0

Department of the 

Treasury Management 

Directive 715

FY 2017
Office of Civil Rights and Diversity FY 2017 MD-715 Report
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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U.S. DEPARTMENT OF THE TREASURY

MANAGEMENT DIRECTIVE 715 FY 2017

TABLE OF CONTENTS

Section I – PARTS A-J

PART A: Treasury Identifying Information

PART B: Total Employment

PART C: Agency Officials Responsible for Oversight of EEO Program

PART D: List of Subordinate Components Covered in This Report

PART E: Executive Summary

PART F: MD-715 Program Certification 

PART G: Self-Assessment Checklist

PART H: Attaining the Essential Elements of a Model EEO Program

PART I: Barrier Identification

PART J: Program Status Report - Individuals with Targeted Disabilities

Appendix A: Secretary’s EEO Policy and Diversity Policy
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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SECTION ONE

PARTS A - J
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PART A - Department or Agency Identifying Information

Agency

Second 

Level 

Component

Address City State

Zip 

Code 

(xxxxxxxxx)

CPDF 

Code 

(xxxx)

FIPS 

Code

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

94,751 1,350 96, 101

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 Kody Kinsley Assistant Secretary for Management 

PART C.2 - Agency Official(s) Responsible For Oversight of EEO Program(s)

EEO 

Program 

Staff

Name Title Occupational 

Series 

Pay 

Plan 

and 

Grade 

Phone 

Number Email Address

Principal EEO 

Director/

Official

Mariam 

Harvey

Director 

(OCRD)

0260 ES 202-622-

0316

Mariam.Harvey@treasury.g

ov

Deputy 

Director EEO

Gail 

Demers

Deputy 

Director 

(OCRD)

0260 GS-15 202-622-

0341 Gail.Demers@Treasury.gov
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Affirmative 

Employment 

Program 

Manager

Mariam 

Harvey

Director 

(OCRD)

0260 ES 202-622-

0316

Mariam.Harvey@treasury

.gov

Complaint 

Processing 

Program 

Manager

Amelia 

Demopulos

EEO 

Program 

Manager

0260 GS-15 202-622-

4178

Amelia.Demopulos@Trea

sury.gov

Diversity & 

Inclusion 

Program 

Manager

Thomas 

Lotito

EEO 

Specialist 0340 GS-14

202-622-

8902

Thomas.Lotito@Treasury.

gov

Manager of 

Special 

Emphasis 

Programs 

Griselda 

Wallace

EEO 

Program 

Manager

0260 GS-15 202-622-

4134

Griselda.Wallace@Treasu

ry.gov

Disability 

Program 

Manager

Lisa Jones EEO 

Specialist 0260 GS-14 202-622-0315

Lisa.Jones@treasury. 

gov

ADR Program 

Manager

Clarissa 

Lara

EEO 

Specialist 0260 GS-14 512-499-5115

Clarissa.Lara@treasury. 

gov

Reasonable 

Accommodation 

Program 

Manager

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

Compliance 

Manager

Ellen 

HawthorneCopenhaver

EEO 

Specialist 0260 GS-14 202-622-0341

Ellen.HawthorneCopenhaver@treasury. 

gov

MD-715

Program 

Manager

Alicia 

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

Subordinate Component City State Country 

(Optional)

CPDF Code 

(xxxx)

FIPS 

Code

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 - Forms/Documents Included with This Report

Is the following Form or Document Uploaded? (Please respond "Yes" or 

"No") Comments

PART F - Statement of Establishment of Continuing 

EEO Programs Yes

Organizational Chart Yes

EEO Policy Statement Yes

Strategic Plan Yes

Anti-Harassment Policy and Procedures Yes

Reasonable Accommodation 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 Yes

Diversity and Inclusion Plan under Executive Order 13583 Yes

Diversity Policy Statement Yes

Human Capital Strategic Plan Yes

EEO Strategic Plan Yes

Results from most recent Federal Employee Viewpoint Survey 

or Annual Employee Survey Yes
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PART E: EXECUTIVE SUMMARY
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EXECUTIVE SUMMARY

TABLE OF CONTENTS

Introduction Page 9

Essential Element A: Demonstrated Commitment from 

Treasury Leadership Page 12

Essential Element B: Integration of EEO into the Strategic 

Mission Page 13

Essential Element C: Management and Program 

Accountability Page 18

Essential Element D: Proactive Prevention of Unlawful 

Discrimination Page 22

Essential Element E: Efficiency Page 25

Essential Element F: Responsiveness and Legal Compliance Page 27

Workforce Demographics Page 28

Disability Program Page 33

Veteran Employment Program Page 35

External Civil Rights Program Page 37

Accomplishments Page 38

Planned Activities/Conclusion Page 41
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Introduction/Mission

This report covers the period of October 1, 

2016, through September 30, 2017, and 

highlights Treasury’s accomplishments 

during Fiscal Year (FY) 2017 in attaining and 

maintaining a model EEO Program. 

The Department of the Treasury’s Mission

Throughout its rich history, Treasury’s core 

mission has not changed. With more than 

95,000 employees, Treasury continues to be 

the leader in safeguarding and growing the 

U. S. economy – taking in revenue, paying 

bills, and, when appropriate, borrowing and 

investing public funds. 

We continue to invest in our people by 

providing them purpose, motivation, support 

and a fair and inclusive work environment in 

which every individual can excel. We also 

take full advantage of information technology 

to maximize the use of sharing data to 

enhance sound decision-making. 

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 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

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). 

These bureaus are Financial Crimes 

Enforcement Network (FinCEN), the Office 

of the Inspector General (OIG), Special 

Inspector General for Troubled Asset Relief 

Program (SIGTARP), Treasury Inspector 

General for Tax Administration (TIGTA) and 

Alcohol and Tobacco Tax and Trade Bureau 

(TTB). Each Treasury bureau, regardless of 

size, has its own distinct reporting structure 

for its EEO and Human Resource (HR) 

offices and programs. Each bureau sets its 

own policy and procedures regarding the 

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.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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The Department of the Treasury FY 2017 Organizational Chart
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The Assistant Secretary for Management FY 2017 Organizational Chart

ASM

Office of the Senior 

Procurement Executive

Office of Minority and 

Women Inclusion

ACIO 

Cybersecurity

ACIO 

IT Strategy and 

Technology 

Management

9

ACIO 

Enterprise 

Business 

Solutions

ACIO 

Infrastructure 

Operations

86.5

Deputy Chief 

Financial 

Officer

Treasury 

Operations

DAS Privacy, 

Transparency, 

and Records

Performance 

Budgeting

Strategic 

Planning and 

Performance 

Improvement

Financial 

Management

DAS Human 

Resources

Talent Dev & 

Tech

Executive & 

HC Services & 

HCSM

Treasury 

Executive 

Institute

DC Pensions

Financial 

Reporting 

and Policy

6

General & 

Special 

Entity 

Accounting

16

Records and 

Info. Mgmt.

FOIA and 

Transparency

8

PTR 

Operations

Risk and 

Control 

Group

7

Financial 

Systems

Shared 

Services

Privacy and 

Civil Liberties Emergency 

Prep

Mission 

Support 

Services

DAS Chief 

Information 

Officer

DAS 

Management 

and Budget

As of March 31, 2016 Credit 

Modeling 

Office of Civil 

Rights and 

Diversity

5 26

Curator

Facilities/

Real Estate
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The Office of Civil Rights and Diversity

OCRD administers the Department-wide 

equal employment opportunity 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 nondiscrimination in programs operated or 

funded by the Department of the Treasury. 

The 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.

Six Essential Elements of a Model EEO 

Program

The following sections of this report 

contain an evaluation of Treasury’s EEO 

programs against the six essential elements 

of a Model EEO program, as established by 

MD-715. 

Essential Element A: Demonstrated 

Commitment from Treasury Leadership 

Steven Terner Mnuchin was confirmed by 

the United States Senate on February 13, 

2017, to serve as the 77th Secretary of the 

Treasury. Secretary Mnuchin affirmed his 

commitment to EEO by issuing his 

inaugural EEO policy statement on May 31, 

2017. The Secretary also issued his 

Diversity and Inclusion Statement to all 

Treasury employees on November 17, 2017 

and invited employees to personalize their 

own commitment to Diversity and inclusion 

with a Diversity and Inclusion Certificate.

The EEO policy, along with the Secretary’s 

Diversity Statement, express the 

Department’s support of diversity, equal 

employment opportunity and a workplace 

free of discriminatory harassment. 

The EEO policy and Diversity statement

were communicated to all Treasury 

employees via email and on the Treasury 

rotary on it internal website and are posted 

on both the intranet and internet. Each of 

Treasury's bureau heads has committed to 

the principles of EEO and diversity by 

either issuing or reissuing their policy 

statements in support of EEO and diversity. 

Each bureau also ensures that its own EEO 

policy and Treasury’s EEO policy are 

disseminated to all new employees during 

orientation and are available on the intranet 

and public internet site if applicable.

Each bureau ensures all newly promoted 

managers and supervisors receive copies of 

both the bureau and Treasury EEO policies 

as a reminder of their role and

responsibility in providing a discrimination

and harassment-free work environment.

Treasury’s policies, orders and directives 

on EEO matters can be found on Treasury’s 

public internet site located at: 

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

nal-
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structure/offices/Mgt/Documents/FY%2020

17.EEO%20Policy%20FY2017%20Draft%

203.30.17.pdf

Treasury and its bureaus also make written 

materials available to all employees and 

applicants, informing them of the variety of 

EEO programs and administrative and 

judicial remedial procedures available to 

them through our internet and intranet sites. 

OCRD’s internet site is located at:

http://www.treasury.gov/about/organization

al-structure/offices/Pages/Office-of-CivilRights-and-Diversity.aspx.

Each Treasury bureau maintains its own 

performance appraisal form for managers 

and supervisors. The Department has a 

standard evaluation form for the Senior 

Executive Service that all bureaus are 

required to utilize and the SES performance 

plan incorporates the required critical 

element that evaluates SES commitment to 

Treasury’s EEO and diversity policies and 

principles. 

In addition, the Department’s EEO Officers

standard performance includes an 

evaluation of the EEO Officer’s efforts to 

build and create a diverse workforce, 

increase the participation rate of persons 

with disabilities and create an inclusive 

work environment. 

Treasury’s Reasonable Accommodation 

policy and procedures are current and easily 

accessible to all employees and applicants 

via our internal and external websites.

OCRD has posted a copy of its current

policy and procedures to its websites at: 

http://www.treasury.gov/about/organization

alstructure/offices/Mgt/Pages/eeo_policy.as

px

Essential Element B: Integration of EEO 

into the Strategic Mission 

The Secretary has delegated authority over 

all EEO matters to the Assistant Secretary 

for Management (ASM) through Treasury 

Order 102-02 located at: 

http://www.treasury.gov/about/role-oftreasury/orders-directives/Pages/to102-

02.aspx.

The ASM, who reports directly to the 

Secretary and Deputy Secretary, is kept 

abreast of EEO matters through meetings 

with the Director of OCRD. The Director 

of the OCRD, who reports directly to the 

ASM, provides the day-to-day management 

of the Equal Employment Opportunity, 

Civil Rights and Diversity programs in 

Treasury, and has direct access to the ASM 

to provide him with critical information 

regarding these programs. In addition, the 

Director of OCRD has regular bi-weekly 

meetings with the ASM on the status of

EEO programs. 

Department of the Treasury Strategic 

Plan

Through Treasury’s Strategic Plan for 

Fiscal Years 2014 - 2017, the Department 

continued to prioritize the importance of 

building and maintaining a high-performing 

and diverse workforce. Achieving these 

objectives demands a concerted 

commitment on the part of everyone in 

Treasury to continuous improvement in 

skills, learning, processes, attitudes and 

organizational culture. Goal five of the 

Department’s Strategic Plan outlines four 

objectives to help the department meet its

plan. 

 Objective 5.1: Increase workforce 

engagement, performance, and 

diversity by instilling excellence, 

innovation and inclusion in 

Treasury’s organizational culture 

and business practices.

 Objective 5.2: Support effective, 

data driven decision-making and 
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encourage transparency through 

intelligent gathering, analysis, 

sharing, use and dissemination of 

information.

 Objective 5.3: Promote efficient 

use of resources through shared 

services, strategic sourcing, 

streamlined business processes and 

accountability.

 Objective 5.4: Create a culture of 

service through relentless pursuit of 

customer value.

The Department is now in the process of 

finalizing its FY 2018 – 2022 Treasury 

Strategic Plan. 

Department of the Treasury Human 

Capital Strategic Plan

To support the Department in meeting its 

strategic goals as set forth in the Treasury 

Strategic Plan for Fiscal Years 2014-2017, 

the Treasury Human Capital Advisory 

Council (HCAC) developed the FY 2014-

2017 Treasury Human Capital Strategic 

Plan (HCSP). The HCSP addresses future 

workforce demands and challenges and 

establishes specific human capital 

management strategies, objectives, 

indicators, and initiatives to meet them. 

While the Treasury Strategic Plan outlines 

the agency-wide goals and measures for 

fulfilling the Department’s operational 

mission, the HCSP specifically focuses on 

five human capital strategic goals.

 Improve Effectiveness, Efficiency, 

and Customer Interaction in the 

delivery of human capital services. 

 Increase Workforce Engagement: 

Enable employees to work more 

effectively toward organizational 

goals. 

 Increase Workforce Performance: 

Develop leaders and managers who 

improve organizational performance 

by positively motivating and 

engaging people to meet and exceed 

goals. 

 Increase Workforce Diversity: 

Build and sustain an inclusive 

environment in which all people are 

treated fairly and have opportunities 

to excel. 

 Pursue Continuous Improvement:

Create a 21st Century approach to 

human capital management in 

government. 

Department of the Treasury Strategic 

Diversity and Inclusion Plan 

Commitment and accountability are the 

hallmarks of a successful effort to build and 

maintain an inclusive and diverse, highquality workforce. A commitment to equal 

opportunity, diversity, and inclusion is critical 

to accomplishing the mission of the 

Department.

Therefore, the Department’s FY 2017-2020 

Inclusive Diversity Strategic Plan focuses on 

leadership engagement, inclusion and 

collaboration, and optimizing inclusive 

diversity efforts through data-driven 

approaches. Our priority over the next few 

years focuses on informing leaders about the 

business case of inclusive diversity to enable 

them to create and maintain a work 

environment that attracts the widest pool of 

talent and provides opportunities for all 

employees to contribute their different 

perspectives, ideas, and solutions that 

ultimately impact the success of the 

Department.

As a result, we have identified as a top 

priority assisting leaders in understanding 

the benefits of diversity and inclusion and 

building a workforce based on these 

principles. We developed indicators that 

will assist in measuring the success of 

policies, procedures, and practices that 

provide opportunities for all employees and 

ensure everyone is treated with dignity and

respect.
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The Inclusive Diversity Strategic Plan 

focuses on three key goals: 1) Diversify the 

Workforce through Active Engagement of 

Leadership, 2) Include and Engage 

Everyone in the Workplace; and 3) 

Optimize Inclusive Diversity Efforts Using 

Data-Driven Approaches.

As part of the Office of Personnel 

Management’s (OPM) oversight over 

agency Diversity and Inclusion programs, a 

Diversity and Inclusion – IQ Index was 

developed. The IQ Index provides agencies 

with a metric for evaluating the 

effectiveness of their Diversity and 

Inclusion Plans. The Diversity and 

Inclusion IQ Index focuses on five 

categories using questions from the Federal 

Employee Viewpoint Survey (FEVS) 

responses: Fairness, Open-minded, 

Cooperative, Supportive and Empowerment 

(FOCSE).

Diversity and Inclusion IQ Index

In FY 2017, Treasury received an overall 

Diversity and Inclusion score of 62 percent;

above the government-wide average of 60

percent. This represents a 2 percent 

increase from FY 2016 where Treasury 

received a 60 percent overall score. 

Treasury had an increase in the overall 

response rates for employees in each

category of the IQ Index; Supportive (from 

80% to 81%), Open (from 58% to 60%), 

Cooperative (from 57% to 60%), 

Empowerment (from 56% to 57%) and 

Fairness (from 49% to 50%). While these 

results were not considered areas of 

significant weakness, they do represent an 

opportunity for continued improvement for 

the Department and its bureaus. 

While Treasury has noted progress in 

improving response rates in all the areas of 

the IQ Index, our lowest score fell within 

the category of Fairness (from 49% to 

50%). The Department considers employee 

responses in the area of Fairness to be the 

most concerning. Therefore, in FY 2018, 

Treasury and its bureaus will continue to 

focus efforts towards developing plans to 

improve employee responses in the Fairness

category.

In conjunction with the Department’s 

Diversity and Inclusion Strategic Plan, each 

of the Department’s bureaus maintained its 

own implementation plan. Throughout FY 

2017, OCRD’s Diversity and Inclusion 

Program Manager met with bureau EEO, 

Diversity and Human Resource Officers to 

discuss the bureau’s implementation plan 

and recommend strategies for continued 

improvement. Together we will continue to 

focus efforts on continuing to improve 

Treasury’s overall results for FY 2018.

Project Career

In FY 2017, Treasury implemented a new 

program called Project Career - Designing 

Your Future; a new initiative that focuses 

on showcasing a variety of tools and 

resources on My Treasury to help 

employees chart their path to personal and 

professional success. 

The initial series focused on coaching and 

how employees could utilize a coach to 

help improve productivity, satisfaction with 

life and work, and attainment of relevant

goals. The series emphasized that coaching 

is a key part of management and employee 

development activities and is championed 

by the Treasury Executive Institute. 

Future series will include articles, tips and 

tool focusing on education and training 

opportunities, as well as work-life balance 

programs and benefits.
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Treasury Executive Institute Coaching –

Putting You First for Excellence

As a service to support Treasury employee 

growth and development, the Treasury 

Executive Institute (TEI) continued to offer

individual coaching services in FY 2017. 

To ensure quality of service, all TEI 

coaches have completed, or are in the 

process of completing, certification through 

the International Coaching Federation 

(ICF). 

TEI’s coaching services provide an

excellent way to assist employees in 

achieving their professional goals to go to 

the next level by: reviewing 360 feedback 

results; solving individual leadership 

challenges; excelling in self-awareness and 

self-management; gaining clarity in 

decision making and purpose; and/or 

developing leadership attributes and 

behaviors of empathy, self-disclosure, 

active listening, and giving and receiving 

feedback.

TEI coaching can be provided in various

formats that include: 

 One-on-One Coaching - This 

offering can be conducted face-toface or virtually. 

 Peer Cohorts - This offering is an 

excellent strategy for building 

leadership skills, collaboration, 

learning, and effective use of 

questions in a group setting.

 Continuing Coach Education 

Series - This session focuses on 

building coaching skills. The 

programs are specific one-day 

workshops offered by marketplace 

leaders and available to all TEI 

cadre coaches. 

 Coaching Skills for Managers 

Workshops - Coaching is a 

powerful tool for any manager 

seeking to develop others in a 

learning organization and to 

maximize employee performance 

and engagement.

 Coach Training - In exchange for 

the coach training, each individual 

agrees to serve on TEI’s internal 

coaching cadre and provide 

approximately 10 hours per month 

of pro-bono coaching to employees 

in TEI participating agencies and 

bureaus for 24 months after 

beginning the coaching program. 

TEI manages the matching of the 

coaches and clients. This program is 

open to GS-14's (and equivalents) 

and above.

In FY 2017, TEI had 116 certified and 

active coaches on hand who provided 1,956

coaching hours to 350 employees of which 

114 were Treasury employees.

Internship Programs 

In past years, internship programs have 

played a significant role in ensuring that a 

diverse pipeline of talent is available to fill 

mission critical occupations being vacated 

by an aging workforce. 

Throughout FY 2017 Treasury and its 

bureaus have continued to establish and 

maintain partnerships with existing external 

internship programs that attract highly 

qualified, educated and diverse students. 

Internship programs such as the Pathways 

Program, Hispanic Association of Colleges 

and Universities’ (HACU) Hispanic 

Serving Institutes National Internship 

Program (HSINIP), the International 

Leadership Foundation (ILF), INROADS, 

Operation Warfighter, the Washington 

Internship Program for Native Students 

(WINS), the Workforce Recruitment 

Program (WRP), and the Washington 

Center continue to provide Treasury and its 

bureaus an avenue to identify and expand 

the pool of potential candidates to fill 
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mission critical vacancies and to grow new 

talent. 

However, with continuing budget 

constraints, transformation requirements 

and limited hiring or hiring freezes, many 

of the Treasury bureaus have been faced 

with limited funding for internship 

opportunities. Nonetheless, the Department 

and its bureaus continued to fund internship 

opportunities whenever possible, but on a 

more limited scale compared to past years.

Hispanic Serving Institutions National 

Internship Program (HSINIP)

As a way to develop a pipeline of Hispanic 

employees, Treasury has maintained its 

partnership with HACU’s Hispanic Serving 

Institutions National Internship Program 

(HSINIP). Viewed as a cornerstone of 

diversity recruitment, the HSINIP aims to 

increase employment opportunities for 

Hispanic students throughout the federal 

government. 

During FY 2017, Treasury placed four (fall, 

spring, and summer) HACU interns in IRS, 

OCC and Mint. 

International Leadership Foundation 

(ILF)

Since FY 2005, Treasury has partnered with 

the International Leadership Foundation 

(ILF) to provide Asian American Students 

exposure to public service. The ILF is a 

non-profit organization which gives 

scholarships to Asian American college 

students and places them in public service 

internships to help prepare them to become 

tomorrow’s leaders.

During FY 2017, Treasury placed eight ILF 

students in FS.

The Washington Center for Internships 

(TWC)

The Washington Center for Internships 

(TWC) is an independent, non-profit

organization serving hundreds of colleges 

and universities in the United States by 

providing students challenging 

opportunities to work and learn in 

Washington, D.C. 

During FY 2017, Treasury placed 15 TWC 

interns in DO and OCC. 

INROADS Program

The INROADS program assists agencies in 

accessing diverse talent through early 

identification and continuous leadership 

development of outstanding students. 

Through its unique leadership development 

process, INROADS assists agencies with 

anticipating business needs and identifying 

quality diverse employees who can 

contribute to meeting agencies’ mission 

needs.

During FY 2017, Treasury placed 26 (fall, 

spring, and summer) INROADS interns in

DO and OCC. 

Operation Warfighter

Operation Warfighter (OWF) is a 

temporary assignment/internship program, 

developed by the Department of Defense, 

for service members who are convalescing 

at military treatment facilities (initially in 

the National Capitol Region but 

increasingly throughout the 

United States). The program provides 

recuperating service members with 

meaningful activity outside of the hospital 

environment and offers a formal means of 

transition back to the military or civilian 

workforce. 
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In FY 2017, Treasury hosted five interns 

through OWF in FS and Mint. Of the five 

interns, FS converted one to permanent 

status.

Other Internship Programs

In FY 2017, Treasury placed 103 interns 

through the Pathways Program. The 103

Pathway Program participants were placed 

in BEP, DO, FinCEN, FS, IRS, IRS-CC, 

Mint, OCC, and TIGTA. Of the Pathway 

Program participants, 20 were converted to 

permanent employees. 

IRS hosted four interns through the 

Washington Internship Institute.

Through Proxtronics Dosimetry, LLC, 

OCC sponsored 2 interns. 

Through the Maryland Department of 

Rehabilitation Services (DORS), FS hosted 

three interns. DORS provides services to 

help persons with disabilities prepare for 

jobs and careers and assists employers in 

finding prescreened applicants.

Throughout FY 2017, IRS-CC sponsored 

29 interns through its Summer Legal 

Program available to second year law 

students. Through developmental 

assignments, the program provides 

exposure to IRS-CC and enables law 

students to work under the supervision of 

experienced tax lawyers.

During FY 2017, IRS hosted 30 Veteran 

interns as part of its non-paid veteran work 

experience program. This program serves 

as a great recruitment tool for hiring 

veterans, of the 30 veteran interns, six

veterans and one student veteran were 

converted to permanent employees. 

In FY 2017, through programs like the DC 

Summer Youth Employment Program and 

the Marion Barry Summer Youth 

Employment Program, IRS, IRS-CC and 

Mint hosted 130 youth between the ages of 

14 to 21 with enriching and constructive 

summer work experiences. 

Through other non-paid internship 

opportunities, Treasury hosted an additional 

47 interns in FS, FinCEN, IRS-CC and 

TIGTA.

Finally, OCC sponsored 11 interns through 

its District Financial Internship Program for 

Entry Level Examiner Program. Of the 11

interns, OCC converted six to permanent 

employees.

Essential Element C: Management and 

Program Accountability 

Treasury exercises program oversight and 

accountability of bureau programs in 

accordance with Treasury’s policy on 

Departmental Oversight of Management 

Functions (HCIS 250.1), which authorizes 

the ASM and the Departmental Functional 

Program Heads to establish Departmentwide strategic goals and objectives, as well 

as individual performance expectations and 

uniform language, to be incorporated into 

the performance plans of Bureau Functional 

Program Heads (CXOs) such as the bureau 

EEO Officers. The CXO policy calls for 

the ASM to participate in the recruitment, 

selection, retention and performance 

alignment of bureau management officials 

to include bureau EEO/Diversity Officers.

As a result of the implementation of this 

policy, significant benefits for both 

Treasury and the bureaus in FY 2017 

resulted in:

 increased collaboration,

 greater transparency of information, 

data, goals, and plans,

 more efficient sharing of resources,

and
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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 greater emphasis on succession 

planning, including more effective 

recruitment and selection leading to 

better qualified hires. 

The Department also continued to enhance 

the EEO community’s access to relevant 

workforce data by providing quarterly 

workforce data tables as well as conducting 

quarterly data reviews to enhance the 

accuracy of Treasury’s workforce data.

Throughout FY 2017, OCRD’s subject 

matter experts (SME) continued to 

participate as data stewards, working in 

conjunction with other Department SME’s 

and the Enterprise Data Management team 

to enhance the Department’s Data 

Dictionary, recognized by OPM as a best 

practice in FY 2016. The Data Dictionary

gives standardized definitions for all fields 

of personnel data and lists all associated 

OPM, NFC and or HR Connect codes for 

data contained in the Department’s 

Workforce Analytics tool. This ensures all 

users have the same understanding of the 

data and are able to pull and analyze the 

proper data relevant to the desired analysis 

projects. 

However, the automated diversity 

dashboards that OCRD began working on 

at the end of FY 2016 have been put on 

hold due to lack of funding in FY 2017. 

OCRD is hopeful funding will be available 

for the dashboard project in FY 2018. Once 

funding becomes available, OCRD will 

continue the process of developing 

automated dashboards that will enhance

Treasury and bureau leadership’s

knowledge of the state of their workforce, 

help identify any areas of potential concern 

and provide insight towards identifying

where new or additional strategies may be 

warranted to improve overall workforce 

diversity and inclusion.

Exit Survey Tool and Analysis

Now in its eighth year, Treasury continued 

the use of its automated Exit Survey tool 

deployed in FY 2010. The Exit Survey 

results are a valuable source for guiding 

bureau HR and EEO staff as well as 

managers towards identifying potential 

barriers in the areas of retention, career 

advancement, professional development, 

and provision of reasonable 

accommodations.

During the reporting period a total of 

10,2051employees separated from 

Treasury; 9,0042 were permanent 

employees and 1,201 were temporary. 

From those separations, 8,942 were 

voluntary; 8,306 permanent and 636

temporary. From the voluntarily separating 

employees, we received a total of 2,303

(28%) responses. Of the 2,303 responses, 

98% (2,248) were permanent/seasonal 

employees, of whom 9% (202) were 

persons with disabilities and 17% (371) 

were veterans; 2% (55) were temporary 

employees3.

While Whites represent 55% of the 

Department’s total permanent workforce, 

Whites represented 58% of the separating 

permanent/seasonal employees and 67% of 

the respondents who took the Exit Survey. 

Males represent 38% of the Department’s 

total permanent workforce, 36% of the 

separating permanent/seasonal employees 

and 40% of those who took the Exit Survey. 

 

1 Data does not include those employees separating 

from the office of the Special Inspector General for 

the Troubled Asset Relief Program (26) or the 

Office of the Inspector General (8).

2 Data on separations was provided by Workforce 

Analytics. Data snapshot is as of pay period 19, 

September 30, 2017.

3 No analysis was conducted on the temporary 

employees because the number of respondents (55) 

is insufficient for conducting a statistically 

significant analysis.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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We also note that separating 

permanent/seasonal employees tended to be 

older; 76% of the permanent/seasonal 

respondents to the Exit Survey reported 

being 50 years of age or older and 53% 

indicated their length of service was more 

than 25 years. This is not an unexpected 

result as the reason most frequently cited 

for separating permanent/seasonal 

respondents was retirement (1,522 out of 

2,248 or 68%). Additionally, 20% or 441, 

identified they were leaving due to a 

promotion, transfer or accepting a position 

at another Federal/State Agency, non-profit 

or private sector organization and 6% or 

125, identified resigning for other reasons 

not listed. Less than 1% of the voluntarily 

separating permanent/seasonal employees 

cited “Other” (47) as to why they were 

leaving. 

A high proportion of departing employees 

identified their Treasury work experience as 

positive (83% of permanent/seasonal 

employees). However, a significant 

percentage (62%) of permanent/seasonal 

employees reported job related stress was 

not manageable, 41% indicated that their 

workload was not reasonable, 44% 

indicated resources were not available to do 

their job, and their pay level in relation to 

their jobs. Additionally, 55% indicated that 

the morale in their office was not good. 

Departing permanent/seasonal employees 

responded favorably overall to most 

questions related to work experience. 

However, a significant number of responses 

from departing permanent/seasonal 

employees concerned career growth: having 

the opportunity to participate in decisions 

(45%) and access to career development 

opportunities (43%).

During the period of October 1, 2016 

through September 30, 2017, 202 

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 48% (97) had more than 

25 years of service and 76% (153) were age 

50 or older. Of the respondents with 

disabilities, 31% (63) were veterans. The 

most frequently cited reason for separation 

of PWD was retirement (126 or 62%).

The factor most frequently cited as 

impacting a PWD’s decision to leave was 

job stress (75%). Additional factors 

frequently cited include office morale 

(64%); office organization and alignment 

with regard to effective and efficient 

service (51%), resources to do the job 

(51%), ability to participate in decisions 

(48%), access to developmental 

opportunities (48%), pay in relation to job 

responsibilities and performance (47%), 

reasonableness of workload (46%), and job 

description in relation to actual duties and 

responsibilities (46%). 

71% of the respondents indicated their 

work experience was generally positive and 

64% stated they would recommend 

Treasury as a good place to work. PWD 

(69%) were slightly less likely to indicate 

that they would recommend Treasury as a 

good place to work, as compared to the 

72% of all respondents.

During the period of October 1, 2016 

through September 30, 2017, 371 

permanent/seasonal veterans responded to 

the Department’s Exit Survey. Overall 

responses from veterans mirrored the 

overall permanent/seasonal employee 

responses in that, 37% (136) had more than 

25 years of service, and 72% (267) were 

age 50 or older. The most frequently cited 

reason for separation of veterans was 

retirement (216 or 58%), transferring, 

promotion or accepting a position in the 

private sector, another federal agency or 

Treasury bureau (97 or 26%) and other (7 

or 2%).
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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The factor most frequently cited by 

veterans for their decision to leave was job 

related stress (58%). Additional factors 

frequently cited included office morale 

(54%), ability to participate in decision 

making (47%), pay in relationship to job

responsibilities (44%) and access to 

developmental opportunities (42%). 

80% of the respondents indicated their 

work experience was generally positive and 

69% stated they would recommend 

Treasury as a good place to work. 

Additionally, 63% of the separating 

veterans said they would be interested in 

returning to work for Treasury.

FY 2017 Employee Viewpoint Survey

The 2017 Federal Employee Viewpoint 

Survey (FEVS) was administered by the

Office of Personnel Management (OPM)

between May 2 and June 13, 2017. As with 

previous years, the 2017 survey was a full 

census, administered to all eligible 

employees, defined as full- or part-time, 

permanent, non-political, and non-seasonal 

employees onboard as of October 31, 2016.

Treasury’s 2017 response rate was 58

percent with 46,368 out of 79,744

eligible employees responding. As in the 

previous year, the Department’s response 

rate remained significantly higher than 

the FY 2017 government-wide rate of 46

percent.

The FEVS includes a total of 98

questions, of which 71 measure federal

employees’ perceptions about how 

effectively agencies manage their

workforce; 13 are specific to employees 

participating in work/life programs; and 

14 relate to demographic information. 

OPM considers items with a positive 

rating of 65 percent or more as an 

organizational strength and 35 percent or 

less as a weakness. The FY 2017 FEVS 

results reflected that none of the question 

responses showed a decline in positive 

response rates, in fact, 90 percent of the 

questions showed an increase in positive 

response rates. This includes increases in 

all three 2017 Treasury-wide engagement 

strategy focus area questions (questions 

23, 53 and 714. Notably, question 71, 

related to employee satisfaction, increased 

by four percentage points, from 55 percent 

in FY 2016 to 59 percent in FY 2017.

The 2017 results also showed that 

Treasury continued to leverage its areas of 

strength to help improve employee 

sentiment across the Department. All 

three strength area focus questions

(questions 42, 49 and 56

5

) showed 

increases in positive response rates; 

including a significant increase of two 

points related to supporting employee 

work/life balance (question 42). 

One of the ways Treasury gauges survey

results about employee perceptions and 

engagement is to look at the overall 

response rates for Engagement (68 percent) 

and Satisfaction (64 percent). In FY 2017, 

overall response rates for Engagement was 

slightly above the government rate of 67 

percent, while Satisfaction at Treasury is 

slightly below the government-wide 

average of 65 percent. However, it is clear 

that based on Treasury employees’

responses, they continue to remain 

committed to the mission, are willing to 

give extra to get the job done and are proud 

of the quality of their work. Treasury 

 

4 Question 23: In my work unit, steps are taken to 

deal with a poor performer who cannot or will not 

improve. Question 53: In my organization, leaders 

generate high levels of motivation and commitment 

in the workforce. Question 71: Considering 

everything, how satisfied are you with your 

organization.

5 Question 42: My supervisor supports my need to 

balance work and other life issues. Question 49: My 

supervisor/team leader treats me with respect. 

Question 56: Manager communicates the goals and 

priorities of the organization.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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employees also had positive responses to 

questions regarding their immediate 

supervisors – a key strength Treasury 

leverages as part of its engagement strategy.

Moving Forward: FEVS Engagement

Plans

To support Treasury and its bureaus efforts 

to continue to improve overall FEVS results 

through employee engagement, DASHRCHCO is developing the Department’s 

Employee Engagement Policy to be issued 

in FY 2018. The policy will provide 

guidance to support and coordinate efforts 

of the Department of the Treasury and its 

Bureaus to strengthen an organizational 

culture of employee engagement and 

recognize employees’ achievements in 

accordance with priorities that are being 

established in the Treasury FY 2018 – 2022 

Strategic Plan.

DASHR-CHCO will also be working with

Treasury’s bureaus on improving existing 

training and mentoring programs and 

opportunities, improve on-boarding 

programs, maximize employee performance 

by tracking implementation of Treasury’s 

non-Senior Executive Service performance 

management policy, providing supervisory 

tools, meaningful employee recognition and 

conducting employee focused meetings 

such as roadshows, listening sessions and 

town halls. 

DASHR-CHCO is also working with the 

OCIO office to create and produce 

automated dashboards that will enhance 

Treasury and bureau leadership’s ability to 

make data driven decisions and develop 

plans to improve employee engagement. 

The test environment will be available to 

users starting November 2017.

Partnership for Public Service Best 

Places to Work in the Federal Government 

Rankings

Designed to help a broad audience of 

government leaders, employees and job 

seekers, the Best Places to Work in the 

Federal Government rankings draw on 

responses from civil servants who complete 

the FEVS to produce a detailed view of 

employee satisfaction and commitment 

across federal agencies and subcomponents.

Employee satisfaction and commitment are 

two necessary ingredients in developing 

high-performing organizations and 

attracting top talent. The Best Places to 

Work rankings are an important tool for 

ensuring that employee satisfaction is a top 

priority for managers and leaders. The 

rankings provide a mechanism to hold 

leaders accountable for the health of their 

organizations; serve as an early warning 

sign for agencies in trouble; offer a 

roadmap for improvement; and give job 

seekers insights into how federal employees 

view their agencies.

The Partnership for Public Service uses 

data from the Office of Personnel 

Management’s Federal Employee 

Viewpoint Survey to rank agencies and 

their subcomponents according to a Best 

Places to Work index score. 

In FY 2017, the Department was ranked

14th among 18 large agencies, as compared 

to ranking 15th place last year.

Agencies are ranked according to overall 

employee engagement, as well as on 

additional categories such as leadership, 

strategic management, innovation, and 

work-life balance. PPS uses a slightly 

different formula for calculating its 

categories than OPM uses for FEVS 

indices. Below are some highlights (minus 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

23

results from FinCEN, TTB, and OIG6) from 

the FY 2017 overall results:

 All Treasury bureaus increased their 

BPTW ranking. Most Treasury 

bureaus improved overall scores 

from 2016, except for DO which 

had a decrease of 2.1 points.

 Treasury increased across all PPS 

Category Scores, with increases of 

more than two points in Pay (3.4 

points, # 16/18), Support for 

Diversity (3.0 points, #11/18), 

Empowerment (2.2 points, #15/18), 

and Strategic Management (2.1 

points, #16/18).

 We continue to rank among the top 

agencies in employee opinion about 

their immediate supervisor (#4/18).

Treasury is also among the top ten 

in Teamwork (#7/18) and Fairness 

(#9/18).

Essential Element D: Proactive 

Prevention of Unlawful Discrimination 

Special Emphasis Programs 

As previously mentioned, OCRD is part of 

Departmental Offices and provides policy, 

oversight and technical guidance to 

Treasury bureaus to include special 

emphasis program (SEP) areas. SEPs

provide a framework for incorporating EEO 

principles of fairness and equal opportunity 

into the fabric of the Department and it 

bureaus, across the employment spectrum. 

Established throughout the bureaus, the 

three federally mandated SEPs -- the 

 

6 While OPM provided government-wide and 

agency data from its 2017 Federal Employee 

Viewpoint Survey (FEVS), it withheld information 

on 186 small agencies and subcomponents until 

early December. This impacted PPS’s ability to 

include these organizations in the 2017 rankings 

released. OPM has since released the data, and 

Partnership plans to release small agency rankings in 

early 2018.

Hispanic Employment Program, the Federal 

Women’s Program and the Persons with 

Disabilities Program -- reflect the 

Department’s commitment to equal 

opportunity, dignity, and respect. 

At their discretion, individual bureaus have 

also established other SEPs such as 

African-American, Asian American/ 

Pacific Islander, American Indian/Alaska 

Native employment programs and Lesbian 

Bisexual Gay and Transgender employment 

programs.

Bureau SEP Managers and Coordinators 

serve as resource persons or advisors to the 

bureau EEO offices on the unique concerns 

of the particular constituent group and 

support the internship programs and other 

partnerships discussed previously.

At the end of FY 2017, OCRD launched 

Prism, a Treasury-wide Employee Resource 

Group focused on lesbian, gay, bisexual, 

transgender and queer (LGBTQ) employees 

and their allies. Prism is an employeedriven group that supports professional 

development, group mentoring, training, 

and retention of LGBTQ employees. Prism 

will provide a safe environment where 

LGBTQ and ally employees can actively 

engage in discussions of shared issues or 

concerns that help to promote an engaged 

workforce and uncover issues that are 

specific to the needs of the LGBTQ 

community. And like all of our employee 

resource groups, all Treasury employees are 

welcome to join.

Additionally, Treasury was one of 31 

Federal agencies that participated in the 

24th annual Federal Inter-Agency 

observance to honor the Days of 

Remembrance. The program, “Evade and 

Endure: Survivors Stories,” was designed to 

provide eyewitness testimony to the horrors 

of the Holocaust and share the stories of 

survivors who have made meaningful 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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contributions to society wile overcoming 

evil. This year’s speakers included Roman 

Kent, survivor of the Lodz Ghetto, 

Auschwitz and other concentrations camps 

and a leading voice on behalf of all 

Holocaust survivors and Renee Fink, one of 

the 12 “Hidden Child” representatives of 

the N.C. Holocaust Speakers Bureau.

OCRD Also provided LGBTQ Cultural 

Competency training on an ad-hoc basis 

throughout FY 2017. The course covered 

sex discrimination protections under Title 

VII of the Civil Rights Act. OCRD held 

eight sessions with IRS employees, 

managers and soon-to-be SES leaders in 

their Candidate Development Program, 

reaching 120 employees. OCRD also held 

one session with the Bureau of Engraving 

and Printing for 80 employees and 

managers, which was recorded for future 

use. Similar information on sex 

discrimination related protections was 

released in a policy statement in December 

2016 and sent as a Manager’s Alert to all 

Treasury managers in March FY 2017.

In September, OCRD partnered with the 

IRS to provide a panelist for the annual 

White House Initiative on Historically 

Black Colleges and Universities HBCU 

Week conference to discuss Treasury

internship opportunities with HBCU 

students.

Treasury-wide Diversity Training Events

In FY 2017, Treasury’s Executive Institute 

(TEI) established a curriculum and hosted a 

variety of training sessions for Treasury 

employees and managers geared towards 

enhancing knowledge of diversity and 

inclusion with additional emphasis on 

leveraging diversity through leadership 

development and conflict management.

These sessions included the following 

seminars:

 Suspending Judgement: A Key to 

Being Culturally Competent

 SES: How to Get There and 

Succeed Once There

 Managing Conflict: A Problem 

Solving Approach

 The NextGen Leader

 A Key to Being Culturally 

Competent

 Harvard Business Simulations: 

Managing Difficult Conversations

 Engaging with Honor: Building a 

Culture of Courageous 

Accountability

 Moving Beyond Diversity: The 

Case for Inclusive Leadership

 Engaging Employees: Cultivating 

Your Organizational Culture

 Permission to Speak Freely: How 

the Best Leaders Cultivate a Culture 

of Candor

 Leveraging the Power of Diversity 

to Achieve Breakthroughs

 A Winning Culture in Government

 The Harvard Business Review Way 

of Resolving Conflict

 We Can’t Talk About That at Work! 

How to Talk about Race, Religion, 

Politics, and Other Polarizing 

Topics

 Inviting Innovation

 Earning It: Hard-Won Lessons from 

Trailblazing Women at the Top of 

the Business World

 Leader to Leader: Exploring 

Success

 Empowerment: Why Me?

In April, Treasury also hosted a screening 

and panel discussion of “Uniquely Nasty”. 

The documentary explores the period 

during which lesbian, gay, bisexual and 

transgender (LGBT) individuals were 

barred from working for the federal 

government and featured the stories of three 

individuals who shared their personal 

experiences during that time period. 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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In July, Treasury hosted a dynamic 

webinar, Untangling the Web Between 

White Women and Women of Color. The 

webinar was designed to be an interactive 

exploration of how, especially in these 

turbulent times, White women and women 

of color, regardless of age, sexual 

orientation and identity, title, or ability, can 

leverage our diversity to build individual 

comfort, group collaboration, and 

organizational synergy.

And in September, Treasury partnered with 

Dr. Zina Sutch, Director of Diversity and 

Inclusion at the Office of Personnel 

Management, to present a new style of 

seminar for the Department’s senior 

leaders. The new series, “Understanding, 

Harnessing, and Leveraging the Power of 

Diversity & Inclusion, was launched this 

summer by OPM, and Treasury was one of 

the first agencies to participate. The 

training discussed how leadership must 

focus on people, practices and performance 

in order for the organization to be 

successful. The training provided attendees 

with information on why and how leaders 

in government can leverage diversity,

create inclusive cultures and promote 

opportunities for all.

Alternative Dispute Prevention (ADR)

Conflict that results in formal disputes is 

costly and disruptive to the workforce. 

Therefore, the Department continues to 

devote significant resources to resolving 

conflict through dispute prevention and 

through alternative dispute resolution 

(ADR) methods. 

As with previous years, the Department 

held its annual Dispute Prevention Program 

hosting two webinars; C3: Communicate, 

Collaborate, Create, and Civil Treatment: 

Building an Inclusive Workplace by 

Addressing Unconscious Bias. 

The C3 webinar highlighted trends and 

strategies related to conflict resolution,

designed to help individuals better 

communicate and collaborate to create 

solutions. The Civil Treatment webinar 

addressed the effects of unconscious bias , 

how to promote civility and help eliminate 

negative behavior by creating foundational 

skills in support of fair and inclusive 

behavior.

In FY 2017, 94 percent of EEO counseling 

contacts were offered ADR, and 61 percent 

of those offered ADR participated in ADR 

at the informal level. 

ADR Offered to Complainants

(Informal) FY 2017

Total Completed 

Counseling

722

Total ADR Offered 678

Total Accepted 434

Offer Rate 94%

Acceptance Rate 61%

In the formal complaint process, during FY 

2017, the Department achieved an 88 

percent ADR offer rate and 9 percent of 

complainants offered ADR participated in 

ADR. 

ADR Offered to Complainants

(Formal) FY 2017

Formal Closed 

Complaints

381

Total ADR Offered 334

Total Accepted 35

Offer Rate 88%

Acceptance Rate 9%

In an effort to increase participation in 

ADR at the formal stage of the complaint 

process, in FY 2018, OCRD will 

incorporate new language into its Formal 

Complaint forms to encourage employees 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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to participate in the formal ADR process 

even though they may not have been able to 

resolve the complaint through ADR at the 

informal stage of the complaint process. 

Shared Neutrals Program

Through the Treasury Shared Neutrals 

(TSN) Program, Treasury maintains a 

nationwide cadre of certified and highly 

trained neutrals (also known as mediators).

TSN mediators are employees from various 

organizations trained in the art of mediation 

who voluntarily serve on a collateral-duty 

basis. Their objective is to assist bureaus in 

resolving all types of workplace disputes at 

the earliest stages of the conflict and to 

provide a resolution through mediation, 

facilitation, and coaching.

During FY 2017, TSN completed a total of 

274 mediations. Of these 274 mediations, 

TSN mediators successfully resolved 114 

(45 percent) disputes. On November 1, 

2017, the TSN mediation coordination 

functions for the Department transitioned to 

the United States Mint. The Mint will serve 

in this role for the next two fiscal years.

Essential Element E: Efficiency 

Treasury has sufficient staffing, funding 

and authority to comply with the time 

frames established in EEOC regulations (29 

CFR §1614) for processing EEO 

complaints of employment discrimination. 

Treasury promotes and utilizes an efficient 

and fair dispute resolution process and has a 

system in place for evaluating the impact 

and effectiveness of the Department’s EEO 

complaint processing program. Treasury's

complaint management system, I-Trak, 

continues to provide greater Departmentwide tracking and case management 

capabilities for both the formal and 

informal complaint process.

As noted above, OCRD tracks all EEO 

complaints filed by Treasury employees 

and applicants for employment with an 

integrated data management complaint 

system (ITRAK or iComplaints). OCRD 

contracts with Micropact to serve as the 

systems administrator for the iComplaints 

system. In June 2016, a security 

assessment of Micropact identified six risk 

deficiencies. Treasury’s OCIO reviewed 

and remedied all six associated risks by 

February 2017. The most significant risk, 

identified through the security assessment, 

was remedied with OCRD and OCIO 

signing an accepted risk memo on October 

2016, which stated the business need for the 

iComplaints login to support both 

ID/password authentication.

Additionally, in order to improve on the 

timely completion of Treasury’s 

investigations in FY 2017, OCRD made the 

decision to directly download investigative 

reports from the “cloud” that USPS offers 

to its clients. The decision to download 

directly from the cloud meant that OCRD 

would no longer have to wait (for a 

minimum of least two weeks) for the 

investigative reports to reach us through the 

mail. This change not only vastly improved 

the timeliness of our investigations it also

reduced overall costs. In fact, at the end of 

FY 2017, Treasury noted a 12 percent 

improvement in the timeliness of our 

investigations (from 78% in FY 2016 to 

90% in FY 2017).

Discrimination Complaints

In the area of discrimination complaints, 

OCRD is responsible for providing 

authoritative advice to bureau EEO staff 

and for processing all administrative EEO 

complaints based on race, color, national 

origin, religion, sex (including sexual 

orientation, gender identity and pregnancy), 

age, disability, protected genetic 

information, reprisal and parental status.

OCRD also develops complaint policies 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

27

and procedures and produces high quality 

final agency decisions. In addition, OCRD 

oversees the Department’s appeal process, 

tracks all appeal decisions, and monitors 

compliance with decisions issued by the 

EEOC.

The Department also has special procedures 

for handling complaints on the basis of 

parental status. This basis was added in 

response to a Presidential Executive Order.

Complaint Activity

Treasury timely submitted the EEOC 462 

Report in October 2017. The 462 Report is 

an annual assessment of the agency’s 

formal and informal complaints, and of 

avenues used to resolve issues prior to and 

during the complaint process. 

During FY 2017, the number of EEO 

complaints filed by Treasury employees 

and applicants (367) decreased by eight

percent from the number of complaints 

filed in FY 2016 (401).

* Prior to FY 2010, protected genetic information complaints 

were processed under the Department’s modified procedures. 

Since the passing of the Genetic Information Non-Discrimination 

Act (GINA) in November 2009, these complaints have been 

processed as EEO complaints in the statutory complaint process. 

At the close of FY 2016, Treasury had 707

complaints pending that were carried over 

to FY 2017. During FY 2017, 367

complaints were filed, four cases (one of 

which was of a complaint that was filed in 

FY 2017) were remanded back to the 

agency by the EEOC and Treasury closed 

380 complaints. 

In FY 2017, the Department’s bureaus 

timely completed 94 percent of EEO

counselings. 

By the end of FY 2017, the Department

completed 314 investigations. There were 

184 investigations (59 percent) completed 

within 180 days, 127 (40 percent) 

completed between 181-360 days and 3 

(one percent) were completed in 361 or 

more days. Because time frames are 

extended under certain situations, 90

percent (284) of all investigations were 

timely completed, a significant 

improvement over the 78 percent timely 

completed in FY 2016.

In FY 2017, Treasury issued 205 final 

agency decisions in cases where a hearing 

was not requested. Of these decisions, 159 

were merit decisions and 46 were 

procedural dismissals. In FY 2017, there 

were six findings of discrimination. 

Overall in FY 2017, Treasury processed 

159 merit decisions within an average of 44

processing days, which is below the 60

processing days mandated by EEOC. 92 

percent (146) of those merit decisions were 

timely issued within 60 days of receipt of 

the decision request. Treasury also issued 

76 final agency actions in cases with an 

administrative judge’s decision (i.e., cases 

where a hearing was requested); one

involved a finding of discrimination. 

At the end of FY 2017, Treasury had 697

complaints pending. Pending complaints 

can be at the acknowledgement, 

investigation, hearing or final agency 

decision stages. 

At the end of FY 2017, 21 percent of 

pending complaints were at the 

investigation stage. Seventy percent were 

pending a hearing before an EEOC 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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Administrative Judge7. A total of 41 (6

percent) of the complaints remained 

pending in the final agency decision/action 

phase with the remaining 17 (2 percent) 

pending decision to accept/dismiss. 

At Treasury, the most frequently cited bases

for complaints are reprisal, age, and 

disability, and the most frequently cited 

issues are harassment (non-sexual), 

performance evaluation/appraisal, and 

disciplinary action.

 

The percentage of Treasury employees who 

filed formal EEO complaints decreased 

slightly from 0.37 percent of the workforce 

in FY 2016 (373 complainants) to 0.36

percent in FY 2017 (348 complainants).

In May 2017, Treasury received a feedback 

letter from the EEOC that identified that the 

reversal rate of procedural dismissals issued 

by the Department had increased from 22% 

in FY 2014 to 33% in FY 2016. EEOC 

recommended Treasury devise a plan to 

decrease the reversal rate. OCRD reviewed 

the FY 2017 data and determined the 

reversal rate of dismissals adjudicated by 

EEOC in FY 2017 was 28% (4 of 14), a 5 

percentage point decrease from the FY 

2016 rate. While it is difficult for only 4 

reversals to have a common theme, the 

Department will provide appropriate 

language to the bureau EEO Counselors for 

use in more clearly informing complainants 

of the effect of refusal to participate in the 

EEO counseling process. In addition, 

OCRD will discuss with our complaint staff 

how the analysis of one of the dismissals 

could have been improved.

 

7 Case decisions pending before an EEOC 

administrative judge are outside the control of the 

agency.

Essential Element F: Responsiveness 

and Legal Compliance 

Treasury is in compliance with the law, 

including EEOC regulations, directives, 

orders and other instructions. The 

Department has posted all required No Fear 

Act information, provided the required 

training, and consistently filed timely MD715 and EEOC Form 462 reports as well as 

other reports required by EEOC and OPM. 

Treasury conducted it mandatory biennial

No Fear Act Training in FY 2016. The 

next biennial required training will be in FY 

2018.

Agency/Bureau State of the Agency 

MD-715 Briefings

During FY 2017, the Department conducted 

its FY 2016 State of the Agency Briefing 

with senior leadership in January 2017. 

After the submission of Treasury’s FY 

2017 MD-715 report, OCRD plans to brief 

senior leadership on the Department’s 

status in maintaining a model EEO Program 

during FY 2018. 

The Department also continued to hold its 

one-on-one briefings with each of its 

bureaus in an effort to improve the mutual 

understanding of bureau program 

deficiencies and workforce triggers 

/barriers. As previously noted each bureau, 

regardless of its size, has its own distinct 

reporting structure for its EEO and HR 

offices and establishes its own policy and 

procedures regarding the hiring, 

recruitment, retention and professional 

development of employees. Therefore, the 

required barrier analysis must be completed 

at the bureau level. These briefings provide 

a forum for OCRD and bureau EEO staffs

to dialogue about possible internal and 

external factors that may be contributing to 

triggers/barriers, recommend the direction

of the bureau barrier analysis and identify 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

29

corporate strategies that may assist bureaus 

in determining if workplace barriers exist. 

In FY 2017, OCRD continued with its 

standard practice of providing bureau 

leadership with feedback on the preparation 

of their previous year’s annual MD-715 

report. However for the last two years, our 

team’s focus has been on reviewing and 

providing recommendations to enhance the 

bureaus’ barrier analysis efforts and 

preparations of required PART I’s. In 

many cases, the team found that the 

analysis was too broad to identify the actual 

barrier, and resulted in recommendations on 

ways to refine and target the root cause 

analysis to more accurately identify if a 

potential barrier existed. 

Treasury Pay Gap Analysis

During FY 2017, OCRD conducted a 

Treasury Pay Gap Analysis. The impetus 

was government-wide pay equality studies 

issued by the Office of Personnel 

Management (OPM) calling on federal 

agencies to analyze their pay data. In 

consultation with the Deputy Assistant 

Secretary for Human Resources and the 

Office of Minority and Women Inclusion 

for the Departmental Offices, OCRD 

reached out to OPM, which agreed to 

provide raw data from its data files on 

“occupational groups” within Treasury, the 

same data set used by OPM in its studies.

However, after review of that data and 

further discussion with the Office of 

Microeconomic Policy (OMEP), it was 

determined that the Department would 

benefit most from a deeper analysis based 

on an examination by actual occupation.

Because OPM would not supply data at that 

level, OCRD pulled data on specific 

occupations from the Department’s 

Workforce Analytics System. Where there 

were a sufficient number of employees (100 

males in the occupation), the analysis was 

conducted separately for non-IRS and IRS 

employees; otherwise, the analysis is based 

on a combination of IRS and non-IRS 

employees. 

After a thorough analysis, we were pleased 

to find substantial equity in pay between 

females and males at the Department.

When common and well-accepted statistical 

models are applied at a granular level, the 

Department’s pay gap for females is only 

2.8 percent. (While it would be unwise to 

ignore any gap, absolute parity is 

statistically unlikely.)

At the Department:

 Pay-setting authorities for female 

and male new hires are very 

similarly applied.

 Female starting salaries for Whitecollar employees in all pay plans 

were 93.2 percent of male starting 

salaries.

 Quality Step Increases are equitably 

awarded, with females slightly more 

likely to receive one.

 Promotions are equitably 

distributed, with males slightly more 

likely to receive one.

 For 30 of the 39 occupations 

analyzed, the pay gap is under five 

percent; seven occupations reflect a 

higher pay for women.

Accordingly, we concluded that this 

analysis establishes that pay setting 

methods are equitably applied within the 

Department and that there is no adverse 

impact on either gender. However, it is 

cautioned that there still may be individual 

instances where a specific pay setting was 

inequitable. The Department plans on 

repeating this analysis within five years to 

ensure that the results remain stable or 

improve.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

30

Workforce Demographics

The MD-715 report contains information on 

Treasury’s workforce demographics over 

the period of FY 2008 to FY 2017

8

. 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 and 

the Senior Executive Service and equivalent 

pay plans (OR, TR, IR and NB), Hispanics 

and persons with targeted disabilities 

(PWTD). 

Throughout most of FY 2017, 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 to 

either conduct meaningful analysis or 

evaluate previously established plans to 

determine their effectiveness. 

Additionally, for a cabinet level agency the 

size of Treasury, it is impractical to expect 

any demographic data to change by more 

than a percent in a single fiscal year. 

Indeed, such 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 (see 

bureau MD-715 Reports for analysis and 

PART I’s associated with bureau specific 

triggers/ barrier analysis), Treasury has 

noted significant progress in increased

participation rates for women and 

 

8 Enterprise Data Management System, Treasury’s 

system of record, maintains employment data that 

covers a rolling period of 10 years. Beginning in FY 

2017 data for trend analysis was available for FY 

2008 through FY 2017.

minorities in SES positions as well as the 

feeder pools and for the overall 

participation rate for Hispanics and PWD 

and PWTD.

 

As of the end of FY 2017, the permanent 

workforce participation rate of Hispanics

was 11.44 percent. This is an overall 

increase of 2 percent when compared to the 

9.63 percent participation rate noted in FY 

2008. This participation rate is above both 

the CLF (9.96 percent) and RCLF (8.50

percent) availability rates. 

Participation Rates in the Permanent 

Workforce

As of the close of FY 2017, Treasury had 

94,751 permanent employees9, a decrease 

of 3,660 (-3.72 percent net change) 

employees from FY 2016. This decrease is 

primarily due to reduced budgets which

have significantly limited or reduced hiring 

opportunities for many of Treasury’s 

bureaus in FY 2017.

Treasury and its bureaus continue to utilize 

the Relevant Civilian Labor Force (RCLF) 

tool updated at the end of FY 2017, which 

provides a more realistic benchmark 

comparator based on the overall 

occupational composition of the

Department’s total workforce. Treasury 

identified all the occupations within the 

Department’s workforce, pulled the 

relevant occupational CLF’s and identified 

availability rates for each occupation to

determine the proper weight each 

occupation should be given in order to

determine the overall RCLF to compare to 

the Department’s workforce. The weighting 

of the actual availability rate of each

occupation in the labor force is the most 

critical part of determining the appropriate 

 

9 For purposes of analysis, non-appropriated fund 

employees are included in the workforce totals as 

permanent or temporary employees depending on 

status.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

31

bench mark. For example secretaries 

comprise approximately 0.56 percent of the 

civilian workforce but the RCLF 

availability rate for secretaries is 96.1 

percent women. If not properly weighted 

based on the 0.56 percent availability rate

in the workforce, it could give a very 

misleading comparator as to what the 

representation of women could be. As a 

result, Treasury now has a more realistic 

comparator for availability rates by 

ethnicity race indicator (ERI) and gender 

based solely on those occupations 

employed at the Department. 

A comparison of FY 2017 participation 

rates in Treasury’s permanent workforce for 

men and women shows little change from 

FY 2007. However, based on the RCLF 

availability rates, we see that women (62.09

percent compared to 64.98 percent RCLF) 

and men (37.91 percent compared to 35.02

percent RCLF) are participating at rates 

very close to their RCLF availability rates.

And 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). 

Demographics and

RCLF Comparison by Gender

FY 2008 and FY 2017

In FY 2008, Treasury’s permanent 

workforce was 60.55 percent White and 

39.35 percent non-White. In FY 2017, the 

participation rate for Whites decreased to

55.64 percent of the workforce and nonWhites increased to 44.36 percent. Thus, 

Treasury has noted a significant positive 

trend in the increased participation rate for 

non-Whites in the overall workforce. In 

fact, Hispanics (11.44 percent compared to 

8.50 percent RCLF), Blacks (26.73 percent

compared to 10.57 percent RCLF), Asians

(5.88 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 

(0.83 percent compared to 0.89 percent

RCLF) are participating at rates very close 

to their availability rates. Whites (54.60

percent compared to 74.93 percent) and 

Two or More Races (0.35 percent compared 

to 0.51 percent RCLF) are the only groups 

participating at rates below their RCLF 

availability rates. 

Demographics and

RCLF Comparison by ERI

FY2008 and FY 2017

* Other includes employees who are American Indian Alaska 

Natives, Native Hawaiian or Other Pacific Islanders and Two or 

More Races 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

32

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 2008, Treasury has 

seen a significant increased participation 

rate for women in the GS-13 through GS-15 

grades and in SES positions.

At the GS-13 grade level, the participation 

rate for women increased by 0.57 percent, 

from 49.22 percent in FY 2008 to 49.73 

percent in FY 2017. At the GS-14 grade 

level, the participation rate for women 

increased by 0.30 percent, from 46.8 

percent in FY 2008 to 47.1 percent in FY 

2017. At the GS-15 grade level, the 

participation rate for women increased by 

2.6 percent, from 43.6 percent in FY 2008 

to 46.2 percent in FY 2017. And at the SES 

level, the participation rate for women 

increased by 5.6 percent, from 32.9 percent 

in FY 2008 to 38.5 percent in FY 2017.

FY 2017 Grade Distribution by Gender

FY 2008 Grade Distribution by Gender

At the GS-13 grade level, the participation 

rate for Hispanics increased by 1.03 

percent, from 6.06 percent in FY 2008 to 

7.09 percent in FY 2017. At the GS-14 

grade level, the participation rate for 

Hispanics increased by 1.51 percent, from 

4.41 percent in FY 2008 to 5.93 percent in 

FY 2017. At the GS-15 grade level, the 

participation rate for Hispanics increased by 

1.11 percent, from 3.72 percent in FY 2008

to 4.83 percent in FY 2017. And at the SES 

level, the participation rate for Hispanics

increased by 0.69 percent, from 2.73

percent in FY 2008 to 3.42 percent in FY 

2017.

At the GS-13 grade level, the participation 

rate for Blacks increased by 2.63 percent, 

from 18.30 percent in FY 2008 to 20.93

percent in FY 2017. At the GS-14 grade 

level, the participation rate for Blacks

increased by 2.41 percent, from 17.44

percent in FY 2008 to 19.85 percent in FY 

2017. At the GS-15 grade level, the 

participation rate for Blacks increased by 

1.98 percent, from 14.61 percent in FY 

2008 to 16.59 percent in FY 2017. And at 

the SES level, the participation rate for 

Blacks increased by 1.51 percent, from 9.82

percent in FY 2008 to 11.33 percent in FY

2017.

At the GS-13 grade level, the participation 

rate for Asians increased by 2.56 percent, 

from 6.74 percent in FY 2008 to 9.30

percent in FY 2017. At the GS-14 grade 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

33

level, the participation rate for Asians

increased by 4.57 percent, from 5.32

percent in FY 2008 to 9.89 percent in FY 

2017. At the GS-15 grade level, the 

participation rate for Asians increased by 

3.61 percent, from 3.75 percent in FY 2008

to 7.36 percent in FY 2017. And at the SES 

level, the participation rate for Asians

increased by 0.14 percent, from 3.82

percent in FY 2008 to 3.96 percent in FY 

2017.

At the GS-13 grade level, the participation 

rate for Others10 increased by 0.10 percent, 

from 1.05 percent in FY 2008 to 1.15

percent in FY 2017. At the GS-14 grade 

level, the participation rate for Others

increased by 0.09 percent, from 1.10

percent in FY 2008 to 1.19 percent in FY 

2017. At the GS-15 grade level, the 

participation rate for Others increased by 

0.29 percent, from 0.59 percent in FY 2008

to 0.88 percent in FY 2017. Currently, there 

are no Other at the SES level.

Because we have a trend of increased 

participation for all the non-White groups 

in the feeder pools and SES positions, it is 

then expected that we would have a trend of 

decreased participation for Whites. At the 

GS-13 grade level, the participation rate for 

Whites decreased by -6.30 percent, from 

67.84 percent in FY 2008 to 61.54 percent 

in FY 2017. At the GS-14 grade level, the 

participation rate for Whites decreased by 

-8.58% percent, from 71.73 percent in FY 

2008 to 63.15 percent in FY 2017. At the 

GS-15 grade level, the participation rate for 

Whites decreased by -6.98 percent, from 

77.32 percent in FY 2008 to 70.34 percent 

in FY 2017. And at the SES level, the 

participation rate for Whites decreased by 

-3.05 percent, from 83.09 percent in FY 

2008 to 80.04 percent in FY 2017.

 

10 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).

FY 2017 Grade Distribution by

White and Non-White

FY 2008 Grade Distribution by

White and Non-White

It is important to note that when Treasury 

looks at Treasury-wide data as a whole, the 

progress noted may not be an accurate 

reflection of the true progress of each 

bureau. In fact, the consolidated view of 

the data may mask where potential barriers 

may 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 has expressed the expectation to the 

bureaus that they are required to complete 

detailed analysis to determine if any EEO 

groups are facing a potential glass ceiling, 

blocked pipeline or glass wall and based on 

their findings, complete any associated
Office of Civil Rights and Diversity FY 2017 MD-715 Report

34

PART I’s for submission with their bureau 

MD-715 reports. Additionally with the 

release of the joint EEOC/OPM 

memorandum issued January 18, 2017, 

Treasury informed all of our bureaus that 

they were required to conduct a more 

focused barrier analysis on the participation 

rates for Hispanics within the major 

occupations distribution in the general 

schedule (GS) grades 12 through SES 

levels to identify and eradicate any barriers 

to equal employment opportunity (EEO), 

consistent with the merit system principles 

and applicable laws. 

Additionally, in FY 2015/2016, Office of 

Civil Rights (OCRD) and the Deputy 

Assistant Secretary for Human Resources 

and Chief Human Capital Officer (DASHR 

CHCO) conduct a review of the diversity of 

the Department’s Senior Executive Service 

(SES) corps and the processes for selecting 

new executives compared to FY 2010 and 

FY 2005. 

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 planned 

activities for completion in FY 2017 had to 

be modified for completion in FY 2018.

(See Treasury PART I for modified 

completion dates.)

Disability Employment Program

In April 2017, the OPM revised its SF-256, 

Identification of Disability. The revised

SF-256 significantly changed the way 

agencies count and track persons with 

disabilities (PWD) and persons with 

targeted disabilities (PWTD) by 

incorporating new codes, improved 

definitions and broader categories of 

disabilities and serious health conditions. 

To ensure Treasury was in compliance with 

the new coding established with 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 identified themselves as not 

having a disability as a PWD. 

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. 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

35

As a result of the implementation of the 

new coding in OPM’s revised SF-256 and 

the Departments resurvey efforts, Treasury 

had a significant increase in the 

participation rates for both PWD and 

PWTD in its permanent workforce. In its 

FY 2016 MD-715 Report, Treasury 

reported a permanent workforce 

participation rate of 9.74 percent for PWD 

and 1.78 percent for PWTD. However at 

the end of FY 2017, Treasury is pleased to 

note that we have exceeded the new FY 

2018 goals of a 12 percent participation rate 

for PWD (13.37 percent) and the sub goal 

of 2 percent for PWTD (3.59 percent). 

Many of Treasury bureaus have also either 

met or exceeded the new goals:

FY 2017 Participation Rate for PWTD

FY 2017 Disability Participation Rates 

By Bureau (Permanent)

Bureau TOTAL PWD 

#

PWD 

%

PWTD 

#

PWTD

%

BEP 1802 255 14.15% 33 1.83%

FS 3543 792 22.35% 144 4.06%

DO 1866 224 12.00% 37 1.98%

FinCEN 268 46 17.16% 13 4.85%

IRS 78240 10277 13.07% 2970 3.80%

IRS-CC 1744 217 12.44% 47 2.40%

Mint 1578 333 21.10% 58 3.68%

OCC 3930 383 9.75% 79 2.01%

OIG 167 30 17.96% 5 2.99%

SIGT11 124 17 13.70% 2 1.61%

TIGTA 789 65 8.24% 5 0.63%

TTB 483 75 15.53% 10 2.07%

TOTAL 94751 12664 13.37% 3403 3.59%

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 subgoal 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 (14.15%) and 

PWTD (4.56%) 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 

 

11 For Treasury’s IG’s (OIG, SIGT, and TIGTA), an 

overall look at disabilities is misleading as these 

bureaus employ a significant number of employees 

in the 1811 (criminal investigating) occupation that 

have specific occupational employment criteria that 

preclude the employment some PWD and PWTD. If 

that occupation is excluded from the overall 

workforce counts for those bureaus, they would have 

significantly higher participation rates (OIG: 19.08% 

PWD, 3.82% PWTD; SIGT: 15.59% PWD, 2.60% 

PWTD; TIGTA: 9.58% PWD, 0.98% PWD). 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

36

percent participation rate at the GS-11 and 

above grades levels. However, the 

participation rates for PWD (9.8%) at the 

GS-11 and above is slightly below the 12 

percent goal, indicating there is still work to 

be done. (See Treasury PART J for more 

detailed information.)

In FY 2017, OCRD continued to conduct 

its “Be a Champion” 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 Representative 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 2017, OCRD 

conducted roadshows for managers and 

supervisors at the Mint, IRS, and TTB.

At the end of FY 2017, Treasury 

implemented the process of utilizing 

OPM’s Talent Portal located on USAJobs 

as a resume mining database for PWD and 

Veterans. Using the Talent Portal will 

provide Treasury and its bureaus’ hiring 

managers’ access to resumes of qualified 

candidates with disabilities and veterans. 

The use of this tool assists Treasury in 

meeting its participation rate goals and

encourages the use of special hiring 

authorities such as Schedule A and the 

hiring authority for veterans with 30% or 

more compensable disability.

The Veteran and Disability Program 

Managers also created a “Be a Champion” 

video that many of Treasury’s bureaus have 

incorporated into their new supervisor 

training curriculum.

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.

Veteran Employment Program

Treasury is committed to achieving a 

workforce that includes those who have 

served in the defense of our country. In FY 

2017, bureaus retained a designated bureau 

Veteran Employment Representative (VER) 

to support the Treasury Veterans 

Employment Program Office (VEPO) with 

recruitment, hiring and retention of veteran 

employees. The Department expanded the 

VEPO services by establishing a Veterans 

Employment Program Coordinator (VEPC) 

position to facilitate a more interactive 

veteran consultation program for veterans 

and disabled veterans seeking employment. 

The IRS maintained a full-time position for 

a VEPO program manager, extending the 

Department’s program execution efforts to 

its largest bureau; IRS held monthly 

stakeholder meetings with all field 

components and offices. 

While the Office of Personnel Management 

(OPM) did not establish veterans hiring or 

retention goals in FY 2017, Treasury 

maintained its prior fiscal year’s numerical 

goals based on OPM’s End of Year Group 

Results by agency size (20k -100k). The FY 

2017 goals for the Department: Veterans in 

the Workforce (15%), Veteran Hires (16%), 

and Disabled Veteran Hires (7%). Though 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

37

Treasury did not meet its goals, nine 

bureaus exceeded the 7 percent hiring goal:

the Bureau of Engraving and Printing, 

Financial Crimes Enforcement Network, 

Bureau of Fiscal Service, IRS Chief 

Counsel, U.S. Mint, Office of the Inspector 

General, the Office of the Special Inspector 

General for the Troubled Asset Relief

Program, the Treasury Inspector General 

for Tax Administration and Alcohol and 

Tobacco Tax and Trade Bureau.

FY 2017 New Veteran Hires

The employment of veterans, including

disabled veterans, continued to be a focus 

of the Department’s Human Capital 

Advisory Council (HCAC). Treasury EEO, 

HR, D&I, and Talent and Engagement 

communities met on a quarterly basis to 

discuss strategies to support Veteran 

Employment Initiatives. The Department 

uses numerous strategies to support the 

recruitment, outreach, career development, 

and retention of its veterans, including:

 Hiring fairs hosted by agencies 

including the Department of 

Defense and the Maryland 

Department of Labor, programs 

including Operation Warfighter, 

Recruit Military, Hiring Heroes, and 

other events held at the state level.

 Partnerships with organizations such 

as the Department of Veteran 

Affairs (VA), VA hospitals, 

Department of Labor Employment 

Service, and private veterans’ 

assistance centers.

 Outreach to schools included 

partnering with Disability and 

Veteran student offices as well as 

the OCC Campus Recruitment 

Program, which targets potential 

employees for entry-level bank 

positions.

 The Non-Paid Work Experience 

Program and paid internship 

opportunities through the above 

programs were bolstered by 

partnering with specific military 

locations such as Fort Hood. 

 Other outreach resources include 

partnerships with Employee 

Resource Groups, community 

groups such as the Pan-Pacific 

American Leaders and Mentors, 

points of contact via e-mail and 

telephone for veteran applicants, 

online portals for Schedule A hiring, 

and targeted postings on social 

media. 

 Treasury Veterans Employee 

Resource Group (VERG) launched 

a three-year plan (FY 2017 – FY

2019) aligning its goals with 

Treasury’s Inclusive Diversity 

goals, including the requirements of 

the Disabled Veterans Affirmative 

Action Plan. Similarly, the IRS 

VEPO presented an overview of its 

services and DVAAP commitments 

to the Internal Revenue Service 

(IRS) veteran employee 

organization, Military Outreach for 

Service, during its semi-annual 

virtual training conference.

 VEPO maintains an external e-mail 

inbox to connect with disabled 

veterans to provide resume 

consultations to assist with their 

federal employment search at 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

38

Treasury and other agencies. In 

addition, bureaus participated in 

other fairs and recruitment 

activities. 

 The Internal Revenue Service (IRS) 

maintains an external e-mail inbox, 

veteran telephone hotline, and 

public career website to highlight 

opportunities. As the Department’s 

largest bureau, the IRS VEPO 

increases the Department’s outreach 

to veterans.

 A Veteran’s Focus newsletter is 

issued quarterly to the workforce 

highlighting veteran employees’ 

success stories. In addition, the 

newsletter is shared with veteran 

candidates providing tools and 

resources to assist with the federal 

hiring process.

The Department’s bureaus instituted 

collaborate efforts with the Selective 

Placement Program, Disability 

Employment Program Managers, Disability 

Management Offices, and Human Resource 

Practitioners. As a result, three out of 12 

bureaus saw an increase in their hiring 

goals from FY 2016 to FY 2017, even with 

the hiring freeze in effect. The Agency 

Human Capital Plan, FY 2014-2017 and 

Inclusive Diversity Strategic Plan, FY 

2017-2020, incorporated strategies outlined 

in Executive Order (E.O.) 13518. To ensure 

disabled veteran applicants are aware of 

potential job opportunities, vacancy 

announcements include a statement 

indicating that the vacancy is open to 30% 

or more disabled veterans. In FY 2017, the 

Department participated in 25 career fairs, 

increasing its participation rate from 20 

career fairs in FY 2016.

The Department mandates that all 9,016 

hiring managers and 1,697 human resources 

practitioners complete annual Veterans 

Employment Training (VET) and 

Uniformed Services Employment and 

Reemployment Rights Act (USERRA) 

Training. In FY17, 94% of hiring managers 

and 98% of human resource practitioners 

completed the VET, and USERRA training 

was completed by 96% of both groups. 

Bureaus provided additional ad-hoc training 

and tools, including webinars, online 

conferences, manager’s toolkit, veterans 

employment reference guide, and 

leadership briefings on veteran workforce 

participation.

FY 2017 Veteran Employment 

Performance Activity

Veterans in the 

workforce

Veteran New 

Hires

Disabled Veteran New 

Hires

BEP 31.20% 34.45% 15.13%

DO 15.28% 15.70% 6.61%

FinCEN 19.12% 47.06% 23.53%

FS 19.61% 18.75% 11.36%

IRS 9.22% 7.31% 4.15%

IRS-CC 10.85% 22.28% 9.33%

MINT 36.45% 41.18% 24.71%

OCC 8.06% 8.02% 4.20%

OIG 23.21% 26.67% 13.33%

SIGT 15.94% 19.35% 6.45%

TIGTA 17.07% 8.70% 8/70%

TTB 20.25% 17.86% 10.70%

External Civil Rights 

OCRD ensures the Treasury bureaus are in 

compliance with the external civil rights 

laws applicable to their federally conducted 

and assisted programs. Treasury’s 

nondiscrimination policy provides that 

individuals have equal opportunity to 

participate in, and receive benefits from, all 

programs or activities funded by the 

Department. To ensure compliance, OCRD 

develops policy and guidance, conducts 

civil rights compliance reviews of Treasury 

programs, provides oversight and technical 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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assistance, and offers training to the 

Treasury bureaus. OCRD also processes 

and investigates complaints from 

individuals alleging discrimination in 

Treasury conducted or assisted programs 

and activities. In addition to its Treasurywide responsibilities, OCRD also manages 

the external civil rights program for the 

Departmental Offices.

Programs offering federal financial 

assistance are defined as programs 

providing monetary or non-monetary 

assistance to a recipient to support a public 

purpose. Federal recipients are entities or 

organizations that receive federal financial 

assistance from the federal government. 

Federal financial assistance includes, but is 

not limited to, grants and loans of federal 

funds, donations of federal property, 

training, details of federal personnel, and 

any agreement, arrangement or other 

contract which has as one of its purposes 

the provision of assistance. A federally 

conducted program or activity is, in simple 

terms, is anything a federal agency does. 

Federally conducted programs include, but 

are not limited to, tax preparation services 

and tours of Treasury buildings.

OCRD has jurisdiction to process:

 Complaints alleging race, color or 

national origin discrimination in 

programs or activities receiving 

Treasury financial assistance may 

be filed pursuant to Title VI of the 

Civil Rights Act of 1964.

 Complaints alleging age 

discrimination in Treasury assisted 

programs may be filed pursuant to 

the Age Discrimination Act of 

1975.

 Complaints alleging sex 

discrimination in Treasury assisted 

educational programs may be filed 

pursuant to Title IX of the 

Education Amendments of 1972.

 Complaints alleging disability 

discrimination in programs or 

activities receiving financial 

assistance from, or conducted by the 

Department, may be filed pursuant 

to Section 504 of the Rehabilitation 

Act of 1973. 

 Complaints alleging denial of 

accessibility to electronic and 

information technology in use by 

the Department may be filed 

pursuant to Section 508 of the 

Rehabilitation Act.

In FY 2017, Treasury received 30

complaints of discrimination or inquiries 

pertaining to the external civil rights 

program, compared to 31 complaints and 

inquiries received during FY 2016. Of the 

external inquiries or complaints received 

during FY 2017, eleven complaints were 

determined to fall under the jurisdiction of 

the Department and were accepted for 

investigation. OCRD issued two findings of 

discrimination during FY 2017.

During FY 2017, OCRD continued the 

work of ensuring that Treasury regulations 

and policies are in place. The Department’s 

final rule implementing Title VI of the Civil 

Rights Act of 1964 became effective on 

January 12, 2017. OCRD continues to lead 

the Department’s work to fully implement 

Title VI. On January 3, 2017, the 

Department published a Notice of Proposed 

Rulemaking for its regulations 

implementing Section 504 of the 

Rehabilitation Act. The Department also

published its final rule implementing the 

Age Discrimination Act of 1975, which

became effective on November 13, 2017. 

OCRD continued to provide technical 

assistance to the bureaus including the IRS 

Civil Rights Unit (CRU). In FY 2017, 

OCRD conducted a Basic External Civil 

Rights Training for Treasury employees. 

The training covered requirements under 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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Title VI of the Civil Rights Act, Title IX of 

the Education Amendments Act of 1972, 

the Age Discrimination Act and Sections 

504 and 508 of the Rehabilitation Act of 

1973. In FY 2017, OCRD completed the 

first Department-wide compliance review 

under Title IX, and will begin the work to 

improve compliance as needed in FY 2018.

Accomplishments

The Department is proud of its 

accomplishments towards maintaining a 

model EEO program in FY 2017. The 

accomplishments below outline our many 

successes throughout the reporting period:

 Developed and issued Treasury’s 

Strategic Inclusive Diversity plan 

version 2.0. 

 Issued a Treasury LGBT and 

Gender Identity non-discrimination 

policy.

 Required bureaus to establish new

Diversity and Inclusion 

Implementation Plans and 

conducted reviews to ensure 

bureaus were meeting requirements 

outlined in the Department’s 

Diversity and Inclusion Plan 2.0 FY 

2017 - 2020.

 In collaboration with DASHR 

CHCO, developed an 

implementation plan for 

recommended strategies identified 

in the Treasury SES barrier analysis.

 Completed a gender pay gap 

analysis through a partnership with 

the Office of Microeconomic Policy 

following OPM’s guidance in its 

Detailed Analysis of Government 

wide Data on Gender Pay 

Difference for White Collar 

Employees (September 2014).

 Issued anti-discrimination policy 

statement for the new Secretary.

 Hosted 582 interns Departmentwide through various paid and nonpaid diversity internship programs, 

universities and colleges.

 Updated the Treasury and bureau 

specific RCLF’s which provide

more realistic benchmark 

comparators based on overall 

occupational workforce composition 

at Treasury and within each of its 

bureaus.

 Provided each bureau with an 

assessment of its FY 2016 barrier 

analysis submitted as part of the 

Annual MD-715 report submissions

 Conducted one-on-one Barrier 

Analysis Sessions with each bureau 

to determine where they were in the 

barrier analysis process on the 

employment of Hispanics as 

required by OPM and EEOC’s joint 

memorandum. Provided guidance 

and recommendations for continued 

analysis. 

 Published quarterly EEO and 

Veterans newsletters which 

provided Treasury’s EEO 

practitioners, managers and 

supervisors, as well as employees, 

with information on relevant 

complaint issues, workforce 

statistics and important upcoming 

agency events/activities. 

 Updated Disability Workforce data 

tables to ensure data reflected new 

disability codes and methodology 

required by OPM’s new SF-256 

which collects disability information 

from employees and applicants for 

employment

 Distributed bi-annual Treasury-wide 

dashboards to keep Bureau Heads 

and other Treasury leaders current 

on the state of Treasury’s workforce 

and progress in meeting the 

established FY 2017 disability and 

veteran hiring goals. 

 Hosted a screening and panel 

discussion of the film “Uniquely 

Nasty”. 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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 Hosted a dynamic webinar, 

Untangling the Web Between White 

Women and Women of Color. 

 Partnered with Dr. Zina Sutch, 

Director of Diversity and Inclusion 

at the Office of Personnel 

Management, to present a new style 

of seminar for the Department’s 

senior leaders. The new series, 

“Understanding, Harnessing, and 

Leveraging the Power of Diversity 

& Inclusion, was launched this 

summer by OPM, and Treasury was 

one of the first agencies to 

participate. 

 Launched Prism, a Treasury-wide 

Employee Resource Group focused 

on lesbian, gay, bisexual, 

transgender and queer 

(LGBTQ) employees and their 

allies.

 Participated in the 24th annual 

Federal Inter-Agency observance to 

honor the Days of Remembrance.

 Conducted three “Be a Champion 

Roadshows”, providing coaching 

for managers at TTB, Mint and IRS. 

 Developed a commemorative 

webpage to bring awareness to all 

Special Emphasis Program Heritage 

Months and activities.

 Exceeded the EEOC’s new FY 2018 

goal that 12 percent of all new 

permanent hires be PWD (13.3712

percent) and the sub goal that 2 

percent be PWTD (3.5 percent).

 Provided eight hours of refresher 

training to Treasury Shared 

Neutral’s current mediator cadre 

members.

 Offered two workforce webinar 

trainings: C3-Conflict Resolution 

Series was conducted by the 

Federal Mediation and Conciliation 

 

12 Participation rate for PWD includes those 

employees (1.37 percent) who do not wish to selfidentify their disability or severe health condition.

Service (FMCS) and featured 

experts renowned in their field 

discussing trends and strategies 

related to conflict resolution 

designed to help individuals better 

communicate and collaborate to 

create solutions. The second was 

Civil Treatment®: Building an 

Inclusive Workplace by Addressing 

Unconscious Bias, which address 

the effects of unconscious bias in 

the workplace -- what unconscious 

bias is and its potential ramifications 

to individuals and organizations.

 Provided 40 hours of new mediator 

training for 21 employees who 

applied to become part of the TSN 

mediator cadre. 

 Completed a total of 274 mediations 

and successfully resolved 114 

(45%) of these completed 

mediations.

 Transitioned the TSN Administrator 

functions from the IRS to the US 

Mint.

 Issued the final rule implementing 

Title VI of the Civil Rights Act of 

1964, effective on January 12, 2017.

 Published a Notice of Proposed 

Rulemaking for Treasury’s rules 

implementing Section 504 of the 

Rehabilitation Act of 1973 on 

January 3, 2017.

 Published Treasury’s final rule 

implementing the Age 

Discrimination Act of 1975, which

became effective on November 13, 

2017.

 Conducted Basic External Civil 

Rights Training for Treasury 

employees. The training covered 

requirements under Title VI of the 

Civil Rights Act, Title IX of the 

Education Amendments Act of 

1972, the Age Discrimination Act 

and Sections 504 and 508 of the 

Rehabilitation Act of 1973.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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 Completed a Treasury-wide Title IX 

compliance review.

 Conducted an accessibility review 

of the DO leased spaces at 1750 

Pennsylvania Avenue N.W.

 Hired an Equal Opportunity 

Specialist for the DO External Civil 

Rights Program.

 Drafted and submitted for internal 

comments the Treasury Title VI 

Guidance for Recipients.

 Reissued two civil rights complaint 

policies under the newly created 

Civil Rights and Diversity Issuance 

System.

 Began utilizing the Talent Portal 

located within OPM’s USAJobs 

portal for managing resumes for 

Veterans and PWD/PWTD. 

Planned Activities/Conclusion

The Office of Civil Rights and Diversity’s 

FY 2017 MD-715 Report outlines our 

successes in our equal opportunity 

programs and activities. The Department of 

Treasury is proud of its accomplishments in 

the areas of attracting and retaining an 

increasingly diverse workforce. However, 

we realize there is still much to be done to 

increase workforce diversity, specifically 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 we have the broadest group 

of diverse, well-qualified talent from which 

to recruit.

OCRD’s FY 2018 planned activities 

include the following:

 In collaboration with DASHR

CHCO, complete the 

implementation plan for 

recommended strategies identified 

in the Treasury SES barrier analysis.

 Establish a Treasury-wide working 

group to finalize the statement of 

work and amendment to the 

reasonable accommodation policy to 

include provisions for providing 

personal assistant services.

 Create new workforce data tables as 

required by the implementation of 

the EEOC’s MD-715 Version 2 to 

be fully implemented in FY 2018 

reporting period.

 Once funding is available, continue 

to develop automated prototype 

diversity dashboards with CIO that 

will provide key performance 

indicators around diversity in the 

workforce for Treasury managers.

 Continue to monitor the bureau 

plans to identify the existence of 

barriers to the employment of any 

group and strategies to eliminate 

any barriers that are uncovered.

 Continue to closely monitor the 

Treasury Complaint Management 

System to ensure continued 

improvement in the timely 

production of Final Agency 

Decisions and EEO investigations.

 Continue to conduct the “Be a 

Champion” Roadshow.

 Ensure the 21 new TSN mediator 

trainees meet their observation and 

co-mediation requirements.

 Provide at least one dispute 

prevention activity for the 

Department.

 Provide one refresher training for 

current TSN mediators.

 Provide Micro-Trigger training

session to the Philadelphia Mint 

leadership and employees. 

 Issue final rule implementing 

Section 504 of the Rehabilitation 

Act of 1973 to Treasury assisted 

programs (31 CFR Part 40).

 Discuss with the DO program 

offices the establishment of a preaward compliance review process 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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and develop an implementation 

plan.

 Clear the draft Treasury Title VI 

Guidance for Recipients internally 

and submit to DOJ for approval.

 Develop a five year External Civil 

Rights Strategic Plan for the 

Treasury-wide and DO programs.

 Publish in the Federal Register an 

updated list of Treasury Title IX 

covered programs.

 Provide guidance to the Treasury 

bureaus about Title IX compliance 

requirements they need to 

implement.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART F: Certification of 

Establishment of Continuing 

EEO Programs
45
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART G: Agency 

Self-Assessment
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART G - Essential Element A, Demonstrated Commitment from Agency Leadership

Element A requires the agency head to issue written policy statements ensuring a workplace 

free of discriminatory harassment and a commitment to equal employment opportunity.

PART G, Essential Element A, Section 1 - Issuance of EEO Policy Statement Indicator

Measures Measure 

Met? Comments

A.1.a. Was EEO policy statement issued within 6 - 9 months 

of installation of Agency Head? (Please list date of agency 

head installation and date of issuance in the comments 

column.)

Yes

Installed: 

February 13, 2017

Issued: May 31, 

2017.

A.1.b. During current Agency Head's tenure, has EEO policy 

statement been re-issued annually? N/A

Not due for reissue until May 

2018.

A.1.c. Are new employees provided a copy of the EEO 

policy statement during orientation? Yes

A.1.d. When an employee is promoted into the supervisory 

ranks, is s/he provided a copy of the EEO policy statement? Yes

PART G, Essential Element A, Section 2 - Communication of EEO Policy Statements Indicator

Measures Measure 

Met? Comments

A.2.a. Have the Heads of subordinate reporting components 

communicated support of all agency EEO policies through the 

ranks?

Yes

A.2.b. Has the agency made written materials available to all 

employees and applicants, informing them of the variety of 

EEO programs and administrative and judicial remedial 

procedures available to them?

Yes

A.2.c. Has the agency prominently posted such written 

materials in all personnel and EEO offices, and on the agency's 

internal website? [29 CFR 1614.102(b)(5)]

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART G, Essential Element A, Section 3 - Evaluation of Managers and Supervisors on Their 

Commitment to EEO Principles Indicator

Measures Measure 

Met? Comments

A.3.a. Are managers and supervisors evaluated on their commitment 

to agency EEO policies and principles? Yes

A.3.b. Are managers and supervisors evaluated on their commitment 

to resolve problems/disagreements and other conflicts in their 

respective work environments as they arise?

Yes

A.3.c. Are managers and supervisors evaluated on their commitment 

to address concerns, whether perceived or real, raised by employees 

and following up with appropriate action to correct or eliminate 

tension in the workplace?

Yes

A.3.d. Are managers and supervisors evaluated on their commitment 

to support the agency's EEO program through allocation of mission 

personnel to participate in community out-reach and recruitment 

programs with private employers, public schools and universities?

Yes

A.3.e. Are managers and supervisors evaluated on their commitment 

to ensure full cooperation of employees under his/her supervision 

with EEO office officials such as EEO counselors, EEO 

investigators, etc.?

Yes

A.3.f. Are managers and supervisors evaluated on their commitment 

to ensure a workplace that is free from all forms of discrimination, 

harassment and retaliation?

Yes

A.3.g. Are managers and supervisors evaluated on their commitment 

to ensure that subordinate supervisors have effective managerial 

communication and interpersonal skills in order to supervise most 

effectively in a workplace with diverse employees and avoid 

disputes arising from ineffective communications?

Yes

A.3.h. Are managers and supervisors evaluated on their commitment 

to ensure the provision of requested religious accommodations when 

such accommodations do not cause an undue hardship?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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A.3.i. Are managers and supervisors evaluated on their 

commitment to ensure the provision of requested disability 

accommodations to qualified individuals with disabilities when 

such accommodations do not cause an undue hardship?

Yes

A.3.j. Have all employees been informed about what behaviors 

are inappropriate in the workplace and that this behavior may 

result in disciplinary actions? If yes, describe what means were 

utilized by the agency to inform its workforce about penalties 

for unacceptable behavior in the comments column.

Yes

A.3.k. Have the procedures for reasonable accommodation for 

individuals with disabilities been made readily 

available/accessible to all employees by disseminating such 

procedures during orientation of new employees and by making 

such procedure available on the World Wide Web or Internet?

Yes

A.3.l. Have managers and supervisors been trained on their 

responsibilities under the procedures for reasonable 

accommodation?

Yes

PART G - Essential Element B, Integration of EEO into the Agency's Strategic Mission

Element B requires that the agency's EEO programs be organized and structured to maintain a 

workplace that is free from discrimination in any of the agency's policies, procedures or 

practices and supports the agency's strategic mission.

PART G, Essential Element B, Section 1 - Reporting Structure for EEO Program Indicator

Measures Measure 

Met? Comments

B.1.a. Is the EEO Director under the direct supervision of 

the Agency Head? [See 29 CFR 1614.102(b)(4)]

Yes

B.1.b. For subordinate level reporting components, is the 

EEO Director/Officer under the immediate supervision of 

the lower level component's head official? (For example, 

does the Regional EEO Officer report to the Regional 

Administrator?)

Yes BEP and Mint

corrected the 

deficiency in FY 

2017.

B.1.c. Are the duties and responsibilities of the EEO 

officials clearly defined?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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B.1.d. Do the EEO officials have the knowledge, skills, and 

abilities to carry out the duties and responsibilities of their 

positions?

Yes

B.1.e. If the agency has 2nd level reporting components, are 

there organizational charts that clearly define the reporting 

structure for EEO programs? (If yes, attach them to this report.)

Yes

B.1.f. If the agency has 2nd level reporting components, does 

the agency-wide EEO Director have authority for EEO 

programs within the subordinate reporting components? (If no, 

please describe how EEO program authority is delegated to 

subordinate reporting components, in Part H.) 

No

Each Treasury 

bureau has its 

own distinct 

reporting 

structure for its 

EEO programs. 

However, the 

Director of 

OCRD has 

oversight 

authority as well 

as input into their 

annual 

performance 

rating. 

PART G, Essential Element B, Section 2 - EEO Communication with Senior Leaders Indicator

Measures Measure 

Met? Comments

B.2.a. Does the EEO Director/Officer have a regular, effective 

means of informing the Agency Head and other top 

management of the effectiveness, efficiency, and legal 

compliance of the agency's EEO program?

Yes

B.2.b. After submission of the previous Form 715, did the EEO 

Director/Officer present a State of the Agency briefing to the 

Agency Head and other senior officials, including a 

performance assessment in each of the 6 elements of the Model 

EEO program, and report agency progress in completing its 

barrier analysis - including barriers identified, eliminated, or 

impact reduced?

Yes January 

2017
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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B.2.c. Are EEO officials present during agency pre-decisional 

deliberations regarding recruitment strategies, vacancy 

projections, succession planning, selections for training/career 

development opportunities, and other workforce changes?

Yes

B.2.d. 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 

re-alignments?

Yes

B.2.e. Are management/personnel policies, procedures and 

practices examined at regular intervals to assess whether there 

are any hidden impediments to the realization of equality of 

opportunity for any group(s) of employees or applicants? [See 

29 C.F.R. 1614.102(b)(3)]

Yes

B.2.f. Is the EEO Director included in the agency's strategic 

planning, especially the agency's human capital plan, regarding 

succession planning, training, etc., to ensure that EEO concerns 

are integrated into the agency's strategic mission?

Yes

PART G, Essential Element B, Section 3 - Sufficient EEO Program Staffing Indicator

Measures Measure 

Met? Comments

B.3.a. Does the EEO Director have the authority and funding to 

ensure implementation of agency EEO action plans to improve 

EEO program efficiency and/or eliminate identified barriers to 

the realization of equality of opportunity?

Yes

.

B.3.b. Are sufficient personnel resources allocated to the EEO 

Program to ensure that agency self-assessments and selfanalyses prescribed by EEO MD-715 are conducted annually 

and to maintain an effective complaint processing system?

Yes

B.3.c. Are statutory/regulatory EEO related Special Emphasis 

Programs sufficiently staffed?

Yes

B.3.d. Is the Federal Women's Program sufficiently staffed - 5 

U.S.C. 7201; 38 U.S.C. 4214; Title 5 CFR, Subpart B, 720.204?

Yes

B.3.e. Is the Hispanic Employment Program sufficiently staffed 

- Title 5 CFR, Subpart B, 720.204?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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B.3.f. Is the People With Disabilities Program Manager; 

Selective Placement Program for Individuals With Disabilities 

sufficiently staffed - Section 501 of the Rehabilitation Act; Title 

5 U.S.C. Subpart B, Chapter 31, Subchapter I-3102: 5 CFR 

213.3102(u); 5 CFR 315.709?

Yes

B.3.g. Are other agency Special Emphasis Programs monitored 

by the EEO Office for coordination and compliance with EEO 

guidelines and principles, such as: FEORP - 5 CFR 720; 

Veterans Employment Programs; Black/African American; 

American Indian/Alaska Native; Asian; and Native 

Hawaiian/Other Pacific Islander Programs?

Yes

PART G, Essential Element B, Section 4 - Sufficient EEO Program Funding Indicator

Measures Measure 

Met? Comments

B.4.a. Are there sufficient resources to enable the agency to

conduct a thorough barrier analysis of its workforce, 

including the provision of adequate data collection and 

tracking systems?

Yes

B.4.b. Is there sufficient budget allocated to all employees to 

utilize, when desired, all EEO programs, including the 

complaint processing program and ADR, and to make a 

request for reasonable accommodation? (Including 

subordinate level reporting components?)

Yes

B.4.c. Has funding been secured for publication and 

distribution of EEO materials (e.g. harassment policies, EEO 

posters, reasonable accommodations procedures, etc.)?

Yes

B.4.d. Is there a central funding or other mechanism for 

funding supplies, equipment and services necessary to 

provide disability accommodations?

No

Each bureau is 

responsible for 

funding disability 

accommodations

requests. However,

OCC and FinCEN 

have implemented a 

centralized fund for 

all accommodations

and DO has 

implemented a 

centralized fund for 

providing interpreter

services.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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B.4.e. Does the agency fund major renovation projects to ensure 

timely compliance with Uniform Federal Accessibility Standards? Yes

B.4.f. Is the EEO Program allocated sufficient resources to train all 

employees on EEO Programs, including administrative and judicial 

remedial procedures available to employees?

Yes

B.4.g. Is there sufficient funding to ensure the prominent posting of 

written materials in all personnel and EEO offices? [See 29 CFR 

1614.102(b)(5)}

Yes

B.4.h. Is there sufficient funding to ensure that all employees have 

access to the training and information identified in B.4.f?

Yes

B.4.i. Is there sufficient funding to provide all managers/supervisors 

with training and periodic up-dates on their EEO responsibilities for 

ensuring a workplace that is free from all forms of discrimination, 

including harassment and retaliation?

Yes

B.4.j. Is there sufficient funding to provide all managers/supervisors 

with training and periodic up-dates on their EEO responsibilities to 

provide religious accommodations?

Yes

B.4.k. Is there sufficient funding to provide all managers/supervisors 

with training and periodic up-dates on their EEO responsibilities to 

provide disability accommodations in accordance with the agency's 

written procedures?

Yes

B.4.l. Is there sufficient funding to provide all managers/supervisors 

with training and periodic up-dates on their EEO responsibilities in the 

EEO discrimination complaint process?

Yes

B.4.m. Is there sufficient funding to provide all managers/supervisors 

with training and periodic up-dates on their EEO responsibilities to 

participate in ADR?

Yes

PART G - Essential Element C, Management and Program Accountability

Element C 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.

PART G, Essential Element C, Section 1 - EEO Communication with Managers & Supervisors 

Indicator

Measures Measure 

Met? Comments

C.1.a. Are regular (monthly/quarterly/semi-annually) EEO updates 

provided to management/supervisory officials by EEO program 

officials?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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C.1.b. Do EEO program officials coordinate the development and 

implementation of EEO Plans with all appropriate agency managers 

to include Agency Counsel, Human Resource Officials, Finance, 

and the Chief Information Officer?

Yes

PART G, Essential Element C, Section 2 - EEO & Human Resources Collaboration & 

Coordination Indicator

Measures Measure 

Met? Comments

C.2.a. Have time-tables or schedules been established for the agency 

to review its Merit Promotion Program Policy and Procedures for 

systemic barriers that may be impeding full participation in 

promotion opportunities by all groups?

Yes

C.2.b. Have time-tables or schedules been established for the 

agency to review its Employee Recognition Awards Program and

Procedures for systemic barriers that may be impeding full 

participation in promotion opportunities by all groups?

Yes

C.2.c. Have time-tables or schedules been established for the agency 

to review its Employee Development/Training Programs for 

systemic barriers that may be impeding full participation in training 

opportunities by all groups?

Yes

PART G, Essential Element C, Section 3 - Disciplinary Action Taken Indicator

Measures Measures 

Met? Comments

C.3.a. Does the agency have a disciplinary policy and/or a table of 

penalties that covers employees found to have committed 

discrimination?

Yes

C.3.b. Have all employees, supervisors, and managers been 

informed as to the penalties for being found to perpetrate 

discriminatory behavior or for taking personnel actions based upon 

a prohibited basis?

Yes

C.3.c. Has the agency, when appropriate, disciplined or sanctioned 

managers/supervisors or employees found to have discriminated 

over the past two years? If yes, in the Comment column, cite the 

number found to have discriminated and list penalty/disciplinary 

action for each type violation.

Yes

See below
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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FY 2016: The Department of the Treasury had nine (9) findings of discrimination, six (6) of 

which were FAD’s. The seventh and eighth were OFO decisions; and the ninth was an 

EEOC Administrative Judge’s decision which was implemented.

FAD’s: (1) disability discrimination for failure to provide reasonable accommodation –

training on the Rehabilitation Act for managers was ordered and was provided; consideration 

of discipline was not ordered; (2) disability discrimination and reprisal for non-selection of 

former bureau employee – training on EEO law with emphasis on disability discrimination 

and reprisal, and consideration of discipline for manager, were ordered; training was 

provided; discipline was considered but found not to be warranted; (3) hostile work 

environment based on gender (LGBT) - training for managers on EEO law with emphasis on 

prohibition of gender discrimination, and consideration of discipline for manager and coworkers, were ordered; training was provided; disciplinary action was considered but found 

not to be warranted; (4) per se reprisal for manager’s comments that could reasonably deter 

an employee from pursuing the EEO process – training on EEO law and the rights of 

employees to express opposition to discrimination and file EEO complaints, and 

consideration of disciplinary action for manager, were ordered but were not provided because 

manager was no longer employed at the time of finding; (5) hostile work environment based 

on sex - no training or consideration of discipline was ordered because the responsible 

management official was no longer employed by the bureau at time of finding; and (6) 

failure to approve religious compensatory time based on religion and national origin; training 

on EEO law with emphasis on prohibition of religious discrimination, and consideration of 

disciplinary action for managers, were ordered - training was provided; disciplinary action 

was considered but found not to be warranted.

OFO Decision: age and race discrimination for failure to select for trainee position – training 

on the ADEA and Title VII for managers, and consideration of discipline, were ordered; 

training on the ADEA and Title VII was provided for one manager, and disciplinary action 

was considered but found not to be warranted; the other manager had retired prior to OFO’s 

finding of discrimination.

OFO Decision: disability and reprisal discrimination for failure to provide reasonable 

accommodation and deterring complainant from requesting reasonable accommodation –

training on reasonable accommodation for involved supervisor, EEO official, and others, and 

consideration of disciplinary action, were ordered; training was provided; disciplinary action 

was not taken because the EEO official upon whose advice other managers relied had retired 

by time of finding.

Final Order on EEOC Administrative Judge’s Decision (judgment without a hearing):

disability discrimination for failure to provide reasonable accommodation for intern –

training on ADA for manager, and consideration of disciplinary action, were ordered; training 

was provided; upper management determined that no disciplinary action would be taken 

because the manager believed he was following the appropriate policy.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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FY 2017: The Department of the Treasury had eleven (11) findings of discrimination, six (6) 

of which were FAD’s. The seventh, eighth and ninth were OFO decisions; and the tenth and 

eleventh were EEOC Administrative Judges’ decisions which were implemented.

FAD’s: (1) discrimination based on sex (female) when complainant was sexually harassed 

by a co-worker and management failed to take prompt and appropriate action, and per se

retaliation when a manager asked her to put the EEO process on hold while management 

determined whether a suggested resolution was successful – training on EEO law with 

emphasis on sex discrimination and reprisal was ordered and was provided; (2) disability 

discrimination for failure to provide reasonable accommodation; training was ordered for all 

responsible management officials in office where complainant worked; training is pending; 

(3) disability discrimination for denial of reasonable accommodation and termination for 

missing too much time from work during probationary period; training and disciplinary 

action were ordered; training was provided; disciplinary action is pending; (4) disability 

discrimination for unnecessary delay in providing operable adaptive equipment, which had 

been approved pursuant to request for reasonable accommodation; it was determined that 

management acted in good faith in attempting to provide effective accommodation; (5) 

disability discrimination for failure to provide reasonable accommodation in line with 

complainant’s physician’s recommendation or even act on her request for reasonable 

accommodation until the EEO complaint was filed; training on the responsibilities of 

management under the Rehabilitation Act was ordered and was provided; disciplinary action 

was not ordered because the individual who was primarily responsible for processing the 

original reasonable accommodation request was no longer employed with the Agency; (6) 

discrimination based on sex (female) when complainant was sexually harassed by male 

co-worker and management failed to take prompt and appropriate action; training and 

disciplinary action were ordered; both are pending; (7) hostile work environment based on 

disability and reprisal when, among other things, complainant was denied reasonable 

accommodation and issued a counseling memorandum; training and consideration of 

disciplinary action were ordered; training was provided; disciplinary action was considered 

but found not to be warranted; (8) disability discrimination for delay in providing reasonable 

accommodation; training and consideration of disciplinary action were ordered; training was 

provided; decision on disciplinary action is pending; (9) disability discrimination for failure 

to provide reasonable accommodation and failure to maintain confidential medical 

information in separate medical file; training and consideration of disciplinary action were 

ordered; training was provided and oral counseling was administered to four management 

officials; and (10) improper disclosure of medical information in violation of the 

Rehabilitation Act; training was ordered and is pending; and (11) improper storage of 

medical information in violation of the Rehabilitation Act; no training or consideration of 

discipline was ordered.

C.3.d. Does the agency promptly (within the established time 

frame) comply with EEOC, Merit Systems Protection Board, 

Federal Labor Relations Authority, labor arbitrators, and 

District Court orders?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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C.3.e. Does the agency review disability accommodation 

decisions/actions to ensure compliance with its written 

procedures and analyze the information tracked for trends, 

problem, etc.?

Yes

PART G - Essential Element D, Proactive Prevention of Unlawful Discrimination

Element D requires that the Agency Head makes early efforts to prevent discriminatory actions 

and eliminate barriers to Equal Employment Opportunity in the workplace.

PART G, Essential Element D, Section 1 - Barrier Analysis Process Indicator

Measures Measure 

Met? Comments

D.1.a. Do senior managers meet with and assist the EEO 

Director and/or other EEO Program Officials in the 

identification of barriers that may be impeding the realization 

of equal employment opportunity?

Yes

D.1.b. When barriers are identified, do senior managers 

develop and implement, with the assistance of the agency 

EEO office, agency EEO Action Plans to eliminate said 

barriers?

Yes

D.1.c. Do senior managers successfully implement EEO 

Action Plans and incorporate the EEO Action Plan 

Objectives into agency strategic plans?

Yes

D.1.d. Are trend analyses of workforce profiles conducted by 

race, national origin, sex, and disability?

Yes

D.1.e. Are trend analyses of the workforce's major 

occupations conducted by race, national origin, sex, and 

disability?

Yes

D.1.f. Are trend analyses of the workforce's grade level 

distribution conducted by race, national origin, sex, and 

disability?

Yes

D.1.g. Are trend analyses of the workforce's compensation 

and reward system conducted by race, national origin, sex, 

and disability?

Yes

D.1.h. Are trend analyses of the effects of 

management/personnel policies, procedures and practices 

conducted by race, national origin, sex, and disability?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART G, Essential Element D, Section 2 - Alternative Dispute Resolution (ADR) is Encouraged 

Indicator

Measures Measures 

Met? Comments

D.2.a. Are all employees encouraged to use ADR? Yes

D.2.b. Is the participation of supervisors and managers in the 

ADR process required?

Yes

PART G - Essential Element E, Efficiency

Element E requires that the Agency Head ensure that there are effective systems in place for 

evaluating the impact and effectiveness of the agency's EEO programs as well as an efficient 

and fair dispute resolution process.

PART G, Essential Element E, Section 1 - Sufficient Resources to Evaluation EEO Program 

Indicator

Measures Measure 

Met? Comments

E.1.a. Does the EEO office employ personnel with adequate 

training and experience to conduct the analyses required by MD715 and these instructions?

Yes

E.1.b. Has the agency implemented an adequate data collection 

and analysis systems that permit tracking of the information 

required by MD-715 and these instructions?

Yes

E.1.c. Have sufficient resources been provided to conduct 

effective audits of field facilities' efforts to achieve a model EEO 

program and eliminate discrimination under Title VII and the 

Rehabilitation Act?

Yes

E.1.d. Is there a designated agency official or other mechanism 

in place to coordinate or assist with processing requests for 

disability accommodations in all major components of the 

agency?

Yes

E.1.e. Are 90 percent of accommodation requests processed 

within the time frame set forth in the agency's procedures for 

reasonable accommodation?

No OCC and IRS 

both reported 

no. See Bureau 

PART H’s

outlining plans 

to correct 

untimely 

processing.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART G, Essential Element E, Section 2 - Effective Complaint Tracking and Monitoring System 

Indicator

Measures Measure 

Met? Comments

E.2.a. Does the agency use a complaint tracking and monitoring 

system that allows identification of the location and status of 

complaints and length of time elapsed at each stage of the 

agency's complaint resolution process?

Yes

E.2.b. Does the agency's tracking system identify the issues and 

bases of the complaints, the aggrieved individuals/complainants, 

the involved management officials and other information to 

analyze complaint activity and trends? 

Yes

E.2.c. Does the agency hold contractors accountable for delay in 

counseling and investigation processing times? If yes, in the 

comments column, briefly describe how.

Yes

E.2.d. Does the agency monitor and ensure that new 

investigators, counselors, including contract and collateral duty 

investigators, receive the 32 hours of training required in 

accordance with EEO Management Directive MD-110?

Yes

E.2.e. Does the agency monitor and ensure that experienced 

counselors, investigators, including contract and collateral duty 

investigators, receive the 8 hours of refresher training required 

on an annual basis in accordance with EEO Management 

Directive MD-110?

Yes

PART G, Essential Element E, Section 3 - Timeliness in EEO Complaint Process Indicator

Measures Measure 

Met? Comments

E.3.a. Are benchmarks in place that compares the agency's 

discrimination complaint processes with 29 CFR Part 1614?

Yes

E.3.b. Does the agency provide timely EEO counseling within 

30 days of the initial request or within an agreed upon extension 

in writing, up to 60 days?

No FS, IRS-CC 

and DO 

reported no. 

See Bureau 

PART H’s for 

plans to correct 

deficiency.

E.3.c. Does the agency provide an aggrieved person with written 

notification of his/her rights and responsibilities in the EEO 

process in a timely fashion?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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E.3.d. Does the agency complete the investigations within the 

applicable prescribed time frame?

Yes Treasury PART 

H closed in FY 

2017.

E.3.e. When a complainant requests a final agency decision; 

does the agency issue the decision within 60 days of the 

request?

Yes

E.3.f. When a complainant requests a hearing, does the 

agency immediately upon receipt of the request from the 

EEOC AJ forward the investigative file to the EEOC Hearing 

Office?

Yes

E.3.g. When a settlement agreement is entered into, does the 

agency timely complete any obligations provided for in such 

agreements?

Yes

E.3.h. Does the agency ensure timely compliance with EEOC 

AJ decisions which are not the subject of an appeal by the 

agency?

Yes

PART G, Essential Element E, Section 4 - Efficient and Fair ADR Process Indicator

Measures Measure 

Met? Comments

E.4.a. In accordance with 29 CFR 1614.102(b), has the 

agency established an ADR Program during the precomplaint and formal complaint stages of the EEO process?

Yes

E.4.b. Does the agency require all managers and supervisors 

to receive ADR training in accordance with EEOC (29 CFR 

Part 1614) regulations, with emphasis on the federal 

government's interest in encouraging mutual resolution of 

disputes and the benefits associated with utilizing ADR? 

Yes

E.4.c. Does the responsible management official directly 

involved in the dispute have settlement authority?

Yes

PART G, Essential Element E, Section 5 - Effectiveness of EEO Data Collection Systems 

Indicator

Measures Measure 

Met? Comments

E.5.a. Does the agency have a system of management 

controls in place to ensure the timely, accurate, complete and 

consistent reporting of EEO complaint data to the EEOC?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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E.5.b. Does the agency provide reasonable resources for the 

EEO complaint process to ensure efficient and successful 

operation in accordance with 29 CFR 1614.102(a)(1)?

Yes

E.5.c. Does the agency EEO office have management 

controls in place to monitor and ensure that the data received 

from Human Resources is accurate, timely received, and 

contains all of the required data elements for submitting 

annual reports to the EEOC?

Yes

E.5.d. Do the agency's EEO programs address all of the laws 

enforced by the EEOC?

Yes

E.5.e. Does the agency identify and monitor significant trends 

in complaint processing to determine whether the agency is 

meeting its obligations under Title VII and the Rehabilitation 

Act?

Yes

E.5.f. Does the agency track recruitment efforts and analyze 

efforts to identify potential barriers in accordance with MD715 standards?Yes

E.5.g. Does the agency consult with other agencies of similar 

size on the effectiveness of their EEO programs to identify 

best practices and share ideas?

Yes

PART G, Essential Element E, Section 6 - Elimination of Conflict of Interest with Legal Defense 

Function Indicator

Measures Measure 

Met? Comments

E.6.a. Are legal sufficiency reviews of EEO matters handled 

by a functional unit that is separate and apart from the unit 

which handles agency representation in EEO complaints?

Yes

E.6.b. Does the agency discrimination complaint process 

ensure a neutral adjudication function?

Yes

E.6.c. If applicable, are processing time frames incorporated 

for the legal counsel's sufficiency review for timely 

processing of complaints?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART G - Essential Element F, Responsiveness and Legal Compliance

Element F requires that federal Agencies are in full compliance with EEO statutes and EEOC 

regulations, policy guidance, and other written instructions.

PART G, Essential Element F, Section 1 - Timely Compliance With Administrative Judge Orders 

Indicator

Measure

Measure 

Met? Comments

F.1.a. Does the agency have a system of management control 

to ensure that the agency officials timely comply with any 

orders or directives issued by EEOC Administrative Judges?

Yes

PART G, Essential Element F, Section 2 - Timely Completion of Ordered Corrective Action 

Indicator

Measures Measure 

Met? Comments

F.2.a. Does the agency have control over the payroll 

processing function of the agency? If yes, answer the two 

questions below.

Yes

F.2.b. Are there steps in place to guarantee responsive, timely, 

and predictable processing of ordered monetary relief?

Yes

F.2.c. Are procedures in place to promptly process other 

forms of ordered relief?

Yes

PART G, Essential Element F, Section 3 - Staff Accountability for Legal Compliance Indicator

Measures Measure 

Met? Comments

F.3.a. Is compliance with EEOC orders encompassed in the 

performance standards of any agency employees? If yes, 

please identify the employees by title in the comments 

column, and state how performance is measured.

Yes An OCRD EEO 

Specialist has 

standard

Performance 

Commitment to 

ensure 

compliance 

with the 

Department’s 

and the EEOC’s

orders.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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F.3.b. Is the unit charged with the responsibility for 

compliance with EEOC orders located in the EEO office? If 

no, please identify the unit in which it is located in the 

comments column.

Yes

F.3.c. Have the involved employees received any formal 

training in EEO compliance?

Yes

F.3.d. Does the agency promptly provide the EEOC Attorney 

Fee documentation for completing compliance, such as a copy 

of the check issued for attorney fees and/or a narrative 

statement by an appropriate agency official, or agency 

payment order dating the dollar amount of attorney fees paid?

Yes

F.3.e. Does the agency promptly provide the EEOC awards 

documentation for completing compliance, such as a narrative 

statement by an appropriate agency official stating the dollar 

amount and the criteria used to calculate the award?

Yes

F.3.f. Does the agency promptly provide the EEOC 

documentation of back pay and interest for completing 

compliance, such as computer print-outs or payroll documents 

outlining gross back pay and interest, copy of any checks 

issued, or narrative statement by an appropriate agency official 

of total monies paid?

Yes

F.3.g. Does the agency promptly provide the EEOC 

documentation regarding compensatory damages for 

completing compliance, such as the final agency decision and 

evidence of payment, if made?

Yes

F.3.h. Does the agency promptly provide the EEOC training 

documentation for completing compliance, such as the 

attendance roster at training session(s), or a narrative statement 

by an appropriate agency official confirming that specific 

persons or groups of persons attended training on a certain 

date?

Yes

F.3.i. Does the agency promptly provide the EEOC personnel 

action documentation for completing compliance (e.g., 

reinstatement, promotion, hiring, reassignment), such as copies 

of SF-50s?

Yes

F.3.j. Does the agency promptly provide the EEOC 

documentation of the posting of Notice of Violation for 

completing compliance, such as the original, signed and dated 

notice, reflecting the dates of posting? (A copy will suffice if 

original is not available.)

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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F.3.k. Does the agency promptly provide the EEOC 

documentation of supplemental investigation, such as: (1) a 

copy of the letter to complainant acknowledging receipt from 

EEOC of remanded case; (2) a copy of the letter to 

complainant transmitting the Report of Investigation (not the 

ROI itself, unless specified); and (3) a copy of the request for a 

hearing (complainant's request or agency's transmittal letter)?

Yes

F.3.l. Does the agency promptly provide the EEOC the Final 

Agency Decision (FAD), such as the FAD or a copy of the 

complainant's request for a hearing?

Yes

F.3.m. Does the agency promptly provide the EEOC 

documentation of restoration of leave, such as a print-out or 

statement identifying the amount of leave restored, if 

applicable? If no, provide an explanation or statement in the 

comments column.

Yes

F.3.n. Does the agency promptly provide the EEOC 

documentation of civil actions, such as a complete copy of the 

civil action complaint demonstrating same issues raised as in 

compliance matter?

Yes

F.3.o. Does the agency promptly provide the EEOC settlement 

agreements, such as the signed and dated agreement with 

specific dollar amounts, and appropriate documentation of 

relief provided?

Yes
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PART H: Attaining the Essential 

Elements of a Model 

EEO Program
Office of Civil Rights and Diversity FY 2017 MD-715 Report

66

EEOC FORM

715-01 

PART H

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

Department of the 

Treasury 

For period covering October 1, 2013 to September 30, 2014

STATEMENT of 

MODEL PROGRAM 

ESSENTIAL ELEMENT 

DEFICIENCY:

Timeliness of Treasury Complaint Center (TCC) investigations completed.

In its MD-715 reports for FY 2006-2011, the Department included a 

“PART H, Essential Element E: Efficiency – Timeliness of Treasury 

Complaint Center (TCC) investigations completed,” which was designated 

as PART H-7. That PART H was closed in FY 2010 as a result of process 

improvements which continuously raised the percentage of timely 

completed investigations from a low of 20 percent (2006) to 81 percent in 

FY 2010, reaching 95 percent in FY 2011. In FY 2013, the Department’s

timely completed investigations rate fell to 65 percent and the 

Department therefore has been taking steps to eliminate this deficiency.

At the start of FY 2015 (as of October 1, 2014), the Office of Civil Rights 

and Diversity (OCRD) assumed responsibility for processing all newly filed 

formal complaints; the former Treasury Complaint Center (TCC) was 

responsible for processing formal complaints filed through September 30, 

2014. The TCC wound down operations as processing was completed and 

closed in the summer of 2015. Accordingly, the Statement of Model 

Program Essential Element Deficiency has been updated to remove the 

reference to TCC. 

OBJECTIVE: To complete investigations within the applicable timeframes.

RESPONSIBLE OFFICIAL: Amelia Demopulos, Complaints Manager, OCRD 

DATE OBJECTIVE 

INITIATED:

06/30/2013

TARGET DATE FOR 

COMPLETION OF 

OBJECTIVE:

09/30/2014 Revised completion date September 30, 2017.

PLANNED ACTIVITIES TOWARD COMPLETION OF OBJECTIVE:

Evaluate and analyze timeframes and overall process

TARGET DATE: 06/28/2013 Completed

Provide training to TCC Investigators.

TARGET DATE: 04/30/2013 Completed

Make recommendations to increase compliance within the prescribed timeframes. 

TARGET DATE: 07/31/2013 Completed

Monitor accomplishments of recommendations to assess progress. 

TARGET DATE: 09/30/2014 Completed
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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PLANNED ACTIVITIES TOWARD COMPLETION OF OBJECTIVE CONTINUED:

Eliminate the overage case inventory.

TARGET DATE: 09/30/2014 Modified: 09/30/2015 Completed

Designate new Acting TCC Director; end prior detail of the Operations Director and return to TCC role.

TARGET DATE: 12/31/2013 Completed

Reassign responsibility for issuing acceptances and dismissals from the TCC to the Office of Civil Rights 

and Diversity (OCRD), allowing additional TCC staff to focus on completing investigations.

TARGET DATE: 12/31/2013 Completed

Closely monitor Investigator progress in completing each investigation; require weekly status updates of 

each investigation. 

TARGET DATE: 09/30/2014 Completed

Weekly meeting of TCC and OCRD management to review weekly status updates and identify areas for 

improvement. 

TARGET DATE: 09/30/2014 Completed

Determine whether TCC structure should be redesigned.

TARGET DATE: 09/30/2014 Completed

Continued focus on improving the timeliness of investigations with the goal of ensuring that 85% are

completed timely.

TARGET DATE: 09/30/2017 Completed

Initiate process of directly download investigative reports from the “cloud” that USPS offers to its clients.

TARGET DATE: 09/30/2017 Completed

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE:

FY 2014 Accomplishments:

OCRD successfully completed all FY 2014 plans outlined in the PART H; however, while the overage case 

inventory was substantially reduced, it was not eliminated. Accordingly, it was determined that the TCC 

structure will be redesigned in FY 2015.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE CONTINUED:

FY 2015 Modifications to Objectives:

Beginning October 1, 2014, all newly filed formal complaints will be processed by OCRD. To accomplish 

this mission, OCRD will establish a Complaint Operations Branch composed of:

One (1) GS-15 EEO Specialist to serve as the Complaint Operations Manager. The Complaints Manager 

will be responsible for overseeing the processing of formal EEO complaints and overseeing the drafting of 

acceptance letters, dismissals and final agency decisions, and report to the Deputy Director of OCRD.

Two (2) GS-14 EEO Specialists: The EEO Specialists will be responsible for meeting regularly with USPS 

(and such other contract investigators whom OCRD may engage) to ensure that investigations are of 

high quality and are completed within designated timeframes. They also will serve as points of contact 

between the Treasury bureau where the complaint originated and the contract investigator. 

One (1) GS-14 EEO Specialist: The EEO Specialist will be reassigned from the OCRD EEO Program staff to 

oversee performance under the Interagency Agreement with USPS (and any other service provider), 

approve payments, monitor complaint status within the Department’s complaint tracking system 

(iComplaints) and prepare the 462 Report.

Three (3) GS-11/ GS-12 EEO Specialists will be selected to supplement OCRD’s existing team of final 

agency decision writers, all of whom will draft acceptances, dismissals, and final agency decisions, as well 

as review Investigative Plans and Reports of Investigation as needed.

One (1) GS-7 EEO Assistant will be selected to provide administrative assistance.

During FY 2015, the TCC will complete the processing of all formal complaints filed in FY 2014 (i.e., on or 

before September 30, 2014). As processing is completed, the staffing level at TCC will be reduced from 

its original 51 FTE slots (not all of which were filled) to none. As of October 1, 2015, the TCC will no 

longer exist.

FY 2015 Accomplishments:

During FY 2015, 79% of the Department’s investigations were timely completed, a significant increase 

from 66% in FY 2014. The Department will continue to strive to improve the timely completion rate, 

which is expected to improve now that all investigations are the responsibility of OCRD, and as a result of 

the selection of a Complaints Manager (who assumed the position in September 2015) and the 

anticipated selection of another Complaint Operations employee in the 2nd quarter of FY 2016.

FY 2016 Accomplishments:

During FY 2016, 78% of the Department’s investigations were timely completed, a modest decrease of 

1% from the 79% in FY 2015. However, OCRD is pleased as there was a 12.8% increase in the number 

of completed investigations and the projected hire of an additional employee in OCRD’s Complaint 

Operations Division did not onboard until late in the 3rd quarter of FY 2016.

FY 2017 Accomplishments: 

In FY 2017, OCRD made the decision to directly download investigative reports from the “cloud” that 

USPS offers to its clients. The decision to download directly from the cloud has vastly improved the 

timeliness of our investigations and has reduced costs. In FY 2017, 90 percent of all investigations were 

timely processed, a 13 percent increase from FY 2016. Treasury is closing this PART H.
Office of Civil Rights and Diversity FY 2017 MD-715 Report

69

EEOC FORM

715-01 

PART H

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

Department of the 

Treasury 

For period covering October 1, 2013 to September 30, 2014

STATEMENT of 

MODEL PROGRAM 

ESSENTIAL ELEMENT 

DEFICIENCY:

In Treasury’s EEOC Technical Assistance Feedback Letter, dated May 22, 

2017, EEOC identified that the percentage of dismissals reversed by OFO 

increased from 22% in FY 2014 to 33% in FY 2016.

OBJECTIVE: To decrease the rate of Treasury reversals by OFO.

RESPONSIBLE OFFICIAL: Gail Demers, Deputy Director, OCRD 

DATE OBJECTIVE 

INITIATED:

May 22, 2017

TARGET DATE FOR 

COMPLETION OF 

OBJECTIVE:

February 15, 2018

PLANNED ACTIVITIES TOWARD 

COMPLETION OF OBJECTIVE: Target Completion Date: Date Completed

Review FY 2017 data to determine the reversal 

rate of dismissals appealed to EEOC and 

adjudicated by EEOC in FY 2017. 

November 30, 2017 November 30, 2017

If reversal rate has not decreased by at least 

5%, conduct an analysis of its reversed 

decisions during FY 2017 to determine whether 

there are common errors.

January 31, 2018 November 30, 2017

Provide training to Complaint staff on any 

common errors identified during the analysis. February 15, 2018 December 6, 2017

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

During FY 2017, the EEOC issued appellate decisions on 14 dismissals issued by the Department. Four 

(4) of the 14 dismissals were reversed (a 28% dismissal rate). Although this dismissal rate is a decrease 

of 5% from the FY 2016 rate, the four (4) reversals were reviewed to determine whether there are 

common errors. 

Two of the complaints involved egregious claims (use of the “N” word and sexual harassment): (1) The 

complainant refused to participate in the counseling process and his subsequent formal complaint was 

dismissed under 29 C.F.R. § 1614.107(a) (2) on the basis that because complainant refused to identify 

his claims in the informal stage, his formal complaint could not raise claims that were “like or related” to 
Office of Civil Rights and Diversity FY 2017 MD-715 Report

70

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE CONTINUED:

any claims brought to an EEO Counselor. The Commission found that the EEO Counselor failed to give 

Complainant notice in writing of the effect of his refusal to participate at the informal stage. (2) The 

Department dismissed the sexual harassment complaint for untimely EEO contact. The EEOC decision 

stated that: “Based on the specific circumstances of this case, we exercise our discretion [to] waive the 

applicable time limits.”

In a third case, (3) the formal complaint was filed one (1) day late and the EEOC found that sufficient 

justification for the delay in the filing based on “these particular circumstances, Complainant’s good faith 

effort to timely file... and the short amount of time ... (one day)...” 

In the fourth case, (4) complainant sought EEO counseling on July 21, 2014, after he was informed that 

his temporary position would end effective March 7, 2015 and he would be returned to his permanent 

position. The Department dismissed the complaint as alleging a proposed personnel action since the 

challenged personnel action had not yet occurred and also, in the alternative, for untimeliness, since 

during an earlier contact with an EEO Counselor in February 2013, complainant had been advised to 

initiate the EEO process within 45 days of being informed that his temporary position would end effective 

March 7, 2015. EEOC found that, since the agency had made the decision to return the complainant to 

his permanent position, complainant was not challenging a proposed action. EEOC further found that 

complainant “timely initiated EEO counseling since he did so prior to the effective date of the personnel 

action.” 

OCRD has carefully reviewed these decisions. With respect to the first decision (1), the Department will 

instruct the bureau EEO Counselors to clearly inform complainants of the effect of refusal to participate in 

the EEO process. With respect to the next two decisions (2 and 3), EEOC exercised its judgement to 

waive the time limits. The Department believes that there was no justification to do so. The last 

decision (4) involved an error by OCRD in not accepting the claim and was discussed with our intake 

staff.

Training outlining common errors identified during the analysis of reversal rate of dismissals appealed to 

EEOC was conducted with complaint processing staff on December 6, 2017. 

Closed
Office of Civil Rights and Diversity FY 2017 MD-715 Report

71

PART I: EEO Plans to Eliminate 

Identified Barrier
Office of Civil Rights and Diversity FY 2017 MD-715 Report

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EEOC FORM

715-01 

PART I

Department of the 

Treasury

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

EEO Plans to Eliminate Identified Barrier

For period covering October 1, 2015 to September 30, 2016

STATEMENT OF 

CONDITION THAT 

WAS A TRIGGER 

FOR A POTENTIAL 

BARRIER:

Provide a brief 

narrative describing 

the condition at 

issue.

How was the 

condition recognized 

as a potential 

barrier?

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

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

Complement Plan (FCP) Questionnaire and a follow up meeting with EEOC 

staff members on June 12, 2015. 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. 

BARRIER 

ANALYSIS:

Provide a 

description of the 

steps taken and 

data analyzed to 

determine cause of 

the condition.

Reviewed bureau policies, MD-715 reports, and 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, applicant data, and bureau SES Career Development 

Program (CDP) participation and application processes.

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 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.
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STATEMENT OF 

IDENTIFIED 

BARRIER:

Provide a succinct 

statement of the 

agency policy, 

procedure or 

practice that has 

been determined to 

be the barrier of the 

undesired condition.

The working group found that the Department as a whole has made 

significant strides in the increased 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 SESCDP program, whereas 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 SESCDP 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:

State the alternative 

or revised agency 

policy, procedure or 

practice to be 

implemented to 

correct the undesired 

condition.

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.

RESPONSIBLE 

OFFICIAL:

Mariam Harvey, Director of the Office of Civil Rights and Diversity

Trevor Norris, Deputy Assistant Secretary for Human Resources and 

Chief Human Capital Officer

DATE OBJECTIVE 

INITIATED:

September 30, 2016

TARGET DATE FOR 

COMPLETION OF 

OBJECTIVE:

September 30, 2018

PLANNED ACTIVITIES TOWARD COMPLETION OF OBJECTIVE: TARGET DATE

(Must be specific)

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) Completed.

June 28, 2016

Brief Departmental Executive Resources Board on the report and get 

endorsement for the recommendations in the report. (OCRD/DASHR CHCO)

Completed.

August 15, 2016

Submit to ASM for approval and dissemination to Bureau Heads. 

Disseminated final report to EEO Officers. (OCRD) Completed.

September 15, 2016

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)

Modified: September 30, 2018

September 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) Modified: September 30, 2018

September 30, 2018

Establish policy to require all bureaus to track applicant flow data for all 

SESCDP programs to enhance barrier analysis capabilities on the SESCDP 

programs. (DASHR CHCO) Modified: September 30, 2018

September 30, 2018
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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)

Modified: September 30, 2018

September 30, 2018

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)

Modified: September 30, 2018

September 30, 2018

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) Modified: 

September 30, 2018

September 30, 2018

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) Modified: September 30, 2018

September 30, 2018

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) Modified: September 

30, 2018

September 30, 2018

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) Modified: September 30, 2018

September 30, 2018

Incorporate a discussion of EEO and diversity into all SES orientation and 

training for new executives. (DASHR CHCO/OCRD) Modified: September 

30, 2018

September 30, 2018
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REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2016 Accomplishments:

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 

DRB 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. 

FY 2017 Accomplishments:

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 changes before

making any further revisions to the existing MD-715 data tables. 
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PART J - Special Program Plan for 

the Recruitment, Hiring, and 

Advancement of Individuals with 

Targeted Disabilities
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EEOC FORM

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

MD-715 – Part J

Department of the Treasury

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

Retention of Persons with Disabilities

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

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

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

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

must complete this Part of the MD-715 report.

Section I: Efforts to Reach Regulatory Goals

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

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

federal government. 

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

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

trigger(s) in the text box.

a. Cluster GS-1 to GS-10 (PWD) Yes 0 No 15.61%

b. Cluster GS-11 to SES (PWD) Yes 11.09% No 0

PWD are participating at a rate (11.09%) slightly below the 12% bench mark at the grade 

cluster GS-11 to SES.

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

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

trigger(s) in the text box.

a. Cluster GS-1 to GS-10 (PWTD) Yes 0 No 4.56%

b. Cluster GS-11 to SES (PWTD) Yes 0 No 2.68%
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3. Describe how the agency has communicated the numerical goals to the hiring 

managers and/or recruiters.

Treasury has communicated the overall disability goals with its bureaus through the quarterly 

HR Stat, HCAC meetings, OCRD Advisory Newsletter, EEO Officer Meetings and the “Be a 

Champion” Roadshows. Treasury’s bureaus also have communicated the disability goals to 

their leadership through various methods to include new manager and supervisor training, 

newsletters, staff meetings, electronic bulletin boards, and bureau/organization specific 

dashboards.

Section II: Model Disability Program

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

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

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

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

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

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

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

the staffing for the upcoming year.

Yes X No 0

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

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

Disability Program Task

# of FTE Staff by 

Employment Status Responsible Official

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

Processing applications from PWD 

and PWTD 59 1 10 See specific bureau PART 

J’s.

Answering questions from the public 

about hiring authorities that take 

disability into account

 40 1 11 See specific bureau PART 

J’s.
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Processing reasonable accommodation 

requests from applicants and 

employees 63 0 13 See specific bureau PART 

J’s.

Section 508 Compliance 111 0 4 See specific bureau PART 

J’s.

Architectural Barriers Act Compliance

 18 1 305 See specific bureau PART 

J’s.

Special Emphasis Program for PWD 

and PWTD 16 0 5 See specific bureau PART 

J’s.

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

Treasury’s Disability and Veteran Employment Program Managers have provided training as 

needed through Treasury Learning Management System (TLMS), Enterprise Learning 

Management System (ELMS), workshops and refresher training. When needed, 

Treasury/bureaus coordinate training with external sources such as EEOC. 

B. Plan to Ensure Sufficient Funding for the Disability Program

Has the agency provided sufficient funding and other resources to successfully implement 

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

ensure all aspects of the disability program have sufficient funding and other resources.

Yes X No 0

Section III: Plan to Recruit and Hire Individuals with Disabilities

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

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

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

Treasury utilizes OPM’s Talent portal in USAJobs to identify qualified PWD, PWTD and 

veterans and refer qualified applicants to hiring managers. Treasury’s Veterans Program 

Coordinator provides all vacancies to veteran organizations that assist transitioning veterans, 

including those with disabilities, in finding employment. Treasury and Bureau Disability and 

Veterans Program Managers have also established relationships with organizations that assist 

PWD, PWTD and Veterans seeking employment. 

Treasury’s Disability and Veterans Program Managers also maintain resumes of qualified PWD 

and PWTD, including veterans with disabilities, who indicate they are interested in seeking 

employment opportunities at Treasury. When a hiring manager identifies an upcoming 

opening, the Disability and Veterans Program Managers send the hiring manager resumes of 

those PWD, PWTD and veterans who may be qualified. 

Treasury and its bureaus also utilize the Workforce Recruitment Program (WRP) to find and 

select college students and recent graduates with disabilities, including those with targeted 

disabilities.

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 is available for use along with Veteran Appointment Authorities to noncompetitively appoint PWD and PWTD and veterans with service-connected disability rating 

of 30% or more. The Department’s Disability and Veterans Program Managers work directly 

with bureau Disability Coordinators, Selective Placement Coordinators and Program Managers 

to assist in finding qualified candidates for non-competitive special hiring authorities. 

Additionally, through its Be a Champion Program, the Disability and Veterans Program 

Managers have established relationships with bureau hiring managers to identify resumes of 

qualified candidates who can be non-competitively selected. 

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. 
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When individuals apply utilizing the Schedule A Hiring Authority, their applications are 

reviewed 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. 

Applicants applying under the Schedule A Hiring Authority who are deemed qualified are 

referred to the hiring manager on a Schedule A certificate of eligibility with guidance on 

selection procedures including the application of veterans’ preference, when applicable. 

Managers have the option to interview and/or hire from the Schedule A certificate or to 

consider other candidates from other issued certificates (Merit Promotion, Non-Competitive, 

VRA, etc.). 

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

Placement Program Coordinator (SPPC) for vacant positions within Treasury, the SPPC refer 

the resumes to requesting hiring managers for consideration. The hiring manager refers selected 

resumes to the HR Specialist who reviews the resumes to determine qualifications. If 

qualifications and Schedule A eligibility are met, the resumes are returned to the hiring 

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

preference, when applicable. 

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

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

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

Yes X No 0 N/A 0

Treasury includes the use of special hiring authorities (e.g. Schedule A, VRA, 30% or more, 

etc.) in its mandatory training for new managers and supervisors. Also, through Treasury’s Be 

a Champion Program, the Disability and Veterans Program Managers provide training for 

bureau hiring managers, educating them on the benefits of using special hiring authorities, and 

assist in identifying resumes of qualified candidates who can be non-competitively selected and 

hired.

Additionally, Treasury’s Disability and Veterans Program Managers have provided bureau 

hiring managers with disability and veteran tool kits which highlight the use of hiring 

authorities that take disability into account.

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. 
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 Partner, lecture, and attend on-site presentations, and classroom visits in order to develop 

stronger relationships with college students and professors and with campus clubs and 

groups focusing on students with disabilities on college campuses.

 Hold periodic meetings with professional organizations to share Treasury’s process for 

providing vacancy announcements and information about opportunities.

 Attend specialty conferences and career/job fairs to share information about Treasury’s 

mission, work environment and job opportunities.

 Host brown bag lunches and roundtable discussions between hiring managers/senior 

management, and HC and organizations that assist PWD/PWTD.

C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING)

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

exist for PWD and/or PWTD among the new hires in the permanent workforce? If 

“yes”, please describe the triggers below.

a. New Hires for Permanent Workforce (PWD) Yes 0 No 16.32%

b. New Hires for Permanent Workforce (PWTD) Yes 0 No 3.02%

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 0 No X

b. New Hires for MCO (PWTD) Yes X No 0
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FY 2017 Hires Applicants vs. Hires Applicants vs. Hires

0110 (20) Hires: PWD: 4.59% - 5.00% PWTD: 2.75% - 0.00%

0340 (11) Hires: PWD: 4.37% - 9.09% PWTD: 1.73% - 9.09%

0343 (62) Hires: PWD: 4.52% - 11.29% PWTD: 1.94% - 3.23%

0501 (29) Hires: PWD: 4.94% - 20.99% PWTD: 1.83% - 0.00%

0511 (18) Hires: PWD: 3.52% - 5.56% PWTD: 1.69% - 0.00%

0570 (167) Hires: PWD: 2.77% - 4.19% PWTD: 1.19% - 0.00%

0905 (50) Hires: PWD: 3.20% - 4.00% PWTD: 1.14% - 0.00%

1169 (35) Hires: PWD: 1.94% - 17.14% PWTD: 0.88% - 2.86%

1811 (53) Hires: PWD: 3.32% - 1.89% PWTD: 1.42% - 0.00%

2210 (377) Hires: PWD: 5.26% - 22.55% PWTD: 2.43% - 3.89%

The 1811, Criminal Investigators occupation, limits the employment opportunities available for 

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

we would expect the hire of PWTD and PWD to be limited.

However, we do note triggers when comparing the applicant flow data with the hires for PWTD 

for the occupational series 0110, 0501, 0511, 0570, and 0905’s. Treasury bureaus that noted 

the same triggers in their workforce evaluation have addressed these triggers in the bureau 

PART J. For plans to improve hiring for PWD within the major occupations listed see the 

specific bureau PART J’s.

3. Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or 

PWTD among the qualified internal applicants for any of the mission-critical 

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

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

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

This data is a new requirement to be implemented with the FY 2018 reporting and revised MD715 V2 data tables. Treasury is in the process of discussing the new MD-715 V2 data tables 

with our data providers; Enterprise Data Management and Monster/CareerConnector. We will

work throughout FY 2018 to develop and release the revised data tables for the FY 2018 

reporting period. 

4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or 

PWTD among employees promoted to any of the mission-critical occupations (MCO)? 

If “yes”, please describe the triggers below.

a. Promotions for MCO (PWD) Yes X No 0

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

0340 - PWD: 4.56% - 2.40% PWTD: 1.90% - 1.20%

0343 - PWD: 3.90% - 1.72% PWTD: 1.62% - 0.86%

0501 - PWD: 4.69% - 4.90% PWTD: 1.80% - 2.94%

0570 - PWD: 2.48% - 1.84% PWTD: 1.30% - 0.74%

0905 - PWD: 1.00% - 0.00% PWTD: 0.00% - 0.00%

1169 - PWD: 1.94% - 1.25% PWTD: 0.88% - 0.31%

2210 - PWD: 4.85% - 1.72% PWTD: 2.57% - 0.57%

We noted triggers when comparing the applicant flow data with the promotion data for PWD in 

the following occupations: 0340, 0343, 0570, 0905, 1169 and 2210. Additionally, triggers 

were noted when comparing the applicant flow data with the promotion data for PWTD in the 

following occupations: 0340, 0343, 0570, 1169 and 2210.Treasury bureaus that noted the same 

triggers in their workforce evaluation have addressed these triggers in their bureau PART J. 

For plans to improve advancement opportunities for PWD and PWTD within the major 

occupations listed see specific bureau PART J’s.

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.

Bureaus have established bureau specific programs for the advancement of PWDs and PWTDs. 

For details see specific bureau Part J’s.
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B. Career Development Opportunities

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

employees. 

Treasury has three bureaus (IRS, OCC and TTB) with formal career development programs. For 

details see specific bureau Part J’s.

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

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

[Collection begins with the FY 2018 MD-715 report, which is due on February 28, 

2019.]

Career Development 

Opportunities

Total Participants PWD PWTD

Applican

ts (#)

Selectees 

(#)

Applican

ts (%)

Selectees 

(%)

Applicant

s (%)

Selectees

(%)

Internship Programs

Fellowship Programs

Mentoring Programs

Coaching Programs

Training Programs

Detail Programs

Other Career 

Development Programs

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 0 N/A X

b. Selections (PWD) Yes 0 No 0 N/A X

Treasury does not have a Treasury-wide career Development program, therefore there is no 

data available. 
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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 0 N/A X

b. Selections (PWTD) Yes 0 No 0 N/A X

Treasury does not have a Treasury-wide career Development program, therefore there is no 

data available. 

C. Awards

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

PWD and/or PWTD for any level of the time-off awards, bonuses, or other incentives? 

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

a. Awards, Bonuses, & Incentives (PWD) Yes X No 0

b. Awards, Bonuses, & Incentives (PWTD) Yes X No 0

The inclusion rate for PWD (12.15%) and PWTD (12.78%) fell slightly below the inclusion 

rate for employees with no disability (14.60%) for time off awards between 1 - 9 hours.

The inclusion rate for PWD (21.61%) for time off awards of more than 9 hours fell slightly 

below the inclusion rate for employees with no disability (21.63%). However, the inclusion rate 

for PWTD (22.89%) was above the inclusion rate for persons with no disability.

The inclusion rate for PWD (15.56%) in cash awards $500 or less, was above the inclusion rate 

for employees with no disability (14.13%). However the inclusion rate for PWTD (12.43%) 

fell below the inclusion rate for employees with no disability. 

The inclusion rate for PWD (40.84%) and PWTD (40.69%) was below the inclusion rate for 

employees with no disability (54.35%) for cash awards of $501 and greater. 

Treasury bureaus that noted the same triggers in their workforce evaluation are required to 

address these triggers in their bureau PART J; see specific bureau PART J’s.
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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.

Treasury bureaus that noted the same triggers in their workforce evaluation are required to 

address these triggers in their bureau PART J; see specific bureau PART J’s.

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

See specific bureau PART J’s.
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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 0 N/A X

ii. Internal Selections (PWD) Yes 0 No 0 N/A X

b. Grade GS-15

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

ii. Internal Selections (PWD) Yes X No 0

c. Grade GS-14 

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

ii. Internal Selections (PWD) Yes X No 0

d. Grade GS-13 

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

ii. Internal Selections (PWD) Yes X No 0

Relevant pool/Applicants/Promotions Relevant Pool/Applicants/Promotions

GS-13 - PWD: 11.85% - 2.71% - 1.82% PWTD: 3.53% - 0.97% - 0.18%

GS-14 - PWD: 9.00% - 4.33% - 2.72% PWTD: 2.48% - 2.02% - 1.49%

GS-15 - PWD: 8.64% - 2.84% - 2.63% PWTD: 2.31% - 1.09% - 1.32%

SES Vacancy announcements are not posted internally to Treasury or its bureaus. All SES 

vacancy announcements are required to be posted externally. Additionally, Treasury’s systems 

do not have the capability to identify internal applicant from external applicants on external 

vacancy announcements. 

Treasury bureaus that noted the same triggers in their workforce evaluation are required to 

address these triggers in their bureau PART J. For plans to improve advancement opportunities 

for PWD and PWTD within the major occupations listed, see specific bureau PART J’s.
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2. Does your agency have a trigger involving PWTD among the qualified internal

applicants and/or selectees for promotions to the senior grade levels? (The appropriate 

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

qualified applicant pool for selectees.) For non-GS pay plans, please use the 

approximate senior grade levels. If “yes”, describe the trigger(s) in the text box.

a. SES

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

ii. Internal Selections (PWTD) Yes 0 No 0 N/A X

b. Grade GS-15

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

ii. Internal Selections (PWTD) Yes X No 0

c. Grade GS-14 

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

ii. Internal Selections (PWTD) Yes X No 0

d. Grade GS-13 

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

ii. Internal Selections (PWTD) Yes 0 No X

 Relevant Pool Applicants/Promotions

GS-13 - PWTD: 3.53% - 0.97% - 0.18%

GS-14 - PWTD: 2.48% - 2.02% - 1.49%

GS-15 - PWTD: 2.31% - 1.09% - 1.32%

SES Vacancy announcements are not posted internally to Treasury or its bureaus. All SES 

vacancy announcements are required to be posted externally. Additionally, Treasury’s bureaus 

do not have the capability to identify internal applicant from external applicants on external 

vacancy announcements. 

Treasury bureaus that noted triggers in their workforce evaluation are required to address these 

triggers in their bureau PART J. For plans to improve advancement opportunities for PWD and 

PWTD within the major occupations listed, see specific bureau PART J’s.
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3. Using the qualified applicant pool as the benchmark, does your agency have a trigger 

involving PWD among the new hires to the senior grade levels? For non-GS pay plans, 

please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the 

text box.

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

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

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

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

This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking 

appropriate steps to be able to report this information as part of the FY 2018 reporting period.

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

involving PWTD among the new hires to the senior grade levels? For non-GS pay 

plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in 

the text box.

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

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

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

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

This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking 

appropriate steps to be able to report this information as part of the FY 2018 reporting period.

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.
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a. Executives

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

ii. Internal Selections (PWD) Yes 0 No 0

b. Managers

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

ii. Internal Selections (PWD) Yes 0 No 0

c. Supervisors 

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

ii. Internal Selections (PWD) Yes 0 No 0

This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking 

appropriate steps to be able to report this information as part of the FY 2018 reporting period.

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 0

ii. Internal Selections (PWTD) Yes 0 No 0

b. Managers

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

ii. Internal Selections (PWTD) Yes 0 No 0

c. Supervisors 

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

ii. Internal Selections (PWTD) Yes 0 No 0
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This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking 

appropriate steps to be able to report this information as part of the FY 2018 reporting period.

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 0

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

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

This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking 

appropriate steps to be able to report this information as part of the FY 2018 reporting period.

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 0

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

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

This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking 

appropriate steps to be able to report this information as part of the FY 2018 reporting period.

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

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

describe the trigger below.

a. Voluntary Separations (PWD) Yes X No 0

b. Involuntary Separations (PWD) Yes X No 0

The inclusion rate for PWD (1.01%) exceeded the rate of persons with no disability (0.69%) for 

involuntary separations. The inclusion rate for PWD (10.21%) also exceeded the inclusion rate 

for persons with no disability (8.56%) for voluntary separations.

The “inclusion rate” for this purpose is determined by dividing the number of permanent 

employees with disabilities who voluntarily separated (129) by the total number of employees 

with disabilities 12,664. That rate, 1.01%, exceeds the 0.69% “inclusion rate” for permanent 

employees without disabilities who voluntarily separated (570 divided by 82,087).

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 0 No X

b. Involuntary Separations (PWTD) Yes X No 0

The (inclusion rate) for PWTD (0.94%) exceeded the rate of persons with no disability (0.69%) 

for involuntary separations. The inclusion rate for PWTD (8.40%) did not exceed the inclusion 

rate for persons with no disability (8.56) for voluntary separations.

In FY 2017, Treasury had 37 Schedule A employees who were eligible for conversion to 

competitive service appointments. Of that: 

 31 were timely converted to career status

 2 were untimely converted 

 2 were not converted based on unsatisfactory performance

 2 were involuntarily separated based on FY 2017 budget cuts in the organization. 
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4. If a trigger exists involving the separation rate of PWD and/or PWTD, please explain 

why they left the agency using exit interview results and other data sources.

During the period of October 1, 2016 through September 30, 2017, 202 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 48% (97) had more than 

25 years of service and 76% (153) were age 50 or older. Of the respondents with disabilities, 

31% (63) were veterans. The most frequently cited reason for separation of PWD was 

retirement (126 or 62%).

The factor most frequently cited as impacting a PWD’s decision to leave was job stress (75%). 

Additional factors frequently cited include office morale (64%); office organization and 

alignment with regard to effective and efficient service (51%), resources to do the job (51%), 

ability to participate in decisions (48%), access to developmental opportunities (48%), pay in 

relation to job responsibilities and performance (47%), reasonableness of workload (46%), and 

job description in relation to actual duties and responsibilities (46%). 

71% of the respondents indicated their work experience was generally positive and 64% stated 

they would recommend Treasury as a good place to work. PWD (69%) were slightly less 

likely to indicate that they would recommend Treasury as a good place to work, as compared to 

the 72% of all respondents.

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 overall “Accessibility” page on the public Treasury.gov website, 

https://www.treasury.gov/accessibility/Pages/default.aspx, provides three links with resources 

for Persons with Disabilities.

Information on how to file a complaint can be found 

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://www.treasury.gov/accessibility/Pages/web.aspx.

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.
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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://www.treasury.gov/accessibility/Pages/physical.aspx.

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/accessibility/Pages/disability.aspx.

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 2017, OCRD conducted two accessibility reviews of buildings occupied by DO 

employees – 1750 Pennsylvania Avenue and Freedman’s Bank Building (Treasury Annex). 

For the Freedman’s Bank Building, the Treasury Library Area was under review. Although the 

accessibility review indicated that the space is mostly accessible, important requirements are 

not being met. OCRD identified ten (10) deficiencies requiring a corrective action. The review 

was signed by Mariam Harvey, Director, OCRD, and submitted to the Deputy Assistant 

Secretary for Operations on May 26, 2017.

For the Treasury Leased Space, 1750 Pennsylvania Avenue, the review also indicated that the 

space was mostly accessible, but that there were important requirements not met. OCRD 

identified twenty-eight (28) deficiencies that required a corrective action. The review was 

signed by Mariam Harvey, Director, OCRD, and submitted to the Deputy Assistant Secretary 

for Operations on May 12, 2017.

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.)
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Each bureau is responsible for independently processing their request for reasonable 

accommodations. See below:

Average Days by Bureau:

BEP 10

DO 20

FinCEN 15

FS 6

Mint 20

IRS 66

OCC 10

TIGTA 10

TTB 40

Overall average of 22 days.

2. Describe the effectiveness of the policies, procedures, or practices to implement the 

agency’s reasonable accommodation program. Some examples of an effective program 

include timely processing requests, timely providing approved accommodations, 

conducting training for managers and supervisors, and monitoring accommodation 

requests for trends.

Overall, the Department has an effective Disability Program, supported by various policies, 

procedures, and practices, as evidenced by timely processing requests for accommodations. 

Mandatory new managers and supervisors training includes responsibilities on providing 

reasonable accommodations. Throughout FY-2017 bureaus provided reasonable 

accommodations guidance via training courses, newsletters and postings on its intranet 

websites (see specific bureau submission for details). The Department established a Treasurywide sign language interpreters contract to provide an effective and efficient procedure for 

providing sign language interpreters. 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.
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OPM established the requirement for Personal Assistance Services to be implemented in 

January 2018. Therefore, for FY 2017, Treasury did not have a policy or procedure in place to 

implement the PAS requirement. During FY 2018, first quarter, Treasury EEO established a 

Personal Assistance Services (PAS) Working Group. The initial purpose of this working group 

is to establish and finalize a Statement of Work (SOW) for procuring a Treasury-wide PAS 

contact. This contract will allow bureaus to establish a purchase order against the Treasurywide base contract. While the PAS contract is being established, the PAS working group will 

create the PAS policy and procedures. In the interim, the Department will follow existing 

reasonable accommodation policy and procedures to provide PAS.

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 FAD, hostile work environment based on disability and reprisal when, among 

other things, complainant was denied reasonable accommodation and issued a counseling 

memorandum; where training and consideration of disciplinary action were ordered – In 

addition to appropriate relief for the complainant, the following corrective action(s) were taken: 

training was provided and disciplinary action was considered but found not to be warranted.

B. EEO Complaint Data involving Reasonable Accommodation

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

alleging failure to provide a reasonable accommodation, as compared to the 

government-wide average? 

Yes X No 0 N/A 0

2. During the last fiscal year, did any complaints alleging failure to provide reasonable

accommodation result in a finding of discrimination or a settlement agreement?

Yes X No 0 N/A 0
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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.

Six FAD’s: (1) disability discrimination for failure to provide reasonable accommodation; 

training was ordered for all responsible management officials in office where complainant 

worked; training is pending; (2) disability discrimination for denial of reasonable 

accommodation and termination for missing too much time from work during probationary 

period; training and disciplinary action were ordered; training was provided; disciplinary 

action is pending; (3) disability discrimination for unnecessary delay in providing operable 

adaptive equipment, which had been approved pursuant to request for reasonable 

accommodation; it was determined that management acted in good faith in attempting to 

provide effective accommodation; (4) disability discrimination for failure to provide reasonable 

accommodation in line with complainant’s physician’s recommendation or even act on her 

request for reasonable accommodation until the EEO complaint was filed; training on the 

responsibilities of management under the Rehabilitation Act was ordered and was provided; 

disciplinary action was not ordered because the individual who was primarily responsible for 

processing the original reasonable accommodation request was no longer employed with the 

Agency; (5) disability discrimination for delay in providing reasonable accommodation; 

training and consideration of disciplinary action were ordered; training was provided; decision 

on disciplinary action is pending; and (6) disability discrimination for failure to provide 

reasonable accommodation and failure to maintain confidential medical information in separate 

medical file; training and consideration of disciplinary action were ordered; training was 

provided and oral counseling was administered to four management officials. 

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
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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

Treasury bureaus that noted triggers in their workforce evaluation are required to 

address these triggers in their bureau PART J. For plans to address and remove 

identified barriers for PWD and PWTD see specific bureau PART J’s.

Barrier(s)

Objective(s)

Responsible Official(s)

Performance Standards Address the 

Plan?

(Yes or No)

Target Date

(mm/dd/yyyy

)

Planned Activities Sufficient 

Staffing & 

Funding

(Yes or 

No)

Modified 

Date

(mm/dd/y

yyy)

Completion 

Date

(mm/dd/yyy

y)

Fiscal Year Accomplishments

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

the planned activities.

See specific bureau PART J’s

5. For the planned activities that were completed, please describe the actual impact of 

those activities toward eliminating the barrier(s).

See specific bureau PART J’s
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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. 

See specific bureau PART J’s
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Appendix A:

Department of the Treasury 

FY 2017 EEO Policy
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