Annual EEO, Civil Rights 

and Diversity Report

FISCAL YEAR 2019

U.S. DEPARTMENT OF THE TREASURY 

OFFICE OF CIVIL RIGHTS & DIVERSITY
MD-715

Parts A Through E

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 

the Treasury N/A 1500 Pennsylvania Ave, NW Washington DC 20220 TR 11001

Part B - Total Employment

Total Employment Permanent Workforce Temporary Workforce Total Workforce

Number of Employees 90319 1520 91839

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

Agency Leadership Name Title

Head of Agency Steven T. Mnuchin Secretary, Department of the Treasury

Head of Agency Designee David F. Eisner Assistant Secretary for Management

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

Mariam 

Harvey

Director 

(OCRD) 0260 ES 202-622-0316 Mariam.Harvey@treasury.gov

Deputy Director 

EEO Snider Page

Deputy 

Director 

(OCRD)

0260 GS-15 202-622-

0341 Snider.Page@treasury.gov

Affirmative 

Employment 

Program 

Manager

Tina 

Lancaster

Manager of 

EEO 

Programs

0260 GS-15 202-622-

1079 Tina.Lancaster@treasury.gov

Complaint 

Processing 

Program 

Manager

Guizelous 

(Guy) 

Molock

Complaints 

Manager 0260 GS-15 202-622-4178 Giuzelous.Molock@treasury.gov

Manager of 

Special 

Emphasis 

Programs

Tina 

Lancaster

Manager of 

EEO 

Programs

0260 GS-15 202-622-

1079

Tina.Lancaster@treasury.gov
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

1

Diversity & 

Inclusion

Program 

Manager

Thomas 

Lotito

EEO 

Specialist 0260 GS-14 202-622-8902

Thomas.Lotito@treasury.gov

Disability 

Program 

Manager 

(SEPM)

Lisa Jones EEO 

Specialist 0260 GS-14 202-622-0315 Lisa.Jones@treasury.gov

Special 

Placement 

Program 

Coordinator 

(Individuals with 

Disabilities)

Lisa Jones EEO 

Specialist 0260 GS-14 202-622-0315 Lisa.Jones@treasury.gov

Reasonable 

Accommodation 

Program 

Manager

Lisa Jones EEO 

Specialist 0260 GS-14 202-622-0315 Lisa.Jones@treasury.gov

AntiHarassment 

Program 

Manager

Clarissa 

Lara

EEO 

Specialist 0260 GS-14 512-499-5115 Clarissa.Lara@treasury.gov

ADR Program 

Manager

Clarissa 

Lara

EEO 

Specialist 0260 GS-14 512-499-5115 Clarissa.Lara@treasury.gov

Compliance 

Manager

Ellen 

HawthorneCopenhaver

EEO 

Specialist 0260 GS-14 202-622-0341

Ellen.HawthorneCopenhaver@treasury.gov

Principal MD715 PreparerTina 

Lancaster

Manager of 

EEO 

Programs

0260 GS-15 202-622-

1079 Tina.Lancaster@treasury.gov
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

2

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 the box.

Subordinate Component City State Country 

(Optional)

Agency 

Code (xxxx)

FIPS

Codes

(xxxxx)

Alcohol and Tobacco Tax and 

Trade Bureau Washington DC US TR40 11001

Bureau of Engraving and 

Printing Washington DC US TRAI 11001

Fiscal Service Parkersburg WV US TRFD 54107

Departmental Offices Washington DC US TR91 11001

Financial Crimes Enforcement 

Network Fairfax VA US TRAF 51600

Internal Revenue Service Washington DC US TR93 11001

Internal Revenue Service Chief 

Counsel Washington DC US TR93(88) 11001

United States Mint Washington DC US TRAD 11001

Office of the Comptroller of the 

Currency Washington DC US TRAJ 11001

Office of the Inspector General Washington DC US TR95 11001

Special Inspector General for 

Troubled Asset Relief Program Washington DC US TRRP 11001

Treasury Inspector General for 

Tax Administration Washington DC US TRTG 11001
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

3

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

Diversity and Inclusion Plan under Executive Order 13583 Yes

Diversity Policy Statement Yes

Human Capital Strategic Plan Yes

EEO Strategic Plan No

Results from most recent Federal Employee Viewpoint Survey 

(FEVS) or Annual Employee Survey Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

4

Part E – Executive Summary

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

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

appointments have the option to Part E.2 to E.5.

Part E.1 - Executive Summary: Mission

Introduction/Mission

This report covers the period of October 1, 2018, through September 30, 2019, and highlights the 

Department of the Treasury’s accomplishments during Fiscal Year (FY) 2019 in attaining and maintaining 

a model equal employment opportunity (EEO) Program. 

The Department of the Treasury’s Mission

Treasury’s mission is to maintain a strong economy and create economic and job opportunities by 

promoting the conditions that enable economic growth and stability at home and abroad, strengthen 

national security by combatting threats and protecting the integrity of the financial system, and manage 

the U.S. Government’s finances and resources effectively. 

The nearly 100,000 dedicated Treasury employees strive to maintain integrity and uphold the public trust 

in all that we do, explore better ways of conducting business through innovation, seek diversity of 

thought and expertise to inform our decisions, embrace and adapt to change, and hold ourselves 

accountable for accomplishing meaningful results for the American public. 

Organization

The Department of the Treasury (Department) is organized into the Departmental Offices, eight operating 

bureaus, and three Offices of the Inspectors General. The Departmental Offices is primarily responsible 

for the formulation of policy and overseeing the bureaus, which manage major operations.

Organizational Reporting Structure

For Equal Employment Opportunity Commission (EEOC) Management Directive (MD) 715 reporting 

purposes, Treasury’s second-level reporting bureaus are: 

• Bureau of Engraving and Printing (BEP),

• Fiscal Service (FS),

• Departmental Offices (DO),

• Internal Revenue Service (IRS),

• Internal Revenue Service Office of the Chief Counsel (IRS-CC),

• Office of the Comptroller of the Currency (OCC), and 

• U.S. Mint (Mint). 

Bureaus employing fewer than 1,000 employees are required to provide their individual MD-715 reports to 

Treasury’s Office of Civil Rights and Diversity (OCRD) for inclusion in the Treasury’s overall report. 

These bureaus are Financial Crimes Enforcement Network (FinCEN), the Office of the Inspector General 

(OIG), Special Inspector General for Troubled Asset Relief Program (SIGTARP), Treasury Inspector 

General for Tax Administration (TIGTA), and Alcohol and Tobacco Tax and Trade Bureau (TTB). 

Each Treasury bureau, regardless of size, has its own distinct reporting structure for its EEO and Human 

Resource (HR) offices and programs. Each bureau sets its own policy and procedures regarding the 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

5

hiring, recruitment, and retention of employees within the broad framework of the Department’s Human 

Capital Strategy. The OCRD, part of the Departmental Offices’ organizational structure, is primarily 

responsible for providing guidance and oversight to the bureaus’ EEO offices.

The Office of Civil Rights and Diversity

The Office of Civil Rights and Diversity administers the Department-wide equal employment opportunity

(EEO) and diversity (EEOD) program by providing policy, oversight, and technical guidance to Treasury 

bureaus, including the Departmental Offices, on affirmative employment, special emphasis program 

areas, diversity, and EEO complaint processing. 

In addition, OCRD oversees Treasury's external civil rights efforts to ensure non-discrimination in 

programs operated or funded by the Department of the Treasury. The OCRD’s External Civil Rights 

Program ensures individuals are not excluded from participation in, denied the benefits of, or otherwise 

subjected to prohibited discrimination under programs or activities conducted or funded by the 

Department. 

OCRD also manages all stages of the formal complaint process, including final agency actions on 

discrimination complaints filed by Treasury employees and applicants for employment.

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

N/A

Part E.3 - Executive Summary: Workforce Analyses

Workforce Demographics

The following are Treasury’s workforce demographic trends over the period of FY 2009 to FY 2019

1

. The 

area where participation rates have been of the most concern government-wide and at the Department 

have been the distribution of women and non-Whites in the General Schedule grades (GS) 13 through 

15, the Senior Executive Service (SES) and equivalent pay plans (OR, TR, IR and NB), and the 

participation rates for Hispanics. 

Additionally, for a cabinet-level agency the size of Treasury, data typically varies only by tenths of a 

percent from one year to the next. However, when evaluating trends over time, and as a result of the 

bureaus’ efforts to improve diversity in those areas with lower than expected participation rates, Treasury 

has noted significant progress for the overall participation rate for Hispanics and people with disabilities 

(PWD) and people with targeted disabilities (PWTD).

 

Participation Rates in the Permanent Workforce

At the close of FY 2019, Treasury had 90,319 permanent employees2, a decrease of 1,830 (-1.99 percent 

net change) employees from FY 2018. This decrease is primarily due to reduced budgets which have

significantly limited or reduced hiring opportunities for many of the Treasury’s bureaus in FY 2019.

Treasury and its bureaus continue to utilize the RCLF tool updated at the end of FY 2019, which provides 

1 Enterprise Data Management System, Treasury’s system of record, maintains employment data that covers a rolling period of 

10 years. Beginning in FY 2018, data for trend analysis was available for FY 2009 through FY 2018.

2 For purposes of analysis, non-appropriated fund employees are included in the workforce totals as permanent or temporary 

employees depending on their status.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

6

a more realistic benchmark comparator. The RCLF is based off of the National Civilian Labor Force. 

However, rather than calculating a weighted average for all available occupations in the federal 

government, it calculates the expected labor force based on a weighted average of only those 

occupations in Treasury’s workforce. 

A comparison of FY 2019 participation rates in Treasury’s permanent workforce for men and women 

shows little change from FY 2009. However, based on the RCLF availability rates, we see that women 

(61.56 percent compared to 64.98 percent RCLF) and men (38.44 percent compared to 35.02 percent 

RCLF) are participating at rates close to their RCLF availability rates. Additionally, based on the RCLF, 

Treasury has a better understanding as to why the participation rate for women at the Department is 

significantly above the CLF availability rate (48.14 percent CLF compared to 64.98 percent RCLF) and 

the participation rate for men is significantly below the CLF availability rate (51.86 percent CLF compared 

to 35.02 percent RCLF). 

In FY 2009, Treasury’s permanent workforce was 59.90 percent White and 40.10 percent non-White. In 

FY 2019, the participation rate for Whites decreased to 53.16 percent of the workforce and non-Whites 

increased to 46.84 percent. Thus, Treasury has noted a positive trend in the increased participation rate 

for non-Whites in the overall workforce. In fact, Hispanics (12.10 percent compared to 8.50 percent 

RCLF), Blacks (26.09 percent compared to 10.57 percent RCLF), Asians (6.45 percent compared to 4.48 

percent RCLF), and Native Hawaiian or Other Pacific Islanders (0.17 percent compared to 0.12 percent 

RCLF) are participating at rates greater than their RCLF availability rates. American Indian/Alaska 

Natives (0.81 percent compared to 0.89 percent RCLF) are participating at rates very close to their 

availability rates. Whites (53.16 percent compared to 74.93 percent) and Two or More Races (0.42

percent compared to 0.51 percent) are the only groups participating at rates below their RCLF availability 

rates. 

Distribution in the Grades

The distribution of women and non-Whites in Treasury’s workforce has been an area of focus for the 

Department. OCRD has closely monitored the distribution of women and non-Whites in the feeder pools 

(GS 13 – GS 15) that lead to SES and SES positions. From FY 2009 to FY 2015, Treasury noted an 

increased participation rate for women in the GS-13 and GS-15 grades as well as in SES positions. 

However, from FY 2015 to FY 2019, Treasury has noted a decrease in the participation rate for women at

the GS-13 through GS-15 and SES level positions. It is also important to note that due to the extended 

furlough that occurred at the beginning of FY 2019, Treasury and many of its bureaus were unable to 

make significant progress towards meaningful barrier analysis in this area. However, in FY 2020, OCRD 

will require the bureaus to focus efforts to determine if there are barriers for women in SES positions and 

the feeder pools (GS-13 through GS-15 grades and equivalents). 

At the GS-13 grade level, the participation rate for women increased by 0.83 percent from 49.49 percent 

in FY 2009 to 50.32 percent in FY 2015. However, Treasury saw a 0.43 percent decreased participation 

rate for women at GS-13 grade level from FY 2015 (50.32 percent) to FY 2019 (49.89 percent). At the 

GS-14 grade level, the participation rate for women decreased by 0.78 percent from 47.44 percent in FY 

2009 to 46.66 percent in FY 2015; the rate increased 0.07 percent in FY 2019 to 46.73 percent. At the 

GS-15 grade level, the participation rate for women increased by 2.22 percent from 44.65 percent in FY 

2009 to 46.87 percent in FY 2015, but decreased by 1.04 percent from FY 2015 to FY 2019 (45.83 

percent). Furthermore, at the SES level, the participation rate for women increased by 4.72 percent from 

35.71 percent in FY 2009 to 40.43 percent in FY 2015, but decreased by 2.88 percent to 37.55 percent in

FY 2019.

At the GS-13 grade level, the participation rate for Hispanics increased by 0.93 percent from 6.07 percent 

in FY 2009 to 7.00 percent in FY 2015, and by FY 2019, it increased by an additional 0.64 percent to 7.64 

percent. At the GS-14 grade level, the participation rate for Hispanics increased by 1.13 percent from

4.54 percent in FY 2009 to 5.67 percent in FY 2015, and by FY 2019, it increased an additional 0.59 

percent to 6.26 percent. At the GS-15 grade level, the participation rate for Hispanics increased by 0.45

percent from 3.84 percent in FY 2009 to 4.29 percent in FY 2015, and by FY 2019, it increased an 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

7

additional 0.41 to 4.70 percent. Similarly, at the SES level, the participation rate for Hispanics increased 

by 1.12 percent from 3.57 percent in FY 2009 to 4.69 percent in FY 2015. However, the participation rate 

decreased by 0.54 percent to 4.15 percent in FY 2019 for Hispanics at the SES level.

At the GS-13 grade level, the participation rate for Blacks increased by 1.98 percent from 18.41 percent in 

FY 2009 to 20.39 percent in FY 2015, and, the rate increased an additional 0.84 percent to 21.23 percent

in FY 2019. At the GS-14 grade level, the participation rate for Blacks increased by 0.97 percent from 

17.65 percent in FY 2009 to 18.62 percent in FY 2015 and, by FY 2019, it increased an additional 1.91 

percent to 20.53 percent. At the GS-15 grade level, the participation rate for Blacks increased by 1.11 

percent, from 15.34 percent in FY 2009 to 16.45 percent in FY 2015, but decreased by 0.29 percent to 

16.16 percent in FY 2019. At the SES level, the participation rate for Blacks increased by 2.11 percent 

from 10.71 percent in FY 2009 to 12.82 percent in FY 2018, but decreased slightly by 0.37 percent in FY 

2019 (12.45 percent).

At the GS-13 grade level, the participation rate for Asians increased by 1.97 percent from 7.09 percent in 

FY 2009 to 9.06 percent in FY 2015, and by FY 2019, it increased an additional 1.07 percent to 10.13 

percent. At the GS-14 grade level, the participation rate for Asians increased by 3.38 percent from 5.81 

percent in FY 2009 to 9.19 percent in FY 2015, by FY 2019, it increased an additional 1.81 percent to 

11.00 percent. At the GS-15 grade level, the participation rate for Asians increased by 2.64 percent from

3.95 percent in FY 2009 to 6.59 percent in FY 2015, and by FY 2019, it increased an additional 1.36 

percent to 7.95 percent. At the SES level, the participation rate for Asians increased slightly by 0.04

percent from 3.75 percent in FY 2009 to 3.79 percent in FY 2015, and by FY 2019, it increased an 

additional 0.54 percent to 4.33 percent.

Because we have a trend of increased participation for all the non-White groups in the feeder pools and 

SES positions, it is then expected that we would have a trend of decreased participation for Whites. At 

the GS-13 grade level, the participation rate for Whites decreased by 4.97 percent from 67.31 percent in 

FY 2009 to 62.34 percent in FY 2015, and by FY 2019, the rate decreased further by 2.62 percent to 

59.72 percent. At the GS-14 grade level, the participation rate for Whites decreased by 5.62 percent from 

71.02 percent in FY 2009 to 65.40 percent in FY 2015, by FY 2019, the rate decreased further by 4.36

percent to 61.04 percent. At the GS-15 grade level, the participation rate for Whites decreased by 4.52

percent from 76.30 percent in FY 2009 to 71.78 percent in FY 2015, by FY 2019, the rate decreased 

further by 1.55 percent to 70.23 percent. Similarly, at the SES level, the participation rate for Whites 

decreased by 3.63 percent, from 81.61 percent in FY 2009 to 77.98 percent in FY 2015 and by 0.37

percent in FY 2019 (77.61percent).

It is important to note that when one looks at Treasury-wide data as a whole, the progress noted may not 

be an accurate reflection of the true progress of each bureau. In fact, the consolidated view of the data 

may mask where potential barriers may exist within some of the bureaus. Therefore, a detailed barrier 

analysis based on bureau specific data into possible glass ceilings, blocked pipelines, and glass walls 

must be conducted by each of the bureaus. The bureaus are required to complete detailed analysis to 

determine if any EEO groups are facing a potential glass ceiling, blocked pipeline, or glass wall, and 

based on their findings, develop plans to eliminate identified barriers. 

Additionally, throughout FY 2019, based on the joint EEOC/Office of Personnel Management (OPM)

memorandum issued January 18, 2017, Subject: Hispanics in the Federal Workplace, Treasury’s

bureaus continued to conduct focused barrier analysis on the participation rates for Hispanics within the 

major occupations and distribution in the GS grades 12 through SES levels to identify and eradicate any 

barriers to EEO, consistent with the merit system principles and applicable laws. 

Disability Employment Program

In Treasury’s FY 2009 MD-715 Report submitted to EEOC, Treasury reported a permanent workforce 

participation rate of 8.82 percent for PWD and 1.71 percent for PWTD. At the end of FY 2019, Treasury 

is pleased to note that we have exceeded the goal of a 12 percent participation rate for PWD (12.67

percent) and the goal of 2 percent for PWTD (3.49 percent). Treasury also exceeded the new hire goals 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

8

with 13.64 percent being PWD of which 3.43 percent were PWTD. 

Many of Treasury bureaus have also either met or exceeded the new goals:

FY 2019 Disability Participation Rates By Bureau

Bureau Total PWD 

#

PWD 

%

PWTD 

#

PWTD 

%

BEP 1742 288 16.53% 38 2.18%

DO 1760 161 9.15% 28 1.59%

FINCEN 275 44 16.00% 10 3.64%

FS 3305 752 22.75% 140 4.24%

IRS 74646 9186 12.31% 2730 3.66%

IRS-CC 2002 181 9.04% 43 2.15%

MINT 1544 329 21.31% 72 4.15%

OCC 3622 329 9.08% 72 1.99%

OIG 149 26 17.45% 7 4.70%

SIGT 52 5 9.62% 0 0.00%

TIGTA 732 75 10.25% 6 0.82%

TTB 490 67 13.67% 10 2.04%

Total 90319 11443 12.67% 3148 3.49%

The goals for the employment of PWD and PWTD include achieving a 12 percent participation rate for 

PWD at both the GS-10 and below and at the GS-11 and above, as well as the goal to achieve a 2 

percent participation rate for PWTD in both groups. We are pleased to note that Treasury’s current 

participation rates for PWD (14.39%) and PWTD (4.36%) at the grades GS-10 and below exceed the 

goals of 12 percent and 2 percent. 

The participation rate for PWTD (2.65%) currently exceeds the goal of a 2 percent participation rate at the 

GS-11 and above grades levels. However, the participation rates for PWD (10.86%) at the GS-11 and 

above is slightly below the 12 percent goal, indicating there is still work to be done. 

In FY 2019, OCRD implemented a resume database for veterans to assist the Department with achieving 

its hiring goals for veterans and PWD. The resume database also serves as a tool to enhance the 

Department’s “Be a Champion” initiative, which promotes the hiring of veterans and PWD in high visibility 

positions. In conjunction with the bureau audits, the Department’s Disability Program Manager and the 

Veterans Employment Coordinator used this platform to promote the Department’s “Be a Champion 

Roadshows.” The Roadshows educated Treasury’s key stakeholders on the many benefits of hiring 

veterans and PWD, including utilizing the non-competitive hire request process for veterans and 

Schedule A candidates. 

During FY 2019, Treasury continued to utilize OPM’s Talent Portal located on USAJobs as a resume 

mining database for PWD and Veterans. Using the Talent Portal provided Treasury and its bureaus’ 

hiring managers access to resumes of qualified candidates with disabilities and veterans. The use of this 

tool continues to assist Treasury in meeting its participation rate goals and encourages the use of special

hiring authorities such as Schedule A and the hiring authority for veterans with 30% or more compensable 

disability.

Also in FY 2019, OCRD partnered with IRS to procure a Treasury-wide reasonable accommodation 

tracking system to improve the timeliness and efficiency of providing reasonable accommodations (RA) to 

qualified PWD. The RA tracking system will be implemented Treasury-wide in FY 2020. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

9

OCRD has posted its Personal Assistance Service (PAS) policy and procedures to our internal and 

external websites. The external link is https://www.treasury.gov/about/organizationalstructure/offices/Mgt/Pages/eeo_programs.aspx. In addition, the Department is pleased to announce its 

newest vehicle, a Treasury-wide Blanket Purchase Agreement (BPA) to facilitate the method for fulfilling 

requests for PAS Providers nationwide. Providing PAS promotes the assurance of full access to equal 

employment opportunity (EEO) to qualifying Treasury employees with targeted disabilities.

OCRD promotes awareness on Disability topics within many of its publications: quarterly newsletters, 

OCRD Advisory, and Manager’s Alerts. Through these varied sources, the Department ensures that 

hiring managers are informed of and encouraged to use various resources and tools that provide 

assistance with the employment of PWD, e.g., CAREERS and the disABLED, OPM’s Bender Consulting 

Services, the Division of Rehabilitation Services (DORS), and State Vocational Rehabilitation Agencies.

Part E.4 - Executive Summary: Accomplishments

Accomplishments

The Department is proud of its accomplishments towards maintaining a model EEO program in FY 2019. 

The accomplishments below outline our many successes throughout the reporting period:

• Reinstituted the bureau audit program, reviewed all phases of the Mint’s and IRS’s EEO 

programs, including diversity and inclusion, external civil rights, and EEO complaint process. 

• Worked with Enterprise Data Management (EDM) and Monster Analytics to improve reporting 

capability of workforce analytics, resulting in improved data analysis capabilities around workforce 

demographics, as shown by meeting the new EEOC reporting requirements. Trained 100% of 

the bureaus in data analysis capabilities enabling bureaus to provide data on demand to 

leadership.

• Collaborated with the Office of the Chief Information Officer (OCIO) and EDM to develop 

automated diversity dashboards that will enhance leadership’s knowledge of the state of their 

workforce, help identify any areas of potential concern, and provide insight towards identifying 

where new or additional strategies may be warranted to improve overall workforce diversity and 

inclusion. These dashboards will contain the individual bureau dashboards for each bureau to 

access. The dashboards’ data will be updated each pay period and deployed in FY 2020. 

• Performed analysis of off-the-shelf commercial programs designed to improve reporting on the 

reasonable accommodation process. Partnered with the Chief Information Officer, Procurement, 

and budget to procure a Treasury-wide reasonable accommodation tracking system scheduled to 

roll out in FY 2020. 

• Held quarterly meetings with the Bureaus’ EEO Officers to discuss EEO emerging issues, best 

practices and concerns, and the various EEO programs and activities being conducted by the 

Bureaus’ EEO offices. 

• Promoted the use of the Alternative Dispute Resolution (ADR) Process to resolve EEO disputes. 

Collaborated with the bureaus’ ADR Coordinators to establish a Working Group to increase 

Treasury’s ADR participation and settlement rates. Developed a list of best practices and 

documents that bureaus could use to improve ADR participation and settlement. 

• Finalized the Blanket Purchase Agreement (BPA) for personal assistance services for all bureaus 

to use, enabling Treasury to meet EEOC expectations regarding personal assistance services for 

our severely-disabled employees.

• Closely monitored the Treasury Complaint Management System to ensure continued 

improvement in the timely production of final agency decisions and EEO investigations, resulting

in at least 94% timeliness rate for investigations and decisions.

• Updated the Department’s Sexual Harassment brochure and Procedures for Addressing 

Allegations of Discriminatory Harassment. These items were made available to our employees 

through OCRD’s internal website.

• Contracted with an additional EEO investigative services provider for back up and special 

circumstance services.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

10

• Ensured Treasury Shared Neutral (TSN) mediator trainees reach certification status and become 

active cadre members.

• As part of Treasury’s FY 2019 ADR Program, coordinated and conducted a Dispute Prevention 

training session that emphasized the benefits of ADR; provided one refresher training for current 

TSN mediators.

• Transitioned the TSN administrator functions to BEP for FY 2020 and FY 2021.

• Continued to monitor the bureau plans to identify the existence of barriers to the employment of 

any group and strategies to eliminate any barriers that are uncovered.

• Conducted training sessions with bureau MD-715 preparers on the use of the new MD-715 V2 

workforce data tables implemented as part of the FY 2019 reporting cycle.

• Updated the Department’s “Be a Champion” leadership Message which encourages managers 

and hiring officials to use special hiring authorities for increasing the participation rate for qualified 

PWTD and disabled veterans. 

• Promoted the use of Operation Warfighter Internships as a tool to increase the hiring of veterans 

with disabilities.

• Exceeded EEOC’s goal that 12 percent of all new permanent hires be PWD (14.17 percent) and 

the sub goal that 2 percent of those hires be PWTD (3.15 percent).

• Established a cadre of 21 certified trainers to assist the Department in providing Civil Treatment 

Training to the workforce. The cadre trained 25 managers at 6 bureaus.

• Published four OCRD Advisory Newsletters to the workforce and two Manager’s Alerts to 

managers and supervisors on information relevant to EEO complaint program matters, changes 

to policy and/or procedures, workforce statistics, and important upcoming agency 

events/activities. 

• Supported Special Emphasis Programs with education and awareness through the use of 

newsletters, trainings, and activities such the annual interagency Pride in Federal Service’s first 

Lesbian Gay Bisexual Transgender and Queer Plus (LGBTQ+) and Ally Conference; Treasury 

Holocaust Day of Remembrance at the Lincoln Theater and Martin Luther King, Jr. Treasury-wide 

Breakfast.

Part E.5 - Executive Summary: Planned Activities

Planned Activities/Conclusion

The Department of the Treasury’s FY 2019 MD-715 Report outlines the many successes in our equal 

opportunity programs and activities. The Department is proud of its accomplishments in the areas of 

attracting and retaining an increasingly diverse workforce. However, there is an unremitting effort to 

increase workforce diversity, specifically within our mission critical occupations, in senior pay levels and 

feeder groups, and to improve the hiring and promotion rates of women, Hispanics, individuals with 

disabilities/targeted disabilities. As we move forward into the next fiscal year, we will maintain our focus 

on developing plans to ensure Treasury and its bureaus have the broadest group of diverse, well-qualified 

talent from which to recruit.

OCRD’s FY 2020 planned activities include the following:

• Implement the Treasury-wide Reasonable Accommodation (RA) Tracking System to improve the 

timeliness and efficiency of providing reasonable accommodations for qualified persons with 

disabilities and improve ability to track data around RA.

• Partner with the Bureau EEO Officers to develop and establish a multi-year Treasury-wide EEO 

Strategic Plan. 

• Continue the bureau audit program, reviewing at least two bureaus in all phases of their EEO 

programs, including diversity and inclusion, external civil rights, and EEO complaint process.

• Partner with OCIO, Procurement, and budget to plan for acquisition of a new EEO Complaint 

Tracking System to produce EEO reports and transfer data between users more efficiently.

• Promote the use of the Alternative Dispute Resolution (ADR) Process to resolve EEO disputes. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

11

• Evaluate the effectiveness of the Treasury Shared Neutrals Program and make improvements. 

• Hold quarterly meetings with the Bureau EEO Officers to discuss EEO emerging issues, best 

practices and concerns, and the various EEO programs and activities being conducted by the 

Bureau EEO offices. 

• Partner with external and internal stakeholders to help generate diverse and qualified pools of 

candidates to fill mission-critical occupations; and, design and conduct targeted activities to 

promote individuals from all backgrounds, including sponsoring attendance in at least three job 

fairs designed to improve diversity, and veterans and disability hiring. 

• Meet customer training needs by: 1) Expanding the Department’s Training Cadre and 

Curriculum; 2) providing at least one webinar or management alert each quarter to increase 

awareness; 3) exploring on-line training or train-the-trainer opportunities on cultural competencies 

for bureau use (e.g., coordinate implementation plan for LGBTQ Cultural Competency Course 

and ensure an advertising campaign during the months related to LGBTQ Observances). 

• Develop a communications and marketing plan that ensures managers and employees are 

educated on the Treasury personal assistance services (PAS) policy and procedures pursuant to 

the implementation of Treasury-wide PAS contract. 

• Improve Treasury’s external and internal websites related to EEO programs resulting in clear, 

accurate, informative, and user-friendly content.

• Evaluate Treasury’s New Inclusion Quotient (IQ) Employee Viewpoint Survey (EVS) scores and 

participate in HR roundtables.

• Implement a customer satisfaction survey measuring effectiveness of EEO and D&I programs.

• Evaluate whether changes to SES processes as a result of the barrier analysis study have an 

impact on the diversity of the SES cadre.

EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

13

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 MD-715'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 agency-wide/parent agency’s report should also include that “No” 

response.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

 

MD-715 - PART G

Agency Self-Assessment Checklist

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

This element requires the agency head to communicate a commitment to equal employment opportunity 

and a discrimination-free workplace.

Compliance 

Indicator

Measures

A.1 – The agency issues an effective, upto-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)]

No Issued 10/2/2019

A.1.b Does the EEO policy statement address all 

protected bases (age, color, disability, sex 

(including pregnancy, sexual orientation and 

gender identity), genetic information, national 

origin, race, religion, and reprisal) contained 

in the laws EEOC enforces? [see 29 CFR § 

1614.101(a)] 

Yes Policy also covers parental 

status.

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: 

Yes

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 Treasury displays the name 

and contact information for 

bureau EEO officers. Bureaus 

display the specific bureau 

contact information. However, 

at each Treasury bureau,

counseling is centralized. 

Therefore, bureaus post 

general contact information on

who to contact to initiate a 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

complaint. 

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

A.2.b.3 Reasonable accommodation procedures? 

[see 29 C.F.R. § 1614.203(d)(3)(i)] If so, 

please provide the internet address in the 

comments column.

Yes https://www.treasury.gov/about

/organizationalstructure/offices/Mgt/Documen

ts/FY%202012%20Interim%20

Reasonable%20Accommodati

on%20Policy%20and%20Proc

edures.pdf

 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 It is posted on both the internal 

and external websites, 

discussed as part of new 

employee and manager 

orientation sessions, and it is 

posted in common 

areas/breakrooms. 

Additionally, every two years 

as part of the No FEAR Act 

training, the information is 

shared with employees. 

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

“yes”, please provide how often. 

Yes It is posted on both the internal 

and external websites and 

discussed as part of new 

employee and manager 

orientation sessions. 

Additionally, Treasury 

conducts an annual Conflict 

Resolution week which 

highlights the importance of 

ADR and conflict resolution.

A.2.c.3 Reasonable accommodation program? [see

29 CFR § 1614.203(d)(7)(ii)(C)] If “yes”, 

please provide how often. 

Yes It is posted on both the internal 

and external websites and 

discussed during new 

employee and manager 

orientation sessions. 

Additionally, every two years 

as part of the No FEAR Act

training, the information is 

shared with employees. 

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 It is posted on both the internal 

and external websites and 

discussed during new 

employee and manager 

orientation sessions. 

Additionally, every two years 

as part of the No FEAR Act 

training and annually as part of 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Prevention of Sexual 

Harassment (POSH) training. 

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 It is discussed in new 

employee and manager 

orientation sessions, included

as part of the No FEAR Act 

training conducted every two 

years, and provided annually 

as part of the POSH training. 

Compliance 

Indicator 

Measures

A.3 – The agency assesses and ensures 

EEO principles are part of its culture.

Measure 

Met?

(Yes/No/NA)

Comments

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 Bureaus identified the Annual 

Rittenhouse Award, 

performance awards 

(mandatory diversity and 

inclusion (D&I) and 

supervisory performance 

goals), monetary and nonmonetary group, and individual 

spot awards.

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

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 dayto-day control over the EEO office? [see 29 

CFR §1614.102(b)(4)]

No

B.1.a.1 If the EEO Director does not report to the 

agency head, does the EEO Director report 

to the same agency head designee as the 

mission-related programmatic offices? If 

“yes,” please provide the title of the agency 

head designee in the comments.

Yes OCRD’s Director reports to the 

Assistant Secretary for 

Management. 

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 Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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] 

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 OCRD presented the FY 2018 

State of the Agency (SOA) 

briefing to Agency Head

designee on 04/30/2019. 

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

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 Bureau EEO Officers are 

responsible for counseling in 

connection with their 

respective bureau EEO 

complaints of discrimination. 

B.2.c Is the EEO Director responsible for 

overseeing the fair and thorough 

investigation of EEO complaints? [see 29 

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

be applicable for certain subordinate level 

components.]

Yes

B.2.d Is the EEO Director responsible for 

overseeing the timely issuance 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 

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

program and providing recommendations for 

improvement to the agency head? [see 29 

CFR §1614.102(c)(2)]

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)]

Yes

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 Treasury’s Strategic Goal 

5.1.C 

Improve diversity and 

engagement through 

transparency, fairness, and 

inclusion.

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 MD715, II(D)]

Yes

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

barrier analysis of its workforce? [see MD715, 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 program, including 

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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)]

Yes

B.4.a.6 to publish and distribute EEO materials (e.g. 

harassment policies, EEO posters, 

reasonable accommodations procedures)?

[see MD-715, II(B)]

Yes

B.4.a.7 to maintain accurate data collection and 

tracking systems for the following types of 

data: complaint tracking, workforce 

demographics, and applicant flow data? [see 

MD-715, II(E)]. If not, please identify the 

systems with insufficient funding in the 

comments section.

Yes

B.4.a.8 to effectively administer its special emphasis 

programs (such as, Federal Women’s 

Program, Hispanic Employment Program, 

and People with Disabilities Program 

Manager)? [5 USC § 7201; 38 USC § 4214; 

5 CFR § 720.204; 5 CFR § 213.3102(t) and 

(u); 5 CFR § 315.709]

Yes

B.4.a.9 to effectively manage its anti-harassment 

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

EEOC Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment 

by Supervisors (1999), § V.C.1]

Yes

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

B.4.e Does the agency ensure that all experienced 

counselors and investigators, including 

contractors and collateral duty employees, 

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

receive the required 8 hours of annual 

refresher training, pursuant to Ch. 2(II)(C) of 

MD-110?

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

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

all managers and supervisors received 

training on their responsibilities under the 

following areas under the agency EEO 

program:

B.5.a.1 EEO Complaint Process? [see MD715(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 MD715(II)(E)]

Yes

Compliance 

Indicator 

Measures

B.6 – The agency involves managers in 

the implementation of its EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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.

Yes Annually and before the 

submission of the bureau MD715 reports to EEOC, OCRD 

evaluates their submissions 

and provides feedback on the 

status of deficiencies, 

implementation of planned 

activities to mitigate 

deficiencies, and recommends 

additional measures required 

to mitigate noted deficiencies.

In FY 2019, OCRD conducted 

an audit review of Mint’s (May 

- June) and IRS’s (July -

September) EEO, civil rights, 

and diversity and inclusion 

programs. Additionally, OCRD 

will conduct an Audit of 

FinCEN’s, BEP’s, and DO’s 

EEO Programs during FY 

2020.

C.1.b Does the agency regularly assess its 

component and field offices on their efforts to 

remove barriers from the workplace? [see 29 

CFR §1614.102(c)(2)] If ”yes”, please 

provide the schedule for conducting audits in 

the comments section.

Yes Annually and before the 

submission of the bureau MD715 reports to EEOC, OCRD 

evaluates their submissions 

and provides feedback on the 

status of deficiencies, 

implementation of planned 

activities to mitigate 

deficiencies and recommends 

additional measure required to 

mitigate noted deficiencies. In 

FY 2019, OCRD conducted an 

audit review of Mint’s (May -

June) and IRS’s (July -

September) EEO, civil rights, 

and diversity and inclusion 

programs. Additionally, OCRD 

will conduct an Audit of 

FinCEN’s, BEP’s and DO’s 

Programs during FY 2020.

C.1.c Do the component and field offices make 

reasonable efforts to comply with the 

recommendations of the field audit? [see 

MD-715, II(C)] 

Yes Following an Audit (within 6 

months), bureaus are required 

to submit a compliance report 

to OCRD.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures

C.2 – The agency has established 

procedures to prevent all forms of EEO 

discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

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 Anti-Harassment Coordinator 

and the EEO Director? [see EEOC Report, 

Model EEO Program Must Have an Effective 

Anti-Harassment 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

C.2.a.4 Does the agency ensure that the EEO office 

informs the anti-harassment program of all 

EEO counseling activity alleging 

harassment? [see Enforcement Guidance, 

V.C.]

Yes

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 The Bureau of Fiscal Service 

(FS) and Office of the 

Comptroller of the Currency 

(OCC) reported that they did 

not promptly conduct all 

inquiries within 10 days of 

notification. FS completed a 

PART H that will be submitted 

as part of their MD-715 report. 

OCC provided a comment on 

its PART G that the untimely 

initiation of inquiries was an 

anomaly due to extenuating 

circumstances for FY 2019 

and no PART H would be

prepared.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

C.2.a.6 Do the agency’s training materials on its antiharassment 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 procedures that 

comply with EEOC’s regulations and 

guidance? [see 29 CFR 1614.203(d)(3)]

No All Treasury bureaus, with the 

exception of IRS and TTB, 

reasonable accommodation 

(RA) policies have been 

updated, reviewed, and 

approved by OCRD. Those 

revisions were submitted to 

EEOC for review and 

approval. EEOC approved 

OCC’s revised RA Policy and 

Procedures on 08/20/2019. In 

the interim, Treasury has 

directed bureaus to post 

interim policies and 

procedures pending EEOC’s 

approval. Once approved, 

bureaus will replace their

interim policies and 

procedures with the EEOC 

approved RA policies and 

procedures. 

C.2.b.1 Is there a designated agency official or other 

mechanism in place to coordinate or assist 

with processing requests for disability 

accommodations throughout the agency?

[see 29 CFR 1614.203(d)(3)(D)]

Yes

C.2.b.2 Has the agency established a firewall 

between the Reasonable Accommodation 

Program Manager and the EEO Director? 

[see MD-110, Ch. 1(IV)(A)]

Yes

C.2.b.3 Does the agency ensure that job applicants 

can request and receive reasonable 

accommodations during the application and 

placement processes? [see 29 CFR 

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

Yes

C.2.b.4 Do the reasonable accommodation 

procedures clearly state that the agency 

should process the request within a 

maximum amount of time (e.g., 20 business 

days), as established by the agency in its 

affirmative action plan? [see 29 CFR 

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

Yes

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.

No IRS reported that it timely 

processed 23% of its requests. 

IRS has prepared a PART H in 

their MD-715 report that 

addresses this matter. 

C.2.c Has the agency established procedures for Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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)]

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.treasury.gov/about

/organizationalstructure/offices/Mgt/Documen

ts/PAS-Policy-andProcedures-as-OCT-2018.pdf

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

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

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 MD715 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 

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715, II(C)]

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 MD715, 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

Compliance 

Indicator 

Measures

C.4 – The agency ensures effective 

coordination between its EEO programs 

and Human Resources (HR) program.

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 with access to other data (e.g., exit 

interview data, climate assessment surveys, 

and grievance data), upon request? [see 

MD-715, II(C)]

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

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.

Yes Three employees: two based 

on decisions from FAD’s and 

one from a civil court case. 

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)]

Yes

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 

Yes The OCRD Director updates 

the Assistant Secretary for

Management (ASM) as issues 

arise. The OCRD Director 

also participates in the ASM’s 

bi-weekly senior staff 

meetings. Additionally, 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Instructions, Sec. I] If “yes”, please identify 

the frequency of the EEO updates in the 

comments column.

diversity dashboards on 

Treasury and individual 

bureaus workforce 

demographics are provided to 

the ASM and Secretary on at 

least an annual basis.

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; anti-harassment 

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 questions on how the 

agency could improve the recruitment, hiring, 

inclusion, retention and advancement of 

individuals with disabilities? [see 29 CFR 

1614.203(d)(1)(iii)(C)]

Yes

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

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 

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

§1614.102(a)(3)]

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; anti-harassment 

program; and/or external special interest 

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

“yes”, please identify the data sources in the 

comments column.

Yes Complaint data through 

iComplaints and workforce 

data and exit survey data 

through Workforce and 

Monster Analytics. Information 

regarding Unions, reasonable 

accommodations, antiharassment, as well as any 

other required information is 

provided by the bureaus’ EEO 

and HR personnel upon 

request. 

Compliance 

Indicator 

Measures

D.3 – The agency establishes appropriate 

action plans to remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

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

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

D.4.a

Does the agency post its affirmative action 

plan on its public website? [see 29 CFR 

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

address in the comments.

Yes https://www.treasury.gov/about

/organizationalstructure/offices/Mgt/Pages/Aff

irmative-Action-Plan.aspx

D.4.b

Does the agency take specific steps to 

ensure qualified people with disabilities are 

aware of and encouraged to apply for job 

vacancies? [see 29 CFR 1614.203(d)(1)(i)]

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

D.4.c

Does the agency ensure that disabilityrelated questions from members of the public 

are answered promptly and correctly? [see 

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

Yes

D.4.d

Has the agency taken specific steps that are 

reasonably designed to increase the number 

of persons with disabilities or targeted 

disabilities employed at the agency until it 

meets the goals? [see 29 CFR 

1614.203(d)(7)(ii)]

Yes

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

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 Treasury benchmark is to 

issue acceptance or dismissal 

letters no more than 30 days 

from file date.

FY 2019 Averages: 

Acceptance letters were 

issued on average in 15 days; 

and Dismissal letters were 

issued on average in 24 days.

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

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 Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

hearing, does the agency timely issue the 

final agency decision, pursuant to 29 CFR 

§1614.110(b)?

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 MD110, Ch. 5(V)(A)] If “yes”, please describe 

how in the comments column.

Yes OCRD conducts bi-weekly 

meetings to review current 

status of all cases, discuss any 

instance where a case may be 

untimely and the reason for 

the untimeliness, and ensure 

there are no systemic 

problems in the process.

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

Compliance 

Indicator 

Measures

E.2 – The agency has a neutral EEO 

process.

Measure 

Met?

(Yes/No/NA)

Comments

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 Legal sufficiency reviews are 

completed in Treasury’s Office 

of General Counsel by an 

attorney who is not 

representing the Agency in the 

particular matter.

E.2.c If the EEO office relies on the agency’s 

defensive function to conduct the legal 

sufficiency review, is there a firewall between 

the reviewing attorney and the agency 

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

Yes

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 Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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)]

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

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 MD110, 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 MDYes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

715, II(E)]

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

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

Yes Treasury recently procured a 

Treasury-wide system to 

process and track reasonable 

accommodation requests. The 

system is scheduled to go live 

in FY 2020. 

E.4.a.6 The processing of complaints for the antiharassment program? [see EEOC 

Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment 

by Supervisors (1999), § V.C.2]

Yes

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 EEOC annual reports, 

Complaint data, RA 

processing, exit survey results, 

FEVS results, analysis of 

workforce data by ERI, 

gender, disability, grades, 

occupation, hires, separations, 

awards, etc.

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 Development of Workforce 

Analytics, Treasury’s 

automated data tool; Treasurywide exit survey and analysis 

tool; Veteran and Disability 

Program “Be a Champion 

Roadshow”; use of internship 

program to establish a pipeline 

of diverse candidates for future 

employment; and, Veteran 

resume data base. 

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

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 MD715, 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

F.2.a Does the agency timely respond and fully 

comply with EEOC orders? [see 29 CFR 

§1614.502; MD-715, II(E)]

Yes

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

F.3 - The agency reports to EEOC its 

program efforts and accomplishments.

Measure 

Met?

(Yes/No/NA)

Comments
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

 

Measures

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY 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

C.2.b

Has the agency established disability reasonable accommodation 

procedures that comply with EEOC’s regulations and guidance? [see 29 

CFR 1614.203(d)(3)]

As part OF EEOC’s feedback on Treasury and it’s bureaus FY 2017 

affirmative action plans, EEOC identified that Treasury and some of its 

bureaus RA policies and procedures had not been reviewed and approved 

based on changes required by the updated 29 CFR 1614.203.

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)

10/01/2018

Ensure Treasury and its bureaus RA policies 

and procedures are in compliance with EEOC 

requirements and submitted to EEOC for final 

approval.

9/30/2019 9/30/2020

Responsible Official(s)

Title Name

Performance 

Standards 

Address the Plan?

(Yes or No)

Director, OCRD Mariam Harvey Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY 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)

08/30/2018

Require bureaus to submit updated RA policies 

and procedures to OCRD for review and 

comment.

Yes

08/24/2018

09/07/2018

OCRD will review bureau RA policies and 

procedures and make any recommended 

changes. Those RA policies and procedures

requiring change will be returned to the 

appropriate bureau for corrections. 

Yes

09/07/2018

01/30/2018

Once bureau RA policies and procedures are 

approved by OCRD, they will be submitted to 

EEOC for review and final approval. 

Yes

01/30/2018

03/30/2018

Pending EEOC’s final approval of bureau RA 

policies and procedures, Bureaus will post 

interim RA policies and procedures to internal 

and external websites.

Yes

09/30/2020

03/30/2019

Once RA policies and procedures are approved 

by EEOC, bureaus post their EEOC approved 

RA policies and procedure to their internal and 

external. 

Yes

09/30/2020

Report of Accomplishments 

Fiscal Year Accomplishments

2018

To date, OCRD has submitted the revised bureau RA policies and 

procedures to EEOC for BEP, FS, DO, IRS, Mint, OCC and TIGTA. EEOC 

reviewed and provided feedback to OCC on its RA policies and procedures. 

OCC resubmitted with revisions. OCRD continues to work with FinCEN, 

IRS-CC, OIG, SIGTARP, and TTB to finalize the revisions to their RA 

Policies and procedures. 

2019

OCRD has submitted all bureau RA policies and procedures to EEOC with 

the exception of IRS. EEOC approved OCC’s revisions for its RA policy and 

procedures. OCRD is currently working with IRS to finalize their revisions 

and the RA policy and procedures. Once finalized, OCRD will submit to 

EEOC for final review and approval. OCRD is currently waiting for EEOC’s 

approval of the remaining bureaus.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY 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

C.2.b.5

Does the agency process all accommodation requests within the time 

frame set forth in its reasonable accommodation (RA) procedures? [see

MD-715, II(C)]. 

IRS reported that it processed 31% of RA requests within the time frame 

set forth in its revised RA procedures.

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)

10/01/2018 Ensure initiation of inquiries processing of IRS 

reasonable accommodation requests.

9/30/2019 9/30/2020

02/17/2019 Establish and implement a Treasury-wide 

reasonable accommodation tracking system.

9/30/2019 9/30/2020

Responsible Official(s)

Title Name

Performance 

Standards 

Address the Plan?

(Yes or No)

Director, OCRD Mariam Harvey 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)
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Target 

Date 

(mm/dd/yyyy)

Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

9/30/2019

Monitor implementation of IRS’s planned

activities to eliminate untimely processing of RA 

requests.

Yes 9/30/2020

04/30/2019 Allocate budget for Treasury-wide RA tracking 

system. Yes 04/04/2019

09/30/2019 Initiate procurement process to compete and 

award a RA tracking system contract. Yes 09/24/2019

04/30/2020 Train RA Coordinators and transition bureaus to 

new RA Tracking system. Yes

05/29/2020 Implement RA tracking system. Yes

Report of Accomplishments 

Fiscal Year Accomplishments

2018 N/A

2019

IRS did not improve its timely processing of RA cases in FY 2019 (23% 

timely processed). As part of OCRD’s oversight, an audit was conducted of 

IRS’ EEO program from July to August 2019. Part of OCRD’s findings was 

the untimely processing of RA requests. As a recommendation for 

corrective action, OCRD encouraged IRS to complete a Lean Sigma 6 study 

of its current processes to determine where process improvements need to 

be made to ensure the timely processing of accommodation requests.

OCRD secured required funding for Treasury-wide RA tracking system and 

awarded the contract to MicroPact.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY 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

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)

10/01/2019

Ensure Treasury and its bureaus conduct a 

prompt inquiry (beginning within 10 days of 

notification) of all harassment allegations, 

including those initially raised in the EEO 

complaint process.

9/30/2020

Responsible Official(s)

Title Name

Performance 

Standards 

Address the Plan?

(Yes or No)

Director, OCRD Mariam Harvey Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY 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)

10/01/2019

Monitor implementation of FS and OCC’s

planned activities to ensure prompt initiation 

(beginning within 10 days of notification) of all 

harassment allegations, including those initially 

raised in the EEO complaint process.

Yes

10/01/2020

In FY 2020, OCRD will explore the procurement 

of a Treasury-wide Anti-Harassment Tracking 

System.

Yes

Report of Accomplishments 

Fiscal Year Accomplishments
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 rates for Women in the GS 13-15 and 

SES grade levels in the overall Treasury-wide workforce.

EEO Group(s) Affected by Trigger

EEO Group

All Men

X 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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Barrier Analysis Process

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes

A-1: Review of overall workforce participation rate for 

Women (61.56 percent in FY 2019) falls below the 

RCLF availability rate (64.98 percent).

A4-1: At the GS-13 grade level, the participation rate 

for women increased by 0.83 percent from 49.49 

percent in FY 2009 to 50.32 percent in FY 2015. 

However, Treasury saw a 0.43 percent decreased 

participation rate for women at GS-13 grade level from 

FY 2015 (50.32 percent) to FY 2019 (49.89 percent). 

At the GS-14 grade level, the participation rate for 

women decreased by 0.78 percent from 47.44 percent 

in FY 2009 to 46.66 percent in FY 2015; the rate 

increased 0.07 percent in FY 2019 to 46.73 percent. At 

the GS-15 grade level, the participation rate for women 

increased by 2.22 percent from 44.65 percent in FY 

2009 to 46.87 percent in FY 2015, but decreased by 

1.04 percent from FY 2015 to FY 2019 (45.83 percent). 

Furthermore, at the SES level, the participation rate for 

women increased by 4.72 percent from 35.71 percent 

in FY 2009 to 40.43 percent in FY 2015, but decreased 

by 2.88 percent to 37.55 percent in FY 2019.

A6: A review of the Treasury workforce broken down 

by the major occupations shows that of the 13 most 

populous major occupations, the Women participation 

rate falls below the Occupational CLF (OCLF) 

availability rate in the following series:

• 0301, Miscellaneous Administration and 

Program, Women participation (60.18 

percent) falls below the OCLF availability 

rate of 63.30 percent;

• 0340, Program Management, Women 

participation (58.36 percent) falls below the 

OCLF availability rate of 63.30 percent;

• 0512, Internal Revenue Agent, Women 

participation (53.24 percent) falls below the 

OCLF availability rate of 64.20 percent;

• 0570, Financial Institution Examining, 

Women participation (38.38 percent) falls 

below the OCLF availability rate of 45.30 

percent;

• 0962, Contact Representative, Women 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

participation (71.71 percent) falls below the 

OCLF availability rate of 82.10 percent; 

and 

• 1169, Internal Revenue Officer, Women 

participation (57.95 percent) falls below the 

OCLF availability rate of 64.20 percent.

A4-1: Reviewing Table A4-1 for each occupation 

identified in the A6 Table as having lower than 

expected participation rates for Women:

• 0301, Miscellaneous Administration and 

Program

At the GS-13 grade level, the participation 

rate for Women (61.43 percent) exceeds 

the availability rate (60.18 percent); 

however, at the GS-14, 15, and SES grade 

levels, the participation rate for Women 

(58.15 percent, 44.18 percent, and 22.94 

percent respectively) fall below the 

availability rate of 60.18 percent.

• 0340, Program Management

At the GS-13 grade level, the participation 

rate for Women (65.52 percent) exceeds 

the availability rate (58.36 percent); 

however, at the GS-14, 15, and SES grade 

levels, the participation rate for Women 

(57.46 percent, 51.58 percent, and 45.83 

percent respectively) fall below the 

availability rate of 58.36 percent.

• 0512, Internal Revenue Agent

At the GS-13, 15, and SES grade levels, 

the participation rate for Women (53.57 

percent, 53.33 percent, and 100.00 

percent respectively) exceeds the 

availability rate (53.24 percent); however, 

at the GS-14 grade level, Women 

participation (47.09 percent) falls below the 

availability rate of 53.24 percent.

• 0570, Financial Institution Examining

At the GS-13 and 15 equivalent grade 

levels, the participation rate for Women 

(39.80 percent and 40.19 percent 

respectively) exceeds the availability rate 

(38.38 percent); however, at the GS-14 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

and SES equivalent grade levels, the 

participation rate for Women (37.31 

percent and 27.59 percent respectively) 

falls below the availability rate of 38.38 

percent.

• 0962, Contact Representative

There are no positions in Treasury in the 

0962 series at the GS-13 and above grade 

level. All positions in the 0962 series are 

GS-11 and below.

• 1169, Internal Revenue Officer

At the GS-13 and 14 grade levels, the 

participation rate for Women (54.96 

percent and 47.52 percent respectively) fall 

below the availability rate (57.95 percent); 

however, at the GS-15 grade level, the 

participation rate for Women (60.00 

percent) exceeds the availability rate of 

57.95 percent. There are no positions for 

the 1169 series at the SES level.

A7-1: A review of the new A7-1 Table shows the new 

hire and internal competitive promotions for GS-13

through 15 and SES grade levels.

GS-13

New Hires: For GS-13 new hires, the 

participation rate for Women applicants was 

43.19 percent, which fell to 42.50 percent at 

the qualified stage of the application process. 

The participation rate for Women continued to 

fall at the referred stage of the process where 

the participation rate for Women was 39.88 

percent. The participation rate for Women 

increased at the interviewed stage of the 

process (48.59 percent), but fell again to 45.18 

percent at the selected stage.

Internal Competitive Promotions: For GS-13 

internal competitive promotions, the 

participation rate for Women applicants was 

64.27 percent, and stayed at 64.14 percent at 

the qualified stage. The participation rate 

dropped at the referred stage to 62.17 percent, 

and fell again at the interviewed stage (61.47 

percent) but increased at the selection stage to 

62.27 percent.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

GS-14

New Hires: For GS-14 new hires, the 

participation rate for Women applicants was 

40.11 percent, which decreased slightly to

40.01 percent at the qualified stage of the 

application process. The participation rate for 

Women dropped at the referred stage of the 

process to 39.54 percent. The participation 

rate for Women increased at the interviewed 

stage of the process (46.76 percent), and 

dropped again to 40.18 percent at the selected 

stage.

Internal Competitive Promotions: For GS-14 

internal competitive promotions, the 

participation rate for Women applicants was 

56.68 percent, and slightly increased to 57.65 

percent at the qualified stage. The 

participation rate remained at 57.25 percent at 

the referred stage, and increased at the 

interviewed stage (64.75 percent). The 

participation rate decreased at the selection 

stage to 57.81 percent.

GS-15

New Hires: For GS-15 new hires, the 

participation rate for Women applicants was 

31.65 percent, which reduced to 31.03 percent 

at the qualified stage of the application 

process. The participation rate for Women 

increased at the referred stage of the process 

to 35.94 percent. The participation rate for 

Women increased at the interviewed stage of 

the process (50.00 percent), and dropped 

again to 46.50 percent at the selected stage.

Internal Competitive Promotions: For GS-15 

internal competitive promotions, the 

participation rate for Women applicants was 

49.55 percent, and increased to 52.73 percent 

at the qualified stage. The participation rate 

increased again to 54.07 percent at the 

referred stage, and decreased at the 

interviewed stage (35.71 percent). The 

participation rate increased at the selection 

stage to 62.50 percent.

SES
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

New Hires: For SES new hires, the 

participation rate for Women applicants was 

33.31 percent, which reduced to 32.63 percent 

at the qualified stage of the application 

process. The participation rate for Women 

continued to decrease at the referred stage of 

the process where the participation rate for 

Women was 30.35 percent. The participation 

rate for Women increased at the interviewed 

stage of the process (55.26 percent), and 

dropped again to 45.24 percent at the selected 

stage.

A8: A review of new hire workforce data shows that in 

FY 2019, 60.35 percent of Treasury new hires were 

Women, falling below the RCLF availability rate of 

64.98 percent. 

A8S: A review of new hire data by those major 

occupations identified in the A6 and A4-1 shows that:

• 0301, Miscellaneous Administration and 

Program

At the GS-13, 14, 15, and SES grade 

levels, the participation rate for Women 

new hires (58.82 percent, 16.67 percent, 

30.77 percent, and 15.00 percent 

respectively) fall below the OCLF 

availability rate of 63.30 percent. 

• 0340, Program Management

In FY 2019, all hires in the 0340 series 

were at the SES grade level. Of those 

hires, 23.08 percent were Women, falling 

below the OCLF availability rate of 63.30 

percent.

• 0512, Internal Revenue Agent

At the GS-13 grade level, the participation 

rate for Women new hires (61.40 percent) 

fell below the OCLF availability rate of 

64.20 percent. There were no hires for the 

GS-14 and above grade levels.

• 0570, Financial Institution Examining

At the GS-13 equivalent grade level, the 

participation rate for Women new hires 

(50.00 percent) exceeded the OCLF 

availability rate (45.30 percent). At the 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

GS-14 and 15 equivalent grade levels, the 

participation rate for Women new hires 

(20.00 percent and 0.00 percent 

respectively) fell below the OCLF 

availability rate (45.30 percent).

• 1169, Internal Revenue Officer

In FY 2019, the participation rate for 

Women new hires (60.00 percent) fell 

below the OCLF availability rate of 64.20 

percent.

A14: Review of separation data for the Treasury 

workforce shows that 70.59 percent of all Involuntary 

separations were Women, exceeding the workforce 

availability rate of 61.56 percent. Similarly, 64.72 

percent of all voluntary separations were Women, 

which also exceeds the workforce availability rate 

(61.56 percent). 

A14S2: A review of new separation data by those 

major occupations identified in the A6 and A4-1 shows 

that:

• 0301, Miscellaneous Administration and 

Program

At the GS-13, 14, 15, and SES grade 

levels, the participation rate for Women 

separations (55.88 percent, 52.78 percent, 

48.72 percent, and 25.00 percent 

respectively) fall below the availability rate 

of 60.18 percent. 

• 0340, Program Management

At the GS-13, 14, and SES grade levels, 

the participation rate for Women 

separations (75.00 percent, 66.67 percent, 

and 62.50 percent respectively) exceed the 

availability rate of 58.36 percent. At the 

GS-15 grade levels, the participation rate 

for Women separations (48.78 percent) 

falls below the availability rate (58.36 

percent).

• 0512, Internal Revenue Agent

At the GS-13 and 14 grade levels, the 

participation rate for Women separations 

(45.24 percent and 48.85 percent) fall 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

below the availability rate of 53.24 percent. 

At the GS-15 grade level, the participation 

rate for Women separations (100.00 

percent) exceeded the availability rate of 

53.24 percent.

• 0570, Financial Institution Examining*

At the GS-13, 14, 15, and SES grade 

levels, the participation rate for Women 

separations (39.68 percent, 41.38 percent, 

38.89 percent, and 66.67 percent 

respectively) exceed the availability rate 

(38.38 percent). 

• 0962, Contact Representative

In FY 2019, all separations in the 1169 

series were in the GS-11 and below grade 

levels.

• 1169, Internal Revenue Officer

At the GS-13 grade level, the participation 

rate for Women separations (44.19 

percent) fell below the availability rate 

(57.95 percent); however, at the GS-14 

and 15 grade levels, the participation rate 

for Women separations (66.67 percent and 

100.00 percent respectively) exceeded the 

availability rate (57.95 percent).

Complaint Data (Trends) Yes

In FY 2019, 395 formal complaints were filed with the 

Department; of those 395, 85 (21.52 percent) identified 

Sex (Female) as one of the bases for the complaint.

In FY 2019, of the 76 complaints that reached 

Settlement, 16 (21.05 percent) identified Sex (Female) 

as one of the basis for the complaint.

Grievance Data (Trends) No

Findings from Decisions (e.g., 

EEO, Grievance, MSPB, AntiHarassment Processes) No

Climate Assessment Survey 

(e.g., FEVS) No

Exit Interview Data No

Focus Groups No
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

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 No

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

Barrier Analysis not yet identified.

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)

Increase participation rates for 

Women in the GS-13 through 

15 and SES grade levels.

09/01/2019 09/30/2021 Yes

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan? 

(Yes or No)

Director, OCRD Mariam Harvey Yes

Planned Activities Toward Completion of Objective

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

12/30/2019 Reach out to EEO Officers for those bureaus 12/20/2019
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Target Date 

(mm/dd/yyyy) Planned Activities Modified Date (mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

(DO and IRS) with noted decrease in the 

participation rate of Women in SES and GS15 feeder pools to request a barrier analysis 

study be implemented in FY 2020.

06/30/2020

Review Exit Interview and FEVS data results 

for FY 2015 through FY 2020 to identify 

trends for Women perceptions in the 

workforce.

07/30/2020

Reach out to Bureau EEO Officers to 

coordinate with their HR Offices to identify 

Grievance data trends for FY 2018 through

FY 2020.

09/30/2020

Identify a high level Treasury Barrier Analysis 

Team, a working group that leverages the 

expertise of members of the OCRD, Human 

Resources, and Bureau EEO Offices to more 

closely identify barriers to Women 

participation in the GS-13 and above grade 

levels.

12/30/2020

Treasury Barrier Analysis Team will create a 

plan that guides critical phases (analysis, 

methods, resources, senior leadership 

support). 

03/30/2021 Treasury Barrier Analysis Team will 

implement plan. 

05/31/2021 Treasury Barrier Analysis Team will collect 

data. 

07/30/2021 Treasury Barrier Analysis Team will analyze 

and report data.

09/30/2021

Treasury Barrier Analysis Team create 

additional action plan to eliminate identified 

barrier(s). 

09/30/2021 Clarify next steps.

Report of Accomplishments 

Fiscal Year Accomplishments
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715 – Part J

Special Program Plan for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities

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

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

describe how their plan will improve the recruitment, hiring, advancement, and retention of applicants and 

employees with disabilities. All agencies, regardless of size, must complete this Part of the MD-715 

report. 

Section I: Efforts to Reach Regulatory Goals

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

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

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

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

text box.

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

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

The participation rate for PWD at the GS-11 to SES grade cluster is 10.86% for FY 2019, which falls 

below the 12% goal.

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

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

text box.

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

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

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

and/or recruiters.

The Department provides Treasury’s leadership updates on the participation, grade distribution, hiring, 

and separations of PWD and PWTD, allowing leadership to make informed decisions on how the 

Department is doing towards meeting the established goals for PWD and PWTD. A Diversity Dashboard 

was developed with PWD and PWTD workforce data compared against the established PWD and PWTD 

benchmarks for Bureau leadership, as well as hiring managers and supervisors. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Section II: Model Disability Program

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

recruit and hire persons with disabilities and persons with targeted disabilities, administer the reasonable 

accommodation program and special emphasis program, and oversee any other disability hiring and 

advancement program the agency has in place. 

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

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

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

staffing for the upcoming year.

Yes X No 0

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

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

Disability Program Task

# of FTE Staff by 

Employment Status

Responsible Official

(Name, Title, Office, 

Email) Full 

Time

Part 

Time

Collateral 

Duty

Processing applications from PWD and 

PWTD 77 3 24

See specific bureau PART 

J’s.

Answering questions from the public about 

hiring authorities that take disability into 

account

59 3 13

See specific bureau PART 

J’s.

Processing reasonable accommodation 

requests from applicants and employees 49 3 12 See specific bureau PART J’s.

Section 508 Compliance

145 1 3

See specific bureau PART 

J’s.

Architectural Barriers Act Compliance

20 2 379

See specific bureau PART 

J’s.

Special Emphasis Program for PWD and 

PWTD 14 1 5

See specific bureau PART 

J’s.

Note: Treasury provides a consolidated count where applicable; however, due to its size, a notation 

“See specific bureau PART J’s” was added to assist in identifying bureau responsible official. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

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

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

Yes X No 0

In FY 2019, OCRD provided multiple training sessions to the bureau’s disability program staff on PARTJ 

and the use of the MD-715 V2 workforce data tables. OCRD and the Department’s Disability Program 

Managers also participated in the quarterly Federal Exchange on Employment and Disability (FEED) 

updates, hosted by EEOC and Department of Labor, which educate attendees on various issues and 

topics related to disability. Treasury HR and EEO professionals completed an annual Department of the 

Treasury online course, mandated by Executive Order (EO) 13518, related to veteran’s employment, with 

critical components on disability. Additionally, HR representatives attended a reasonable accommodation 

(RA) refresher course, which includes a disability component. 

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

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

disabilities, including individuals with targeted disabilities. 

• The Workforce Recruitment Program (WRP) is continually promoted as a source for recruiting 

students and graduating seniors with disabilities, including disabled veterans.

• The Pathways Intern Program is maximized to hire interns with targeted disabilities.

• Outreach efforts with Disability and Military Student offices are routinely conducted to promote 

internship opportunities.

• Recruitment events, fairs, and conferences are mapped for annual participation, i.e., Hiring Heroes, 

Federal Disability Workforce Consortium, the Department of Labor’s WRP Training, and the 

Treasury Department’s Veteran Employment Summit at the Treasury Executive Institute to market 

Treasury and its job opportunities.

• As a part of Treasury’s “Be A Champion” initiative, the Department’s Disability and Veteran’s 

Program Managers work closely with hiring managers to identify qualified PWD and PWTD, to 

include disabled veterans, to non-competitively hire using Schedule A Hiring Authority. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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. 

Schedule A Hiring Authority is promoted and available for use along with Veteran Appointment 

Authorities to non-competitively appoint PWD/PWTD and veterans with a service-connected disability 

rating of 30% or more. The Treasury and Bureau Disability Program Managers (DPM) have 

established numerous external partnerships with private and public organizations that assist 

PWD/PWTD candidates in finding meaningful employment, such as Gallaudet University, Workforce 

Recruitment Program, State Vocational Rehabilitation Centers, Texas School for the Deaf, and Careers 

and the Disabled Expos. The Department promotes the “Be A Champion” initiative to remind hiring 

managers of the value of hiring applicants with disabilities. 

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. 

When individuals utilize the Schedule A Hiring Authority, the process for eligibility and hire encompass: 

1) Application qualification review process – conducted by the servicing HR Specialist who confirms that 

the applicants meet the qualification requirements of the announced position and have provided required 

proof of disability; 2) Applicant referral - individuals deemed qualified are referred to the hiring manager 

on a Schedule A certificate of eligibility with guidance on selection procedures, including the application of 

veterans’ preference, when applicable. Managers have the option to interview and/or hire from the 

Schedule A certificate or to consider other candidates from other issued certificates (Merit Promotion, 

Non-Competitive, Veterans’ Recruitment Appointment (VRA), etc.). 

Alternatively, when individuals submit their resumes directly to the Special Placement Program 

Coordinator (SPPC) for vacant positions, the SPPC refers the resumes to the hiring official for review and 

consideration. The hiring official forwards the selected resumes to the HR Specialist to determine 

qualifications. If qualifications and Schedule A eligibility are met, the resumes are then returned to the 

hiring manager with guidance on selection procedures, including the application of veterans’ preference, 

when applicable. 

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

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

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

Yes X No 0 N/A 0

All Treasury managers, supervisors, and selected HR professionals are required to complete Supervisory 

Readiness, Annual Training on Merit System Principals, Prohibited Personnel Practices, and 

Whistleblower, and the Veteran’s Employment Training which contain segments on the use of hiring 

authorities and are provided online through the Treasury’s Integrated Talent Management System 

(ITMS). Additionally, hiring managers are offered the Americans with Disability Act: An Overview for 

Managers and A Manager’s Guide to Diversity, Inclusion and Accommodations, along with other hiring 

manager tools available through ITMS. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 Department engages with varied organizations such as Department of Vocational Rehabilitation 

Centers, Veterans Administration (VA) and Department of Labor Employment Service by partnering, 

providing lectures, and attending on-site presentations and classroom visits to develop stronger 

relationships with college students and professors, and with college campus clubs and groups that 

maintain focus on students with disabilities.

Meetings with various organizations that support disability employment, such as Wounded Warriors and 

Department of Vocational Rehabilitation Centers are held periodically to share Treasury’s process for 

providing vacancy announcements, and share information about opportunities, including career 

development tracks.

Through a Memorandum of Understanding, Treasury maintains a working relationship with the 

Computer/Electronic Accommodation Program (CAP) to secure devices frequently used by PWD and 

PWTD. 

The existing sign language interpreter contract ends in FY 19, therefore the Department is exploring a new 

sign language interpreter contract to provide an effective and efficient procedure for providing sign 

language interpreters beginning FY 20.

C. Progression Towards Goals (Recruitment and Hiring) 

1. Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do triggers exist for 

PWD and/or PWTD among the new hires in the permanent workforce? If “yes”, please 

describe the triggers below.

a. New Hires for Permanent Workforce (PWD) Yes 0 No X

b. New Hires for Permanent Workforce (PWTD) Yes 0 No X

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

FY 2019 New Hires Qualified vs. New Hires Qualified vs. New Hires

0110 (44) PWD: 5.48% - 2.27%*** PWTD: 3.39% - 0.00%***

0340 (13) PWD: 4.02% - 7.69% PWTD: 0.54% - 7.69%

0343 (76) PWD: 7.56% - 28.95% PWTD: 3.42% - 1.32%**

0501 (29) PWD: 5.68% - 13.79% PWTD: 2.36% - 3.45%

0511 (22) PWD: 8.12% - 0.00%*** PWTD: 3.50% - 0.00%***

0570 (66) PWD: 4.90% - 4.55%** PWTD: 1.29% - 1.52%
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

0905 (102) PWD: 5.91% - 2.94%** PWTD: 2.36% - 0.00%**

1169 (269) PWD: 6.33% - 20.07% PWTD: 3.29% - 4.09%

1811 (99) PWD: 2.55% - 3.03% PWTD: 1.31% - 0.97%*

2210 (755) PWD: 7.80% - 18.81% PWTD: 4.03% - 2.78%**

The above triggers were identified as a result of analyzing the above data for new hires by occupational 

series and permanent mission-critical occupations: 

*The 1811, Criminal Investigators occupational series, limits the employment opportunities available for 

PWTD based on OPM’s established medical requirements for the position. Therefore, we would expect 

the hiring of PWD and PWTD to be limited in this series and do not consider the lack of participation to be 

a trigger.

**Other triggers were noted in the 0343, 0570, 0905, and 2210 occupational series when comparing the 

qualified applicant flow data with the new hires for PWD and PWTD. There was an overall increase in the 

number of 0343 new hires in the last year; and although there was a trigger for PWTD, there was a higher 

rate of actual selections than the prior year. A slight difference of 0.34% was noted for 0570 occupational 

series, however, that difference is not significant enough to be considered a critical trigger at this time. 

The triggers noted in the 0905 occupational series were consistent to the prior year for both PWD and 

PWTD. A new trigger was noted for the 2210 occupational series for PWTD. For the Treasury bureaus 

that noted the same triggers in their workforce evaluation, these triggers are noted in their PART J’s. 

Plans to improve hiring for PWD/PWTD within the major occupations listed are detailed in the specific 

bureau PART J’s. Treasury will monitor all bureaus’ PART J’s to ensure appropriate plans are developed 

to eliminate any identified barrier(s). 

*** When there is limited hiring, there cannot be a realistic expectation that all groups (PWD and PWTD) 

would be hired at rates comparable to their qualification rates. Therefore, Treasury established a 

threshold of 50 new hires. Any hire rate less than 50 will not support a statistically significant outcome. 

Occupations with limited hiring such as the 0511 did not have enough hires to determine if there is an 

actual trigger. (*1811 is an exception as stated above). However those differences are less than 1% and 

not considered triggers at this time. 

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

 Relevant Applicant Pool Relevant Internal Applicants Pool

MCO vs. Qualified Internal Applicants vs. Qualified Internal Applicants

0110 (23) PWD: 8.33% - 0.00% PWTD: 0.00% - 0.00%

0340 (303) PWD: 3.96% - 3.45%** PWTD: 0.57% - 0.37%**

0343 (76) PWD: 5.93% - 5.94% PWTD: 2.74% - 2.73%**

0501 (715) PWD: 5.90% - 5.92% PWTD: 2.72% - 2.72%

0511 (29) PWD: 4.00% - 4.17% PWTD: 0.00% - 0.00%

0570 (1) PWD: 3.48% - 3.42%** PWTD: 0.99% - 0.92%**

0905 (4) PWD: 0.00% - 0.00% PWTD: 0.00% - 0.00%

1169 (343) PWD: 5.45% - 5.41% PWTD: 2.57% - 2.58%**

1811 (890 PWD: 0.51% - 0.00% PWTD: 0.51% - 0.00%*
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

2210 (179) PWD: 10.43% - 9.69%** PWTD: 4.33% - 4.52%**

The below triggers were identified when analyzing the above data for permanent mission-critical 

occupations among qualified internal applicants: 

*The 1811, Criminal Investigators occupational series, limits the employment opportunities available for 

PWD and PWTD based on OPM’s established medical requirements for the position. Therefore, we 

would expect the hiring of PWD and PWTD to be limited.

**We noted differences when comparing the applicant flow data with the qualified applicants for PWD 

and PWTD in the 0340, 0343, 0570, 1169, and 2210 occupational series. However, those differences 

are less than 1% and not considered triggers at this time. 

For Treasury bureaus that noted the same triggers in their workforce evaluation, these triggers are 

noted in their PART J’s. Plans to improve hiring for PWD within the major occupations listed are 

detailed in the specific bureau PART J’s. Treasury will monitor and provide feedback for all bureaus’

PART J’s to ensure appropriate plans are developed to eliminate any identified barriers. 

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 X No 0

FY 2019 Promotions Qualified Internal Applicants Qualified Internal Applicants

 to MCOs vs. Internal Promotions vs. Internal Promotions

0110 (23) PWD: 0.00% - 13.04%*** PWTD: 0.00% - 4.35%***

0340 (303) PWD: 3.45% - 10.56% PWTD: 0.37% - 1.98%

0343 (76) PWD: 5.94% - 8.94% PWTD: 2.73% - 2.10%**

0501 (715) PWD: 5.92% - 9.65% PWTD: 2.72% - 3.36%

0511( 29) PWD: 4.17% - 3.45%*** PWTD: 0.00% - 0.00%

0570 (1) PWD: 3.42% - 0.00%*** PWTD: 0.99% - 0.00%***

0905 (4) PWD: 0.00% - 0.00% PWTD: 0.00% - 0.00%

1169 (343) PWD: 5.41% - 8.16% PWTD: 2.57% - 0.87%**

1811 (89) PWD: 0.00% - 1.12% PWTD: 0.51% - 0.00%*

2210 (379) PWD: 9.69% - 18.73% PWTD: 4.33% - 5.01%

The below new triggers were identified when analyzing the above data for qualified internal applicants

among employees promoted to a mission-critical occupation: 

*The 1811, Criminal Investigators occupational series, limits the employment opportunities available for 

PWD and PWTD based on OPM’s established medical requirements for the position. Therefore, we 

would expect the hiring of PWD and PWTD to be limited.

**Other triggers were noted in the 0343, 0511, 0570, and 1169 occupational series above when 

comparing the qualified applicant flow data with the new hires for PWD and/or PWTD. There was a 

significant decrease in the number of 0343 new hires compared to last year; and although there is a 

trigger for PWTD, the difference is less than 1% and not considered a trigger. Plans to improve hiring 

for PWD/PWTD within the major occupations listed are detailed in the specific bureau PART J’s. 

Treasury will monitor all bureaus’ PART J’s to ensure appropriate plans are developed to eliminate any 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

identified barrier(s). 

*** When there is limited hiring, there cannot be a realistic expectation that all groups (PWD and 

PWTD) would be hired at rates comparable to their qualification rates. Therefore, Treasury established

a threshold of 50 new hires. Any hire rate less than 50 will not support a statistically significant 

outcome. Occupations with limited hiring such as the 0110, 0511, 0570, and 0905 series did not have 

enough hires to determine if there is an actual trigger. (*1811 occupational series is an exception as 

stated above). However those differences are less than 1% and not considered triggers at this time. 

While there were internal vacancy announcements that reflect the applicant flow data, the significant 

difference in the percentage of the Qualified Internal Applicant Pool and the Internal Promotions are the 

result of existing employees who applied to not only internal vacancy announcements, but to all status 

vacancy announcements open to all Federal employees in FY 2019. This will also result in differences 

between internal/external selections and promotions rates.

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.

Treasury’s opportunities for advancement are accessible and open to all employees, including employees 

with disabilities. Treasury offers non-competitive opportunities to streamline the hiring process to fill 

critical and non-critical positions quickly (e.g., details, including positions that can lead to promotion). 

Leadership development opportunities exist for all qualified employees through such programs as 

Leadership Succession Review (LSR) for GS-12 to SES employees, Executive Readiness (XR), and 

Candidate Development Programs (CDP), which can potentially lead to the SES. 

Treasury encourages diverse employee (including PWD/PWTD) participation in management, leadership 

and career development programs through the use of employee network groups (ENGs), such as the 

Adelante and the Veterans Employee Resource Group (VERG), and a variety of other communication 

venues throughout the agency. Developmental opportunities are broadly communicated to all employees 

through internal weekly and monthly newsletters, intranet website postings, and shared by ENGs.

Treasury encourages individual development plans for all employees. Managers are reminded to 

consider permanently assigned PWD/PWTD for development opportunities as part of their Individual 

Development Planning process. 

In conjunction with available training, Treasury will explore, for FY 2020, the development of a committee 

composed of bureau representatives to explore additional opportunities (e.g., mentoring) to the disabled 

community.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

B. Career Development Opportunities

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

employees. 

The Department of Treasury does not have a formal Career Development Program. However, Treasury 

bureaus have established varied opportunities to further develop the careers of employees, including 

PWD and PWTD. The below highlights some programs offered. To view the exhaustive list, please see 

bureau specific reports. 

Bureau of Engraving and Printing (BEP) offers a series of programs for GS 7-15. Programs include:

 

• New Leaders Program (NLP) – Targets GS 7-11 employees (or equivalent) and focuses on 

developing future public service leaders and includes leadership self-assessments, experiential 

learning, and individual development opportunities integrated into a competency-based learning 

approach. 

• Executive Leadership Program (ELP) – Targets GS 12-13 employees (or equivalent), who are 

seeking to support their organization in meeting its mission and goals, by focusing specifically on the 

competency of “leading people” through developmental activities and experiences.

• Executive Potential Program (EPP) – A competency-based leadership program that prepares highpotential GS 14-15 employees (or equivalent) to lead effectively at the senior level. The curriculum is 

focused on “leading change” and transforming senior managers into change leaders.

• Career Development (CADE) Program – The CADE Program provides upward mobility via defined 

career training and opportunities that allow the selection and training of disabled veterans (and other 

employees) GS-11 (or equivalent) and below, whose positions offer limited promotion potential, for 

placement into positions in other occupational series for which they would not otherwise be qualified. 

• Electro-Machinist & Mechanical-Machinist Trainee Program - This program is advertised as a 

four-year trainee program to journeyman Electro-Machinist. This position is located in the ElectroMachine Shop, Office of Security Printing. The incumbent participates in a four year training program 

with the Bureau of Engraving and Printing including formal, laboratory, and "on-the-job" training. The 

incumbent is normally assigned to maintain/support all currency printing/processing equipment, 

including temporary and permanent modifications and installations required to maintain production 

goals. The incumbent works with journeymen and other peers, while participating in "on-the-job" 

training.

Departmental Offices (DO) partners with the Treasury Executive Institute (TEI) to offer employees 

individual coaching services for a six-month period. TEI’s coaching services assist DO employees with 

achieving professional goals, solve individual leadership challenges, and develop leadership attributes.

Fiscal Service (FS) offers developmental programs for employees to take classes to make them eligible 

for promotion to higher grades in their career ladder. Fiscal Service also offers career development 

classes in person and online that enable employees to develop skills to help them advance and qualify for 

other positions in Fiscal Service.

Internal Revenue Service (IRS) offers career development opportunities service-wide to all employees 

for non-competitive details/promotions and internal merit promotions. In addition, leadership development 

opportunities are available for all employees to consider. IRS Chief Counsel offers training and 

development opportunities for attorneys Counsel-wide. Reasonable accommodations are made for all 

training.

U.S. Mint offers Manufacturer Certification and Apprenticeship Program and Operator Certification and 

Apprenticeship programs which are available to PWD and PWTD.

Office of the Comptroller of the Currency (OCC) offers professional development programs for its bank 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

examiners and cross-training and developmental assignments to equip attorneys with legal skills and 

experiences across multiple legal practices areas through the Honors Attorney Program. Overall, training 

and development courses are available to all employees, in the classroom, online, virtual, and self-study. 

Temporary details and short–term work assignments are advertised on the agency’s Opportunities Board 

to all employees, such as: 

• The EXCEL I Program, sponsored by the Large Bank Supervision (LBS) department, provides bank 

examiners in pay band NB-V the opportunity to develop expertise in one of eight specialty areas.

• The EXCEL II Program expanded professional development opportunities for bank examiners in pay 

band NB-IV in the eight specialty areas of the EXCEL I Program.

• Midsize and Community Bank Supervision (MCBS) Pre-commission Bank Examiners Career Forums 

provide information about bank examiner career opportunities and explain the Uniform Commission 

Examination (UCE) preparatory process.

• The Honors Attorney Program is designed to provide cross-training and developmental assignments 

to equip attorneys with legal skills and experiences across multiple legal practices areas.

• The Leadership Exploration and Development (LEAD) Program is an enterprise-wide leadership 

development program targeted to employees at the NB-V to NB-VI.2 levels, to help develop specific 

competencies aligned to skills and abilities needed at the team leader and/or manager level.

• The MCBS NB-V Career Forum for Bank Examiners provides bank examiners exposure to the career 

options available in the various bank supervision lines of business, and resources and factors to 

consider when making career decisions. It also provides opportunities to network with senior leaders 

throughout the agency.

• Non-examiner Career Forums provide non-examiners exposure to the variety of career options in the 

non-examiner lines of business. 

• Agency training and development courses are available to all employees via the classroom, online, 

virtual, and self-study.

Treasury Inspector General for Tax and Alcohol (TIGTA) programs include: 

• The Office of Audit’s Leadership Development Program for Auditors at the GS-13, GS-14, and GS-15 

levels allows qualified diverse employees to participate in career development training, and 

opportunities that will prepare them for Audit management vacancies. 

• The Office of Investigations provides diverse employees an opportunity to participate in their Equity, 

Diversity, and Inclusion Program, which offers career development opportunities for all employees. 

• Career developmental opportunities using rotational assignments and business unit details are also 

encouraged for all TIGTA employees. TIGTA communicates vacancy announcements and detail 

opportunities to all employees, including PWD/PWTD, through email, intranet, and internet.

Alcohol and Tobacco, Tax and Trade Bureau (TTB) primary career development program (CDP) is the 

Emerging Leaders Program (ELP) – a three year centralized training program that is competitive with 

selections made at the Assistant Administrator level. During the 4th quarter of each fiscal year, TTB 

broadcasts an ELP annual opportunity announcement to request applicants for the Program. The 

announcement provides general information about the ELP and its three programs, identifies the threeyear curriculum for each program, and explains how employees may apply. The TTB ELP framework 

consists of three separate and distinct programs:

– Program for non-supervisory employees;

– Program for 1st level supervisors; and

– Program for 2nd level supervisors and senior leaders.

Further: 

• All TTB employees, including disabled veterans, are eligible for consideration for the ELP and may 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

apply during the annual announcement period. Selections are made through a competitive process. 

TTB’s Training and Professional Development Division chairs a meeting with senior leaders and 

provides its recommendations for selection. Senior leaders make the final selections. In FY 2019,

TTB had 9 graduates from its ELP, with 16% of those being veterans.

• The ELP is TTB’s primary leadership CDP. However, it is not considered a formal CDP in 

accordance with Treasury’s definition, given that it does not meet the following criteria:

– Must be announced via USAJOBS;

– Announcement must include a statement indicating this is a CDP;

– Program must be competitive and individuals must apply; and

– Upon completion of the Program, the employee would be considered qualified for a promotion to

the next higher grade. 

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

require competition and/or supervisory recommendation/approval to participate. 

Career Development 

Opportunities*

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees 

(%)

Internship Programs

Fellowship Programs

Mentoring Programs 

Coaching Programs

Training Programs

Detail Programs

Other Career Development 

Programs

*For bureau specific career development opportunities, see bureau PART J’s. While the Department does not

have a system in place to capture this data, Treasury is exploring resources to capture this data in the future. 

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

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

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

text box.

a. Applicants (PWD) Yes 0 No X

b. Selections (PWD) Yes 0 No X
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

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

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

in the text box.

a. Applicants (PWTD) Yes 0 No X

b. Selections (PWTD) Yes 0 No X

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

The inclusion rate for PWD (19.25%) and PWTD (19.19%) in cash awards $1,000 - $1,999, was below 

the inclusion rate for employees with no disability (27.42%). 

The inclusion rate for PWD (2.19%) and PWTD (1.56%) in cash awards $2,000 - $2,999, was below the 

inclusion rate for employees with no disability (3.51%). 

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

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 0 No X

ii. Internal Selections (PWD) Yes 0 No X

b. Grade GS-15

i. Qualified Internal Applicants (PWD) Yes 0 No X

ii. Internal Selections (PWD) Yes 0 No X

c. Grade GS-14 

i. Qualified Internal Applicants (PWD) Yes 0 No X

ii. Internal Selections (PWD) Yes 0 No X

d. Grade GS-13 

i. Qualified Internal Applicants (PWD) Yes 0 No X

ii. Internal Selections (PWD) Yes 0 No X

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 X No 0

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 0 No X

d. Grade GS-13 

i. Qualified Internal Applicants (PWTD) Yes 0 No X

ii. Internal Selections (PWTD) Yes 0 No X
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

 Qualified Internal Applicant Internal Promotions 

 

GS-15 PWTD: 3.19% 1.16%* 

SES PWTD: 0.51% 0.00%* 

Triggers were identified for PWTD when analyzing Qualified Internal Applicants and Selectees for Promotion 

to senior grade levels, indicating the following results: 

*A trigger was identified for PWTD who were promoted to the SES and GS-15. The trigger was noted 

between the rate at which applicants were qualified and their rate of selection. For Treasury bureaus that 

noted triggers in their workforce, evaluations are noted in their PART J’s. Plans to improve hiring for PWTD 

within the grade groupings are detailed in the specific bureau PART J’s. Treasury will monitor all bureaus’ 

PART J’s to ensure appropriate plans are developed to eliminate any identified barriers. 

While there were internal vacancy announcements that reflect the applicant flow data, the significant 

difference in the percentage of the Qualified Internal Applicant Pool and the Internal Promotions are the 

result of existing employees who applied to not only internal vacancy announcements, but to all status 

vacancy announcements open to all Federal employees in FY 2019. This will also result in differences 

between internal/external selections and promotions rates. 

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.

e. New Hires to SES (PWD) Yes X No 0

f. New Hires to GS-15 (PWD) Yes 0 No X

g. New Hires to GS-14 (PWD) Yes 0 No X

h. New Hires to GS-13 (PWD) Yes 0 No X

 Qualified External Applicants External Hires 

GS-13 PWD: 7.11% 16.89% 

GS-14 PWD: 6.44% 15.59% 

GS-15 PWD: 6.98% 11.49% 

SES PWD: 7.48% 6.98%* 

A trigger was identified for PWD when analyzing Qualified Internal Applicants and Selectees for 

Promotion to senior grade levels, indicating the following results: 

*We noted differences when comparing the qualified external applicants with the external hires for PWD 

in the SES. However the difference is less than 1% and not considered a trigger at this time. 

For Treasury bureaus that noted triggers in their workforce, evaluations are noted in their PART J’s. 

Plans to improve hiring for PWD within the grade groupings are detailed in the specific bureau PART J’s. 

Treasury will monitor all bureaus’ PART J’s to ensure appropriate plans are developed to eliminate any 

identified barriers. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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.

i. New Hires to SES (PWTD) Yes 0 No X

j. New Hires to GS-15 (PWTD) Yes 0 No X

k. New Hires to GS-14 (PWTD) Yes X No 0

l. New Hires to GS-13 (PWTD) Yes X No 0

Qualified External Hires 

 External Applicants 

GS-13 PWTD: 3.26% 2.14%** 

GS-14 PWTD: 2.87% 2.63%* 

GS-15 PWTD: 3.45% 3.45% 

SES PWTD: 2.85% 6.98%

Triggers were identified for PWTD when analyzing Qualified External Applicants and Selectees for 

External Hires to senior grade levels, indicating the following results: 

 

*We noted differences when comparing the qualified external applicants with the external hires for PWTD 

in the GS-14 grade levels. However, the difference is less than 1% and not considered a trigger at this 

time. 

**Treasury noted a trigger between the qualified external applicants and the actual hires in the GS-13 

grade level. 

For Treasury bureaus that noted triggers in their workforce, evaluations are noted in their PART J’s. 

Plans to improve hiring for PWTD within the grade groupings are detailed in the specific bureau PART 

J’s. Treasury will monitor all bureaus’ PART J’s to ensure appropriate plans are developed to eliminate 

any identified barriers. 

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.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

a. Executives

i. Qualified Internal Applicants (PWD) Yes 0 No X

ii. Internal Selections (PWD) Yes 0 No X

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

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 0 No X

ii. Internal Selections (PWTD) Yes 0 No X

b. Managers

i. Qualified Internal Applicants (PWTD) Yes 0 No X

ii. Internal Selections (PWTD) Yes 0 No X

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Yes 0 No X

ii. Internal Selections (PWTD) Yes 0 No X

7. Using the qualified applicant pool as the benchmark, does your agency have a trigger 

involving PWD among the selectees for new hires to supervisory positions? If “yes”, 

describe the trigger(s) in the text box.

a. New Hires for Executives (PWD) Yes X No 0

b. New Hires for Managers (PWD) Yes X No 0

c. New Hires for Supervisors (PWD) Yes 0 No X

Supervisory Positions Qualified External New Hires

 Applicants 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Executives PWD: 6.99% 2.45%*

Managers PWD: 8.98% 7.45%*

Supervisors PWD: 5.00% 0.00%**

Triggers were identified for PWD when analyzing Qualified External Applicants and New Hires to 

supervisory positions, indicating the following results: 

* We noted differences when comparing the qualified external applicants with the new hires for PWD at 

the Executives and Managers level. 

** Treasury noted a trigger between the Qualified External Applicants and New Hires to the Supervisors 

level, however, the non-selection of 1 qualified Supervisory external applicant at 5% would not warrant 

further analysis at this time. 

For Treasury bureaus that noted the same triggers in their workforce evaluation, these triggers are noted 

in their PART J’s. Plans to improve hiring for PWD within are detailed in the specific bureau PART J’s. 

Treasury will monitor all the bureaus’ PART J’s to ensure appropriate plans are developed to eliminate 

any identified barriers.

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.

m. New Hires for Executives (PWTD) Yes X No 0

n. New Hires for Managers (PWTD) Yes X No 0

o. New Hires for Supervisors (PWTD) Yes 0 No X

Supervisory Positions Qualified External New Hires

 Applicants 

Executives PWTD: 2.69% 1.96%*

Managers PWTD: 4.10% 3.19%*

Supervisors PWTD: 0.00% 0.00%

Triggers were identified for PWTD when analyzing Qualified External Applicants and New Hires to 

supervisory positions, indicating the following results: 

* We noted differences when comparing the qualified external applicants with the new hires for PWTD at 

the Executives and Managers level. However, for each, the difference is less than 1% and not 

considered a trigger at this time. 

For Treasury bureaus that noted triggers in their workforce, evaluations are noted in their PART J’s. 

Plans to improve hiring for PWTD within the grade groupings are detailed in the specific bureau PART 

J’s. Treasury will monitor all bureaus’ PART J’s to ensure appropriate plans are developed to eliminate 

any identified barriers. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 0 No X N/A 0

In FY 2019, Treasury had 34 Schedule A employees with a disability who were eligible to convert into the 

competitive service after two years of satisfactory service. Of the 34 eligible Schedule A employees, 17 

were not converted timely. This is a 29% increase in untimely conversions compared to 5 eligible 

employees not converted timely in FY18. Treasury bureaus indicated the following status for the 17 

eligible Schedule A employees, who were not converted timely:

• Ten (10) employees’ conversions were submitted and processed late;

• One (1) employee was not converted because the employee misunderstood the conversion and 

declined. However, after sharing information regarding Schedule A conversion, the conversion is 

now pending in HR; 

• One (1) employee’s conversion was still pending at the time of this report since eligibility was at the 

end of this FY;

• One (1) employee is pending performance improvement;

• Three (3) were based on unsatisfactory performance; and

• One (1) employee was terminated for unsatisfactory performance. 

Note: The above consolidated view of data may mask the potential barrier(s) in the processes within the 

independent bureaus. Therefore, bureaus are required to analyze their data for trigger(s) that lead to a 

potential barrier and develop a separate plan(s) to address the notable deficiencies, such as bureau level 

conversions. The Department monitors each bureau’s progress and provides guidance 

(quarterly/annually) that will assure a clear path for timely conversions of all eligible Schedule A 

candidates with a disability into the competitive service, after two years. 

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary 

and involuntary separations exceed that of persons without disabilities? If “yes”, describe 

the trigger below.

a. Voluntary Separations (PWD) Yes X No 0

b. Involuntary Separations (PWD) Yes X No 0

The inclusion rate for PWD (10.39%) exceeded the inclusion rate of persons without disability (8.74%) 

for voluntary separations. 

The inclusion rate for PWD (0.96%) exceeded the inclusion rate of persons without disability (0.76%) 

for involuntary separations.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

When evaluating the types of voluntary separations, we noted that 53% were due to retirement, 8% 

were transfers, and 37% were resignations. The remaining 2% were due to deaths. Based on 

comments in the FY 19 Treasury Employee Exit Survey and the explanation cited below in question #4, 

Treasury does not consider the separations “due to retirement” a trigger. However, each bureau where 

a trigger has been identified will be asked to evaluate those voluntary separations due to retirements, 

transfers and resignations, along with information gleaned from their exit survey, to determine if these 

triggers are potential barriers.

3. Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary 

and involuntary separations exceed that of persons without targeted disabilities? If “yes”, 

describe the trigger below.

a. Voluntary Separations (PWTD) Yes X No 0

b. Involuntary Separations (PWTD) Yes X No 0

The (inclusion rate) for PWTD (10.99%) exceeded the rate of persons without targeted disability (8.74%) 

for voluntary separations. 

The (inclusion rate) for PWTD (1.16%) exceeded the rate of persons with without targeted disability 

(0.76%) for involuntary separations. 

When evaluating the types of voluntary separations, we noted that 53% were due to retirement, 8% were 

transfers, and 37% were resignations. The remaining 2% were due to deaths. Based on comments in 

the FY 19 Treasury Employee Exit Survey and the explanation cited below in question #4, Treasury does 

not consider the separations “due to retirement” a trigger. However, each bureau where a trigger has 

been identified will be asked to evaluate those voluntary separations due to retirements, transfers and 

resignations, along with information gleaned from their exit survey, to determine if these triggers are 

potential barriers.

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.

When evaluating total voluntary separations of PWD and PWTD, we noted that 53% were due to 

retirement, 8% were transfers, and 37% were resignations. 

When evaluating the total involuntary separations, we noted that 4% were due to end of appointment. 

Treasury does not consider the separations due to retirement a trigger. However, bureaus will be 

asked to evaluate those voluntary and involuntary separations due to transfers and resignations, along 

with the information gleaned from the exit survey, to determine if these triggers are potential barriers. 

During the period of October 1, 2018 through September 30, 2019, 195 permanent (85%), seasonal

(10%) and temporary (5%) PWD responded to the Department’s Exit Survey. The overall responses 

from PWD were similar to the overall permanent/seasonal employee responses, in that 33% (64) had 

more than 25 years of service and 46% (90) were age 60 or older. Of the respondents with disabilities, 

33% (65) were disabled veterans. The most frequently cited reason for separation of PWD was 

retirement (110 or 56%).

The factor most frequently cited as impacting a PWD’s decision to leave was job stress 49% (97) and 

office morale 33% (66). Additional responses specified that 70% (136) of the respondents indicated 

their work experience was generally positive; 56% (109) stated nothing could have been done to 

prevent them from leaving; 63% (123) stated they would be interested in returning to work for Treasury; 

and 70% (137) stated they would recommend Treasury as a good place to work. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 “Accessibility” page on the public Treasury.gov website, https://home.treasury.gov/utility/accessibility, 

provides three links with resources for Persons with Disabilities.

Information on how to file a complaint can be found at: https://www.treasury.gov/about/organizationalstructure/offices/Mgt/Pages/discrimination-complaint.aspx

The following address, located on the Treasury.gov public website, provides information and explains 

employee and applicant rights under Section 508 of the Rehabilitation Act: 

https://section508.gov/manage/laws-and-policies.

Additionally, the following link (which is also located on the “Accessibility” page), provides information 

regarding how to file a complaint of discrimination: https://www.treasury.gov/about/organizationalstructure/offices/Mgt/Documents/Section508_Complaint_Processing.pdf.

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.

Regarding physical accessibility, the following address is located under the “Accessibility” page on the 

public Treasury.gov website: https://home.treasury.gov/utility/accessibility/physical-accessibility. 

Additionally, the following link (which is also located on the “Accessibility” page) provides information 

regarding how to file a complaint of discrimination: 

https://home.treasury.gov/utility/accessibility/disability-resources. 

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 2019, OCRD conducted five accessibility reviews: two at the U.S. Mint, at Headquarters in 

Washington, D.C. and Fort Knox, NY facility and three at IRS Taxpayer Assistance Centers (TAC), in 

Washington, D.C., Austin and San Antonio, TX. Each location has taken actions to ensure compliance 

with Sections 501 and 504 of the Rehabilitation Act of 1973 (29 C.F.R 1614 and 31 C.F.R Part 17) to 

provide access to persons with disabilities, but minor improvements should be made to fully comply 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

with the accessibility requirements. 

Such as: 

In the U.S. Mint headquarters building, the entrance and exit doors push assist buttons were not 

working, no van accessible parking spaces, the height of the water fountains do not meet the height 

standard, some grab bars did not have the required clearance space between the wall and the bar, and 

some bathrooms had exposed sink pipes.

In Fort Knox, there was no accessible route from the provided parking lot to the facility and main 

building, no accessible exit from the security post into the facility, ramp located at the entrance of the 

facility was not fully compliant, and water fountains clearance and spout heights do not meet the 

accessibility requirements.

In the IRS TAC – Landover, MD the entrance to the building, entrance door exceeds the allowed force 

and does not have a push assist button; access aisles assigned to van accessible parking spaces did 

not meet the required width; a few of the bathroom grab bars exceeded the maximum height; and 

some grab bars did not have the required clearance space between the wall and the bar.

In Austin, the signs marking the accessible parking spaces did not meet the required height, interior 

spaces lack directional signs and signs did not have Braille characters, dispensers in the bathrooms 

were positioned at a height that exceeded the standards, and some grab bars did not have the required 

clearance space between the wall and the bar. 

In San Antonio, the van accessible parking spaces were not wide enough to meet the standard, the 

dispensers in the bathrooms were positioned at a height that exceeded the standards, some grab bars 

did not have the required clearance space between the wall and the bar, the turn-around clearance 

space in the men’s bathroom did not meet the standard and in the women’s bathroom, the changing 

table was obstructing the clearance space.

In FY 2020, OCRD was scheduled to conduct an accessibility review of office spaces at BEP and DO. 

However, due to COVID-19, OCRD re-adjusted its plan and rescheduled the BEP and DO accessibility 

reviews for FY 2021. 

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.)

Each bureau is responsible for independently processing their requests for reasonable accommodations. 

The average time frame (number of days) for processing within the bureaus for FY 2019 are:

BEP 09

DO 20

FinCEN 14

FS 04

Mint 08

IRS 76

IRS CC 20

OCC 07
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

TIGTA 20

TTB 13

The overall average time for processing the Departments’ initial requests for reasonable accommodations 

is 19 days. The Department recognizes the high average for IRS which is currently reviewing its 

methodology for calculating “average days for providing reasonable accommodations.” Treasury has 

acquired a Treasury-wide reasonable accommodation tracking system that will eliminate the need to 

manually calculate processing timeframes and increase the efficiency of processing requests. 

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.

The Department has an effective Disability Program, supported by various policies, procedures, and 

practices, as evidenced by overall timely processing requests for accommodations. Mandatory training 

for new managers and supervisors includes responsibilities on providing reasonable accommodations. 

Throughout FY 2019, bureaus provided reasonable accommodations guidance via training courses, 

newsletters, and postings on its intranet websites (see specific bureau submission for details). Bureaus 

are responsible for monitoring reasonable accommodation data for trends relating to the workforce. 

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.

Treasury established its PAS policy and procedures during FY 2018, however, Treasury did not receive 

any requests for PAS in FY 2019. A Department-wide BPA was established to provide PAS to all eligible 

Treasury employees. Information and training is on-going to all managers, supervisors, and selected HR 

Professionals. PAS training has been added to orientation for all newly-hired managers and newlypromoted managers. 

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 0 No X N/A 0
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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.

The percentage of Treasury’s formal complaints filed by PWDs alleging harassment was 10.94% which is 

significantly low when compared to the government-wide average of 19.69%. Note: EEOC’s 

Government-wide averages on processing initial requests are available for formal complaints only. 

In FY 2019, Treasury did not have any findings of discrimination involving harassment based on disability 

status; however, there was one complaint involving harassment based on disability status that ended in a 

settlement.

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 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.

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

The percentage of Treasury’s formal complaints filed by PWDs alleging failure to accommodate was 8.54% which is low when 

compared to the government-wide average of 13.53%. Note: EEOC’s Government-wide averages on processing initial 

requests are available for formal complaints only. 

Treasury did not have any findings of discrimination involving failure to provide a RA; however, Treasury had two

complaints involving failure to provide RA that resulted in settlements.
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

 

Yes 0 No 0 N/A X

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

Note: Based on the triggers reported in this document, each bureau is 

required to report independently, its plan to address those notable 

deficiencies.

Barrier(s)

Objective(s)

Responsible Official(s)

Performance Standards Address the 

Plan?

(Yes or No)

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

Sources of Data

Sources 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables 

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)

Target Date

(mm/dd/yyyy)

Planned Activities Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

(mm/dd/yy

yy)

Completion 

Date

(mm/dd/yyyy)
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Fiscal Year Accomplishments

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

planned activities.

It is important to note that when the Department looks at Treasury-wide data as a whole, 

the progress noted may not be an accurate reflection of the true progress of each 

bureau. The consolidated view of the data may mask where potential barriers still exist 

within some of the bureaus. Therefore, a detailed barrier analysis based on bureau 

specific data into possible glass ceilings, blocked pipelines and glass walls must be 

conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete this analyses and based on their findings, develop plans to eliminate identified 

barriers.

5. For the planned activities that were completed, please describe the actual impact of those 

activities toward eliminating the barrier(s). 

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.