Department of the Treasury

Management 

Directive 715 

FY 2018
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 91179 1686 92865

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 (xxxxxx-xxxx)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
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Complaint 

Processing 

Program 

Manager

Amelia 

Demopulos

EEO 

Program 

Manager

0260 GS-15 202-622-4178 Ameila.Demopulos@treasury.gov

Manager of 

Special 

Emphasis 

Programs

Tina 

Lancaster

Manager 

of EEO 

Programs

0260 GS-15 202-622-1079 Tina.Lancaster@treasury.gov

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 PreparerAlicia 

Whittington

EEO 

Specialist 0260 GS-15 202-927-1093 Alicia.Whittington@ treasury.gov
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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
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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
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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, 2017, through September 30, 2018, and highlights the 

Department of the Treasury’s accomplishments during Fiscal Year (FY) 2018 in attaining and maintaining 

a model EEO Program. 

The Department of the Treasury’s Mission

Treasury remains one of the world’s premier finance ministries, responsible for the nation’s debt 

management, cash production, loans made to other federal agencies, tax collection, and economic policy 

formulation. We are a trusted policy advisor to the President, formulating and recommending domestic 

and international financial, economic, and tax policy. Our contributions to policy development shape 

America’s economic health and security. 

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 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, while the operating bureaus carry out the specific operations assigned to the 

Department. 

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 
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(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 

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

Capital Strategy. The Office of Civil Rights and Diversity (OCRD), part of the Departmental Offices’ 

organizational structure, is primarily responsible for providing guidance and oversight to the bureau 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 20181. 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 and persons with disabilities (PWD) and persons with targeted disabilities 

(PWTD). 

Throughout the last two years, Treasury and its bureaus have had significant decreases to their budgets 

and have been in either a hiring freeze or have had limited hiring opportunities. Because of this, some 

bureaus have had limited opportunity either to conduct meaningful analysis or to evaluate previously 

established plans to determine their effectiveness. 

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 in increased participation rates for women and minorities in SES positions 

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.
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as well as the feeder pools, and for the overall participation rate for Hispanics, PWD and PWTD.

 

As of the end of FY 2018, the permanent workforce participation rate of Hispanics was 11.73 percent. 

This is an overall increase of almost 2 percent when compared to the 9.84 percent participation rate 

noted in FY 2009. This participation rate is above both the Civilian Labor Force (CLF) (9.96 percent) and 

Relevant Civilian Labor Force (RCLF) (8.50 percent) availability rates. 

Participation Rates in the Permanent Workforce

As of the close of FY 2018, Treasury had 91,179 permanent employees2, a decrease of 5,171 (-5.37 

percent net change) employees from FY 2017. 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 2018.

Treasury and its bureaus continue to utilize the RCLF tool updated at the end of FY 2018, which provides 

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 workforces. 

A comparison of FY 2018 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 

(62.05 percent compared to 64.98 percent RCLF) and men (37.95 percent compared to 35.02 percent 

RCLF) are participating at rates very 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 40.1 percent non-White. In 

FY 2018, the participation rate for Whites decreased to 53.83 percent of the workforce and non-Whites 

increased to 46.17 percent. Thus, Treasury has noted a significant positive trend in the increased 

participation rate for non-Whites in the overall workforce. In fact, Hispanics (11.73 percent compared to 

8.50 percent RCLF), Blacks (27.02 percent compared to 10.57 percent RCLF), Asians (6.06 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 (0.82 percent compared to 0.89 percent RCLF) are participating at rates very close 

to their availability rates. Whites (53.83 percent compared to 74.93 percent) and Two or More Races 

(0.37 percent compared to 0.51 percent RCLF) 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. Since FY 2009, Treasury has seen an increased 

participation rate for women in the GS-13 and GS-15 grades and in SES positions. However, in FY 2018, 

Treasury saw a slight decreases in the participation rate for women at the GS-14 grade level.

At the GS-13 grade level, the participation rate for women increased by 0.46 percent, from 49.49 percent 

in FY 2009 to 49.95 percent in FY 2018. 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 2018. At the GS-15 

grade level, the participation rate for women increased by 1.57 percent, from 44.65 percent in FY 2009 to 

46.22 percent in FY 2018. Furthermore, at the SES level, the participation rate for women increased by 

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

employees depending on status.
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3.49 percent, from 35.71 percent in FY 2009 to 39.20 percent in FY 2018.

At the GS-13 grade level, the participation rate for Hispanics increased by 1.49 percent, from 6.07 

percent in FY 2009 to 7.56 percent in FY 2018. At the GS-14 grade level, the participation rate for 

Hispanics increased by 1.32 percent, from 4.54 percent in FY 2009 to 5.86 percent in FY 2018. At the 

GS-15 grade level, the participation rate for Hispanics increased by 1.11 percent, from 3.84 percent in FY 

2009 to 4.95 percent in FY 2018. Similarly, at the SES level, the participation rate for Hispanics 

increased by 0.06 percent, from 3.57 percent in FY 2009 to 3.63 percent in FY 2018.

At the GS-13 grade level, the participation rate for Blacks increased by 2.84 percent, from 18.41 percent 

in FY 2009 to 21.25 percent in FY 2018. At the GS-14 grade level, the participation rate for Blacks 

increased by 2.66 percent, from 17.65 percent in FY 2009 to 20.31 percent in FY 2018. At the GS-15 

grade level, the participation rate for Blacks increased by 0.79 percent, from 15.34 percent in FY 2009 to 

16.14 percent in FY 2018. Likewise, at the SES level, the participation rate for Blacks increased by 1.45 

percent, from 10.71 percent in FY 2009 to 12.16 percent in FY 2018.

At the GS-13 grade level, the participation rate for Asians increased by 2.37 percent, from 7.09 percent in 

FY 2009 to 9.46 percent in FY 2018. At the GS-14 grade level, the participation rate for Asians increased 

by 4.49 percent, from 5.81 percent in FY 2009 to 10.31 percent in FY 2018. At the GS-15 grade level, the 

participation rate for Asians increased by 3.82 percent, from 3.95 percent in FY 2009 to 7.77 percent in 

FY 2018. Again, at the SES level, the participation rate for Asians increased by 0.61 percent, from 3.75 

percent in FY 2009 to 4.36 percent in FY 2018.

At the GS-13 grade level, the participation rate for Others3increased by 0.08 percent, from 1.11 percent 

in FY 2009 to 1.19 percent in FY 2018. At the GS-14 grade level, the participation rate for Others 

increased by 0.19 percent, from 0.98 percent in FY 2009 to 1.17 percent in FY 2018. At the GS-15 grade 

level, the participation rate for Others increased by 0.34 percent, from 0.57 percent in FY 2009 to 0.91 

percent in FY 2018. Additionally, at the SES level, the participation rate for Others increased by 0.91 

percent, from 0.36 percent in FY 2009 to 1.36 percent in FY 2018.

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

SES positions, it is 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 6.77 percent, from 67.31 percent in FY 

2009 to 60.54 percent in FY 2018. At the GS-14 grade level, the participation rate for Whites decreased 

by -8.67 percent, from 71.02 percent in FY 2009 to 62.36 percent in FY 2018. At the GS-15 grade level, 

the participation rate for Whites decreased by -6.07 percent, from 76.30 percent in FY 2009 to 70.23 

percent in FY 2018. Similarly, at the SES level, the participation rate for Whites decreased by -3.02 

percent, from 81.61 percent in FY 2009 to 78.58 percent in FY 2018.

It is important to note that Treasury-wide data aggregates the data from all the bureaus and does not 

reflect the progress at any particular bureau. In fact, the aggregated data can mask barriers that may still 

exist within one or more bureaus. Therefore, each bureau must conduct its own detailed barrier analysis 

into possible glass ceilings, blocked pipelines, and glass walls. OCRD has advised the bureaus that they 

are required to complete detailed analyses to determine if any EEO groups are facing a potential glass 

ceiling, blocked pipeline, or glass wall, and based on their findings, to 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 analyses on the participation rates for Hispanics within the 

major occupations and their distribution in the general schedule (GS) grades 12 through SES levels to 

identify and eradicate any barriers to EEO, consistent with the merit system principles and applicable 

laws. 

3 Others includes those groups that are represented at a rate less than one percent of the Treasury workforce (AIAN, NHOPI, 

and two or More Races).
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During FY 2015/2016, OCRD and the Deputy Assistant Secretary for Human Resources and Chief 

Human Capital Officer (DASHR CHCO) conducted a review of the diversity of the Department’s Senior 

Executive Service corps and the processes for selecting new executives compared to FY 2005 and FY 

2010. The Departmental Executive Resources Board was briefed on the report and agreed to endorse 

the recommendations in the report. Therefore, in FY 2017, OCRD and DASHR developed the framework 

to institutionalize the recommendations made in the report in the upcoming year. 

However, due to the transition to a new administration, OPM’s implementation of the new Identification of 

Disability Standard Form (SF) 256, as well as many other competing requirements, the activities planned 

for completion in FY 2017 had to be modified and were completed in FY 2018. Those planned activities 

around revising the existing applicant flow data tables to distinguish between internal vacancy 

announcements and those announced as status/open have been completed. Additionally, the Office of 

Executive Resources issued guidance to the bureau HR offices outlining new policy requirements 

designed to assist in increasing the diversity of SES applicants and applicants for SES Candidate 

Development Programs (CDP).

Disability Employment Program

To ensure Treasury was in compliance with the new coding established with the release of OPM’s new 

SF-256 form for tracking PWD and PWTD in its workforce, OCRD worked closely with Enterprise Data 

Management (EDM) to institute a crosswalk within workforce Analytics, Treasury’s data analytics system 

for analyzing workforce data. Treasury also incorporated data requirements that resulted from changes 

to Section 501 of the Rehabilitation Act of 1973, which allows agencies to include veterans who are 

coded as having a 30% or more compensable disability as a PWD. To ensure we eliminated the 

possibility of double counting veterans as PWD, OCRD worked with EDM to identify the appropriate 

reporting logic that would automatically include only those veterans with 30 percent compensable 

disabilities who had also identified themselves as not having a disability. 

Additionally, from August through October 2017, OCRD conducted a Treasury-wide resurvey campaign, 

asking current employees to access their personnel data through HR Connect, Treasury’s personnel data 

system, and update their disability status using the revised SF-256 form. 

As a result of the implementation of the new coding in OPM’s revised SF-256 and the Department’s 

resurvey efforts, Treasury had a significant increase in the participation rates for both PWD and PWTD in 

its permanent workforce. In its 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. However at 

the end of FY 2018, Treasury is pleased to note that we have exceeded the new FY 2018 goals of a 12 

percent participation rate for PWD (12.39 percent) and the goal of 2 percent for PWTD (3.57 percent). 
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Many of Treasury bureaus have also either met or exceeded the new goals:

FY 2018 Disability Participation Rates By Bureau

Bureau Total PWD 

#

PWD 

%

PWTD 

#

PWTD 

%

BEP 1730 259 14.97% 35 2.02%

DO 1788 169 9.45% 35 1.96%

FINCEN 286 51 17.83% 11 3.85%

FS 3324 707 21.27% 138 4.15%

IRS 75269 9125 12.12% 2835 3.77%

IRS-CC 1936 166 8.57% 42 2.17%

MINT 1518 307 20.22% 57 3.75%

OCC 3823 337 8.82% 77 2.01%

OIG 163 30 18.40% 9 5.52%

SIGT 101 13 12.87% 3 2.97%

TIGTA 751 69 9.19% 5 0.67%

TTB 490 68 13.88% 11 2.24%

Total 91179 11301 12.39% 3258 3.57%

The new FY 2018 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 (4.51%) at the grades GS-10 and 

below exceed the new goals of 12 percent and 2 percent. 

The participation rate for PWTD (2.68%) currently exceeds the new goal of a 2 percent participation rate 

at the GS-11 and above grades levels. However, the participation rates for PWD (10.36%) at the GS-11 

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

In FY 2018, OCRD continued to conduct its “Be a Champion Roadshow” initiative. The Department 

considers this initiative to be a best practice for encouraging the hiring of veterans and PWD in high 

visibility positions. The Department’s Disability Program Manager and the Veterans Employment 

Coordinator conducted a series of Roadshows at Treasury’s bureaus, providing face-to-face coaching to 

Treasury’s managers and other key personnel (bureau Veteran Employment Representatives, Disability 

Program Managers, and Selective Placement Coordinators). 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. In FY 2018, OCRD conducted roadshows 

for managers and supervisors at DO and FS.

OCRD also provided Treasury and its bureaus EEO staff and Reasonable Accommodation/Disability 

Program Coordinators with training on Reasonable Accommodation Under the ADA and Rehabilitation 

Act: What you need to know. The session focused on practical application of the ADA and its 

amendments and how Agencies must and should respond to requests for accommodations. The training 

also covered current trends and mistakes to avoid during the reasonable accommodation process.

During FY 2018, Treasury utilized 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. This tool continues 

to assist Treasury to meet its participation rate goals and encourages the use of special hiring authorities,
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such as Schedule A and the hiring authority for veterans with 30% or more compensable disability.

In FY 2018, OCRD finalized and posted its PAS Policy and procedures to our internal and external 

website. The external link is https://www.treasury.gov/about/organizationalstructure/offices/Mgt/Pages/eeo_programs.aspx. OCRD also finalized a personal assistance service 

provider position description to facilitate their hiring. 

OCRD also includes a Disability Awareness section in its quarterly newsletter, the OCRD Advisory.

Through the newsletter and other sources, the Department ensures that hiring managers are informed of 

and encouraged to use various resources that provide assistance with the employment of qualified people 

with disabilities, e.g., CAREERS and the disABLED, OPM’s Bender Consulting Services, the Division of 

Rehabilitation Services (DORS), and State Vocational Rehabilitation Agencies.

Based on feedback from Treasury’s FY 2017 Affirmative Action Plan, OCRD required all of its bureaus to 

review and update as required their existing reasonable accommodations (RA) policies and procedures. 

Once the bureaus have completed their updates to the existing RA policies and procedures, submitted 

them to OCRD for review/comment, OCRD will submit them to the EEOC for review and approval. To 

date, OCRD has submitted to EEOC the revised bureau RA policies and procedures for BEP, FS, DO, 

IRS, Mint, OCC and TIGTA. OCRD is working with FinCEN, IRS-CC, OIG, SIGTARP, and TTB to finalize 

their revisions to their RA Policies and procedures. The bureaus have been directed that once a bureau’s 

RA policy and procedures have been approved by EEOC, the bureau is to post the approved RA policy 

and procedures to its external and internal website.

Part E.4 - Executive Summary: Accomplishments

Accomplishments

The Department is proud of its accomplishments towards maintaining a model EEO program in FY 2018. 

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

• In collaboration with DASHR CHCO, completed the implementation plan for recommended 

strategies identified in the Treasury SES barrier analysis.

• Established and posted Treasury-wide Personal Assistant Services (PAS) policy and procedures 

to the Department’s external and internal websites.

• Created a personal assistance service provider position description to facilitate hiring.

• Conducted multiple training sessions with bureau MD-715 preparers on the preparation of the 

new MD-715 Version 2 PARTS A-J; ensuring a smooth transition into EEOC’s new reporting 

requirements for the FY 2018 reporting period. 

• Conducted a two-day barrier analysis training workshop for representatives of the Mint EEO staff 

from each of its five facilities. The workshop provided instruction on use of the MD-715 workforce 

data tables, the identification of triggers, associating like triggers to determine the direction of the 

barrier analysis process, conducting root cause analysis to identify potential barriers, as well as 

how to prepare required plans to eliminate any identified barriers.

• OCRD partnered with Enterprise Data Management, CareerConnector, and Monster to create 

new workforce data tables required by the implementation of the EEOC’s MD-715 Version 2, 

which will be fully implemented in the FY 2019 reporting period.

• Collaborated with Monster and CareerConnector to establish and implement new reporting 

methodology for capturing applicant flow data, including with respect to applicants who were 

referred and interviewed, as well as data on bureau formal career development programs through 

which competitively selected candidates become eligible for promotion upon completion. 

• Published quarterly EEO and Veterans newsletters which provided Treasury’s EEO practitioners, 

managers, supervisors, and employees with information on relevant complaint issues, workforce 

statistics and important upcoming agency events/activities. 

• Conducted two “Be a Champion Roadshows” with FS and DO managers and hiring officials to 

educate them on the use of special hiring authorities to increase the participation rate for PWTD 

and disabled veterans
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• Participated in the 25th Annual Federal Inter-Agency Observance to Honor the Days of 

Remembrance.

• Released the Secretary’s updated Equal Opportunity and Diversity Statement for FY 2018. 

• Launched two new Department-wide Employee Resource Groups (ERG): Adelante (Hispanic) 

and LEO (Law Enforcement Officers). 

• Expanded official leadership for existing Prism (Lesbian, Gay, Bisexual, Transitioning, and 

Questioning (LGBTQ)) and VERG (Veterans) ERG groups.

• Supported all four ERG’s through regular meetings, training events, and other outreach 

opportunities.

• Designed and presented LGBTQ Cultural Competency training for 543 employees across IRS, 

FS and DO.

• Provided assistance to four employees undergoing gender transition; notified employees through

intersex announcements across the Department. 

• Issued seven Observance newsletters; shared inclusion opportunities associated with special 

emphasis groups and observances held throughout Treasury.

• Partnered with bureau Diversity and Inclusion Liaisons to review bureau specific Federal 

Employee Viewpoint Survey data and updated their New IQ plans as part of the Inclusive 

Diversity Strategic Plan for 2018. 

• Conducted micro aggression training sessions for the Philadelphia Mint leadership and 

employees, 

• Exceeded EEOC’s goal that 12 percent of all new permanent hires be PWD (12.39 percent) and 

the sub goal that 2 percent of those hires be PWTD (3.57 percent).

• Provided eight hours of refresher training to Treasury Shared Neutral’s current mediator cadre 

members.

• As part of the Department’s Conflict Resolution Week, provided a lunch and learn training session 

titled, Understanding the Civility Spectrum in the Workplace. The Session discussed the impact 

of workplace culture on productivity and collaboration, how to recognize and diminish incivility in 

the workplace, and what to do to promote a culture of courtesy, respect, and collaboration.

• Completed a total of 259 mediations and successfully resolved 99 (38%) of the complaints 

mediated.

Part E.5 - Executive Summary: Planned Activities

Planned Activities/Conclusion

The Office of Civil Rights and Diversity’s FY 2018 MD-715 Report outlines the many successes in our 

equal opportunity programs and activities. The Department of the Treasury is proud of its 

accomplishments in attracting and retaining an increasingly diverse workforce. However, we realize there 

is always more to be done 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 

individuals with 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, wellqualified talent from which to recruit.

OCRD’s FY 2019 planned activities include the following:

• Reinstitute the bureau audit program, reviewing all phases of at least two bureaus’ EEO 

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

scheduled to audit FinCEN, Mint’s and IRS’s EEO programs. 

• Work with Enterprise Data Management and Monster Analytics to improve reporting capability of 

workforce analytics, resulting in improved data analysis capabilities around workforce 

demographics, as shown by meeting new EEOC reporting requirements. Train 80% of the 

bureaus in data analysis capabilities that will enable bureaus to provide data on demand to 

leadership.

• Perform analysis of off-the-shelf commercial programs designed to improve reporting on the 
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DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

12

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

and Budget to plan for acquisition and roll out in FY 2020. 

• 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. 

• Promote the use of the ADR process to resolve EEO disputes. Evaluate the effectiveness of 

ADR and monitor use findings to make improvements. 

• Perform continuous improvement processes, including best practice review on the EEO complaint 

process, to maintain/improve excellent results in timely investigations and decisions. Achieve at 

least a 90% timeliness rate for investigations and decisions.

• Finalize Blanket Purchase Agreement (BPA) for personal assistance services for all bureaus to 

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

severely disabled employees.

• Closely monitor the Treasury Complaint Management System to ensure continued improvement 

in the timely production of final agency decisions and EEO investigations.

• Update the Department’s Sexual Harassment brochure and make available to our employees 

through OCRD’s internal website.

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

circumstance services.

• Explore re-competing the contract for IComplaints services to provide superior technical support 

for processing functions and document storage.

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

active cadre members.

• As part of Treasury’s FY 2019 Annual Dispute Prevention Program, coordinate and conduct a 

Dispute Prevention training session that emphasizes the benefits of ADR. 

• Provide one refresher training for current TSN mediators.

• Transition the TSN administrator functions to Bureau of Engraving and Printing for FY 2020 and

FY 2021.

• Continue to monitor bureau plans to identify the existence of barriers to the employment of any 

group and strategies to eliminate any barriers that are uncovered.

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

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

• Conduct the “Be a Champion” Roadshow for Treasury leadership.

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

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

PWTD and disabled veterans. 

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

with disabilities.

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14

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

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)]

Yes Issued 04/13/2018

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

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. Bureau’s 

display the specific bureau

contact information. However, 

at each Treasury bureau,

counseling is centralized. 

Therefore, bureaus post 

general contact information of 

who to contact to initiate a 

complaint. 
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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, and on 

informational posters posted in 

common areas/breakrooms; is 

part of new employee and 

manager orientation sessions; 

and every two years is part of 

the No FEAR Act training.

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 is

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 

included during new employee 

and manager orientation 

sessions and every two years 

as part of the No FEAR Act 

training.

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 

included during new employee 

and manager orientation

sessions, every two years as 

part of the No FEAR Act 

training, and annually as part 

of 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.

It is included in new employee 

and manager orientation

sessions, as part of the No 

FEAR Act training conducted 

every 2 years, and annual 

POSH training. 
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DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures

A.3 – The agency assesses and ensures 

EEO principles are part of its culture.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

A.3.a Does the agency provide recognition to 

employees, supervisors, managers, and 

units demonstrating superior 

accomplishment in equal employment 

opportunity? [see 29 CFR § 1614.102(a) (9)] 

If “yes”, provide one or two examples in the 

comments section.

Yes 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 

effective means of advising the agency head 

and other senior management officials of the 

effectiveness, efficiency and legal 

compliance of the agency’s EEO program?

[see 29 CFR §1614.102(c)(1); MD-715 

Instructions, Sec. I] 

Yes
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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 2017 

State of the Agency (SOA) 

briefing to Agency Head on 

04/30/2018. SOA for the FY 

2018 reporting period will be 

conducted prior to the 

submission of the FY 2018 

MD-715 report to EEOC.

B.1.d Does the EEO Director regularly participate 

in senior-level staff meetings concerning 

personnel, budget, technology, and other 

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

Yes

Compliance 

Indicator

Measures

B.2 – The EEO Director controls all 

aspects of the EEO program.

Measure 

Met?

(Yes/No/NA)

Comments

New Compliance Indicator

B.2.a Is the EEO Director responsible for the 

implementation of a continuing affirmative 

employment program to promote EEO and to 

identify and eliminate discriminatory policies, 

procedures, and practices? [see MD-110, 

Ch. 1(III)(A); 29 CFR §1614.102(c)] 

Yes

B.2.b Is the EEO Director responsible for 

overseeing the completion of EEO 

counseling [see 29 CFR §1614.102(c)(4)]

Yes

B.2.c Is the EEO Director responsible for 

overseeing the fair and thorough 

investigation of EEO complaints? [see 29 

CFR §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 

program and providing recommendations for 

improvement to the agency head? [see 29 

CFR §1614.102(c)(2)]

Yes
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DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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
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B.4.a.4 to provide all supervisors and employees 

with training on the EEO program, including 

but not limited to retaliation, harassment, 

religious accommodations, disability 

accommodations, the EEO complaint 

process, and ADR? [see MD-715, II(B) and 

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

training with insufficient funding in the 

comments column. 

Yes

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

counselors and investigators, including 

contractors and collateral duty employees, 

receive the required 8 hours of annual 

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

MD-110?

Yes

Compliance 

Indicator 

Measures

B.5 – The agency recruits, hires, 

develops, and retains supervisors and 

managers who have effective managerial, 

communications, and interpersonal skills.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

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

all managers and supervisors received 

training on their responsibilities under the 

following areas under the agency EEO 

program:

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

New Indicator 

B.6.a Are senior managers involved in the 

implementation of Special Emphasis 

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

Yes

B.6.b Do senior managers participate in the barrier 

analysis process? [see MD-715 Instructions, 

Sec. I] 

Yes

B.6.c When barriers are identified, do senior 

managers assist in developing agency EEO 

action plans (Part I, Part J, or the Executive 

Summary)? [see MD-715 Instructions, Sec. I]

Yes
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B.6.d Do senior managers successfully implement 

EEO Action Plans and incorporate the EEO 

Action Plan Objectives into agency strategic 

plans? [29 CFR § 1614.102(a)(5)]

Yes

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY

This element requires the agency head to hold all managers, supervisors, and EEO 

officials responsible for the effective implementation of the agency’s EEO Program and 

Plan.

Compliance 

Indicator 

Measures

C.1 – The agency conducts regular 

internal audits of its component and field 

offices.

Measure 

Met?

(Yes/No/NA)

Comments

C.1.a Does the agency regularly assess its 

component and field offices for possible EEO 

program deficiencies? [see 29 CFR 

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

schedule for conducting audits in the 

comments section.

Yes Annually, before the 

submission of the bureau MD715 reports to EEOC, OCRD 

evaluates their submissions 

and provides feedback on the 

status of deficiencies and

implementation of planned 

activities to eliminate 

deficiencies, and recommends 

additional measures required 

to eliminate noted deficiencies.

Additionally, OCRD will be 

conducting an audit review of 

Mint (May - June), IRS (July -

September), and FinCEN 

(September) EEO Programs 

during FY 2019.

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, before the 

submission of the bureau MD715 reports to EEOC, OCRD 

evaluates their submissions 

and provides feedback on the 

status of barrier analysis and 

implementation of planned 

activities to eliminate barriers,

and recommends additional 

measures required to identify 

and eliminate noted barriers.

Additionally, OCRD will be 

conducting an audit review of 

Mint (May - June), IRS (July -

September), and FinCEN 

(September) EEO Programs 

during FY 2019.
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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

Compliance 

Indicator 

Measures

C.2 – The agency has established 

procedures to prevent all forms of EEO 

discrimination.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

C.2.a Has the agency established comprehensive 

anti-harassment policy and procedures that 

comply with EEOC’s enforcement guidance?

[see MD-715, II(C); Enforcement Guidance 

on Vicarious Employer Liability for Unlawful 

Harassment by Supervisors (Enforcement 

Guidance), EEOC No. 915.002, § V.C.1 

(June 18, 1999)]

Yes

C.2.a.1 Does the anti-harassment policy require 

corrective action to prevent or eliminate 

conduct before it rises to the level of unlawful 

harassment? [see EEOC Enforcement 

Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), 

§ V.C.1]

Yes

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

between the 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
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C.2.a.5 Does the agency conduct a prompt inquiry 

(beginning within 10 days of notification) of 

all harassment allegations, including those 

initially raised in the EEO complaint process? 

[see Complainant v. Dep’t of Veterans 

Affairs, EEOC Appeal No. 0120123232 (May 

21, 2015); Complainant v. Dep’t of Defense 

(Defense Commissary Agency), EEOC 

Appeal No. 0120130331 (May 29, 2015)] If 

“no”, please provide the percentage of 

timely-processed inquiries in the comments 

column.

Yes

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’

reasonable accommodation 

(RA) policies have been 

updated and submitted to 

OCRD for review and 

approval. As the revised 

bureau RA policies and 

procedures are approved by 

OCRD, they will be submitted 

to EEOC for review and 

approval. In the interim,

Treasury has directed bureaus 

to post interim policies and 

procedures pending EEOC’s 

approval. Once approved,

bureaus will replace interim 

policy 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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 31% of it requests. 

C.2.c Has the agency established procedures for 

processing requests for personal assistance 

services that comply with EEOC’s 

regulations, enforcement guidance, and 

other applicable executive orders, guidance, 

and standards? [see 29 CFR 1614.203(d)(6)]

Yes

C.2.c.1 Does the agency post its procedures for 

processing requests for Personal Assistance 

Services on its public website? [see 29 CFR 

§ 1614.203(d)(5)(v)] If “yes”, please provide 

the internet address in the comments 

column.

Yes https://www.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

New Indicator

C.3.a Pursuant to 29 CFR §1614.102(a)(5), do all 

managers and supervisors have an element 

in their performance appraisal that evaluates 

their commitment to agency EEO policies 

and principles and their participation in the 

EEO program?

Yes

C.3.b Does the agency require rating officials to 

evaluate the performance of managers and 

supervisors based on the following activities:

C.3.b.1 Resolve EEO 

problems/disagreements/conflicts, including 

the participation in ADR proceedings? [see 

MD-110, Ch. 3.I]

Yes

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 

MD-715, II(C)]

Yes

C.3.b.8 Support the anti-harassment program in 

investigating and correcting harassing 

conduct. [see Enforcement Guidance, V.C.2]

Yes

C.3.b.9 Comply with settlement agreements and 

orders issued by the agency, EEOC, and 

EEO-related cases from the Merit Systems 

Protection Board, labor arbitrators, and the 

Federal Labor Relations Authority? [see 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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 Five (three from FAD’s and 

two from civil court cases)

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 

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

the frequency of the EEO updates in the 

comments column.

Yes The OCRD Director updates 

the ASM as issues arise. The 

OCRD Director also 

participates in the ASM’s 

weekly staff meetings. 

Additionally, diversity 

dashboards on Treasury and 

individual bureau workforce 

demographics are provided to 

the ASM 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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

New Indicator

D.2.a Does the agency have a process for 

analyzing the identified triggers to find 

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

Yes

D.2.b Does the agency regularly examine the 

impact of management/personnel policies, 

procedures, and practices by race, national 

origin, sex, and disability? [see 29 CFR 

§1614.102(a)(3)]

Yes

D.2.c Does the agency consider whether any 

group of employees or applicants might be 

negatively impacted prior to making human 

resource decisions, such as re-organizations 

and realignments? [see 29 CFR 

§1614.102(a)(3)]

Yes

D.2.d Does the agency regularly review the 

following sources of information to find 

barriers: complaint/grievance data, exit 

surveys, employee climate surveys, focus 

groups, affinity groups, union, program 

evaluations, anti-harassment program, 

special emphasis programs, reasonable 

accommodation program; 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 

iComplaint; 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 bureau EEO and 

HR personnel upon request. 
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

Compliance 

Indicator 

Measures

D.3 – The agency establishes appropriate 

action plans to remove identified barriers.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

D.3.a. Does the agency effectively tailor action 

plans to address the identified barriers, in 

particular policies, procedures, or practices?

[see 29 CFR §1614.102(a)(3)]

Yes

D.3.b If the agency identified one or more barriers 

during the reporting period, did the agency 

implement a plan in Part I, including meeting 

the target dates for the planned activities? 

[see MD-715, II(D)] 

Yes

D.3.c Does the agency periodically review the 

effectiveness of the plans? [see MD-715, 

II(D)]

Yes

Compliance 

Indicator 

Measures

D.4 – The agency has an affirmative 

action plan for people with disabilities, 

including those with targeted disabilities.

Measure 

Met?

(Yes/No/NA)

Comments

New Indicator

D.4.a

Does the agency post its affirmative action 

plan on its public 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

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 

letter no more than 30 days 

from file date.

FY 18 Averages: 

Acceptance letters were 

issued in 15 days.

Dismissal letters were issued 

in 22 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 

hearing, does the agency timely issue the 

final agency decision, pursuant to 29 CFR 

§1614.110(b)?

Yes

E.1.i Does the agency timely issue final actions 

following receipt of the hearing file and the 

administrative judge’s decision, pursuant to 

29 CFR §1614.110(a)?

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 

stats of all cases and 

discusses any instance where 

a case may be untimely and 

the reason for the untimeliness 

and ensures 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

Revised Indicator

E.2.a Has the agency established a clear 

separation between its EEO complaint 

program and its defensive function? [see 

MD-110, Ch. 1(IV)(D)] 

Yes

E.2.b When seeking legal sufficiency reviews, does 

the EEO office have access to sufficient legal 

resources separate from the agency 

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

If “yes”, please identify the source/location of 

the attorney who conducts the legal 

sufficiency review in the comments column. 

Yes Legal Sufficiency reviews are 

completed in Treasury General 

Counsel Office 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 

incorporated for the legal counsel’s 

sufficiency review for timely processing of 

complaints? [see EEOC Report, Attaining a 

Model Agency Program: Efficiency (Dec. 1, 

2004)]

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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 MD715, II(E)]

Yes

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

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

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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; Veteran and 

Disability 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

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

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

Indicator moved from E-III 

Revised

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

comply with EEOC orders? [see 29 CFR 

§1614.502; MD-715, II(E)]

Yes

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
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

DEPARTMENT OF THE TREASURY ANNUAL EEO PROGRAM STATUS REPORT 

 

Compliance 

Indicator

 

Measures

F.3 - The agency reports to EEOC its 

program efforts and accomplishments.

Measure 

Met?

(Yes/No/NA)

Comments

F.3.a Does the agency timely submit to EEOC an 

accurate and complete No FEAR Act report? 

[Public Law 107-174 (May 15, 2002), 

§203(a)]

Yes

F.3.b Does the agency timely post on its public 

webpage its quarterly No FEAR Act data?

[see 29 CFR §1614.703(d)]

Yes
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 timely processing of IRS reasonable 

accommodation requests.

9/30/2019

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)

9/30/2019

Monitor implementation of IRS’s planned 

activities to eliminate untimely processing of RA 

requests.

Yes
EEOC FORM 

U.S. Equal Employment Opportunity Commission 

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Report of Accomplishments 

Fiscal Year Accomplishments

2018 N/A
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’s 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’s and its bureaus’ RA policies 

and procedures are in compliance with EEOC 

requirements and submitted to EEOC for final 

approval.

9/30/2019

Responsible Official(s)

Title Name

Performance 

Standards 

Address the Plan?

(Yes or No)

Director, OCRD Mariam Harvey Yes
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Planned Activities Toward Completion of Objective

Target 

Date 

(mm/dd/yyyy)

Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

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 procedure 

requiring change will be returned to the 

appropriate bureau for correct. 

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

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

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 websites. 

Yes

Report of Accomplishments 

Fiscal Year Accomplishments

2018

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

procedures for BEP, FS, DO, IRS, Mint, OCC, and TIGTA. Of those 

submitted to EEOC, EEOC has approved OCC’s RA policies and 

procedures. OCRD is currently working with FinCEN, IRS-CC, OIG, 

SIGTARP, and TTB to finalize their revisions to their RA Policies and 

procedures. 
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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

EEOC 

Feedback A4-1

In August FY 2015, Treasury received a feedback letter from the EEOC 

based on the Department’s and its bureaus’ responses to the EEOC’s 

Federal Complement Plan (FCP) Questionnaire and a June 12, 2015

follow-up meeting with EEOC staff members. The letter indicated that 

the Department had not identified any triggers involving EEO groups in 

its SES positions or a barrier analysis in PART I as part of its FY 2014 

MD-715 reporting, even though its bureaus had indicated triggers for 

several EEO groups in their responses to the FCP.

A review of bureau Management Directive (MD) 715 Reports indicated the 

presence of potential barriers for women and some minorities in reaching 

SES positions as well as in the feeder pools (GS-15 and equivalent 

positions) that can lead to SES positions. 

EEO Group(s) Affected by Trigger

EEO Group Affected by Trigger?

(Yes or No)

All Men No

All Women Yes

Hispanic or Latino Males Yes

Hispanic or Latino Females Yes

White Males No

White Females Yes

Black or African American Males Yes

Black or African American Females Yes

Asian Males No
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EEO Group Affected by Trigger?

(Yes or No)

Asian Females Yes

Native Hawaiian or Other Pacific Islander Males No

Native Hawaiian or Other Pacific Islander Females No

American Indian or Alaska Native Males Yes

American Indian or Alaska Native Females No

Two or More Races Males Yes

Two or More Races Females Yes

Barrier Analysis Process

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes

Reviewed bureau specific workforce data by race, 

ethnicity, and gender, for (1) career SES positions and 

OCC equivalent NB 8-9 positions at the end of FY 2014

compared to FY 2010 and FY 2005 and (2) the FY 2014 

SES feeder pool positions (i.e., GS-15 and OCC 

equivalents) compared to FY 2010 and FY 2005, and 

relevant applicant flow data.

Complaint Data (Trends) No

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

Interviews Yes

Reviewed bureau HR/EEO responses to the following 

questions: 

1. How are SES vacancies announced? 

2. Are all SES announcements processed 

through CareerConnector/Monster?

3. Are all SES announcements Public? Or 

Status? If not, can they be restricted to 
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Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

internal?

4. What is the required length of time for posting 

SES vacancies?

5. How do you recruit for SES vacancies?

6. Do you conduct targeted recruitment and 

outreach? And if so, what does that mean/look 

like? (for any ERI, gender or occupational 

series)

7. Is the application process resume only? Or 

does it allow for ECQ’s?

8. What is the selection process? (Be specific)

9. How do you rate/rank? 

10. If you use a selection panel, is there a policy 

pertaining to the diversity of the panel?

11. If there is a policy pertaining to the diversity of 

the panel, how do you enforce the policy?

12. Who determines the criteria for the vacancy 

announcement?

13. Are your interviewers trained in interviewing 

techniques?

14. Are your interviewers trained in unconscious 

bias?

15. Provide a list of the occupations that feed into 

your SES ranks.

Reports (e.g., Congress, 

EEOC, MSPB, GAO, OPM) No

Other (Please Describe) Yes

Reviewed bureau policies, MD-715 reports, and bureau 

SES Career Development Program (CDP) participation 

and application processes.

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

Yes Yes
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Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

The working group found that the Department as a whole has made significant strides to increase 

diversity within the SES and SES feeder pool for both women and minorities. However, for those 

bureaus or occupations with 10 or fewer SES positions, the limited number of positions and infrequency

with which these positions turn over will impact the ability to make progress.

For those bureaus with a significant number of SES, we found that with the exception of IRS and OCC, limited 

or no outreach is being conducted. The working group found that most bureaus are either simply posting the 

positions on USAJobs or seeking qualified candidates from existing employees who have successfully 

completed a SES CDP program. IRS and OCC reported taking additional steps and posting to sites such as 

Twitter, Facebook, and LinkedIn, or to occupation-focused organizations.

In those cases where the bureau seeks to fill vacant SES positions with an existing internal SES CDP 

graduate, diversity by ERI and gender depends on the bureau’s existing diversity. In most cases, the diversity 

is not there; therefore, little change in the overall demographics of the SES cadre can be expected. 

In reviewing Executive Resources Board (ERB) panel procedures, we found that none of the bureaus 

have an official policy to ensure that the ERB panels are diverse, nor are there standard processes to 

ensure panel diversity. We also noted that none of the bureaus require ERB panel members to 

complete mandatory interviewing or unconscious bias training.

Overall, it was reported that bureaus post vacancies for SES positions for 14 days; however, vacancies 

can be posted for up to 30 days. FS reported that when it posts SES vacancies internally, it may do so 

for only five days. Posting a vacancy announcement for 14 days or fewer does not necessarily give the 

agency the broadest pool of candidates, nor necessarily give candidates ample time to find out about 

the vacancy, prepare an application package, and apply before it closes.
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Objective(s) and Dates for EEO Plan

Objective

Date 

Initiated 

(mm/dd/yyyy)

Target 

Date 

(mm/dd/yyyy)

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date 

(mm/dd/yyyy)

Date 

Completed 

(mm/dd/yyyy)

Enhance or establish 

appropriate Treasury-wide 

policy and procedures to ensure 

equal access to opportunity for 

advancement to SES, 

participation in SES CDP 

programs and eliminate 

potential for unconscious bias in 

the selection process.

09/30/2016 09/20/2017 Yes 09/30/2018 09/27/2018

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan? 

(Yes or No)

Director, OCRD Mariam Harvey Yes

DASHR CHCO Trevor Norris Yes

Planned Activities Toward Completion of Objective

Target Date 

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

Completion 

Date 

(mm/dd/yyyy)

6/30/2016

Draft and finalize Diversity in the Career Senior 

Executive Service at the Department of the 

Treasury and the Processes for Selecting New 

Executives FY 2005 through FY 2015 Report. 

(OCRD)

06/28/2016

8/30/2016

Brief Departmental Executive Resources Board on 

the report and get endorsement for the 

recommendations in the report. (OCRD/DASHR 

CHCO)

08/15/2016

09/30/2016

Submit final report to ASM for approval and 

dissemination to Bureau Heads. Disseminated final 

report to EEO Officers. (OCRD)

09/15/2016
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09/30/2017

Require bureaus to update internal procedures 

requiring appropriate management official to 

review the statistics relating to the diversity of the 

internal pool prior to recruiting internally, to help 

develop a sufficient pool of diverse internal 

candidates from which to recruit. (DASHR 

CHCO/OCRD)

09/30/2018 09/27/2018

09/30/2017

Coordinate changes and/or the development of 

new tables with CareerConnector/Monster 

Analytics to ensure applicant flow data is available 

for all vacancy announcements, not just internal 

announcements. (OCRD)

09/30/2018 08/25/2018

09/30/2017

Establish policy to require all bureaus to track 

applicant flow data for all SES CDP programs to 

enhance barrier analysis capabilities on the SES

CDP programs. (DASHR CHCO)

09/30/2018 09/27/2018

09/30/2017

To ensure the broadest pool of candidates for SES 

vacancies, SES vacancy announcements are to be 

posted/open for a minimum of 30 days to allow 

sufficient time to recruit widely. Shorter periods 

should be on an exception only basis, when there 

is a demonstrated urgent need. (DASHR CHCO)

09/30/2018 09/27/2018

09/30/2017

To ensure employment opportunities are reaching 

those intended groups, the working group 

recommends that each bureau reevaluate where it 

is currently sending its vacancy announcements to 

give them the best opportunity to reach those 

groups with lower than expected application rates 

as well as overall workforce participation in 

comparison to their OCLF benchmarks. As part of 

this recommendation, the working group 

recommends expansion of the Departmental 

Offices’ contract with the Professional Diversity 

Network (PDN) to allow all bureaus to announce all 

SES positions through PDN or an equivalent 

service. (DASHR CHCO/OCRD)

09/30/2018 09/27/2018

09/30/2017

Establish policy guidance as to composition of the 

ERBs used to evaluate candidates. Inform 

Bureaus they should strive to ensure ERB panels 

are diverse as to gender, race, and ethnicity 

whenever possible. If a diverse group of subject 

matter experts is not available, the bureau EEO 

Officer (if an executive) should be a part of the 

process. (DASHR CHCO)

09/30/2018 09/27/2018
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09/30/2017

Establish policy guidance requiring ERB panel 

members and hiring officials to complete 

unconscious bias or similar training prior to serving 

on an ERB panel. (DASHR CHCO)

09/30/2018 09/27/2018

09/30/2017

Establish policy requiring HR offices to mask 

candidate’s names or other identifying information 

when rating/ranking applications for SES or SES 

candidate development programs. (DASHR 

CHCO)

09/30/2018 09/27/2018

09/30/2017

Establish policy that when a new SES candidate is 

appointed, an agency EEO officer will brief her or 

him on EEO and diversity, including discussing 

their roles and responsibilities and the 

demographic composition of their workforce. 

(OCRD)

09/30/2018 09/27/2018

09/30/2017

Incorporate a discussion of EEO and diversity into 

all SES orientation and training for new executives. 

(DASHR CHCO/OCRD)

09/30/2018 09/27/2018

Report of Accomplishments 

Fiscal Year Accomplishments

2016

OCRD completed the Diversity in the Career Senior Executive Service at 

the Department of the Treasury and the Processes for Selecting New 

Executives FY 2005 through FY 2015 Report; the Departmental Executive 

Resource Board was briefed and concurred with the report findings and 

recommended actions. The final report was submitted to the ASM for 

signature and release to Bureau Heads on September 15, 2016 and to 

bureau EEO Officers on September 22, 2016. (A copy of the report has 

been uploaded as a supporting document in FedSEP)

In August 2015, OCRD notified CareerConnector and Monster Analytics of 

the requirement to expand the current workforce data tables to include 

external vacancies as well as internal ones. CareerConnector, OCRD, and 

Monster are working together to implement the new requirements in FY 

2017. 

2017

Due to the transition to a new administration, as well as many other 

competing budget and reform requirements, the planned activities for 

completion in FY 2017 had to be modified for completion in FY 2018.

Additionally, with the implementation of OPM’s new SF-256 in April FY 

2017, Monster was unable to make the changes to allow Treasury and its 

bureaus to look at external as well as internal applicant flow data. Instead, 

the focus was to ensure applicant flow data tables were capable of 

collecting and reporting on the new/revised disability codes implemented by 

the new SF-256. In addition, it was announced that EEOC is in the process 

of revising the A/B workforce data table requirements for FY 2019. The 

decision was made to wait until EEOC finalizes and announces any new 
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changes before making any further revisions to the existing MD-715 data 

tables.

2018

OCRD partnered with Workforce Analytics, Monster and CareerConnector

to identify the methodology for capturing required data to complete the 

revision of the A and B workforce data tables based on EEOC instruction 

issued with the new MD-715 Version 2 in October 2017.

The new workforce data tables now allow the agency to review both 

internal promotions and external hires applicant flow data for the 

occupations, feeder pools and SES, as well as by Management Officials 

(Executives, Managers and Supervisory level) and for formal CDP 

programs. The tables also incorporated the requirement to be able to view 

applicant flow data for those that were referred as well as interviewed. 

In support of the new requirements, DASHR CHCO issued a memorandum 

to HR Officers at the bureau level requiring them to integrate the new 

procedures into their process to ensure the capability to capture and report 

on the new requirements in FY 2019. 

Additionally, Senior Executive Services issued a guidance memo on 

September 27, 2018, requiring bureaus to implement policy changes

outlined in the planned activities above.
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MD-715 – Part J

Special Program Plan for the Recruitment, Hiring, Advancement, 

and Retention of Persons with Disabilities

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

persons with targeted disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) 

and MD-715 require agencies to describe how their plan will improve the recruitment, 

hiring, advancement, and retention of applicants and employees with disabilities. All 

agencies, regardless of size, must complete this Part of the MD-715 report.

Section I: Efforts to Reach Regulatory Goals

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

numerical goals for increasing the participation of persons with reportable and targeted 

disabilities in the federal government. 

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

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

in the text box.

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

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

The participation rate for PWD at the GS-11 to SES grade cluster is 10.36% in FY 

2018, which falls below the 12% goal.

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

N/A

2. Describe how the agency has communicated the numerical goals to the hiring 

managers and/or recruiters.
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Treasury issued a memorandum on or around September 25, 2017 to Human 

Resources (HR) staff and hiring managers, describing the Department’s commitment 

to meeting the numerical goals set forth at Section 501. The memorandum 

emphasized improving hiring efforts in the mission critical occupations: IT 

Management; Program Analyst; Accounting; and Financial Management Analysis. 

Additionally 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 the Department’s progress towards 

meeting the established goals for PWD and PWTD.

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

N/A
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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 

76 3 36 See specific bureau 

PART J.

Answering questions from the 

public about hiring authorities that 

take disability into account

55 3 25 See specific bureau 

PART J.

Processing reasonable 

accommodation requests from 

applicants and employees

47 5 12 See specific bureau 

PART J.

Section 508 Compliance 144 1 5 See specific bureau 

PART J.

Architectural Barriers Act 

Compliance

 20 2 256 See specific bureau 

PART J.

Special Emphasis Program for 

PWD and PWTD

14 1 5 See specific bureau 

PART J.

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

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

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 2018, OCRD provided multiple sessions to the bureau’s staff on the new 

PARTJ and use of the new MD-715 V2 workforce data tables. OCRD and the 

bureau’s Disability Program Managers also participated in the quarterly Federal 

Exchange on Employment and Disability (FEED) meetings, hosted by EEOC and 

Department of Labor, which educate attendees on various issues and topic related to 

disability. 

Annually, all HR professionals are required to complete online courses related to 

veteran’s employment, which include disability components. This training, provided 

by the Department of the Treasury, is mandated by Executive Order (EO) 13518. 

Also, HR representatives attended a reasonable accommodation (RA) refresher 

course, which included a disability component.
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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

N/A

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.
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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 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. 

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 Disability Program 

Manager (DPM) has established numerous external partnerships with private and 

public organizations that assist PWD/PWTD candidates in finding meaningful 

employment. The DPM alerted both selecting officials and embedded HR personnel 

on the value of hiring external disabled applicants. Alerts were made through Saba

Centra, an e-Learning product which expands remote access such as email

communications, conference calls, and Department-wide online training. 
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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 applicants utilize the Schedule A Hiring Authority, the process for eligibility and 

hire encompasses: 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, NonCompetitive, Veterans’ Recruitment Appointment (VRA), etc.). 

Alternatively, when individuals submit their resumes directly to the Treasury or IRS

Special Placement Program Coordinator (SPPC) for vacant positions, the SPPC 

refers the resumes to the designated servicing HR Specialist. The HR Specialist 

reviews the resumes to determine qualifications. If qualifications and Schedule A 

eligibility are met, the resumes are then forwarded to the hiring manager for 

consideration, 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 veteran’s employment online training provided through the Treasury’s 

Integrated Talent Management System (ITMS). Disability training, such as Americans 

with Disability Act: An Overview for Managers and A Manager’s Guide to Diversity, 

Inclusion and Accommodations, along with other hiring manager tools are also 

available through ITMS.

 
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B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT 

ORGANIZATIONS

Describe the agency’s efforts to establish and maintain contacts with organizations that 

assist PWD, including PWTD, in securing and maintaining employment. 

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 professional organizations 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 has established a working 

relationship with the Computer/Electronic Accommodation Program (CAP) to secure 

devices frequently used by PWD and PWTD. 

The Department also established a Treasury-wide sign language interpreters contract 

to provide an effective and efficient procedure for providing sign language interpreters.

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

Overall Treasury rates of participation are above the federal benchmark. 

• PWD New Hires: 14.17% vs 12.0%

• PWTD New Hires: 3.15% vs 2.0%
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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

Data from the Treasury Workforce Analytics (WA) Table B8 (All): New hires by 

Occupational Series and Monster Table B8 (Management Positions by New Hires and 

Occupational Series) were analyzed to identify triggers among new hires, indicating 

the following results: 

FY 2018 New Hires Qualified vs. New Hires Qualified vs. New Hires

0110 (18) PWD: 3.49% - 5.56% PWTD: 1.74% - 0.00%***

0340 (3 ) PWD: 5.37% - 0.00%*** PWTD: 3.36% - 0.00%***

0343 (19) PWD: 7.71% - 21.05% PWTD: 3.33% - 0.00%***

0501 (10) PWD: 5.88% - 10.00% PWTD: 1.78% - 0.00%***

0511 (6) PWD: 7.18% - 50.00% PWTD: 3.35% - 0.00%***

0570 (98) PWD: 3.14% - 9.18% PWTD: 1.19% - 1.19%

0905 (80) PWD: 5.20% - 2.50%** PWTD: 1.80% - 1.25%**

1169 (0) PWD: 3.78% - 0.00%*** PWTD: 2.33% - 0.00%***

1811 (10) PWD: 1.58% - 10.00% PWTD: 0.88% - 0.00%*

2210 (214) PWD: 5.21% - 31.78% PWTD: 1.90% - 6.54%

The following triggers were identified: 

*The 1811, Criminal Investigators occupation, 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.

**However, triggers were noted when comparing the qualified applicant flow data with 

the hires for PWD in the 0905 occupational series. A slight difference of 0.55% was 

noted for PWTD in the 0905 occupational series, however, that difference is not 

significant enough to be considered a trigger at this time. For the five Treasury 

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

noted in their PART Js. Plans to improve hiring for PWD/PWTD within the major 

occupations listed are detailed in the specific bureau PART Js. Treasury will monitor 

all bureau PART Js 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. 
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Therefore, Treasury determined a threshold of 20 new hires. Any participation less 

than 20, will not support a realistic outcome. The occupations with limited hiring

0110, 0340, 0343, 0501, 0511, and 1169, did not have enough hires to determine if 

there is an actual trigger. (*1811 is an exception as stated above). 

NOTE: It is important to note that when the Department looks at aggregated 

Treasury-wide data, the progress noted may not accurately reflect 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 directed the bureaus to complete 

detailed analyses to determine if any PWD or PWTDs are facing a potential glass 

ceiling, blocked pipeline, or glass wall; and, based on their findings, to develop plans 

to eliminate identified barriers.

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 missioncritical occupations (MCO)? If “yes”, please describe the triggers below.

a. Qualified Applicants for MCO (PWD) Yes X No 0

b. Qualified Applicants for MCO (PWTD) Yes X No 0

Data from Monster Table B6 (Mission-Critical Occupations), was analyzed to identify 

triggers among qualified internal applicants, indicating the following results: 

FY 2018 Hires Internal Applicants Internal Applicants 

 to MCO vs. Qualified vs. Qualified

0110 (11) PWD: 5.26% - 3.70%*** PWTD: 2.63% - 3.70%

0340 (229) PWD: 6.26% - 5.67%** PWTD: 2.47% - 2.18%**

0343 (320) PWD: 5.99% - 5.55%** PWTD: 2.24% - 2.07%**

0501 (326) PWD: 5.14% - 4.89%** PWTD: 2.03% - 1.79%**

0570 (1) *** PWD: 1.98% - 2.27% PWTD: 0.79% - 0.91%

0905 (9) *** PWD: 4.35% - 5.00% PWTD: 0.00% - 0.00%

1169 (30) PWD: 2.44% - 1.27% *** PWTD: 0.49% - 0.64%

1811 (48) PWD: 1.93% - 0.58%* PWTD: 1.35% - 0.58%*

2210 (543) PWD: 7.50% - 7.35%** PWTD: 3.16% - 3.28%**

The following triggers were identified: 

*The 1811, Criminal Investigators occupation, 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.
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**We noted differences when comparing the applicant flow data with the qualified 

applicants for PWD and PWTD in the 0340, 0343, 501 and 2210. 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 Js. Plans to improve hiring for PWD within the 

major occupations listed are detailed in the specific bureau PART Js. Treasury will 

monitor all bureau PART Js to ensure appropriate plans are developed to eliminate 

any identified barriers. 

*** 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 determined a threshold of 20 new hires. Any participation less 

than 20 will not support a realistic outcome. For those occupations with limited hiring

in 0110, 0570, 0905, and 1169, there were not enough hires to determine if there is 

an actual trigger. 

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 0 No X

b. Promotions for MCO (PWTD) Yes 0 No X

Data from the Treasury WA Table B6 (Participation Rates for Mission Critical Occupations) 

and Monster Table B6 (Participation Rates for Mission-Critical Occupations) were analyzed to 

identify new hires, indicating the following results: 

FY 2018 Hires Qualified Qualified

 to MCOs vs. Internal Promotions vs. Internal Promotions

0110 (11) PWD: 3.70% - 0.00% * PWTD: 3.70% - 0.00%*

0340 (229) PWD: 5.67% - 8.30% PWTD: 2.18% - 2.18%

0343 (320) PWD: 5.55% - 9.38% PWTD: 2.07% - 2.19%

0501 (326) PWD: 4.89% - 9.82% PWTD: 1.79% - 2.15%

0570 (1) PWD: 2.27% - 0.00% * PWTD: 0.91% - 0.00%

0905 (9) PWD: 5.00% - 0.00% * PWTD: 0.00% - 0.00%

1169 (30) PWD: 1.27% - 1.25% PWTD: 0.64% - 0.31%

1811 (48) PWD: 0.58% - 4.17% PWTD: 0.58% - 0.00%

2210 (543) PWD: 7.35% - 14.55% PWTD: 3.26% - 3.50%

The following triggers were identified:
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While there are no noted triggers at the Treasury level, those Treasury bureaus that 

noted triggers in their workforce evaluation are noted in their PART Js. Plans to 

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

specific bureau PART Js. Treasury will monitor all bureaus’ PART Js to ensure 

appropriate plans are developed to eliminate any identified barriers. 

* 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 determined a threshold of 20 hires or less is not enough hires to 

expect that all groups would be hired at rates comparable to their qualification rates. 

For those occupations (0110, 0570 and 0905) with limited hiring, there were not 

enough hires resulting in internal promotions to determine if there is an actual trigger.

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 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 employee network 

groups (ENGs), such as the Adelante’ and the Veterans Employee Resource Group and 

a variety of other communication venues throughout the agency. Developmental 
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opportunities are broadly communicated to all employees through internal weekly and 

monthly newsletters and internet website postings, and are 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. All development opportunity 

announcements are posted on Treasury’s internal website.

In conjunction with available training, Treasury will explore, for FY 2020, the 

development of a committee composed of bureau representatives to consider additional 

opportunities (e.g., mentoring) for the disabled community.

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. 

The Bureau of Engraving offers a series of programs for GS 7-15. Programs include:

 

• The New Leaders Program (GS 7-11 employees or equivalent). This program 

focuses on developing future public service leaders and includes leadership selfassessments, experiential learning, and individual development opportunities 

integrated into a competency-based learning approach. 

• The Executive Leadership Program (GS 12-13 employees or equivalent). This 

program enhances support to organizational mission and goals, focusing 

specifically on the competency of “leading people” through developmental activities 

and experiences.

• The Executive Potential Program (GS 14-15 employees or equivalent), a

competency-based leadership program that prepares high-potential employees to 

focus on leading change effectively at the senior level. 

• The Career Development Program (GS-11 and below or equivalent), provides to 

employees whose positions offer limited promotion potential, upward mobility via 

defined career training using individual career development plans for training and 

other opportunities for placement into positions in other occupational series for 

which they would not otherwise be qualified. 

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

employees individual coaching services for a six-month period. TEI’s coaching services 
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assist DO employees to achieve professional goals, solve individual leadership 

challenges, and develop leadership attributes.

Fiscal Service (FS) offers career development training courses to its employees in career 

ladder positions to enhance their eligibility for potential promotion to higher grades. Inperson and online classes enable FS employees to develop skills to help them advance 

and qualify for other positions.

IRS offers career development opportunities service-wide to all employees for noncompetitive details/promotions and internal merit promotions. In addition, leadership 

development opportunities are available for all employees. IRS Chief Counsel offers 

training and development opportunities for attorneys Counsel-wide. Reasonable 

accommodations are made for all training.

The Mint offers Manufacturer Certification and Apprenticeship programs and Operator 

Certification and Apprenticeship programs which are available to PWD and PWTD.

The OCC offers at least three professional development programs for its bank examiners. 

Non-examiners are also exposed to career forums that provide a variety of career options 

in the non-examiner lines of business. Additionally, OCC offers the 0905 occupational 

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

and experience across multiple legal practice 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 to all employees on the agency’s Opportunities Board.

TIGTA’s programs include:

• The Office of Audit’s Leadership Development Program for Auditors in Grades GS13, GS-14, and GS-15allows 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.

TTB’s primary career development program (CDP) is the Emerging Leaders Program 

(ELP) – a competitive three year centralized training program available to employees 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 
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programs, identifies the three year 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

- Program for 2nd level supervisors and senior leaders

All TTB employees, including disabled veterans, are eligible for consideration for the ELP 

and may 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.

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 Js. Treasury will take necessary 

steps to create a plan of action to track the above requested data. 
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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

N/A

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 X No 0

The IRS SES Candidate Development Program indicated the following triggers for 

any career development programs:

Relevant Applicant Pool Applicants Selections

GS 14 - 15s (PWTD): 2.60% 5.79% 2.50%

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 Department analyzed data from the Treasury WA Table B9 against the inclusion 

rate indicating the following triggers: 

The inclusion rate for PWD (12.08%) and PWTD (13.26%) fell slightly below the 

inclusion rate for employees with no disability (14.67%) for time off awards between 1 

- 9 hours.

The inclusion rate for PWD (5.87%) and PWTD (5.95%) fell slightly below the 

inclusion rate for employees with no disability (6.31%) for time off awards between 

31- 40 hours.
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The inclusion rate for PWD (19.48%) and PWTD (18.72%) in cash awards $1,000 -

$1,999, was below the inclusion rate for employees with no disability (27.90%). 

The inclusion rate for PWD (2.31%) and PWTD (2.00%) in cash awards $2,000 -

$2,999, was below the inclusion rate for employees with no disability (3.95%). 

2. Using the inclusion rate as the benchmark, does your agency have a trigger 

involving PWD and/or PWTD for quality step increases or performance-based 

pay increases? If “yes”, please describe the trigger(s) in the text box.

a. Pay Increases (PWD) Yes X No 0

b. Pay Increases (PWTD) Yes X No 0

The inclusion rate for PWD (2.43%) and PWTD (2.41%) was below the inclusion rate 

for employees with no disability (3.64%) for QSI awards.

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

N/A
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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 X No 0

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

Data from the Treasury WA Table B7 Applicants and Hires by Disability and the 

Monster (M) B7 – Applicants and Hires by Senior Grade Levels were analyzed to 

identify qualified internal applicants and/or selectees for promotion to senior grade 

levels with disabilities, indicating the following results: 

 Qualified Internal Promotions (WA) 

 Applicants vs Selectees (M) 

GS-13 PWD: 4.06% 3.58% 11.53% 

GS-14 PWD: 6.77% 5.96% 10.27% 

GS-15 PWD: 6.34% 5.17% 10.96% 

SES PWD: 23.08% 5.56% 16.67%*

 

*Triggers were identified for PWD selections at the SES level when looking at both 

internal selections and promotions. The trigger was noted between the rate at which 

applicants were qualified (23.08%) and their rate of selection (5.56%) when analyzing 

the tables (M). However, we also note that when analyzing the additional table for 

promotion/conversion (WA), rates for PWD at the SES level exceeded their selection 
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rate as well. While there were internal vacancy announcements that reflect the 

applicant flow data, the significant difference in the percentage of the Qualified 

Applicant Pool, the Selection and the Promotions are the result of existing employees 

who applied not only to internal vacancy announcements, but to all status vacancy 

announcements open to all Federal employees in FY 2018. This will also result in 

differences between internal/external selections and promotions rates. 

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 X No 0

ii. Internal Selections (PWTD) Yes 0 No X

 

Data from the Treasury WA Table B7 Applicants and Hires by Disability and the Monster

(M) B7 – Applicants and Hires by Senior Grade Levels were analyzed to identify qualified 

internal applicants and/or selectees for promotion to senior grade levels with targeted 

disabilities, indicating the following results: 

 Qualified Internal Promotions (WA)

 Applicants vs Selectees (M) 

GS-13 PWTD: 3.53% 0.97% * 2.28%

GS-14 PWTD: 2.82% 2.66% 2.60%

GS-15 PWTD: 3.35% 2.89% * 1.83%

SES PWTD: 7.69% * 5.56% * 0.00%
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The following triggers were identified: 

*Triggers were identified for PWTD selections at the GS-13, GS-15 and SES level. The 

triggers were noted between the rate at which applicants were qualified and their rate of 

selection (M). However, we also note that when analyzing the additional table for 

promotion/conversion (WA), rates for PWTD at the GS-15 and SES level are lower than 

their selection rate. 

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

significant difference in the percentages of the Qualified Applicant Pool, the Selections

and the 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 2018. 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 nonGS pay plans, please use the approximate senior grade levels. If “yes”, describe 

the trigger(s) in the text box.

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

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

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

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

N/A

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

trigger involving PWTD among the new hires to the senior grade levels? For nonGS pay plans, please use the approximate senior grade levels. If “yes”, describe 

the trigger(s) in the text box.

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

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

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

d. New Hires to GS-13 (PWTD) Yes 0 No X
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N/A

5. Does your agency have a trigger involving PWD among the qualified internal 

applicants and/or selectees for promotions to supervisory positions? (The 

appropriate benchmarks are the relevant applicant pool for qualified internal 

applicants and the qualified applicant pool for selectees.) If “yes”, describe the 

trigger(s) in the text box.

a. Executives

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

ii. Internal Selections (PWD) Yes 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

Data from the Treasury WA Table B8 New Hires by Disability and the Monster B8 –

(Management Positions by New Hires and Occupational Series) Applicants and Hires 

were analyzed to identify qualified internal applicants and/or selectees for promotion 

to supervisory positions, with disabilities, indicating the following results: 

Supervisory positions Qualified Applicants Promotions

Executives PWD: 5.56% 11.31%

Managers PWD: 0.00% 9.77%

Supervisors PWD: 0.00% 9.98%

There were no internal-only Manager and Supervisor vacancy announcements in FY 

2018. The selection for promotions noted above are the result of existing employees 

applying to all status vacancy announcements open to all Federal employees in FY 

2018.
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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 X No 0

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

Data from the Treasury WA Table B8 New Hires by Disability and the Monster B8 –

(Management Positions by New Hires and Occupational Series) Applicants and Hires 

were analyzed to identify qualified internal applicants and/or selectees for promotion 

to supervisory positions, with targeted disabilities, indicating the following results: 

Supervisory Positions Qualified Applicants Promotions

Executives PWTD: 5.56% 1.81%*

Managers PWTD: 0.00% 2.14%

Supervisors PWTD: 0.00% 2.67%

There were no internal-only Manager and Supervisor vacancy announcements in FY 

2018. The selection for promotions noted above are the result of existing employees 

applying to all status vacancy announcements open to all Federal employees in FY 

2018.

However, the following trigger was identified: 

*The promotion/conversion rate for PWTD at the Executive level is lower than their 

qualified rate.

NOTE: 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 
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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 detailed analyses to determine if any PWD or PWTDs are 

facing a potential glass ceiling, blocked pipeline or glass wall; and based on their 

findings, develop plans to eliminate identified barriers.

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

trigger involving PWD among the selectees for new hires to supervisory 

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

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

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

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

N/A

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

trigger involving PWTD among the selectees for new hires to supervisory 

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

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

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

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

Data from the Treasury WA Table B8 New Hires by Disability and the Monster B8 –

(Management Positions by New Hires and Occupational Series) Applicants and Hires 

were analyzed to identify qualified external applicants and/or selectees for new hires

to supervisory positions, with targeted disabilities, indicating the following results: 

Supervisory Positions Qualified External New Hires

 Applicants 

Executives PWTD: 2.78% 3.70%

Managers PWTD: 2.28% 4.00%

Supervisors PWTD: 30.00% 0.00%*

The following triggers were identified:
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*While 30% of the external applicants with a targeted disability in our supervisory 

positions were qualified, an external applicant was not hired. 

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 2018, Treasury had 65 Schedule A employees who were eligible for conversion 

to competitive service appointments. Of that: 

• 57 were timely converted to career status;

• 5 are untimely (2 pending conversion and 3 pending personnel action);

• 1 was not converted based on unsatisfactory performance; and

• 2 were voluntarily separated. 

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 0 No X

The inclusion rate for PWD (11.41%) exceeded the inclusion rate of persons with no 

disability (9.08%) for voluntary separations. 
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When evaluating the types of voluntary separations, we noted that 59% were due to 

retirement, 5% were transfers and 30% were resignations. The remaining 5% were 

due to death. Based on comments in the FY 2018 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 transfers,

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

these triggers are a potential barrier.

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

voluntary and involuntary separations exceed that of persons without targeted 

disabilities? If “yes”, describe the trigger below.

a. Voluntary Separations (PWTD) Yes X No 0

b. Involuntary Separations (PWTD) Yes 0 No X

The inclusion rate for PWTD (11.17%) exceeded the rate of persons with no disability 

(9.08%) for voluntary separations. 

When evaluating the types of voluntary separations, we noted that 59% were due to 

retirement, 5% were transfers and 30% were resignations. The remaining 5% were 

due to death. Based on comments in the FY 18 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 transfers 

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

these triggers are a potential barrier.

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 the types of voluntary separations, we noted that 59% were due to 

retirement, 5% were transfers and 30% were resignations. The remaining 5% were 

due to death. Treasury does not consider the separations “due to retirement” a 

trigger. However, bureaus will be asked to evaluate those voluntary separations due 

to transfers and resignations, along with information gleaned from the exit survey, to 

determine if these triggers are potential barrier.
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During the period of October 1, 2017 through September 30, 2018, 254

permanent/seasonal PWD responded to the Department’s Exit Survey. The overall 

responses from PWD were similar to the overall permanent/seasonal employee 

responses, in that 41% (105) had more than 25 years of service and 78% (198) were 

age 50 or older. Of the respondents with disabilities, 32% (82) were disabled 

veterans. The most frequently cited reason for separation of PWD was retirement 

(149 or 59%).

The factor most frequently cited as impacting a PWD’s decision to leave was job 

stress (69%). Additional factors frequently cited include office morale (60%); office 

organization and alignment with regard to effective and efficient service (51%);

resources to do the job (50%); access to developmental opportunities (53%); ability to 

participate in decisions (48%); pay in relation to job responsibilities and performance 

(47%) reasonableness of workload (50%); and, job description in relation to actual

duties and responsibilities (45%). 

Separately, 74% of the respondents indicated their work experience was generally 

positive; 61% stated they would be interested in returning to work for Treasury; and,

67% stated they would recommend Treasury as a good place to work. 

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
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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 2018, OCRD conducted two accessibility reviews of buildings occupied by DO 

employees – 717 14th Street and 1801 L Street. 

At 717 14th Street, a Treasury-leased space, the accessibility review indicated a 

number of important requirements are not being met. OCRD identified forty-eight (48) 

deficiencies requiring a corrective action. The review was signed by the OCRD 

Director and submitted to the Deputy Assistant Secretary for Operations on July 10, 

2018.

For 1750 Pennsylvania Avenue, also a Treasury-leased space, the review indicated 

that the space was mostly accessible. OCRD identified twenty-nine (29) deficiencies 

that required a corrective action. The review was signed by the OCRD Director and 

submitted to the Deputy Assistant Secretary for Operations on October 5, 2018. 

OCRD is monitoring the completion of work to correct identified deficiencies.
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In FY 2019, OCRD will conduct two accessibility reviews on DO leased properties 

located at 1722 I Street and the Colorado Building. In addition, OCRD will conduct an 

accessibility review of the external program conducted by Fiscal Service.

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 2018 are:

BEP 04

DO 20

FinCEN 14

FS 06

Mint 08

IRS 76

OCC 07

TIGTA 10

TTB 13

The overall average for processing the Departments initial requests for reasonable 

accommodations is 18 days. The Department recognizes the high average for IRS 

which is currently reviewing its methodology for calculating “average days for 

providing reasonable accommodations.” Treasury developed an implementation plan 

to acquire a Treasury-wide reasonable accommodation tracking system that will

eliminate the need to manually calculate processing timeframes.
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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 2018,

bureaus provided reasonable accommodations guidance via training courses, 

newsletters, and postings on its intranet websites (see specific bureau submission for 

details). The Department manages a Treasury-wide contract that provides an 

effective and efficient procedure for providing sign language interpreter services. 

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. Training will be provided to all 

managers, supervisors, and selected HR Professionals throughout FY 2019. PAS 

training will be added to orientation for all newly-hired managers and newly-promoted 

managers. 
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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

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.

Treasury had one final agency decision involving harassment based on disability and 

reprisal. This case resulted in an order of training and consideration of disciplinary 

action. Complainant appealed the AJ’s order and a settlement agreement was 

reached resolving all matters. 

B. EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO 

complaint alleging failure to provide a reasonable accommodation, as compared 

to the government-wide average? 

Yes 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
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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

2. Has the agency established a plan to correct the barrier(s) involving PWD 

and/or PWTD? 

Yes 0 No 0 N/A X

Five Findings - (3) Final Agency Decisions (FAD) and (2) Administrative Judge (AJ) 

final order. 

FADs:

(1) Disability discrimination for failure to provide reasonable accommodation – training was 

ordered and provided; disciplinary actions were ordered to be considered and are 

pending. 

(2) Disability discrimination for failure to provide reasonable accommodation -

provision of the software was provided; training was ordered and provided; and 

disciplinary actions were ordered to be considered and provided in the form of an oral 

counseling. 

(3) Disability discrimination for unreasonable delay in providing ergonomic chair -

training was ordered and provided.

AJ Final Orders:

(4) Disability discrimination for harassment and termination during probationary 

period in mixed motive case - training and consideration of discipline were ordered to 

be considered; complainant appealed; and agency and Complainant entered into 

settlement agreement resolving all matters. 

(5) Hostile work environment in reprisal for prior EEO activity - no training or consideration 

of disciplinary action was ordered due to separated responsible management official.
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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, AntiHarassment 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/yyyy)

Completion 

Date

(mm/dd/yyyy)
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Fiscal 

Year

Accomplishments

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

any of the planned activities.

NOTE: It is important to note that when the Department looks at aggregated 

Treasury-wide data, the progress noted may not accurately reflect the progress of 

each bureau. The aggregated 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 directed the bureaus to complete detailed 

analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, 

blocked pipeline, or glass wall; and, based on their findings, to 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).

NOTE: It is important to note that when the Department looks at aggregated

Treasury-wide data, the progress noted may not accurately reflect the progress of 

each bureau. The aggregated 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 directed the bureaus to complete detailed 

analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, 

blocked pipeline, or glass wall; and, based on their findings, to develop plans to 

eliminate identified barriers.

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.

NOTE: It is important to note that when the Department looks at aggregated 

Treasury-wide data, the progress noted may not accurately reflect the progress of 

each bureau. The aggregated 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 directed the bureaus to complete detailed 
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analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, 

blocked pipeline, or glass wall; and, based on their findings, to develop plans to 

eliminate identified barriers.