DFC did not have any findings in FY 2022.

Section VII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a 

policy, procedure, or practice may be impeding the employment opportunities of a protected EEO 

group.

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect 

employment opportunities for PWD and/or PWTD? 

Yes X No 

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD? 

Yes X No 

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 Results from the FY 2022 FEVS

Barrier(s) Perceptions, Attitudinal barriers

Objective(s) Improve FEVS results for DFC PWD and PWTD employees

Responsible Official(s) Performance Standards Address the Plan?
(Yes or No)

EEO Director

Vice President, Office of Human Resources 

Management Yes (both)

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

No No. During FY 2022, the agency identified FEVS 

results as a trigger.

Sources of Data

Sources 

Reviewe

d?

(Yes or 

No)

Identify Information Collected

2022 FEVS Yes

Target Date

(MM/DD/YYYY)

Planned Activities Sufficient 

Staffing & 

Funding

(Yes or No)

Modified Date

(MM/DD/YYYY)

Completion 

Date

(MM/DD/YYYY)

09/30/2023 Establish Focus Groups No 12/31/2023

09/30/2023 Appoint a Disability Program 

Manager

No 12/31/2023

09/30/2023 Establish a cross-functional 

Barrier Analysis Team (BAT)

No 12/31/2023

09/30/2023 Conduct Barrier Analysis training 

for the EEO staff and BAT 

members

No 03/31/2024

Fiscal Year Accomplishments

4. Please explain the factor(s) that prevented the agency from timely completing any of the 

planned activities.

In FY 22, the agency’s EEO Office had insufficient staffing to conduct barrier analysis. 

5. For the planned activities that were completed, please describe the actual impact of those 
activities toward eliminating the barrier(s).

Not applicable.

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.