FY 2021 Management Directive 715 

(MD-715) Report

U.S. DEPARTMENT OF THE TREASURY 

OFFICE OF CIVIL RIGHTS AND DIVERSITY

FY 2021 MD-715 REPORT I 3

U.S. DEPARTMENT OF THE TREASURY 

OFFICE OF CIVIL RIGHTS AND DIVERSITY

Contents

Part A: Department or Agency Identifying Information 4

Part B: Total Employment 4

Part C.1: Head of Agency and Head of Agency Designee 4

Part C.2: Agency Official(s) Responsible for Oversight of EEO Program(s) 4

Part D.1: List of Subordinate Components Covered in this Report 6

Part D.2: Mandatory and Optional Documents for this Report 7

Part E: Executive Summary 8

Introduction/Mission 8

Six Essential Elements for a Model EEO Program 9

Employee Perspective Surveys 15

Workforce Analysis 17

Treasury Complaint Program 27

Accomplishments 27

Planned Activities 28

Part F: Certification of Establishment of Continuing Equal Employment Opportunity Programs 30

Part G: Agency Self-Assessment Checklist 31

Part H: Agency EEO Plan to Attain the Essential Elements of a Model EEO Program 52

Part I: Agency EEO Plan to Eliminate Identified Barrier 58

Part J: Special Program Plan for the Recruitment, Hiring, Advancement, and Retention 71

of Persons with Disabilities
4 I FY 2021 MD-715 REPORT 

Part A: Department or Agency Identifying Information

Agency Second 

Level 

Component

Address City State Zip Code 

(xxxxx)

Agency 

Code 

(xxxx)

FIPS 

Code 

(xxxx)

Department of the 

Treasury

N/A 1500 Pennsylvania Avenue, 

NW

Washington DC 20220 TR 11001

Part B: Total Employment

Total Employment Permanent Workforce Temporary Workforce Total Workforce

Number of Employees 95,369 776 96,145

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

Agency Leadership Name Title

Head of Agency Janet L. Yellen Secretary, Department of the Treasury

Head of Agency Designee J. Trevor Norris Acting Assistant Secretary for Management

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

Program(s)

EEO Program 

Staff Name Title Occupational Series (xxxx)

Pay 

Plan - 

Grade 

(xx-xx)

Phone 

Number 

(xxx-xxx-xxxx)

Email Address

Principal EEO 

Director/Official

Snider 

Page

Acting Director 

(OCRD)

0260 GS-15 202-622-0341 Snider.Page@treasury.gov

Deputy Director 

EEO

Tina 

Lancaster

Acting Deputy 

Director (OCRD)

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

Affirmative 

Employment 

Program 

Manager

Tina 

Lancaster

Assistant 

Director for EEO 

Programs

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

Complaint 

Processing 

Program 

Manager

Guizelous 

(Guy) Molock

Assistant 

Director for 

Complaints 

Program

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

Manager 

of Special 

Emphasis 

Programs

Tina 

Lancaster

Assistant 

Director for EEO 

Programs

0260 GS-15 202-622-1079 Tina.Lancaster@treasury.gov
FY 2021 MD-715 REPORT I 5

EEO Program 

Staff Name Title Occupational Series (xxxx)

Pay 

Plan - 

Grade 

(xx-xx)

Phone 

Number 

(xxx-xxx-xxxx)

Email Address

Diversity 

& Inclusion 

Program 

Manager

Charmaine 

McDaniel

EEO Specialist 0260 GS-14 202-622-8902 Charmaine.McDaniel@

treasury.gov

Disability 

Program 

Manager 

(SEPM)

Elizabeth 

Ortiz

EEO Specialist 0260 GS-14 202-868-9192 Elizabeth.Ortiz@treasury.gov

Special 

Placement 

Program 

Coordinator 

(Individuals with 

Disabilities)

Elizabeth 

Ortiz

EEO Specialist 0260 GS-14 202-868-9192 Elizabeth.Ortiz@treasury.gov

Reasonable 

Accommodation 

Program 

Manager

Elizabeth 

Ortiz

EEO Specialist 0260 GS-14 202-868-9192 Elizabeth.Ortiz@treasury.gov

AntiHarassment 

Program 

Manager

Clarissa 

Lara

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

ADR Program 

Manager

Clarissa 

Lara

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

Compliance 

Manager

Ellen 

HawthorneCopenhaver

EEO Specialist 0260 GS-14 202-622-0341 Ellen.HawthorneCopenhaver@treasury.gov

Principal MD715 PreparerDenise 

Ratcliff

EEO Specialist 0260 GS-14 202-622-9069 Denise.Bernfeld@treasury.gov
6 I FY 2021 MD-715 REPORT 

Part D.1: List of Subordinate Components Covered 

in this Report

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

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

Subordinate Component City State Country 

(Optional)

Agency Code 

(xxxx)

FIPS

Codes

(xxxxx)

Alcohol and Tobacco Tax and Trade Bureau Washington DC US TR40 11001

Bureau of Engraving and Printing Washington DC US TRAI 11001

Fiscal Service Parkersburg WV US TRFD 54107

Departmental Offices Washington DC US TR91 11001

Financial Crimes Enforcement Network Fairfax VA US TRAF 51600

Internal Revenue Service Washington DC US TR93 11001

Internal Revenue Service Chief Counsel Washington DC US TR93(88) 11001

United States Mint Washington DC US TRAD 11001

Office of the Comptroller of the Currency Washington DC US TRAJ 11001

Office of the Inspector General Washington DC US TR95 11001

Special Inspector General for Troubled Asset Relief Program Washington DC US TRRP 11001

Treasury Inspector General for Tax Administration Washington DC US TRTG 11001
FY 2021 MD-715 REPORT I 7

Part D.2: Mandatory and Optional Documents for this Report

In the table below, the agency must submit these documents with its MD-715 report.

Please respond 

Yes or No

Comments

Did the agency submit the following mandatory documents?

Organizational Chart Yes

EEO Policy Statement Yes

Strategic Plan Yes FY 2022 Plan will be released in the 2nd 

Quarter

Anti-Harassment Policy and Procedures Yes Last approved on February 21, 2021

Reasonable Accommodation Procedures Yes Last approved by EEOC on February 3, 2021

Personal Assistance Services Procedures Yes

Alternative Dispute Resolution Procedures Yes

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

Please respond 

Yes or No

Comments

Did the agency submit the following mandatory documents?

Disabled Veterans Affirmative Action Program (DVAAP) 

Report

No

Operational Plan for Increasing Employment of Individuals with 

Disabilities under Executive Order 13548

No

Diversity and Inclusion Plan under Executive Order 13583 Yes Treasury’s Diversity and Inclusion (D&I) and 

EEO Strategic Plan (FY 2021-2024)

Diversity Policy Statement Yes Included in EEO Policy Statement.

Human Capital Strategic Plan No Human Capital (HC) goals are included within 

the new Treasury Strategic Plan released in 

2nd Quarter of FY 2022

EEO Strategic Plan Yes Treasury’s D&I and EEO Strategic Plan (FY 

2021-2024)

Results from most recent Federal Employee Viewpoint Survey 

(FEVS) or Annual Employee Survey

No
8 I FY 2021 MD-715 REPORT 

Part E: Executive Summary

Introduction/Mission

The Department of the Treasury serves to protect the Nation’s economic and financial infrastructure, support U.S. 

leadership in the global economy, and promote job growth and shared prosperity. To accomplish our mission, we must 

be able to recognize the needs of all citizens and understand the multi-cultural forces that shape the global economy. To 

effectively serve this diverse nation, our workforce must be representative of all segments of society, and we must give 

all employees the ability to compete on a fair and level playing field with equal opportunity for all. 

To achieve a workforce that reflects our country’s diversity, Treasury continuously works to align efforts to establish 

an equitable and civil culture and reduce barriers to racial equity. Treasury’s efforts to identify opportunities, make 

recommendations, and develop and implement strategies to increase inclusivity and diversity at the agency are 

embedded in this report.

The Department of the Treasury’s Mission

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

that enable economic growth and stability at home and abroad, strengthen national security by combatting threats and 

protecting the integrity of the financial system, and manage the U.S. Government’s finances and resources effectively. 

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

do, explore better ways of conducting business through innovation, seek diversity of thought and expertise to inform our 

decisions, embrace and adapt to change, and hold ourselves accountable for accomplishing meaningful results for the 

American public. 

Organization

Treasury is composed of eight bureaus and four separate Inspector General Offices, with diverse missions, from 

collecting taxes, to manufacturing currency, to paying our nation’s bills and regulating our banking system. The 

Departmental Offices is primarily responsible for the formulation of policy and overseeing the bureaus, which manage 

major operations.

Organizational Reporting Structure

For Equal Employment Opportunity Commission (EEOC) Management Directive (MD) 715 reporting purposes, Treasury’s 

second-level reporting bureaus are:

• Bureau of Engraving and Printing (BEP),

• Fiscal Service (FS),

• Departmental Offices (DO),

• Internal Revenue Service (IRS),

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

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

• U.S. Mint (Mint).

Bureaus employing fewer than 1,000 employees are required to provide their individual Management Directive (MD) 

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

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

Special Inspector General for Pandemic Relief (SIGPR), 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). 
FY 2021 MD-715 REPORT I 9

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 OCRD, part of 

the Departmental Offices’ organizational structure, is primarily responsible for providing guidance and oversight to 

the bureaus’ EEO offices. To learn more about the Department of the Treasury and its mission, and how the agency 

supports diversity and inclusion efforts, go to About Treasury.

The Office of Civil Rights and Diversity

The Office of Civil Rights and Diversity administers the Department-wide equal employment opportunity (EEO) and diversity 

(EEOD) program by providing policy, oversight, and technical guidance to Treasury bureaus, including the Departmental 

Offices, on affirmative employment, special emphasis program areas, diversity, and EEO complaint processing. To learn 

more about OCRD programs, go to About OCRD.

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

or funded by the Department of the Treasury. The OCRD’s External Civil Rights Program ensures individuals are 

not excluded from participation in, denied the benefits of, or otherwise subjected to prohibited discrimination under 

programs or activities conducted or funded by the Department. To learn more about OCRD’s External Civil Rights 

Program, go to About External Civil Rights.

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 for a Model EEO Program

The Six Essential Elements for a Model EEO Program outlines the foundation upon which an agency shall build an 

effective EEO Program. Treasury is required to review the agency’s EEO and personnel programs, policies, and 

performance standards against all six elements to identify where the program can become more effective. 

Essential Element A: Demonstrated Commitment from Agency Leadership

Secretary Yellen affirmed her commitment to EEO by issuing an EEO Policy on September 1, 2021. The EEO Policy, 

expresses the Department’s support of diversity, equal employment opportunity, and a workplace free of discriminatory 

harassment. The EEO Policy was communicated via email to all Treasury employees and was posted to the internal and 

external Treasury websites. 

Each of Treasury’s bureaus heads committed to the principles of EEO and diversity by either issuing or reissuing their policy 

statements in support of EEO and diversity. Each bureau ensures that its own EEO Policy and Treasury’s EEO Policy are 

disseminated to all new employees during orientation and are available on the internal and external websites, if applicable. 

Bureaus ensure all newly promoted managers and supervisors receive copies of the bureau and Treasury EEO Policies 

as a reminder of their role and responsibility in providing a discrimination and harassment-free work environment. 

Treasury and its bureaus 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 the internal and 

external websites. 

Treasury’s Reasonable Accommodation Policy and Procedures (Civil Rights Directive (CRD) 014: Voluntary Modification 

and Reasonable Accommodation Policy and Procedures) has been approved by EEOC and is pending final clearance before 

signature and release. In the interim, Treasury’s CRD 012: Voluntary Modification and Reasonable Accommodation Policy, 

dated February 2020, is easily accessible to all employees and applicants via the internal and external websites.
10 I FY 2021 MD-715 REPORT 

To further enhance Treasury’s commitment to diversity, equity, inclusion, and accessibility, and in response to President 

Biden’s administrative priorities outlined in Executive Orders (EO) 13985: Advancing Racial Equity and Support for 

Underserved Communities Through the Federal Government and 14035: Advancing Diversity, Equity, Inclusion, and 

Accessibility in the Federal Workforce, Treasury hired a Counselor for Racial Equity which is located within the Office of 

the Deputy Secretary.

Essential Element B: Integration of EEO into the Agency’s Strategic Mission

The Secretary of the Treasury has delegated authority over all EEO matters to the Assistant Secretary for Management 

(ASM) through Treasury Order 102-02. The ASM, who reports directly to the Secretary and Deputy Secretary, is kept 

informed of EEO matters through regular communication with the Director of OCRD. The Director of OCRD, who reports 

directly to the ASM, provides the day-to-day management of the EEO, Diversity and Inclusion, and Civil Rights programs in 

Treasury, and has direct access to the ASM to provide him with critical information regarding the programs. 

Department of the Treasury Strategic Plan

Through Treasury’s Strategic Plan for Fiscal Years 2018-2022, the Department continues to prioritize the importance 

of building and maintaining a high-performing and diverse workforce. Achieving these objectives demands a concerted 

commitment in cultivating an organizational culture of inclusion where diverse talent is leveraged with continuous 

improvement in skills, learning, processes, and attitudes. Objective 5.1: Workforce Management of the Department’s 

Strategic Plan outlines strategies to help the Department meet its plan. The purpose of this objective is to foster a 

culture of innovation to hire, engage, develop, and optimize a diverse workforce with the competencies necessary 

to accomplish the Departments mission. The Departments strategy (5.1.C) is to improve diversity and engagement 

through transparency, fairness, and inclusion.

Treasury’s Diversity and Inclusion (D&I) and Equal Employment Opportunity Strategic Plan

In FY 2021, OCRD along with bureau EEO and Diversity and Inclusion Officers implemented Treasury’s first combined 

Diversity and Inclusion (D&I) and Equal Employment Opportunity Strategic Plan for Fiscal Years 2021-2024. The 

Strategic Plan identified a comprehensive set of six goals that highlight both D&I and EEO priorities and promotes the 

cross collaboration necessary to include people with a variety of talents and from a variety of backgrounds, resulting 

in a workplace where people can feel respected and accepted. Treasury’s D&I and EEO Strategic Plan outlines the 

second phase of the President’s 2011 EO 13583, Establishing a Coordinated Government-wide Initiative to Promote 

Diversity and Inclusion in the Federal Workforce. EO 13583 directs executive departments and agencies to develop and 

implement a comprehensive, integrated, and strategic plan that focuses on diversity and inclusion as a key component of 

their human resources strategies.

The following Goals and Priorities are identified in the Strategic Plan:

• Goal 1: Demonstrate Diversity & Inclusion as Mission Critical Values

Priority 1.1: Leadership Responsibility and Transparency

Priority 1.2: Data-Based Research and Accountability

• Goal 2: Enhance Communication, Collaboration, 

and Consistency

Priority 2.1: Establish Role Clarity to Enhance Collaboration Between Human Resources, Equal Employment 

Opportunity and Diversity and Inclusion Offices

Priority 2.2: Communicate Importance of D&I, EEO, and Affirmative Employment to Treasury’s Mission

Priority 2.3: Support and Strengthen Internal Inclusion Efforts

Priority 2.4: Create Memoranda of Understanding with Outside Organizations 
FY 2021 MD-715 REPORT I 11

• Goal 3: Center Safety, Fairness and Trust

Priority 3.1: Facilitate Inclusion and Trust in Day to Day Work

Priority 3.2: Create Space for and Listen to Candid Employee Feedback to Improve Customer Experience

• Goal 4: Comply with Regulatory Mandates and Departmental Policies

Priority 4.1: Process EEO Complaints of Discrimination and Reporting Complaint Activity

Priority 4.2: Increase Alternative Dispute Resolution (ADR) Participation and Settlement Rates

Priority 4.3: Reduce Processing Times for Reasonable Accommodation Requests

• Goal 5: Educate and Engage the Treasury Workforce

Priority 5.1: Training and Education for All Staff

• Goal 6: Leverage Technology

Priority 6.1: Increase Use of Information Technology to Improve Efficiency of EEO Programs and Analyze Trends in 

Program Data and Workforce Demographics

Priority 6.2: Promote a Digital-First Culture that Prioritizes Stakeholder Interactions and Experiences

The priority over the next few years will focus on leadership accountability, responsibility and transparency; communicating 

the importance of Diversity, Inclusion and EEO; collaborating with Human Resources; facilitating inclusion and trust in 

daily interactions; increasing compliance with federal regulatory EEO Complaints and Departmental policies; providing 

educational opportunities to the workforce on creating an inclusive workplace; and increasing the use of information 

technology to improve the efficiency of EEO Programs. 

Throughout FY 2021, OCRD’s Director of EEO Programs met with Treasury Bureau EEO, Diversity and Human 

Resource Officers to discuss the implementation plan and recommend strategies for continued improvement. 

Together we will continue to focus efforts on improving Treasury’s overall results for FY 2022.

After the release of the Government-Wide Strategic Plan to Advance Diversity, Equity, Inclusion, and Accessibility 

(DEIA) in the Federal Workforce in FY 2022, OCRD established a cross-agency approach to align the Treasury’s FY 

2021-2024 D&I and EEO Strategic Plan with Executive Order (EO) 14035: Advancing Diversity, Equity, Inclusion, and 

Accessibility in the Federal Workforce and OMB implementation guidance. 

Treasury’s Historically Black Colleges and Universities Competitive Strategy Framework Plan

In FY 2020, through its FY 2021-2022 Historically Black Colleges and Universities (HBCUs) Competitive Strategy 

Framework Plan, Treasury required its bureaus to set and track internal goals that provide for regular outreach events 

with HBCUs. Treasury bureaus are required to identify HBCUs with areas of focus that align with the bureaus’ key job 

series to build lasting partnerships. Treasury and its bureaus committed to conducting direct, targeted outreach to 

HBCU students and recent graduates for Treasury employment opportunities.

Internship Programs

Internship programs play 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 2021, Treasury and its bureaus continued to establish 

and maintain partnerships with existing external internship programs that attract highly qualified and diverse students. 

Internship programs such as the Pathways Program, Operation Warfighter, and the Workforce Recruitment Program 

(WRP) continue to provide Treasury and its bureaus an avenue to identify and expand the pool of potential candidates 

and grow new talent.
12 I FY 2021 MD-715 REPORT 

Treasury’s Departmental Offices established the Treasury-wide Treasury Scholars Program through use of a blanket 

purchase agreement. Through this program, all Treasury bureaus have existing partnerships with the following organizations:

• Hispanic Association of Colleges and Universities (HACU),

• INROADS, and 

• The Washington Center.

Bureaus also maintain their own partnerships with diverse organizations, for example:

• FinCEN has established partnerships with HBCUs and Gallaudet University;

• FS maintains partnerships with the Hispanic Serving Institutions National Internship Program (HSINIP) and 

Washington Internships for Native Students (WINS); 

• IRS maintain a partnership with the Society of American Indian Government Employees (SAIGE); and

• BEP maintained a partnership with Minority Serving Institutions as part of a five-year contract to recruit paid interns.

Training

OCRD’s Complaints Program coordinates annual EEO Counselor Refresher training for all bureau EEO Counselors to 

ensure all counselors receive the required training to maintain appropriate certification.

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 Department-wide 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, 

such as the bureau EEO Officers. The 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 the policy, Treasury and the bureaus benefit from increased collaboration, greater transparency of 

information, data, goals, and plans, more efficient sharing of resources, and greater emphasis on succession planning.

In FY 2021, Treasury’s OCRD continued with the Bureau Audit Program by auditing the Departmental Offices (DO) bureau; 

additionally, OCRD participated in the Human Capital Evaluations of the Mint and IRS HR, D&I, and EEO programs. The 

Bureau Audit includes a review of each phase of Treasury bureaus’ EEO programs, including diversity and inclusion (D&I), 

EEO complaint processes, and building accessibility reviews to ensure compliance with the applicable law and regulations. 

Among those topics for review is Performance Standards established for Managers, Supervisors, and Senior Executive 

Service (SES) members to ensure performance commitments include mandatory EEO and D&I elements. At the conclusion 

of the bureau audit, bureaus receive a report identifying any program deficiencies, an evaluation of the effectiveness of their 

efforts to achieve and maintain a Model EEO Program, and a list of recommendations for improvement. 

The Department 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. 

Treasury is actively engaged with the workforce and senior leaders; management and senior leaders are informed of 

trends within their workforce throughout the year by OCRD and respective bureau EEO Officers by use of Quarterly 

Progress Reviews (QPRs), deep-dive workforce analysis (Diversity Dashboards), OCRD Advisory newsletters, and 

Managers Alerts.
FY 2021 MD-715 REPORT I 13

Treasury publishes OCRD Advisory Newsletters to the workforce, as well as Manager’s Alerts to managers and 

supervisors, on information rele–vant to EEO complaint program matters, changes to policy and/or procedures, 

workforce statistics, and important upcoming agency events/activities, including hiring events and use of special 

hiring authorities.

Essential Element D: Proactive Prevention of Unlawful Discrimination

Barrier Analysis Efforts 

In FY 2020, OCRD established a Treasury-wide Barrier Analysis Working Group (BAWG), consisting of EEO personnel 

from each bureau, tasked with identifying barriers for female employment in the General Schedule (GS)-13 and above 

grade levels. In FY 2021, each bureau reviewed workforce data and identified one or two mission-critical and/or most 

populous occupations where female participation rates at the GS-13 and above grade levels consistently falls below 

the respective availability rate. Bureaus have formed sub-working groups consisting of sub-component EEO personnel 

(if applicable), HR, and hiring managers/supervisors. Bureaus are analyzing their data to identify triggers within various 

phases of employment, including recruitment and outreach. The Treasury-wide BAWG meets monthly to discuss plans 

and progress, as well as to identify any challenges to completing the barrier analysis efforts. 

Treasury bureaus’ missions vary greatly, from collecting taxes, to manufacturing currency, to paying our nation’s 

bills, and regulating our banking system. Because each bureau has a different mission, each bureau’s workforce is 

also different, and therefore, each bureau has different conditions, practices, and policies that affect each bureau 

individually. Bureaus are required by EEOC and OCRD to conduct bureau-level barrier analysis on known triggers in 

an effort to identify and eliminate potential barriers.

Special Emphasis Programs

OCRD is part of DO 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 its bureaus, across the employment spectrum. 

Established throughout the bureaus, the three federally mandated SEPs -- the 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, Gay, Bi-sexual, Transgender, and 

Queer (LGBTQI+) employment programs.

Bureau SEP Managers and Coordinators serve as resource persons or advisors to the bureau EEO offices on the 

unique concerns of the constituent groups and support the internship programs and other partnerships.

OCRD revised its LGBTQ Cultural Competency training for online use and made it accessible to all Treasury employees 

using its Integrated Management Learning System. The training was developed in FY 2020 and launched in early FY 

2021 and reintroduced during LGBTQ Pride Month events. 

In FY 2021, the Treasury Asian Pacific American (TAPA) Employee Resource Group (ERG) organized the Asian 

American and Native American Pacific Islander (AANAPI) History program, Anti-Asian American Pacific Islander 

(AAPI) Discrimination and Introduction to Bystander Intervention Training, and AAPI Panel discussion on increased 

discrimination against AAPI communities due to COVID.
14 I FY 2021 MD-715 REPORT 

Employee Resource Groups

Treasury has two minority-serving ERGs: Hispanic Employee Resource Group (Adelante) and TAPA. Other ERGs include: 

the Veteran Employee Resource Group (VERG), LGBTQ Employee Resource Group (PRISM), and the Law Enforcement 

Officers ERG (LEO). These Treasury-wide ERGs provide Treasury employees support and provides the opportunity to 

receive guidance for success in their employment. ERGs partner with OCRD, the principal consultant to Treasury’s 

organizational officials, and senior managers, to provide a direct pipeline to the heads of the agency for employees to 

recommend changes to enhance and support diversity and inclusion efforts in the agency.

Additionally, many of the Treasury bureaus have a variety of bureau-specific ERGs available to their respective workforce.

In FY 2021, OCRD announced interest in launching a new Treasury-wide ERG for Individuals with Disabilities. 

To include and engage everyone in the workforce, Treasury launched a campaign for leadership to the Adelante and the 

TAPA ERGs. The leadership for each of the Treasury-wide ERGs are selected as collateral duty assignments. Campaigns 

are extended to other Treasury-wide ERGs like LEO, PRISM, and VERG.

Shared Neutrals Program

The Department sustained its Treasury Shared Neutrals (TSN) Program with 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. 

Training

In FY 2020, OCRD developed an “LGBTQ – Nondiscrimination in the Federal Workplace” training for the Integrated 

Talent Management (ITM) system. In FY 2021, OCRD marketed and recommended the training, which is available to all 

Treasury-employees.

In FY 2021, Treasury continued to offer Civil Treatment for Employees and Leaders training by a cadre of in-house 

trainers. This training prepared Treasury employees to teach D&I concepts to the workforce. Plans for providing 

additional training were placed on hold due to the pandemic but are expected to continue where possible in FY 2022.

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, fair, and impartial dispute resolution process and has a system in place for evaluating the impact and 

effectiveness of the Department’s EEO complaint processing program. The Department has an established EEO 

complaint program separate from the Department’s defensive function. 

Regarding 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 and procedures and produces high quality final agency decisions. 

In addition, OCRD oversees the Department’s EEO complaint appeal process, tracks all appeal decisions, and 

monitors compliance with decisions issued by the EEOC. 

The Department maintains special procedures for handling complaints on the bases of parental status. This basis was 
FY 2021 MD-715 REPORT I 15

added in response to Presidential Executive Order 13152, amending Executive Order 11478.

OCRD continued to implement principles which support the use of data and evidence-based decision making by 

continuing a partnership with the Treasury’s Enterprise Data Management (EDM) office in FY 2021. Bureau Human 

Capital Offices focused on consolidating data sources and data products from a technology perspective, whereas the 

use of the EDM platform is a primary data hub and system to provide reports/dashboards. In FY 2021, the EDM 

worked with OCRD to provide access to EEO data for the IRS Human Capital Data Management Technology (HCDMT) 

team, where consolidate/unified MD-715 profiles and Exit Surveys are included enhancing their efforts to address 

reporting (and governance).

OCRD collaborated with the EDM in an effort to increase inter-agency communication and share best practices with 

agencies of similar size. In FY 2021, the two offices responded to three inter-agency knowledge-share sessions to share 

best practices for workforce data collection, retrieval, and analysis. OCRD will continue inter-agency communications in 

following years.

Essential Element F: Responsiveness and Legal Compliance

Treasury remains compliant with the law, including EEOC regulations, directives, orders, and other guidance. The 

Department continues to post all required No FEAR Act information, provide required training to the workforce, and 

consistently file timely annual required reports, including the MD-715 and EEOC Form 462 Reports.

During FY 2021, the Department conducted its FY 2020 State of the Agency Briefing with the ASM in April 2021 and 

with the Department’s Secretary and Deputy Secretary in September 2021.

In FY 2021, OCRD continued the practice of providing bureau EEO Officials and MD-715 Preparers with direct feedback 

on the previous year’s annual MD-715 report. OCRD reviews each bureau’s MD-715 Report, provides technical 

assistance and guidance, and makes recommendations for ensuring the technical elements required future reports.

Employee Perspective Surveys

Diversity and Inclusion (New IQ) Index

As part of the Office of Personnel Management’s (OPM) oversight of agencies’ Diversity and Inclusion programs, a 

Diversity and Inclusion – New Inclusion Quotient (IQ) Index was developed. The IQ Index provides agencies with a metric 

for evaluating the effectiveness of their Diversity and Inclusion Strategic Plans. The IQ Index focuses on five categories 

using questions from the Federal Employee Viewpoint Survey (FEVS) responses: Fairness, Open-minded, Cooperative, 

Supportive, and Empowerment.

In FY 2020, the Federal Employee Viewpoint Survey (FEVS) was modified to assess challenges of the COVID-19 

pandemic. The shortened standard sections allowed for a new section on how the COVID-19 pandemic impacted 

individual work and wellbeing and omitted the Diversity and Inclusion Index categories (Fairness, Open-Minded, 

Cooperative, Supportive, Empowerment). However, the FY 2021 FEVS questions were slightly changed to help us better 

understand perceptions on leadership, work-life balance, supervisory relationships, performance management and 

to help senior leadership plan. It will also include several questions about how the COVID-19 pandemic has impacted 

employees, their work, and the agency. 

The absence of the New IQ questions on the FY 2020 and FY 2021 FEVS inhibits the EEO and D&I community from 

gauging employees’ perspectives in this critical area and greatly impacted the community’s work in advancing diversity 

and inclusion in accordance with President Biden’s EO 14035. In FY 2021, Treasury’s Deputy Assistant Secretary 

for Human Resources (DASHR), Departmental Offices’ Office of Minority and Women Inclusion (OMWI), and OCRD 

contacted OPM to administer the New IQ questions as a separate survey for Treasury bureaus, which was approved 
16 I FY 2021 MD-715 REPORT 

by Secretary Yellen. The survey is expected to be administered to a random sample of about 10 percent of Treasury 

employees by OPM and will launch in February of 2022. In addition to the New IQ questions, the survey will include a 

small number of diversity questions, as well as a few questions that will obtain an understanding of the state of data 

tools and training in the agency.

Exit Survey Responses

In FY 2021, Treasury continued use of its automated Exit Survey tool that was 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 9,6461 permanent employees separated from Treasury; of those permanent 

separations, 8,938 were voluntary separations and 708 were involuntary. Of the 8,938 voluntarily separating 

permanent employees, Treasury received 1,885 (21.09%) responses.

While the FY 2021 Treasury permanent workforce was 61.38% female and 64.36% of voluntarily separating 

permanent employees were female, 57.19% of the Exit Survey respondents were female.

Of the respondents, 45.04% were age 60 and Over, followed by the 50-59 age group (29.44%). The category for 60 

and Over for voluntarily separating permanent employees had a length of service of more than 25 years (48.54%), 

followed by employees who had 13-25 years of service (20.16%). Additionally, respondents in the GS 13-15 or 

equivalent grade levels rated (44.30%), followed by the GS 5-8 or equivalent grade level (26.95%).

The largest percentage of respondents, 65.99%, were separating to retire, followed by 8.44% who were transferring 

to another federal agency. Of those employees who were separating to retire, 35.45% have been eligible to retire for 

five or more years while 39.87% were eligible for one to four years, and 24.68% were eligible to retire for less than one 

year. Of the retiring respondents, 37.46% of the retiring employees indicated they would be interested in becoming a 

reemployed annuitant. 

The element most cited as having an impact on the decision to separate was “Job-Related Stress,” where 54.27% 

of the respondents stated that it had an impact on the decision to separate. Following “Job-Related Stress,” “Office 

Morale” (36.34%) and “Reasonableness of Workload” (35.76%) were also listed as having an impact on the decision 

to separate. 

1 Data does not include those employees separating from the Special Inspector General for the Troubled Asset Relief Program (10) or the Office of 

the Inspector General (14).

Respondent Participation Separation Rate Workforce Participation

Hispanic 8.01% 13.43% 13.00%

White 63.08% 51.73% 51.06%

Black 21.70% 28.48% 27.68%

Asian 4.83% 4.82% 6.82%

NHOPI, AIAN, Two+* 2.39% 1.54% 1.43%

PWD 8.12% 13.90% 13.86%

*NHOPI, AIAN, Two+ refers to Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More Races
FY 2021 MD-715 REPORT I 17

A high percentage of separating employees responded that their work experience was generally positive (84.56%); 

63.71% stated that they would return to work for Treasury in the future, and 82.39% stated they would recommend 

Treasury as a good place to work. 

Workforce Analysis

The following are Treasury’s workforce demographic trends over a 10-year period, FY 2012 to FY 2021. The area 

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

distribution of Women and Persons of Color in the General Schedule (GS) grades 13 through 15 and the Senior 

Executive Service (SES), and in the equivalent pay plans for use by Treasury only (OR, TR, IR, and NB)2, as well as the 

participation rates for Hispanics in the Bureaus and within the mission critical occupations.

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

year to the next. However, when evaluating trends over time, and as a result of the bureaus’ effort to improve diversity 

in those areas with lower-than-expected participation rates, Treasury has noted significant progress for the overall 

participation rate for Hispanics and Persons with Disabilities (PWD) and Persons with Targeted Disabilities (PWTD).

Treasury and its bureaus continue to utilize the Relevant Civilian Labor Force (RCLF) tool, updated annually at the end of 

each fiscal year, which provides a more realistic benchmark comparator. The RCLF is based off the National Civilian Labor 

Force (CLF); however, rather than calculating a weighted average for all available occupations in the federal government, it 

calculates the expected labor force based on a weighted average of only those occupations in Treasury’s workforce.

At the end of FY 2021, Treasury had 96,145 employees, a decrease of 1,244 (-1.28 percent net change) employees 

from FY 2020. Treasury’s permanent workforce increased by 728 employees from FY 2020 to FY 2021 with 

95,369 employees at the end of FY 2021, a net change of 0.77 percent. Treasury’s temporary workforce experienced 

a significant decrease from 2,748 in FY 2020 to 776 in FY 2021, a net change of -71.76 percent. The following 

workforce demographics specifically relate to the permanent workforce.

Overall Participation Rates

A comparison of FY 2021 participation rates in Treasury’s permanent workforce for Males and Females shows little 

change since FY 2012, though the participation rates for Females decreased from 62.87 percent in FY 2012 to 

61.38 percent in FY 2021. The Male participation rate increased from 37.13 percent in FY 2012 to 38.63 percent 

in FY 2021. Treasury’s FY 2021 Female participation rate (62.87 percent) exceed the RCLF availability rate of 59.47 

percent, while the Male participation rate (38.62 percent) falls below the RCLF availability rate of 40.53 percent.

2 OR: This code is used by employees of the Office of Financial Research (OFR) within the Department of the Treasury only.

TR: This code is used by employees of the Mint and BEP within the Department of the Treasury only.

IR: This code is used by employees of the IRS within the Department of the Treasury only.

NB: This code is used by employees of the OCC within the Department of the Treasury only.

Element Percentage of Respondents indicating Impact

Job-related stress 54.27%

My office’s morale 36.34%

Reasonableness of my workload 35.76%

My pay level in relation to my job responsibilities and performance 34.80%

My ability to participate in decision-making 33.79%

Resources available to do my job 33.63%
18 I FY 2021 MD-715 REPORT 

Apart from White and American Indian/Alaskan Native, participation rates for all Ethnicity/Race Indicator (ERI) 

categories have increased from FY 2012 to FY 2021. From FY 2012 to FY 2021, Hispanic participation rates 

increased from 10.50 percent to 13.00 percent, and exceed the RCLF availability rate of 8.29 percent. White 

participation rates decreased from 58.36 percent in FY 2012 to 51.06 percent in FY 2021, which falls below the 

RCLF availability rate of 74.77%. The participation rate for Black/African American employees increased from 24.60 

percent in FY 2012 to 27.68 percent in FY 2021 and exceeds the RCLF availability rate of 10.61 percent. From FY 

2012 to FY 2021, Asian participation rates increased from 5.34 percent to 6.82 percent, and exceed the RCLF 

availability rate of 4.81 percent. Native Hawaiian/Other Pacific Islander participation rates increased from 0.13 percent 

in FY 2012 to 0.18 percent in FY 2021 and exceeds the RCLF availability rate of 0.12 percent. The participation rate 

for American Indian/Alaskan Native employees decreased from 0.85 percent in FY 2012 to 0.75 percent in FY 2021 

and falls below the RCLF availability rate of 0.89 percent. While the participation rate for Two or More Races employees 

increased from 0.21 percent in FY 2012 to 0.50 percent in FY 2021, the participation rate falls just short of the RCLF 

availability rate of 0.51 percent.

FY 2021 Participation Rates by Sex

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

80.00%

60.00%

40.00%

20.00%

0.00%

Male Female

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 FY 2012 37.13% 62.87%

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 FY 2021 38.62% 61.38%

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 RCLF 40.53% 59.47%
FY 2021 MD-715 REPORT I 19

Participation Rates by ERI/Sex3

Treasury-wide, participation rates for Hispanic Males and Females, Black Males and Females, Asian Males and Females, 

and Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More Races Males and 

Females have increased from FY 2012 to FY 2021. In FY 2021, participation rates for all ERI/Sex categories except 

White Males and Females and Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or 

More Races Males and Females exceed the respective RCLF availability rates. 

The participation rates for Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More 

Races Males and Females fall just below the respective RCLF availability rates: Males, 0.49 percent vs. 0.53 percent 

RCLF; and Females, 0.94 percent vs. 0.98 percent RCLF. 

3 Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More Races participation rates are combined into one 

category for this section.

Hispanic White Black/African

American Asian NHOPI AIAN Two+

FY 2012 10.50% 58.36% 24.60% 5.34% 0.13% 0.85% 0.21%

FY 2021 13.00% 51.06% 27.68% 6.82% 0.18% 0.75% 0.50%

RCLF 8.29% 74.77% 10.61% 4.81% 0.12% 0.89% 0.51%

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

55.00%

60.00%

65.00%

70.00%

75.00%

80.00%

FY 2021 Participation Rates by ERI

Hispanic Female Black/African 

American

Asian NHOPI AIAN Two+

Male Female

Y 2012 37.13% 62.87%

Y 2021 38.62% 61.38%

CLF 40.53% 59.47%

0.00%

0.00%

0.00%

0.00%

0.00%

FY 2021 Participation Rates by Sex

 FY 2012 10.50% 58.36% 24.60% 5.34% 0.13% 0.85% 0.21%

Male Female

2 37.13% 62.87%

1 38.62% 61.38%

40.53% 59.47%

%

%

%

%

%

FY 2021 Participation Rates by Sex

 FY 2021 13.00% 51.06% 27.68% 6.82% 0.18% 0.75% 0.50%

Male Female

37.13% 62.87%

38.62% 61.38%

40.53% 59.47%

021 Participation Rates by Sex

 RCLF 8.29% 74.77% 10.61% 4.81% 0.12% 0.89% 0.51%
20 I FY 2021 MD-715 REPORT 

The participation rate for White Males, 23.55 percent, falls below the 31.38 percent RCLF availability rate, while the 

participation rate for White Females, 27.51 percent, falls below the 43.39 percent RCLF availability rate.

Grade Distribution by Sex and ERI4

The distribution of Females and Persons of Color (POC) in Treasury’s workforce has been an area of focus for the 

Department. Yearly, OCRD monitors the distribution of Females and POC in the feeder pools that lead to SES positions. 

In FY 2021, the Female participation rate decreases from 65.68 percent in the GS-11 grade to 41.94 percent in the 

SES grade level. Female participation falls below the Workforce availability rate in all GS 12 and above grade levels. 

4 Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More Races participation rates are combined into one 

category for this section

HM HF WM WF BM BF AM AF

NHOPI,

AIAN, 2+

M

NHOPI,

AIAN, 2+

F

FY 2012 3.34% 7.16% 25.38% 32.98% 5.75% 18.85% 2.28% 3.06% 0.38% 0.81%

FY 2021 4.57% 8.43% 23.55% 27.51% 6.88% 20.80% 3.13% 3.69% 0.49% 0.94%

RCLF 3.01% 5.28% 31.38% 43.39% 3.36% 7.25% 2.25% 2.56% 0.53% 0.98%

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

FY 2021 Participation Rates by ERI/Sex

HM HF WM WF BM BF AM AF

NHOPI, 

AIAN, 2+ 

M

NHOPI, 

AIAN, 

2+ F

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 FY 2012 3.34% 7.16% 25.38% 32.98% 5.75 18.85% 2.28% 3.06% 0.38% 0.81%

Male Female

2012 37.13% 62.87%

2021 38.62% 61.38%

LF 40.53% 59.47%

00%

00%

00%

00%

00%

FY 2021 Participation Rates by Sex

 FY 2021 4.57% 8.43% 23.55% 27.51% 6.88% 20.80% 3.13% 3.69% 0.49% 0.94%

Male Female

2012 37.13% 62.87%

2021 38.62% 61.38%

LF 40.53% 59.47%

00%

00%

00%

00%

00%

FY 2021 Participation Rates by Sex

 RCLF 3.01% 5.28% 31.38% 43.39% 3.36% 7.25% 2.25% 2.56% 0.53% 0.98%

0% 20% 40% 60% 80% 100%

GS 11

GS 12

GS 13

GS 14

GS 15

SES

Workforce

GS 11 GS 12 GS 13 GS 14 GS 15 SES Workforce

Male 34.32% 41.77% 48.84% 53.22% 52.52% 58.06% 38.62%

Female 65.68% 58.23% 51.16% 46.78% 46.48% 41.94% 61.38%

FY 2021 Grade Distribution (GS 11 and Above) by Sex

GS-11 GS-12 GS-13 GS-14 GS-15 SES Workforce

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 Male 34.32% 41.77% 48.84% 53.22% 52.52% 58.06% 38.62%

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 Female 65.68% 58.23% 51.16% 46.78% 46.48% 41.94% 61.38%
FY 2021 MD-715 REPORT I 21

In FY 2021, the Hispanic participation rate decreases from 14.61 percent in the GS-11 grade to 4.61 percent in the 

SES grade level; Hispanic participation falls below the Workforce availability rate in all GS 12 and above grade levels.

The White participation rate increases from 47.29 percent in the GS-11 grade to 75.82 percent in the SES grade level; 

White participation exceeds the Workforce availability rate in all GS-12 and above grade levels.

The Black/African American participation rate decreases from 32.39 percent in the GS-11 grade to 13.49 percent 

in the SES grade level; Black/African American participation falls below the Workforce availability rate in all GS-13 and 

above grade levels. 

The Asian participation rate increases from 4.66 percent in the GS-11 grade level to 11.76 percent at the GS-14 

grade level, afterwards decreasing again to 4.77 percent at the SES grade level; Asian participation exceeds the 

Workforce availability rate in the GS-12 through GS-15 grade levels.

The Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More Races participation rate 

increases from 1.05 percent in the GS-11 grade level to 1.64 percent in the GS 12 grade level, afterwards decreasing 

to 1.08 percent in the GS-15 grade level. Participation increases again at the SES grade level (1.31 percent). 

Participation for Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native, and Two or More Races falls 

below the Workforce availability rate in all GS-11 and above grade levels.

GS-11 GS-12 GS-13 GS-14 GS-15 SES Workforce

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

GS 11

GS 12

GS 13

GS 14

GS 15

SES

Workforce

GS 11 GS 12 GS 13 GS 14 GS 15 SES Workforce

Hispanic 14.61% 9.77% 8.79% 6.74% 5.21% 4.61% 13.00%

White 47.29% 53.72% 57.61% 59.19% 67.42% 75.82% 51.06%

Black/African American 32.39% 27.94% 21.78% 21.14% 16.86% 13.49% 27.68%

Asian 4.66% 6.93% 10.53% 11.76% 9.43% 4.77% 6.82%

NHOPI, AIAN, 2+ 1.05% 1.64% 1.29% 1.17% 1.08% 1.31% 2.38%

FY 2021 Grade Distribution (GS 11 and Above) by ERI

 Hispanic 14.61% 9.77% 8.79% 6.74% 5.21% 4.61% 13.00%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

GS 11

GS 12

GS 13

GS 14

GS 15

SES

Workforce

GS 11 GS 12 GS 13 GS 14 GS 15 SES Workforce

14.61% 9.77% 8.79% 6.74% 5.21% 4.61% 13.00%

47.29% 53.72% 57.61% 59.19% 67.42% 75.82% 51.06%

an American 32.39% 27.94% 21.78% 21.14% 16.86% 13.49% 27.68%

4.66% 6.93% 10.53% 11.76% 9.43% 4.77% 6.82%

AN, 2+ 1.05% 1.64% 1.29% 1.17% 1.08% 1.31% 2.38%

FY 2021 Grade Distribution (GS 11 and Above) by ERI

 White 47.29% 53.72% 57.61% 59.19% 67.42% 75.82% 51.06%

40% 50% 60% 70% 80% 90% 100%

S 13 GS 14 GS 15 SES Workforce

9% 6.74% 5.21% 4.61% 13.00%

61% 59.19% 67.42% 75.82% 51.06%

78% 21.14% 16.86% 13.49% 27.68%

53% 11.76% 9.43% 4.77% 6.82%

9% 1.17% 1.08% 1.31% 2.38%

n (GS 11 and Above) by ERI

 Black/African American 32.39% 27.94% 21.78% 21.14% 16.86% 13.49% 27.68%

70% 80% 90% 100%

GS 15 SES Workforce

.21% 4.61% 13.00%

7.42% 75.82% 51.06%

6.86% 13.49% 27.68%

.43% 4.77% 6.82%

.08% 1.31% 2.38%

 by ERI

 Asian 4.66% 6.93% 10.53% 11.76% 9.43% 4.77% 6.82%

% 80% 90% 100%

SES Workforce

4.61% 13.00%

75.82% 51.06%

13.49% 27.68%

4.77% 6.82%

1.31% 2.38%

RI

 NHOPI, AIAN, 2+ 1.05% 1.64% 1.29% 1.17% 1.08% 1.31% 2.38%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

GS 11

GS 12

GS 13

GS 14

GS 15

SES

Workforce

GS 11 GS 12 GS 13 GS 14 GS 15 SES Workforce

Hispanic 14.61% 9.77% 8.79% 6.74% 5.21% 4.61% 13.00%

White 47.29% 53.72% 57.61% 59.19% 67.42% 75.82% 51.06%

Black/African American 32.39% 27.94% 21.78% 21.14% 16.86% 13.49% 27.68%

Asian 4.66% 6.93% 10.53% 11.76% 9.43% 4.77% 6.82%

NHOPI, AIAN, 2+ 1.05% 1.64% 1.29% 1.17% 1.08% 1.31% 2.38%

FY 2021 Grade Distribution (GS 11 and Above) by ERI
22 I FY 2021 MD-715 REPORT 

Treasury Hispanic Workforce

The Hispanic workforce within Treasury continues to be an area of focus for Treasury and its bureaus, specifically in the 

GS-13 and above grade levels. Through FY 2021, based on the joint EEOC)/Office of Personnel Management (OPM) 

memorandum issued on January 18, 2017, Hispanics in the Federal Workplace, Treasury’s bureaus continued to 

conduct focused barrier analysis on the participation rates for Hispanics within the major occupations and distribution 

in the GS grades 12 through SES levels to identify and eradicate any barriers to EEO, consistent with the merit system 

principles and applicable laws. 

The Treasury Hispanic participation rate, 13.00 percent, exceeds the RCLF availability rate of 8.29 percent. In FY 2021, 

the Hispanic participation rate for New Hires was 16.62 percent, exceeding the RCLF availability rate of 8.29 percent. 

The Hispanic participation rate for Separations was 13.33 percent, slightly exceeding the workforce availability rate 

(13.00 percent). 

The participation rates for Hispanic Males and Females exceed the respective RCLF availability rates at the GS 1-10 and 

GS 11-12 grade clusters. At the GS 13-15 and SES grade levels, the participation rates for Hispanic Males exceeds the 

RCLF availability rate, while the participation rates for Hispanic Females falls below the RCLF availability rate. 

Hispanic Female participation rates decrease by 10.58 percent from 12.06 percent in the GS 1-10 grade cluster to 

1.48 percent at the SES grade level. Hispanic Male participation rates decrease by 1.91 percent from 5.04 percent in 

the GS 1-10 grade cluster to 3.13 percent at the SES grade level.

The Hispanic participation rates exceed the respective RCLF availability rate in nine Treasury bureaus: Bureau of 

Engraving and Printing (BEP), Internal Revenue Service (IRS), IRS – Office of the Chief Counsel (IRS-CC), U.S. Mint (Mint), 

Office of the Comptroller of the Currency (OCC), Office of the Inspector General (OIG), Special Inspector General for the 

Troubled Asset Relief Program (SIGTARP), Treasury Inspector General for Tax Administration (TIGTA), and the Alcohol 

and Tobacco Tax and Trade Bureau (TTB). 

The Treasury Hispanic Male participation rate, 4.57 percent, exceeds the RCLF availability rate of 3.01 percent. The 

Hispanic Male participation rates exceed the respective RCLF availability rate in nine Treasury bureaus: BEP, FinCEN, 

IRS, Mint, OCC, OIG, SIGTARP, TIGTA, and TTB.

The Treasury Hispanic Female participation rate, 8.43 percent, exceeds the RCLF availability rate of 5.28 percent. The 

Hispanic Female participation rates exceed the respective RCLF availability rate in five Treasury bureaus: IRS, IRS-CC, 

Mint, OIG, and TTB.

GS 1-10 GS 11-12 GS 13-15 GS-14 Workforce

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 Hispanic M 5.04% 4.50% 3.68% 3.13% 4.57%

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 Hispanic F 12.06% 7.51% 3.83% 1.48% 8.43%

HF RCLF: 5.28%

HM RCLF: 3.01%
FY 2021 MD-715 REPORT I 23

Bureau Name Total 

Hispanic

RCLF Hispanic 

Male

RCLF Hispanic 

Female

RCLF

BEP 9.59% 9.13% 7.76% 6.20% 1.83% 2.92%

DO 5.58% 6.79% 3.18% 3.31% 2.40% 3.48%

FinCEN 4.66% 7.45% 3.58% 3.37% 1.08% 4.08%

FS 3.85% 6.91% 2.05% 2.76% 1.80% 4.15%

IRS 14.24% 8.55% 4.65% 2.90% 9.59% 5.65%

IRS-CC 5.57% 5.06% 2.19% 2.37% 3.38% 2.68%

Mint 11.98% 9.61% 7.88% 6.61% 4.10% 3.00%

OCC 7.95% 7.12% 4.51% 2.68% 3.44% 4.44%

OIG 7.84% 6.25% 3.43% 2.44% 4.41% 3.81%

SIGPR 20.00% * 17.14% * 2.86% *

SIGTARP 9.38% 6.10% 9.38% 3.02% 0.00% 3.08%

TIGTA 7.25% 6.71% 4.10% 2.65% 3.15% 4.06%

TTB 7.99% 6.51% 4.10% 2.86% 3.89% 3.65%

Treasury 13.00% 8.29% 4.57% 3.01% 8.43% 5.28%

* SIGPR was established in FY 2021 and therefore does not have its own RCLF calculation at this time. SIGPR’s RCLF will be included in FY 2022 

calculations.

Treasury bureau geographical duty stations play a significant role in the diversity of the workforce. While BEP, IRS, and 

Mint have multiple duty stations in diverse geographical areas, FS’ primary duty station, Parkersburg, West Virginia, 

remains a non-diverse location, providing limited opportunities to recruit, hire, and maintain a diverse workforce. 

Within Treasury’s Major Occupations, Hispanic participation rates exceed the respective Occupational Civilian 

Labor Force (OCLF) availability rate in eight occupations: 0301: Misc. Administration and Program; 0340: Program 

Management; 0343: Management and Program Analyst; 0501: Financial Administration and Program; 0511: Auditing; 

0570: Bank Examiner; 0905: General Attorney; and 1169: Revenue Officer.

Hispanic Male participation rates exceed the respective OCLF availability rate in nine of Treasury’s major occupations: 

0110: Economist, 0301: Misc. Administration and Program; 0340: Program Management; 0343: Management and 

Program Analyst; 0501: Financial Administration and Program; 0511: Auditing; 0570: Bank Examiner; 0905: General 

Attorney; and 1169: Revenue Officer.

Hispanic Female participation rates exceed the respective OCLF availability rate in seven of Treasury’s major occupations: 

0301: Misc. Administration and Program; 0343: Management and Program Analyst; 0501: Financial Administration and 

Program; 0511: Auditing; 0905: General Attorney; 1169: Revenue Officer; and 1811: Criminal Investigating.

Occ. Series Total 

Hispanic

OCLF Hispanic 

Male

OCLF Hispanic 

Female

OCLF

0110: Economist 4.67% 5.10% 4.09% 3.30% 0.58% 1.80%

0301: Misc. Admin. & Program 9.06% 8.60% 3.17% 2.80% 5.89% 5.80%

0340: Program Management 8.96% 8.60% 3.40% 2.80% 5.56% 5.80%

0343: Mgmt. Program Analyst 7.40% 4.60% 2.58% 2.40% 4.82% 2.20%

0501: Financial Admin and Pgm. 14.25% 9.80% 4.92% 4.10% 9.33% 5.70%

0511: Auditing 8.22% 6.10% 4.22% 2.20% 4.00% 3.90%
24 I FY 2021 MD-715 REPORT 

Occ. Series Total 

Hispanic

OCLF Hispanic 

Male

OCLF Hispanic 

Female

OCLF

0570: Bank Examiner 7.91% 6.80% 4.89% 3.10% 3.02% 3.70%

0905: General Attorney 5.03% 4.30% 2.66% 2.50% 2.37% 1.80%

1169: Revenue Officer 15.27% 10.70% 6.52% 4.70% 8.75% 6.00%

1811: Criminal Investigating 9.41% 11.20% 6.26% 8.20% 3.15% 3.00%

2210: Info Technology Mgmt. 6.15% 7.60% 4.17% 5.40% 1.98% 2.20%

Disability Employment Program

In FY 2021, Treasury exceeded all established goals for PWD and PWTD. 

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

rate of 8.82 percent for PWD and 1.71 percent for PWTD. At the end of FY 2021, Treasury is pleased to note that 

we have exceeded the 12 percent goal of participation rates for PWD (13.86 percent) and the goal of 2 percent for 

PWTD (3.36 percent). Treasury also exceeded the new hire goals of 12 percent PWD and 2 percent PWTD with 13.01 

percent of hires being PWD and 2.48 percent were PWTD. 

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

FY 2021 Disability Participation Rates by Bureau

Bureau Total PWD # PWD % PWTD # PWTD %

BEP 1803 355 19.69 45 2.50

DO 1952 204 10.45 31 1.59

FINCEN 279 47 16.85 9 3.23

FS 3618 967 26.73 164 4.53

IRS 79028 10524 13.32 2579 3.49

IRS-CC 2101 197 9.23 39 1.86

MINT 1586 373 23.52 68 4.29

OCC 3547 342 9.64 64 1.80

OIG 204 44 21.57 8 3.92

SIGT 32 1 3.13 0 0.00

TIGTA 731 87 11.90 6 0.82

TTB 488 78 15.98 13 2.66

Total 95369 13216 13.86 3206 3.36

The goals for the employment of PWD and PWTD include achieving a 12 percent participation rate for PWD at both the GS10 and below and at the GS-11 and above grades, as well as the goal to achieve a 2 percent participation rate for PWTD in 

both groups. We are pleased to note that Treasury’s current participation rates for PWD (14.69 percent) and PWTD (3.98 

percent) at the grades GS-10 and below exceed the goals of 12 percent and 2 percent. The participation rate for PWD 

(12.84 percent) and PWTD (2.70 percent) at the grades GS-11 and above exceed the goals of 12 percent and 2 percent. 

During FY 2021, Treasury continued to utilize OPM’s Talent Portal located on USAJobs as a resume mining database 

for veterans. Using the Talent Portal provided Treasury and its bureaus’ hiring managers access to resumes of qualified 

candidates with disabilities and veterans. The use of this tool continues to assist Treasury in meeting its participation 

rate goals and encourages the use of special hiring authorities, such as Schedule A and the hiring authority for veterans 

with 30 percent or more compensable disability.
FY 2021 MD-715 REPORT I 25

OCRD has posted its Personal Assistance Service (PAS) policy and procedures to the internal and external Treasury 

websites. The external link is https://www.treasury.gov/about/organizational-structure/offices/Mgt/Pages/eeo_

programs.aspx. In addition, the Department continued a Treasury-wide Blanket Purchase Agreement (BPA) to facilitate 

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

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

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

and Manager’s Alerts. Through these varied sources, the Department ensures that hiring managers are informed of 

and encouraged to use various resources and tools that help with the employment of PWD, e.g., CAREERS and the 

disABLED, OPM’s Bender Consulting Services, the Division of Rehabilitation Services (DORS), and State Vocational 

Rehabilitation Agencies. 

Treasury Complaint Program 

OCRD tracks all EEO complaints filed by Treasury employees and applicants for employment with an integrated data 

management complaint system (iComplaints). OCRD has a contract in place that serves as the systems administrator 

for the iComplaints system. 

Complaint Activity

Treasury timely submitted the EEOC 462 Report in October 2020. The 462 Report is an annual assessment of the 

agency’s formal and informal complaints. This report also provides the methods used for resolution prior to and during 

the complaint process. During FY 2021, the number of EEO complaints filed by Treasury employees and applicants 

(315) decreased by 6% when compared to the number of complaints filed in FY 2020 (334).

At the close of FY 2021, the Department had 464 complaints pending that were carried over to FY 2020. During 

FY 2021, 315 complaints were filed, with an additional seven cases remanded back to the agency by the EEOC, and 

Treasury closed 398 complaints. 

In FY 2021, the Department’s bureaus timely completed 99% of EEO counselings.

By the end of FY 2021, the Department completed 232 investigations. There were 175 investigations (75%) 

completed within 180 days, 54 (23%) completed between 181-360 days and 3 (1%) were completed in 361 or more 

days. Overall, 94% (219) of all investigations were timely completed.

FY17 FY18 FY19 FY20 FY21

Complaints Filed 367 447 395 334 315

0

50

100

150

200

250

300

350

400

450

500

Complaints Filed FY 2017 to FY 2021

FY17 FY18 FY19 FY20 FY21

Male Female

FY 2012 37.13% 62.87%

FY 2021 38.62% 61.38%

RCLF 40.53% 59.47%

0.00%

20.00%

40.00%

60.00%

80.00%

FY 2021 Participation Rates by Sex

 Complaints Filed 367 447 395 334 315
26 I FY 2021 MD-715 REPORT 

In FY 2021, the Department issued 155 final agency decisions in cases where a hearing was not requested. Of these 

decisions, 112 were merit decisions and 43 were procedural dismissals. In FY 2021, two (2) final agency decisions 

resulted in findings of discrimination.

Overall, in FY 2021, the Department processed 112 merit decisions within an average of 46 processing days, which 

is below the 60 processing days mandated by EEOC. Of those merit decisions, 96% (109) were timely issued within 

60 days of receipt of the decision request. The Department also issued 137 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 in 

which the agency appealed the finding and remedy. 

At the end of FY 2021, the Department had 386 complaints pending. Pending complaints can be at the 

acknowledgement, investigation, hearing, or final agency decision stages. At the end of FY 2021, 23% of pending 

complaints were at the investigation stage. Sixty-one percent (61%) were pending a hearing before an EEOC 

Administrative Judge. A total of 41 (11%) of the complaints remained pending in the final agency decision/action phase 

with the remaining 19 (5%) pending decision to accept/dismiss. 

In FY 2021, the Department’s most frequently cited bases for complaints are reprisal, disability (physical), and race 

(Black), and the most frequently cited issues are harassment (non-sexual), performance evaluation/appraisal, and 

terms/condition of employment.

In addition, the percentage of Treasury employees who filed formal EEO complaints decreased from 0.33 percent of the 

workforce in FY 2020 (312 complainants) to 0.29 percent of the workforce in FY 2021 (281 complainants).

Alternative Dispute Resolution (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) or ADR methods. 

In FY 2021, 92% of EEO counseling contacts were offered ADR, and 55% of those offered ADR participated in ADR at 

the informal level, a 7% decrease in the ADR participation rate from FY 2020.

ADR Offered (Informal)

FY 2021

Total Completed Counseling 650

Total ADR Offered 600

Total Accepted 328

Offer Rate 92%

Acceptance Rate 55%

In the formal complaint process, during FY 2021, the Department achieved an 89% ADR offer rate and 16% 

participation rate, a 5% increase from the FY 2020 ADR participation rate.

ADR Offered (Formal)

FY 2021

Formal Closed Complaints 398

Total ADR Offered 354

Total Accepted 57

Offer Rate 89%

Acceptance Rate 16%
FY 2021 MD-715 REPORT I 27

Due to the pandemic, the Department was unable to schedule its annual Dispute Prevention Program (DPW) training.

Shared Neutrals Program

For FY 2021, the TSN completed a total of 189 mediations. Of these 189 mediations, TSN mediators successfully 

resolved 66 (35%) disputes. Also, in FY 2021, the TSN Program re-certified 48 out of 50 of its existing cadre members 

to serve as mediators until FY 2023 and TSN Administrator functions were transferred to the Office of Civil Rights and 

Diversity (OCRD). 

Accomplishments

Compliance

• Worked to implement the requirements to ensure compliance with Administration priorities in the following 

Executive Orders (EOs): 13985, Advancing Racial Equity and Support for Underserved Communities Through 

the Federal Government; 13950, Combating Race and Sex Stereotyping (until it was revoked in January 2021), 

13988, Preventing and Combating Discrimination on the Basis of Gender Identity or Sexual Orientation; and 

14035, Advancing Diversity, Equity, Inclusion, and Accessibility in the Federal Workforce. 

• To further enhance Treasury’s commitment to diversity, equity, inclusion, and accessibility, and in response 

to President Biden’s administrative priorities outlined in EOs 13985 and 14035, Treasury hired its first ever 

Counselor for Racial Equity, who is located within the Office of the Deputy Secretary.

• Through Treasury’s Bureau Audit Program, reviewed all phases of DO’s EEO programs, including D&I and the EEO 

complaint processes.

• Assist DASHR-CHCO with the Human Capital Evaluations of the Mint’s and IRS’s EEO and D&I programs.

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

practices, and concerns, and the various EEO programs and activities conducted by the Bureau EEO Offices.

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

informative, and user-friendly content. 

Complaints Program

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

with the bureaus’ ADR Coordinators to establish a Working Group to increase Treasury’s ADR participation 

and settlement rates. Developed a list of best practices and documents that bureaus could use to improve ADR 

participation and settlement. 

• Monitored the Treasury Complaint Management System to ensure continued improvement in the timely production 

of final agency decisions and EEO investigations, resulting in at least 94% timeliness rate for investigations and 96% 

timeliness for decisions.

• Oversaw the Department’s informal EEO process to timely complete 99% of EEO counselings.

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

• Ensured TSN mediators met re-certification status to remain active cadre members.

Diversity and Inclusion Program

• Distributed Treasury’s D&I and EEO Strategic Plan (FY 2021-2024) to Treasury Bureau EEO and D&I Officers

• Maintained a cadre of certified trainers to assist the Department in providing Civil Treatment Training to the workforce. 

• Supported special emphasis programs with education and awareness using newsletters, trainings, observances, 

and activities. 

• Supported all five Treasury-wide ERGs through regular meetings, training events, and other outreach opportunities.
28 I FY 2021 MD-715 REPORT 

• Partnered with Minority Serving Organizations such as Hispanic Association of Colleges and Universities (HACU), 

Historically Black Colleges and Universities (HBCUs) and Wounded Warrior Project (WWP) that support special 

emphasis programs nationwide providing advice and guidance for special emphasis program Managers on 

different subjects. 

• Partnered with internal and external stakeholders to coordinate the Treasury-wide virtual job fair that promoted 

treasury openings to HBCU and Minority Servicing Institution (MSI) students, alumni, and the public. The job fair 

provided occupational presentations to over 1200 participants. 

• Partnered with MSIs to coordinate and develop Federal Institute Partnership Trainings, 

• Senior Executive Service Leadership Mentoring Programs, career development events and informational meetings 

for approximately 5000 federal employees nationwide.

Disability Employment Program

• Treasury Veterans Employment Program Office (VEPO) partnered with external and internal stakeholders and 

attended three virtual job fairs designed for hiring of veterans and persons with disabilities.

• Continued to successfully implement the Treasury-wide Reasonable Accommodation (RA) Tracking System to 

improve the timeliness and efficiency of providing reasonable accommodations for qualified persons with disabilities 

and improve ability to track data around RAs.

• OCRD, with partners, developed the process to migrate IRS data to the Reasonable Accommodation (RA) 

tracking system.

• Treasury exceeded EEOC’s established goals for PWD (13.86 percent) and PWTD (3.36 percent) in the 

overall workforce.

• Treasury exceeded EEOC’s goal that 12 percent of all new permanent hires be PWD (13.86 percent) and the sub 

goal that 2 percent of those hires be PWTD (3.36 percent).

• Treasury exceeded EEOC’s established goals for PWD (14.69 percent) and PWTD (3.98 percent) in the GS-10 and 

below grades and in the GS-11 and above grades (12.84 percent/ 2.70 percent).

Workforce Demographics/Barrier Analysis

• In FY 2021, each bureau reviewed workforce data and identified one or two mission-critical and/or most populous 

occupations where female participation rates at the GS-13 and above grade levels consistently falls below the 

respective availability rate. 

• OCRD provided assistance with Treasury’s Enterprise Business Solutions (EBS) to prepare the FY 2022 transition 

from Monster Analytics to USAStaffing for applicant flow data.

• Conducted one-on-one training sessions with new EEO staff and MD-715 preparers on workforce data systems 

and the Treasury MD-715 reporting structure.

Planned Activities

Compliance

• Continue to implement the requirements to ensure compliance with Administration priorities in the following EOs: 

13985, 13950, 13988, and 14035. 

• Partner with Bureau EEO Officers to update and issue revised FY 2021-2024 Treasury-wide D&I and EEO Strategic 

Plan in compliance with EO 14035: Advancing Diversity, Equity, Inclusion and Accessibility in the Federal Workplace.

• Continue the Treasury Bureau Audit Program, reviewing two bureaus in all phases of their EEO programs, including 

D&I, external civil rights, and EEO complaint process.

• Assist DASHR-CHCO with scheduled Human Capital Evaluations of EEO and D&I programs.

• Continue quarterly EEO Directors meetings with the Bureau EEO Officers to discuss EEO emerging issues, best 
FY 2021 MD-715 REPORT I 29

practices and concerns, and the various EEO programs and activities conducted by the Bureau EEO offices.

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

accurate, informative, and user-friendly content.

Complaints Program

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

produce EEO reports and transfer data between users more efficiently.

• Improve Treasury ADR participation and settlement rates throughout FY 2022. 

• Partner with Treasury bureaus to improve ADR Program marketing strategies and evaluation processes.

• Gradually phase-out the TSN Program and move mediation coordination to each bureau’s EEO Program Office. 

Diversity and Inclusion Program

• Partner with Bureau EEO Officers to establish and implement Treasury’s DEIA Strategic Plan pursuant to EO 

14035. 

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

mission-critical occupations; design and conduct targeted activities to promote individuals from all backgrounds, 

including hosting at least three job fairs designed to improve diversity; and veterans and disability hiring. 

• Meet customer training needs by 1) continually sharing bureau requests for training to the Department’s 

Training Cadre, comprised of bureau EEO and Diversity specialists, to facilitate; 2) providing at least one webinar 

or management alert each quarter to increase awareness; 3) providing on-line training and/or train-the-trainer 

opportunities on cultural competencies where possible.

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

• Publish OCRD Advisory Newsletters to the workforce and Manager’s Alerts to managers and supervisors 

on information relevant to EEO complaint program matters, changes to policy and/or procedures, workforce 

statistics, and important upcoming agency events/activities.

Disability Employment Program

• Enhance communications and marketing plans to continually educate managers and employees on Treasury’s 

personal assistance services (PAS) policy and procedures pursuant to the implementation of Treasury-wide PAS 

contract.

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

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

from all backgrounds, including hosting at least three job fairs designed to improve diversity, and veterans and 

disability hiring. 

• OCRD will instruct Bureaus to assess their internal and external websites and vacancy announcements to ensure 

accessibility to individuals with disability, and implement changes where required.

• Celebrate the FY 2022 National Defense Employment Awareness Month (NDEAM)) with a Treasury-wide event, to 

pay tribute to the accomplishments of the Treasury men and women with disabilities and bring awareness of the 

challenges persons with disabilities are confronted in the workplace.

Workforce Demographics/Barrier Analysis

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

strategies to eliminate and barriers that are uncovered.

• Continue to assist EBS with the transition from Monster Analytics to USAStaffing for applicant flow data.
30 I FY 2021 MD-715 REPORT 

Part F: Certification of Establishment of Continuing 

Equal Employment Opportunity Programs`

Department of the Treasury FY 2021 MD-715 Report 

31 | Page

Part F: Certification of Establishment of Continuing 

Equal Employment Opportunity Programs 

I, Snider Page, Acting Director, Office of Civil Rights and Diversity, 0260, GS-15 , am the 

(Insert name above) (Insert official/title/series/grade above) 

Principal EEO Director/Official for the Department of the Treasury 

(Insert Agency/Component Name above) 

The agency has conducted an annual self-assessment of Section 717 and Section 501 programs 

against the essential elements as prescribed by EEO MD-715. If an essential element was not fully 

compliant with the standards of EEO MD-715, a further evaluation was conducted, and, as appropriate, 

EEO Plans for Attaining the Essential Elements of a Model EEO Program, are included with this 

Federal Agency Annual EEO Program Status Report.

The agency has also analyzed its workforce profiles and conducted barrier analyses aimed at detecting 

whether any management or personnel policy, procedure, or practice is operating to disadvantage any 

group based on race, national origin, sex, or disability. EEO Plans to Eliminate Identified Barriers, as 

appropriate, are included with this Federal Agency Annual EEO Program Status Report.

I certify that proper documentation of this assessment is in place and is being maintained for EEOC 

review upon request. 

04/15/2022 

Signature of Principal EEO Director/Official Date 

Certifies that this Federal Agency Annual EEO Program Status Report is in compliance with the EEO 

MD-715. 

Signature of Agency Head or Agency Head Designee Date 

Snider Page Digitally signed by Snider Page 

Date: 2022.04.15 18:41:10 -04'00'

John T. Norris Digitally signed by John T. Norris 

Date: 2022.04.25 14:21:10 -04'00'
FY 2021 MD-715 REPORT I 31

PART G: Agency Self-Assessment Checklist

Essential Element A: Demonstrated Commitment From agency Leadership

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

discrimination-free workplace.

u

Compliance Indicator

q

Measures

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

EEO policy statement.

Measure Met?

(Yes/No/NA)

Comments

A.1.a Does the agency annually issue a signed and dated 

EEO policy statement on agency letterhead that 

clearly communicates the agency’s commitment 

to EEO for all employees and applicants? If “yes”, 

please provide the annual issuance date in the 

comments column. [see MD-715, II(A)]

Yes Issued 9/1/2021

Secretary’s EO Policy

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

protected bases (age, color, disability, sex (including 

pregnancy, sexual orientation and gender 

identity), genetic information, national origin, race, 

religion, and reprisal) contained in the laws EEOC 

enforces? [see 29 CFR § 1614.101(a)] 

Yes Policy also covers parental status.

u

Compliance Indicator

q

Measures

A.2 – The agency has communicated EEO policies 

and procedures to all employees.

Measure Met?

(Yes/No/NA)

Comments

A.2.a Does the agency disseminate the following policies 

and procedures to all employees:

A.2.a.1 Anti-harassment policy? [see MD 715, II(A)] Yes

A.2.a.2 Reasonable accommodation procedures? [see 29 

C.F.R § 1614.203(d)(3)]

Yes

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

information throughout the workplace and on its 

public website: 

A.2.b.1 The business contact information for its EEO 

Counselors, EEO Officers, Special Emphasis 

Program Managers, and EEO Director? [see 29 

C.F.R § 1614.102(b)(7)]

Yes Treasury annually displays and 

updates the name and contact 

information for bureau EEO Officers 

(Bureau EEO Offices). Bureaus 

display the specific bureau contact 

information. At each Treasury 

bureau, counseling is centralized; 

therefore, bureaus post general 

contact information on who to 

contact to initiate a complaint.
32 I FY 2021 MD-715 REPORT 

A.2.b.2 Written materials concerning the EEO program, 

laws, policy statements, and the operation of 

the EEO complaint process? [see 29 C.F.R § 

1614.102(b)(5)]

Yes (External)

OCRD Policies

A.2.b.3 Reasonable accommodation procedures? [see 29 

C.F.R. § 1614.203(d)(3)(i)] If so, please provide the 

internet address in the comments column.

Yes (External)

OCRD Policies

 A.2.c Does the agency inform its employees about the 

following topics: 

A.2.c.1 EEO complaint process? [see 29 CFR §§ 

1614.102(a)(12) and 1614.102(b)(5)] If “yes”, 

please provide how often. 

Yes It is posted on external (EEO 

Complaint Processing) website, 

discussed as part of new employee 

and manager orientation sessions, 

and it is posted in common areas/

breakrooms. Additionally, every 

two years as part of the No FEAR 

Act training, the information is 

shared with employees. New 

employees are required to take 

the No FEAR Act training within 

90 days of onboarding.

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

please provide how often. 

Yes It is posted on both the internal 

(ADR) and external (OCRD Policies) 

websites and discussed as part 

of new employee and manager 

orientation sessions. Additionally, 

Treasury conducts an annual 

Conflict Resolution week which 

highlights the importance of ADR 

and conflict resolution. 

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

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

provide how often. 

Yes It is posted on the internal (RA 

Program) and external websites 

(EEO FAQ) and discussed during 

new employee and manager 

orientation sessions. Additionally, 

every two years as part of the No 

FEAR Act training, the information 

is shared with employees. New 

employees are required to take 

the No FEAR Act training within 90 

days of onboarding.
FY 2021 MD-715 REPORT I 33

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

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

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

Yes It is posted on both the internal 

(Anti-Harassment Policy) and 

external websites (EEO FAQ) and 

discussed during new employee 

and manager orientation sessions. 

Additionally, as part of the No 

FEAR Act training and annually as 

part of the Prevention of Sexual 

Harassment (POSH) training.

A.2.c.5 Behaviors that are inappropriate in the workplace 

and could result in disciplinary action? [5 CFR § 

2635.101(b)] If “yes”, please provide how often.

Yes It is discussed in new employee 

and manager orientation sessions, 

included as part of the No FEAR 

Act training conducted every two 

years, and provided annually as 

part of the POSH training. New 

employees are required to take 

the No FEAR Act training within 90 

days of onboarding.

u

Compliance Indicator

q

Measures

A.3 – The agency assesses and ensures EEO 

principles are part of its culture.

Measure Met?

(Yes/No/NA)

Comments

A.3.a Does the agency provide recognition to employees, 

supervisors, managers, and units demonstrating 

superior accomplishment in equal employment 

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

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

comments section.

Yes Bureaus identified the Annual 

Rittenhouse Award, performance 

awards (mandatory diversity and 

inclusion (D&I) and supervisory 

performance goals), monetary and 

non-monetary group, and individual 

spot awards.

A.3.b Does the agency utilize the Federal Employee 

Viewpoint Survey or other climate assessment 

tools to monitor the perception of EEO principles 

within the workforce? [see 5 CFR Part 250]

Yes

Essential Element B: Integration of EEO into the agency’s Strategic Mission

This element requires that the agency’s EEO programs are structured to maintain a workplace that is free from 

discrimination and support the agency’s strategic mission.

u

Compliance Indicator

q

Measures

B.1 - The reporting structure for the EEO program 

provides the principal EEO official with appropriate 

authority and resources to effectively carry out a 

successful EEO program.

Measure Met?

(Yes/No/NA)

Comments

B.1.a Is the agency head the immediate supervisor 

of the person (“EEO Director”) who has day-today control over the EEO office? [see 29 CFR 

§1614.102(b)(4)] 

No OCRD’s Director reports to 

the Assistant Secretary for 

Management (ASM), who is the 

EEO Officer for Treasury.
34 I FY 2021 MD-715 REPORT 

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

head, does the EEO Director report to the same 

agency head designee as the mission-related 

programmatic offices? If “yes,” please provide the 

title of the agency head designee in the comments.

Yes OCRD’s Director reports to the 

ASM, who is the EEO Officer for 

Treasury.

B.1.a.2 Does the agency’s organizational chart clearly 

define the reporting structure for the EEO office? 

[see 29 CFR §1614.102(b)(4)]

Yes

B.1.b Does the EEO Director have a regular and 

effective means of advising the agency head 

and other senior management officials of the 

effectiveness, efficiency and legal compliance 

of the agency’s EEO program? [see 29 CFR 

§1614.102(c)(1); MD-715 Instructions, Sec. I] 

Yes

B.1.c During this reporting period, did the EEO Director 

present to the head of the agency, and other 

senior management officials, the “State of 

the agency” briefing covering the six essential 

elements of the model EEO program and the 

status of the barrier analysis process? [see MD715 Instructions, Sec. I)] If “yes”, please provide 

the date of the briefing in the comments column. 

Yes OCRD presented the FY 2020 

State of the Agency (SOA) briefing 

to the Agency Head Designee 

(ASM) in April 2021 and the 

Secretary and Deputy Secretary of 

the Treasury in September 2021.

B.1.d Does the EEO Director regularly participate in 

senior-level staff meetings concerning personnel, 

budget, technology, and other workforce issues? 

[see MD-715, II(B)]

Yes

u

Compliance Indicator

q

Measures

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

EEO program.

Measure Met?

(Yes/No/NA)

Comments

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

implementation of a continuing affirmative 

employment program to promote EEO and to 

identify and eliminate discriminatory policies, 

procedures, and practices? [see MD-110, Ch. 1(III)

(A); 29 CFR §1614.102(c)] 

Yes

B.2.b Is the EEO Director responsible for overseeing 

the completion of EEO counseling [see 29 CFR 

§1614.102(c)(4)]

Yes Bureau EEO Officers are responsible 

for counseling in connection with 

their respective bureau EEO 

complaints of discrimination.

B.2.c Is the EEO Director responsible for overseeing 

the fair and thorough investigation of EEO 

complaints? [see 29 CFR §1614.102(c)(5)] 

[This question may not be applicable for certain 

subordinate level components.]

Yes
FY 2021 MD-715 REPORT I 35

B.2.d Is the EEO Director responsible for overseeing 

the timely issuance of final agency decisions? 

[see 29 CFR §1614.102(c)(5)] [This question 

may not be applicable for certain subordinate 

level components.]

Yes

B.2.e Is the EEO Director responsible for ensuring 

compliance with EEOC orders? [see 29 CFR §§ 

1614.102(e); 1614.502]

Yes

B.2.f Is the EEO Director responsible for periodically 

evaluating the entire EEO program and providing 

recommendations for improvement to the agency 

head? [see 29 CFR §1614.102(c)(2)]

Yes

B.2.g If the agency has subordinate level components, 

does the EEO Director provide effective guidance 

and coordination for the components? [see 29 

CFR §§ 1614.102(c)(2) and (c)(3)]

Yes

u

Compliance Indicator

q

Measures

B.3 - The EEO Director and other EEO professional 

staff are involved in, and consulted on, 

management/personnel actions.

Measure Met?

(Yes/No/NA)

Comments

B.3.a Do EEO program officials participate in agency 

meetings regarding workforce changes that 

might impact EEO issues, including strategic 

planning, recruitment strategies, vacancy 

projections, succession planning, and selections 

for training/career development opportunities? 

[see MD-715, II(B)]

Yes

B.3.b Does the agency’s current strategic plan 

reference EEO / diversity and inclusion 

principles? [see MD-715, II(B)] If “yes”, please 

identify the EEO principles in the strategic plan in 

the comments column. 

Yes Treasury’s Strategic Goal 5.1.C

Improve diversity and engagement 

through transparency, fairness, 

and inclusion.

u

Compliance Indicator

q

Measures

B.4 - The agency has sufficient budget and staffing 

to support the success of its EEO program.

Measure Met?

(Yes/No/NA)

Comments

B.4.a Pursuant to 29 CFR §1614.102(a)(1), has the 

agency allocated sufficient funding and qualified 

staffing to successfully implement the EEO 

program, for the following areas: 

B.4.a.1 to conduct a self-assessment of the agency for 

possible program deficiencies? [see MD-715, II(D)]

Yes

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

analysis of its workforce? [see MD-715, II(B)]

Yes
36 I FY 2021 MD-715 REPORT 

B.4.a.3 to timely, thoroughly, and fairly process 

EEO complaints, including EEO counseling, 

investigations, final agency decisions, and legal 

sufficiency reviews? [see 29 CFR § 1614.102(c)

(5) & 1614.105(b) – (f); MD-110, Ch. 1(IV)(D) & 

5(IV); MD-715, II(E)]

Yes

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

training on the EEO program, including but not 

limited to retaliation, harassment, religious 

accommodations, disability accommodations, 

the EEO complaint process, and ADR? [see 

MD-715, II(B) and III(C)] If not, please identify the 

type(s) of training with insufficient funding in the 

comment column. 

Yes

B.4.a.5 to conduct thorough, accurate, and effective 

field audits of the EEO programs in components 

and the field offices, if applicable? [see 29 CFR 

§1614.102(c)(2)]

Yes

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

harassment policies, EEO posters, reasonable 

accommodations procedures)? [see MD-715, II(B)]

Yes

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

systems for the following types of data: complaint 

tracking, workforce demographics, and applicant 

flow data? [see MD-715, II(E)]. If not, please 

identify the systems with insufficient funding in the 

comments section.

Yes

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

programs (such as, Federal Women’s Program, 

Hispanic Employment Program, and People with 

Disabilities Program Manager)? [5 USC § 7201; 

38 USC § 4214; 5 CFR § 720.204; 5 CFR § 

213.3102(t) and (u); 5 CFR § 315.709]

Yes

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

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

Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(1999), § V.C.1]

Yes

B.4.a.10 to effectively manage its reasonable 

accommodation program? [see 29 CFR § 

1614.203(d)(4)(ii)] 

Yes

B.4.a.11 to ensure timely and complete compliance with 

EEOC orders? [see MD-715, II(E)]

Yes

B.4.b Does the EEO office have a budget that is separate 

from other offices within the agency? [see 29 CFR 

§ 1614.102(a)(1)]

Yes
FY 2021 MD-715 REPORT I 37

B.4.c Are the duties and responsibilities of EEO officials 

clearly defined? [see MD-110, Ch. 1(III)(A), 2(III), 

& 6(III)]

Yes

B.4.d Does the agency ensure that all new counselors and 

investigators, including contractors and collateral 

duty employees, receive the required 32 hours of 

training, pursuant to Ch. 2(II)(A) of MD-110?

Yes

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

counselors and investigators, including 

contractors and collateral duty employees, receive 

the required 8 hours of annual refresher training, 

pursuant to Ch. 2(II)(C) of MD-110?

Yes

u

Compliance Indicator

q

Measuress

B.5 – The agency recruits, hires, develops, and 

retains supervisors and managers who have 

effective managerial, communications, and 

interpersonal skills.

Measure Met?

(Yes/No/NA)

Comments

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

managers and supervisors received training on 

their responsibilities under the following areas 

under the agency EEO program:

B.5.a.1 EEO Complaint Process? [see MD-715(II)(B)] Yes

B.5.a.2 Reasonable Accommodation Procedures? [see 29 

C.F.R. § 1614.102(d)(3)]

Yes

B.5.a.3 Anti-Harassment Policy? [see MD-715(II)(B)] Yes

B.5.a.4 Supervisory, managerial, communication, and 

interpersonal skills in order to supervise most 

effectively in a workplace with diverse employees 

and avoid disputes arising from ineffective 

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

Yes

B.5.a.5 ADR, with emphasis on the federal government’s 

interest in encouraging mutual resolution of 

disputes and the benefits associated with utilizing 

ADR? [see MD-715(II)(E)]

Yes

u

Compliance Indicator

q

Measures

B.6 – The agency involves managers in the 

implementation of its EEO program.

Measure Met?

(Yes/No/NA)

Comments

B.6.a Are senior managers involved in the 

implementation of Special Emphasis Programs? 

[see MD-715 Instructions, Sec. I]

Yes

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

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

Yes
38 I FY 2021 MD-715 REPORT 

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

assist in developing agency EEO action plans (Part 

I, Part J, or the Executive Summary)? [see MD715 Instructions, Sec. I]

Yes

B.6.d Do senior managers successfully implement EEO 

Action Plans and incorporate the EEO Action Plan 

Objectives into agency strategic plans? [29 CFR § 

1614.102(a)(5)]

Yes

Essential Element C: Management and Program Accountability

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

effective implementation of the agency’s EEO Program and Plan.

u

Compliance Indicator

q

Measures

C.1 – The agency conducts regular internal audits 

of its component and field offices.

Measure Met?

(Yes/No/NA)

Comments

C.1.a Does the agency regularly assess its component 

and field offices for possible EEO program 

deficiencies? [see 29 CFR §1614.102(c)(2)] If 

”yes”, please provide the schedule for conducting 

audits in the comments section.

Yes Annually, and before the submission 

of the bureau MD-715 reports 

to EEOC, OCRD evaluates their 

submissions and provides feedback 

on the status of deficiencies, 

implementation of planned 

activities to mitigate deficiencies, 

and recommends additional 

measures required to mitigate 

noted deficiencies. 

In FY 2021, OCRD conducted an 

audit review of DO’s EEO and D&I 

programs. OCRD plans to conduct 

two bureau audits in FY 2022 

and will also participate in Human 

Capital Evaluations scheduled by 

the Treasury DASHR-CHCO.
FY 2021 MD-715 REPORT I 39

C.1.b Does the agency regularly assess its component 

and field offices on their efforts to remove barriers 

from the workplace? [see 29 CFR §1614.102(c)

(2)] If ”yes”, please provide the schedule for 

conducting audits in the comments section.

Yes Annually, and before the submission 

of the bureau MD-715 reports 

to EEOC, OCRD evaluates their 

submissions and provides feedback 

on the status of deficiencies, 

implementation of planned 

activities to mitigate deficiencies, 

and recommends additional 

measures required to mitigate 

noted deficiencies. 

In FY 2021, OCRD conducted 

an audit review of DO’s EEO and 

diversity and inclusion programs. 

OCRD plans to conduct two 

bureau audits in FY 2022 and will 

also participate in Human Capital 

Evaluations scheduled by the 

Treasury DASHR-CHCO.

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

efforts to comply with the recommendations of the 

field audit? [see MD-715, II(C)] 

Yes Following a bureau audit, within six 

months, bureaus are required to 

submit a compliance report 

to OCRD.

u

Compliance Indicator

q

Measures

C.2 – The agency has established procedures to 

prevent all forms of EEO discrimination.

Measure Met?

(Yes/No/NA)

Comments

C.2.a Has the agency established comprehensive antiharassment policy and procedures that comply 

with EEOC’s enforcement guidance? [see MD-715, 

II(C); Enforcement Guidance on Vicarious Employer 

Liability for Unlawful Harassment by Supervisors 

(Enforcement Guidance), EEOC No. 915.002, § 

V.C.1 (June 18, 1999)]

Yes

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

action to prevent or eliminate conduct before 

it rises to the level of unlawful harassment? 

[see EEOC Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1]

Yes

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

the Anti-Harassment Coordinator and the 

EEO Director? [see EEOC Report, Model 

EEO Program Must Have an Effective AntiHarassment Program (2006]

Yes
40 I FY 2021 MD-715 REPORT 

C.2.a.3 Does the agency have a separate procedure 

(outside the EEO complaint process) to address 

harassment allegations? [see Enforcement 

Guidance on Vicarious Employer Liability 

for Unlawful Harassment by Supervisors 

(Enforcement Guidance), EEOC No. 915.002, § 

V.C.1 (June 18, 1999)]

Yes

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

informs the anti-harassment program of all EEO 

counseling activity alleging harassment? [see 

Enforcement Guidance, V.C.]

Yes

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

(beginning within 10 days of notification) of all 

harassment allegations, including those initially 

raised in the EEO complaint process? [see 

Complainant v. Dep’t of Veterans Affairs, EEOC 

Appeal No. 0120123232 (May 21, 2015); 

Complainant v. Dep’t of Defense (Defense 

Commissary Agency), EEOC Appeal No. 

0120130331 (May 29, 2015)] If “no”, please 

provide the percentage of timely-processed 

inquiries in the comments column.

Yes

C.2.a.6 Do the agency’s training materials on its antiharassment policy include examples of disabilitybased harassment? [see 29 CFR 1614.203(d)(2)]Yes

C.2.b Has the agency established disability reasonable 

accommodation procedures that comply with 

EEOC’s regulations and guidance? [see 29 CFR 

1614.203(d)(3)]

Yes Treasury’s RA Policy and 

Procedures was approved by the 

EEOC on February 3, 2021.

At the end of FY 2021, all 

Treasury bureau Reasonable 

Accommodation Policies have been 

updated, reviewed, and approved by 

OCRD. The Policies were submitted 

to, and approved by, EEOC. 

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

other mechanism in place to coordinate or 

assist with processing requests for disability 

accommodations throughout the agency? [see 29 

CFR 1614.203(d)(3)(D)]

Yes

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

Reasonable Accommodation Program Manager 

and the EEO Director? [see MD-110, Ch. 1(IV)(A)]

Yes

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

request and receive reasonable accommodations 

during the application and placement processes? 

[see 29 CFR 1614.203(d)(1)(ii)(B)]

Yes
FY 2021 MD-715 REPORT I 41

C.2.b.4 Do the reasonable accommodation procedures 

clearly state that the agency should process the 

request within a maximum amount of time (e.g., 20 

business days), as established by the agency in its 

affirmative action plan? [see 29 CFR 1614.203(d)

(3)(i)(M)]

Yes

C.2.b.5 Does the agency process all accommodation 

requests within the time frame set forth in 

its reasonable accommodation procedures? 

[see MD-715, II(C)] If “no”, please provide the 

percentage of timely-processed requests in the 

comments column.

No IRS reported that it timely 

processed 31% of its requests. IRS 

has prepared a Part H in their MD715 report that directly addresses 

this matter.

C.2.c Has the agency established procedures for 

processing requests for personal assistance 

services that comply with EEOC’s regulations, 

enforcement guidance, and other applicable 

executive orders, guidance, and standards? [see 

29 CFR 1614.203(d)(6)]

Yes

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

processing requests for Personal Assistance 

Services on its public website? [see 29 CFR § 

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

internet address in the comments column.

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

offices/management/civil-rightsand-diversity/eeo-and-civil-rightspolicies

u

Compliance Indicator

q

Measures

C.3 - The agency evaluates managers and 

supervisors on their efforts to ensure equal 

employment opportunity.

Measure Met?

(Yes/No/NA)

Comments

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

managers and supervisors have an element in 

their performance appraisal that evaluates their 

commitment to agency EEO policies and principles 

and their participation in the EEO program?

Yes

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

the performance of managers and supervisors 

based on the following activities:

C.3.b.1 Resolve EEO problems/disagreements/conflicts, 

including the participation in ADR proceedings? 

[see MD-110, Ch. 3.I]

Yes

C.3.b.2 Ensure full cooperation of employees under 

his/her supervision with EEO officials, such as 

counselors and investigators? [see 29 CFR 

§1614.102(b)(6)]

Yes

C.3.b.3 Ensure a workplace that is free from all forms 

of discrimination, including harassment and 

retaliation? [see MD-715, II(C)]

Yes
42 I FY 2021 MD-715 REPORT 

C.3.b.4 Ensure that subordinate supervisors have effective 

managerial, communication, and interpersonal 

skills to supervise in a workplace with diverse 

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

Yes

C.3.b.5 Provide religious accommodations when such 

accommodations do not cause an undue 

hardship? [see 29 CFR §1614.102(a)(7)]

Yes

C.3.b.6 Provide disability accommodations when such 

accommodations do not cause an undue 

hardship? [ see 29 CFR §1614.102(a)(8)]

Yes

C.3.b.7 Support the EEO program in identifying and 

removing barriers to equal opportunity. [see MD715, II(C)]

Yes

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

investigating and correcting harassing conduct. 

[see Enforcement Guidance, V.C.2]

Yes

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

issued by the agency, EEOC, and EEO-related 

cases from the Merit Systems Protection Board, 

labor arbitrators, and the Federal Labor Relations 

Authority? [see MD-715, II(C)]

Yes

C.3.c Does the EEO Director recommend to the agency 

head improvements or corrections, including 

remedial or disciplinary actions, for managers 

and supervisors who have failed in their EEO 

responsibilities? [see 29 CFR §1614.102(c)(2)]

Yes

C.3.d When the EEO Director recommends remedial 

or disciplinary actions, are the recommendations 

regularly implemented by the agency? [see 29 

CFR §1614.102(c)(2)]

Yes

u

Compliance Indicator

q

Measures

 C.4 – The agency ensures effective coordination 

between its EEO programs and Human Resources 

(HR) program.

Measure Met?

(Yes/No/NA)

Comments

C.4.a

Do the HR Director and the EEO Director meet 

regularly to assess whether personnel programs, 

policies, and procedures conform to EEOC laws, 

instructions, and management directives? [see 29 

CFR §1614.102(a)(2)]

Yes
FY 2021 MD-715 REPORT I 43

C.4.b Has the agency established timetables/schedules 

to review at regular intervals its merit promotion 

program, employee recognition awards program, 

employee development/training programs, and 

management/personnel policies, procedures, 

and practices for systemic barriers that may be 

impeding full participation in the program by all 

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

Yes

C.4.c Does the EEO office have timely access to 

accurate and complete data (e.g., demographic 

data for workforce, applicants, training programs, 

etc.) required to prepare the MD-715 workforce 

data tables? [see 29 CFR §1614.601(a)]

Yes

C.4.d Does the HR office timely provide the EEO office 

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

climate assessment surveys, and grievance data), 

upon request? [see MD-715, II(C)]

Yes

C.4.e Pursuant to Section II(C) of MD-715, does the EEO 

office collaborate with the HR office to:

Yes

C.4.e.1 Implement the Affirmative Action Plan for 

Individuals with Disabilities? [see 29 CFR 

§1614.203(d); MD-715, II(C)]

Yes

C.4.e.2 Develop and/or conduct outreach and recruiting 

initiatives? [see MD-715, II(C)]

Yes

C.4.e.3 Develop and/or provide training for managers and 

employees? [see MD-715, II(C)]

Yes

C.4.e.4 Identify and remove barriers to equal opportunity 

in the workplace? [see MD-715, II(C)]

Yes

C.4.e.5 Assist in preparing the MD-715 report? [see MD715, II(C)]Yes

u

Compliance Indicator

q

Measures

C.5 – Following a finding of discrimination, 

the agency explores whether it should take a 

disciplinary action.

Measure Met?

(Yes/No/NA)

Comments

C.5.a Does the agency have a disciplinary policy and/

or table of penalties that covers discriminatory 

conduct? [see 29 CFR § 1614.102(a)(6); see 

also Douglas v. Veterans Administration, 5 MSPR 

280 (1981)]

Yes

C.5.b When appropriate, does the agency discipline 

or sanction managers and employees 

for discriminatory conduct? [see 29 CFR 

§1614.102(a)(6)] If “yes”, please state the 

number of disciplined/sanctioned individuals 

during this reporting period in the comments.

Yes Managers/employees associated 

with the two administrative 

EEO cases where the agency 

found discrimination were 

disciplined/sanctioned.
44 I FY 2021 MD-715 REPORT 

C.5.c If the agency has a finding of discrimination (or 

settles cases in which a finding was likely), does 

the agency inform managers and supervisors 

about the discriminatory conduct? [see MD-715, 

II(C)]

Yes

u

Compliance Indicator

q

Measures

C.6 – The EEO office advises managers/

supervisors on EEO matters.

Measure Met?

(Yes/No/NA)

Comments

C.6.a Does the EEO office provide management/

supervisory officials with regular EEO updates on 

at least an annual basis, including EEO complaints, 

workforce demographics and data summaries, 

legal updates, barrier analysis plans, and special 

emphasis updates? [see MD-715 Instructions, 

Sec. I] If “yes”, please identify the frequency of the 

EEO updates in the comments column.

Yes The OCRD Director updates the 

ASM as issues arise. The OCRD 

Director also participates in 

the ASM’s bi-weekly senior staff 

meetings. Additionally, the ASM 

has direct access to Diversity 

Dashboards to view workforce 

demographics as needed.

C.6.b Are EEO officials readily available to answer 

managers’ and supervisors’ questions or 

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

Yes

Essential Element D: Proactive Prevention

This element requires that the agency head make early efforts to prevent discrimination and to identify and 

eliminate barriers to equal employment opportunity.

u

Compliance Indicator

q

Measures

D.1 – The agency conducts a reasonable 

assessment to monitor progress towards 

achieving equal employment opportunity 

throughout the year.

Measure Met?

(Yes/No/NA)

Comments

D.1.a Does the agency have a process for identifying 

triggers in the workplace? [see MD-715 

Instructions, Sec. I]

Yes

D.1.b Does the agency regularly use the following 

sources of information for trigger identification: 

workforce data; complaint/grievance data; exit 

surveys; employee climate surveys; focus groups; 

affinity groups; union; program evaluations; special 

emphasis programs; reasonable accommodation 

program; anti-harassment program; and/or 

external special interest groups? [see MD-715 

Instructions, Sec. I]

Yes

D.1.c Does the agency conduct exit interviews or 

surveys that include questions on how the agency 

could improve the recruitment, hiring, inclusion, 

retention and advancement of individuals with 

disabilities? [see 29 CFR 1614.203(d)(1)(iii)(C)]

Yes
FY 2021 MD-715 REPORT I 45

u

Compliance Indicator

q

Measures

D.2 – The agency identifies areas where barriers 

may exclude EEO groups (reasonable basis to act.)

Measure Met?

(Yes/No/NA)

Comments

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

identified triggers to find possible barriers? [see 

MD-715, (II)(B)]

Yes

D.2.b Does the agency regularly examine the impact 

of management/personnel policies, procedures, 

and practices by race, national origin, sex, and 

disability? [see 29 CFR §1614.102(a)(3)]

Yes

D.2.c Does the agency consider whether any group 

of employees or applicants might be negatively 

impacted prior to making human resource 

decisions, such as re-organizations and 

realignments? [see 29 CFR §1614.102(a)(3)]

Yes

D.2.d Does the agency regularly review the following 

sources of information to find barriers: complaint/

grievance data, exit surveys, employee climate 

surveys, focus groups, affinity groups, union, 

program evaluations, anti-harassment program, 

special emphasis programs, reasonable 

accommodation program; anti-harassment 

program; and/or external special interest groups? 

[see MD-715 Instructions, Sec. I] If “yes”, please 

identify the data sources in the comments column.

Yes Complaint data through 

iComplaints and workforce data 

and exit survey data through Data 

Insight and Monster Analytics. 

Information regarding Unions, 

reasonable accommodations, antiharassment, as well as any other 

required information is provided by 

the bureaus’ EEO and HR personnel 

upon request.

u

Compliance Indicator

q

Measures

D.3 – The agency establishes appropriate action 

plans to remove identified barriers.

Measure Met?

(Yes/No/NA)

Comments

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

to address the identified barriers, in particular 

policies, procedures, or practices? [see 29 CFR 

§1614.102(a)(3)]

Yes

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

the reporting period, did the agency implement a 

plan in Part I, including meeting the target dates 

for the planned activities? [see MD-715, II(D)] 

Yes

D.3.c Does the agency periodically review the 

effectiveness of the plans? [see MD-715, II(D)]

Yes
46 I FY 2021 MD-715 REPORT 

u

Compliance Indicator

q

Measures

D.4 – The agency has an affirmative action plan 

for people with disabilities, including those with 

targeted disabilities.

Measure Met?

(Yes/No/NA)

Comments

D.4.a Does the agency post its affirmative action 

plan on its public website? [see 29 CFR 

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

address in the comments.

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

offices/management/civil-rightsand-diversity

D.4.b Does the agency take specific steps to ensure 

qualified people with disabilities are aware of and 

encouraged to apply for job vacancies? [see 29 

CFR 1614.203(d)(1)(i)]

Yes

D.4.c Does the agency ensure that disability-related 

questions from members of the public are 

answered promptly and correctly? [see 29 CFR 

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

Yes

D.4.d Has the agency taken specific steps that are 

reasonably designed to increase the number of 

persons with disabilities or targeted disabilities 

employed at the agency until it meets the goals? 

[see 29 CFR 1614.203(d)(7)(ii)]

Yes

Essential Element E: Efficiency

This element requires the agency head to ensure that there are effective systems for evaluating the impact and 

effectiveness of the agency’s EEO programs and an efficient and fair dispute resolution process.

u

Compliance Indicator

q

Measures

E.1 - The agency maintains an efficient, fair, and 

impartial complaint resolution process.

Measure Met?

(Yes/No/NA)

Comments

E.1.a Does the agency timely provide EEO counseling, 

pursuant to 29 CFR §1614.105?

Yes In FY 21, 99% of EEO counselings 

were timely.

E.1.b Does the agency provide written notification of 

rights and responsibilities in the EEO process 

during the initial counseling session, pursuant to 

29 CFR §1614.105(b)(1)?

Yes

E.1.c Does the agency issue acknowledgment letters 

immediately upon receipt of a formal complaint, 

pursuant to MD-110, Ch. 5(I)?

Yes
FY 2021 MD-715 REPORT I 47

E.1.d Does the agency issue acceptance letters/

dismissal decisions within a reasonable time 

(e.g., 60 days) after receipt of the written EEO 

Counselor report, pursuant to MD-110, Ch. 5(I)? If 

so, please provide the average processing time in 

the comments.

Yes Treasury benchmark is to issue 

acceptance or dismissal letters no 

more than 30 days from file date.

FY 2021 Averages: Acceptance 

letters were issued on average 

in 19.7 days; and Dismissal 

letters were issued on average 

in 20.1 days.

E.1.e Does the agency ensure all employees fully 

cooperate with EEO counselors and EEO 

personnel in the EEO process, including granting 

routine access to personnel records related to 

an investigation, pursuant to 29 CFR 

§1614.102(b)(6)? 

Yes

E.1.f Does the agency timely complete investigations, 

pursuant to 29 CFR §1614.108?

Yes In FY 21, 94% of investigations 

were timely.

E.1.g If the agency does not timely complete 

investigations, does the agency notify 

complainants of the date by which the investigation 

will be completed and of their right to request 

a hearing or file a lawsuit, pursuant to 29 CFR 

§1614.108(g)?

Yes Correspondence is issued to 

complainant.

E.1.h When the complainant does not request a hearing, 

does the agency timely issue the final agency 

decision, pursuant to 29 CFR §1614.110(b)?

Yes In FY 21, 96% were timely.

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

following receipt of the hearing file and the 

administrative judge’s decision, pursuant to 29 

CFR §1614.110(a)?

Yes In FY 21, 97% were timely.

E.1.j If the agency uses contractors to implement 

any stage of the EEO complaint process, does 

the agency hold them accountable for poor 

work product and/or delays? [See MD-110, 

Ch. 5(V)(A)] If “yes”, please describe how in the 

comments column.

Yes OCRD contracts with the United 

States Postal Service to conduct 

its EEO investigations. We also 

have a contract with Martin Miser 

to serve as our backup for EEO 

investigations. OCRD meets with the 

EEO Investigators of each complaint 

frequently to discuss issues or 

concerns and ensure timeliness 

of the investigation. OCRD also 

conducts bi-weekly meetings to 

review the current status of all 

cases, discuss any instance where 

a case may be untimely and the 

reason for the untimeliness, and 

ensure there are no systemic 

problems in the process.
48 I FY 2021 MD-715 REPORT 

E.1.k If the agency uses employees to implement any 

stage of the EEO complaint process, does the 

agency hold them accountable for poor work 

product and/or delays during performance 

review? [See MD-110, Ch. 5(V)(A)]

Yes

E.1.l Does the agency submit complaint files and other 

documents in the proper format to EEOC through 

the Federal Sector EEO Portal (FedSEP)? [See 29 

CFR § 1614.403(g)]

Yes

u

Compliance Indicator

q

Measures

E.2 – The agency has a neutral EEO process. Measure Met?

(Yes/No/NA)

Comments

E.2.a Has the agency established a clear separation 

between its EEO complaint program and its 

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

Yes

E.2.b When seeking legal sufficiency reviews, 

does the EEO office have access to sufficient 

legal resources separate from the agency 

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

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

attorney who conducts the legal sufficiency review 

in the comments column. 

Yes Legal sufficiency reviews are 

conducted internally by the Asst. 

Director for Complaint Operations. 

If outside counsel is needed, we 

engage the Office of General 

Counsel, ensuring a firewall between 

any representational activities and 

providing advice to OCRD.

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

function to conduct the legal sufficiency review, is 

there a firewall between the reviewing attorney 

and the agency representative? [see MD-110, Ch. 

1(IV)(D)]

Yes

E.2.d Does the agency ensure that its agency 

representative does not intrude upon EEO 

counseling, investigations, and final agency 

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

Yes

E.2.e If applicable, are processing time frames 

incorporated for the legal counsel’s sufficiency 

review for timely processing of complaints? [see 

EEOC Report, Attaining a Model Agency Program: 

Efficiency (Dec. 1, 2004)]

Yes

u

Compliance Indicator

q

Measures

E.3 - The agency has established and encouraged 

the widespread use of a fair alternative dispute 

resolution (ADR) program.

Measure Met?

(Yes/No/NA)

Comments
FY 2021 MD-715 REPORT I 49

E.3.a Has the agency established an ADR program for 

use during both the pre-complaint and formal 

complaint stages of the EEO process? [see 29 

CFR §1614.102(b)(2)]

Yes

E.3.b Does the agency require managers and 

supervisors to participate in ADR once it has been 

offered? [see MD-715, II(A)(1)]

Yes

E.3.c Does the agency encourage all employees to use 

ADR, where ADR is appropriate? [see MD-110, 

Ch. 3(IV)(C)]

Yes

E.3.d Does the agency ensure a management official 

with settlement authority is accessible during the 

dispute resolution process? [see MD-110, Ch. 

3(III)(A)(9)]

Yes

E.3.e Does the agency prohibit the responsible 

management official named in the dispute from 

having settlement authority? [see MD-110, Ch. 3(I)]

Yes

E.3.f Does the agency annually evaluate the 

effectiveness of its ADR program? [see MD-110, 

Ch. 3(II)(D)]

Yes

u

Compliance Indicator

q

Measures

E.4 – The agency has effective and accurate 

data collection systems in place to evaluate its 

EEO program.

Measure Met?

(Yes/No/NA)

Comments

E.4.a Does the agency have systems in place to 

accurately collect, monitor, and analyze the 

following data:

E.4.a.1 Complaint activity, including the issues and bases 

of the complaints, the aggrieved individuals/

complainants, and the involved management 

official? [see MD-715, II(E)]

Yes

E.4.a.2 The race, national origin, sex, and disability 

status of agency employees? [see 29 CFR 

§1614.601(a)] 

Yes

E.4.a.3 Recruitment activities? [see MD-715, II(E)] Yes

E.4.a.4 External and internal applicant flow data 

concerning the applicants’ race, national origin, 

sex, and disability status? [see MD-715, II(E)]

Yes

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

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

Yes The Treasury-wide system to 

process and track reasonable 

accommodation requests went live 

in FY 2020.

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

Guidance on Vicarious Employer Liability for Unlawful 

Harassment by Supervisors (1999), § V.C.2]

Yes
50 I FY 2021 MD-715 REPORT 

E.4.b Does the agency have a system in place to resurvey the workforce on a regular basis? [MD-715 

Instructions, Sec. I]

Yes

u

Compliance Indicator

q

Measures

E.5 – The agency identifies and disseminates 

significant trends and best practices in its 

EEO program.

Measure Met?

(Yes/No/NA)

Comments

E.5.a Does the agency monitor trends in its EEO 

program to determine whether the agency is 

meeting its obligations under the statutes EEOC 

enforces? [see MD-715, II(E)] If “yes”, provide an 

example in the comments.

Yes Analysis tools include: EEOC 

annual reports, Complaint data, 

RA processing, exit survey 

results, FEVS results, analysis of 

workforce data by ERI, gender, 

disability, grades, occupation, hires, 

separations, awards, etc.

E.5.b Does the agency review other agencies’ best 

practices and adopt them, where appropriate, to 

improve the effectiveness of its EEO program? 

[see MD-715, II(E)] 

If “yes”, provide an example in the comments.

Yes Development of Workforce 

Analytics, Treasury’s automated 

data tool; Treasury-wide exit survey 

and analysis tool; Veteran and 

Disability Program “Be a Champion 

Roadshow;” use of unpaid 

internship programs to establish 

a pipeline of diverse candidates for 

future employment; and Veteran 

resume data base.

E.5.c Does the agency compare its performance in the 

EEO process to other federal agencies of similar 

size? [see MD-715, II(E)] 

Yes

Essential Element F: Responsiveness and Legal Compliance

This element requires federal agencies to comply with EEO statutes and EEOC regulations, policy guidance, and 

other written instructions.

u

Compliance Indicator

q

Measures

F.1 – The agency has processes in place to ensure 

timely and full compliance with EEOC Orders and 

settlement agreements.

Measure Met?

(Yes/No/NA)

Comments

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

controls to ensure that its officials timely comply 

with EEOC orders/directives and final agency 

actions? [see 29 CFR §1614.102(e); MD-715, II(F)] 

Yes

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

controls to ensure the timely, accurate, and 

complete compliance with resolutions/settlement 

agreements? [see MD-715, II(F)]

Yes
FY 2021 MD-715 REPORT I 51

F.1.c Are there procedures in place to ensure the timely 

and predictable processing of ordered monetary 

relief? [see MD-715, II(F)]

Yes

F.1.d Are procedures in place to process other forms of 

ordered relief promptly? [see MD-715, II(F)]

Yes

F.1.e When EEOC issues an order requiring compliance 

by the agency, does the agency hold its compliance 

officer(s) accountable for poor work product and/

or delays during performance review? [see MD110, Ch. 9(IX)(H)]

Yes

u

Compliance Indicator

q

Measures

F.2 – The agency complies with the law, including 

EEOC regulations, management directives, orders, 

and other written instructions.

Measure Met?

(Yes/No/NA)

Comments

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

with EEOC orders? [see 29 CFR §1614.502; 

MD-715, II(E)]

Yes

F.2.a.1 When a complainant requests a hearing, does the 

agency timely forward the investigative file to the 

appropriate EEOC hearing office? [see 29 CFR 

§1614.108(g)]

Yes

F.2.a.2 When there is a finding of discrimination that is 

not the subject of an appeal by the agency, does 

the agency ensure timely compliance with the 

orders of relief? [see 29 CFR §1614.501]

Yes

F.2.a.3 When a complainant files an appeal, does the 

agency timely forward the investigative file to 

EEOC’s Office of Federal Operations? [see 29 CFR 

§1614.403(e)]

Yes

F.2.a.4 Pursuant to 29 CFR §1614.502, does the 

agency promptly provide EEOC with the required 

documentation for completing compliance?

Yes

u

Compliance Indicator

q

Measures

F.3 - The agency reports to EEOC its program 

efforts and accomplishments.

Measure Met?

(Yes/No/NA)

Comments

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

accurate and complete No FEAR Act report? 

[Public Law 107-174 (May 15, 2002), §203(a)] 

Yes

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

its quarterly No FEAR Act data? [see 29 CFR 

§1614.703(d)]

Yes Public webpage: https://home.

treasury.gov/footer/no-fear-act
52 I FY 2021 MD-715 REPORT 

Part H: Agency EEO Plan to Attain the Essential Elements 

of a Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

o If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency

Type of Program Deficiency Brief Description of Program Deficiency

C.2.b Has the agency established disability reasonable accommodation procedures that comply 

with EEOC’s regulations and guidance? [see 29 CFR 1614.203(d)(3)]

As part of EEOC’s feedback on Treasury and its bureaus FY 2017 affirmative action plans, 

EEOC identified that Treasury and some of its bureaus RA policies and procedures had not 

been reviewed and approved based on changes required by the updated 29 CFR 1614.203.

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy)

Objective Target Date 

(mm/dd/yyyy)

Modified Date 

(mm/dd/yyyy)

Date Completed 

(mm/dd/yyyy)

10/01/2018 Ensure Treasury and its bureaus RA policies and 

procedures are in compliance with EEOC requirements 

and submitted to EEOC for final approval.

9/30/2019 9/30/2020

Responsible Official(s) 

Title Name Performance Standards Address the Plan? (Yes or No)

Director, OCRD Mariam Harvey Yes

Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy)

Planned Activities Sufficient Funding 

& Staffing? 

(Yes or No)

Modified Date 

(mm/dd/yyyy)

Completion 

Date 

(mm/dd/yyyy)

08/30/2018 Require bureaus to submit updated RA policies and 

procedures to OCRD for review and comment.

Yes 08/24/2018

09/07/2018 OCRD will review bureau RA policies and procedures 

and make any recommended changes. Those RA 

policies and procedures requiring change will be 

returned to the appropriate bureau for corrections. 

Yes 09/07/2018

01/30/2018 Once bureau RA policies and procedures are 

approved by OCRD, they will be submitted to EEOC 

for review and final approval. 

Yes 01/30/2018
FY 2021 MD-715 REPORT I 53

03/30/2018 Pending EEOC’s final approval of bureau RA policies 

and procedures, Bureaus will post interim RA policies 

and procedures to internal and external websites.

Yes 09/30/2020

03/30/2019 Once RA policies and procedures are approved by 

EEOC, bureaus post their EEOC approved RA policies 

and procedure to their internal 

and external. 

Yes 09/30/2020

Report of Accomplishments

Fiscal Year Accomplishments

2018 To date, OCRD has submitted the revised bureau RA policies and procedures to EEOC for BEP, FS, DO, IRS, Mint, 

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

with revisions. OCRD continues to work with FinCEN, IRS-CC, OIG, SIGTARP, and TTB to finalize the revisions to their 

RA Policies and procedures. 

2019 OCRD has submitted all bureau RA policies and procedures to EEOC with the exception of IRS. EEOC approved 

OCC’s revisions for its RA policy and procedures. OCRD is currently working with IRS to finalize their revisions and 

the RA policy and procedures. Once finalized, OCRD will submit to EEOC for final review and approval. OCRD is 

currently waiting for EEOC’s approval of the remaining bureaus.

2020 OCRD met with EEOC regarding the RA Policy and Procedures status. OCRD submitted to EEOC the remaining 

RAPs for final review and approval. The EEOC’s review was finalized at the end of FY 2020 resulting in a request for 

changes. OCRD received final approval from EEOC in FY 2021.

2021 Treasury’s RA Policy and Procedures was approved by the EEOC on February 3, 2021. Treasury’s approved policy 

will be entered into Treasury’s Official Directives and Departmental Offices Systems (TODDS) assignment database 

for regular monitoring and updates.

At the end of FY 2021, all Treasury bureau Reasonable Accommodation Policies have been updated, reviewed, and 

approved by OCRD. The Policies were submitted to, and approved by, EEOC. 

This deficiency is CLOSED.
54 I FY 2021 MD-715 REPORT 

Part H: Agency EEO Plan to Attain the Essential Elements 

of a Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

o If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency 

Type of Program Deficiency Brief Description of Program Deficiency

C.2.b.5 Does the agency process all accommodation requests within the time frame set forth in its 

reasonable accommodation (RA) procedures? [see MD-715, II(C)]. 

IRS reported that it processed 31% of RA requests within the time frame set forth in its 

revised RA procedures.

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy)

Objective Target Date 

(mm/dd/yyyy)

Modified Date 

(mm/dd/yyyy)

Date Completed 

(mm/dd/yyyy)

10/01/2018 Ensure timely initiation of inquiries for IRS reasonable 

accommodation requests.

9/30/2019 9/30/2020

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

accommodation tracking system.

9/30/2019 9/30/2020

Responsible Official(s) 

Title Name Performance Standards Address the Plan? (Yes or No)

Director, OCRD Mariam Harvey Yes

Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy)

Planned Activities Sufficient Funding 

& Staffing? 

(Yes or No)

Modified Date 

(mm/dd/yyyy)

Completion 

Date (mm/dd/

yyyy)

9/30/2019 Monitor implementation of IRS’s planned activities to 

eliminate untimely processing of RA requests.

Yes 9/30/2020

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

system.

Yes 04/04/2019

09/30/2019 Initiate procurement process to compete and award 

a RA tracking system contract.

Yes 09/24/2019

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

RA Tracking system.

Yes 09/30/2020

05/29/2020 Implement RA tracking system. Yes 07/30/2020
FY 2021 MD-715 REPORT I 55

09/30/2022 IRS will continue communication with OCRD and 

system moderators to implement enhancements for 

successful migration to Treasury-wide RA tracking 

system.

Yes

Report of Accomplishments 

Fiscal Year Accomplishments

2018 N/A

2019 IRS did not improve its timely processing of RA cases in FY 2019 (23% timely processed). As part of OCRD’s 

oversight, an audit was conducted of IRS’ EEO program from July to August 2019. Part of OCRD’s findings was 

the untimely processing of RA requests. As a recommendation for corrective action, OCRD encouraged IRS to 

complete a Lean Sigma 6 study of its current processes to determine where process improvements need to be 

made to ensure the timely processing of accommodation requests.

OCRD secured required funding for Treasury-wide RA tracking system and awarded the contract to MicroPact.

2020 In FY 2020, OCRD implemented the Treasury-wide RA tracking system, trained RA Coordinators, and transitioned 

the bureaus to the new system, with the exception of IRS. IRS requested further customization for the new system. 

In the interim, IRS maintained their prior RA tracking system. Implementation of the customized features are 

anticipated for FY 2021.

IRS slightly improved its timely processing of RA cases in FY 2020 (28% timely processed). In February 2020, 

the IRS began a Lean Six Sigma (LSS) evaluation of its RA processes. In July 2020, the LSS team concluded the 

data gathering phase of the study. In order to better position the LSS team to analyze the data and formulate 

recommendations on processes to increase efficiency in responding and fulfilling requests for reasonable 

accommodation, the IRS initiated additional partners to the process to include senior subject matter experts 

from the Facilities Management & Security Services and Information Technology functions. The LSS team expects 

to present its findings and recommendations for changes to leadership to implement processes in Fiscal Year 

2021. Those recommendations will need to be vetted with partner support functions and might necessitate either 

contract or impact bargaining with the union before implementation.

2021 As of June 2021, IRS continued to make improvements regarding timely processing of RA cases (31% timely 

processed). 

Following data gathering including eliciting input from all Business Units, the LSS team identified several ‘quickhits’ which were socialized with all Business Units and implemented. The quick-hits pertained to expediting 

accommodation request assessment and approval/denial as well as fulfillment of accommodation needs involving 

adaptive technology or furniture and workspace modifications. Preliminary data suggest the quick-hits are yielding 

beneficial results. An additional recommendation to maintain an inventory of hardware components commonly used 

to address RA needs was accepted and the Service is moving to address logistical challenges and establish the 

inventory. Having a ready inventory will expedite delivery of adaptive technology accommodations as procurement 

actions will already have taken place. One more proposal for reducing RA fulfillment time is being finalized.
56 I FY 2021 MD-715 REPORT 

Part H: Agency EEO Plan to Attain the Essential Elements of a 

Model EEO Program

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

o If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency 

Type of Program Deficiency Brief Description of Program Deficiency

C.2.a.5 Does the agency conduct a prompt inquiry (beginning within 10 days of notification) of 

all harassment allegations, including those initially raised in the EEO complaint process? 

[see Complainant v. Dep’t of Veterans Affairs, EEOC Appeal No. 0120123232 (May 21, 

2015); Complainant v. Dep’t of Defense (Defense Commissary Agency), EEOC Appeal No. 

0120130331 (May 29, 2015)], If “no”, please provide the percentage of timely-processed 

inquiries in the comments column.

Objective(s) and Dates for EEO Plan 

Date Initiated 

(mm/dd/yyyy)

Objective Target Date 

(mm/dd/yyyy)

Modified Date 

(mm/dd/yyyy)

Date Completed 

(mm/dd/yyyy)

10/01/2019 Ensure Treasury and its bureaus conduct a prompt 

inquiry (beginning within 10 days of notification) of all 

harassment allegations, including those initially raised 

in the EEO complaint process.

9/30/2020

Responsible Official(s) 

Title Name Performance Standards Address the Plan? (Yes or No)

Director, OCRD Mariam Harvey Yes

Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy)

Planned Activities Sufficient Funding 

& Staffing? 

(Yes or No)

Modified Date 

(mm/dd/yyyy)

Completion 

Date (mm/dd/

yyyy)

10/01/2019 Monitor implementation of FS and OCC’s planned 

activities to ensure prompt initiation (beginning within 

10 days of notification) of all harassment allegations, 

including those initially raised in the EEO complaint 

process.

Yes

10/01/2020 In FY 2020, OCRD will explore the procurement of a 

Treasury-wide Anti-Harassment Tracking System.

Yes 09/30/2020
FY 2021 MD-715 REPORT I 57

09/30/2021 In FY 2021, OCRD will meet with each of the bureaus 

to ensure they are accurately calculating timeframes 

for conducting Harassment inquiries. 

Yes

Report of Accomplishments 

Fiscal Year Accomplishments

2020 In FY 2020, OCRD worked with the Office of the Chief Information Officer (OCIO) to explore several solutions to 

serve as a Treasury-wide tracking system for anti-harassment complaints. OCRD actively demonstrated a system to 

determine its effectiveness. In FY 2021, OCRD will continue to work with OCIO to see if there is system suitable to 

meet Treasury’s requirements. 

In FY 2020, FS conducted 52 investigations, all of which were initiated within 10 calendar days of receipt of the 

complaint. This deficiency is CLOSED for FS.

In FY 2020, OCC conducted 40 investigations, of which 33 were timely (83%). On OCC’s Part G, it was stated that 

there were occasions in which employees who raised allegations failed to participate in the investigatory process 

or the process was extended. For example, after making allegations, employees resigned, went on extended leave, 

and/or failed to respond to requests for follow-up. In some instances, allegations were raised by management 

officials, with no follow through by the employees. Thus, efforts to conduct a prompt inquiry had to be postponed. 

The OCC will begin an internal review process in FY 2021 to examine the program and such occasions to 

determine if changes are needed.

2021 In FY 2021, OCC modified the Anti-Harassment policy for compliance with EEOC mandatory requirements; 

additionally, OCC modified and posted the annual training on safe workplaces and preventing sexual harassment 

for all employees and managers. Throughout FY 2021, OCC conducted mandatory orientation sessions for new 

managers, including topics such as Merit System Principles and Prohibited Personnel Practices. 

Based on the modified Anti-Harassment policy, OCC incorporated a more streamlined interface with Acquisitions in 

the Statement of Work (SOW) for the re-compete of the current investigatory contract. Within the updated SOW, 

language requiring contemporaneous inquiries to be conducted promptly and the availability of multiple investigators 

was inserted. 

Additionally, an EEO/Diversity Performance element was included for management annual reviews. This deficiency is 

CLOSED for OCC.
58 I FY 2021 MD-715 REPORT 

Part I: Agency EEO Plan to Eliminate Identified Barrier

Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, 

or practices for employees and applicants by race, ethnicity, and gender. 

o If the agency did not conduct barrier analysis during the reporting period, please check the box.

Statement of Condition That Was a Trigger for a Potential Barrier: 

Source of the Trigger Specific Workforce Data Table Narrative Description of Trigger

Lower than expected participation rates for Women in the GS 13-15 

and SES grade levels in the overall Treasury-wide workforce.

EEO Group(s) Affected by Trigger 

EEO Group

All Men

X All Women

Hispanic or Latino Males

Hispanic or Latino Females

White Males

White Females

Black or African American Males

Black or African American Females

Asian Males

Asian Females

Native Hawaiian or Other Pacific Islander Males

Native Hawaiian or Other Pacific Islander Females

American Indian or Alaska Native Males

American Indian or Alaska Native Females

Two or More Races Males

Two or More Races Females
FY 2021 MD-715 REPORT I 59

Barrier Analysis Process 

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

Workforce Data Tables Yes A-1: Review of overall workforce participation rate for Women (61.56 percent in FY 2019) 

falls below the RCLF availability rate (64.98 percent).

A4-1: At the GS-13 grade level, the participation rate for women increased by 0.83 

percent from 49.49 percent in FY 2009 to 50.32 percent in FY 2015. However, Treasury 

saw a 0.43 percent decreased participation rate for women at GS-13 grade level from 

FY 2015 (50.32 percent) to FY 2019 (49.89 percent). At the GS-14 grade level, the 

participation rate for women decreased by 0.78 percent from 47.44 percent in FY 2009 

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

percent. At the GS-15 grade level, the participation rate for women increased by 2.22 

percent from 44.65 percent in FY 2009 to 46.87 percent in FY 2015; but decreased by 

1.04 percent from FY 2015 to FY 2019 (45.83 percent). Furthermore, at the SES level, 

the participation rate for women increased by 4.72 percent from 35.71 percent in FY 

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

FY 2019.

A6: A review of the Treasury workforce broken down by the major occupations shows 

that of the 13 most populous major occupations, the participation rate for women falls 

below the Occupational CLF (OCLF) availability rate in the following six series:

• 0301: Miscellaneous Administration and Program, participation (60.18 percent) 

falls below the OCLF availability rate of 

63.30 percent;

• 0340: Program Management, participation (58.36 percent) falls below the OCLF 

availability rate of 63.30 percent;

• 0512: Internal Revenue Agent, participation (53.24 percent) falls below the OCLF 

availability rate of 64.20 percent;

• 0570: Financial Institution Examining, participation (38.38 percent) falls below the 

OCLF availability rate of 45.30 percent;

• 0962: Contact Representative, participation (71.71 percent) falls below the OCLF 

availability rate of 82.10 percent; and 

• 1169: Internal Revenue Officer, participation (57.95 percent) falls below the OCLF 

availability rate of 64.20 percent.

A4-1: Reviewing Table A4-1 for each occupation identified in the A6 Table as having lower 

than expected participation rates for Women:

• 0301: Miscellaneous Administration and Program at the GS-13 grade level, the 

participation rate for Women (61.43 percent) exceeds the availability rate (60.18 

percent); however, at the GS-14, 15, and SES grade levels, the participation rate for 

Women (58.15 percent, 44.18 percent, and 22.94 percent respectively) fall below 

the availability rate of 60.18 percent.
60 I FY 2021 MD-715 REPORT 

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

• 0340: Program Management

At the GS-13 grade level, the participation rate for Women (65.52 percent) 

exceeds the availability rate (58.36 percent); however, at the GS-14, 15, and SES 

grade levels, the participation rate for Women (57.46 percent, 51.58 percent, and 

45.83 percent respectively) fall below the availability rate of 58.36 percent.

• 0512: Internal Revenue Agent

At the GS-13, 15, and SES grade levels, the participation rate for Women (53.57 

percent, 53.33 percent, and 100.00 percent respectively) exceeds the availability 

rate (53.24 percent); however, at the GS-14 grade level, Women participation 

(47.09 percent) falls below the availability rate of 53.24 percent.

• 0570: Financial Institution Examining

At the GS-13 and 15 equivalent grade levels, the participation rate for Women 

(39.80 percent and 40.19 percent respectively) exceeds the availability rate (38.38 

percent); however, at the GS-14 and SES equivalent grade levels, the participation 

rate for Women (37.31 percent and 27.59 percent respectively) falls below the 

availability rate of 38.38 percent.

• 0962: Contact Representative

There are no positions in Treasury in the 0962 series at the GS-13 and above grade 

level. All positions in the 0962 series are GS-11 and below.

• 1169: Internal Revenue Officer

At the GS-13 and 14 grade levels, the participation rate for Women (54.96 percent 

and 47.52 percent respectively) falls below the availability rate (57.95 percent); 

however, at the GS-15 grade level, the participation rate for Women (60.00 

percent) exceeds the availability rate of 57.95 percent. There are no positions for 

the 1169 series at the SES level.

A7-1: A review of the new A7-1 Table shows the new hire and internal competitive 

promotions for GS-13 through 15 and SES grade levels.

GS-13

New Hires: For GS-13 new hires, the participation rate for Women applicants was 

43.19 percent, which fell to 42.50 percent at the qualified stage of the application 

process. The participation rate for Women continued to fall at the referred stage 

of the process where the participation rate for Women was 39.88 percent. The 

participation rate for Women increased at the interviewed stage of the process 

(48.59 percent); but fell again to 45.18 percent at the selected stage.

Internal Competitive Promotions: For GS-13 internal competitive promotions, the 

participation rate for Women applicants was 64.27 percent, and stayed at 64.14 

percent at the qualified stage. The participation rate dropped at the referred stage 

to 62.17 percent and fell again at the interviewed stage (61.47 percent); but 

increased at the selection stage to 62.27 percent.
FY 2021 MD-715 REPORT I 61

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

GS-14

New Hires: For GS-14 new hires, the participation rate for Women applicants 

was 40.11 percent, which decreased slightly to 40.01 percent at the qualified 

stage of the application process. The participation rate for Women dropped at the 

referred stage of the process to 39.54 percent. The participation rate for Women 

increased at the interviewed stage of the process (46.76 percent) and dropped 

again to 40.18 percent at the selected stage.

Internal Competitive Promotions: For GS-14 internal competitive promotions, the 

participation rate for Women applicants was 56.68 percent, and slightly increased 

to 57.65 percent at the qualified stage. The participation rate remained at 57.25 

percent at the referred stage and increased at the interviewed stage (64.75 

percent). The participation rate decreased at the selection stage to 57.81 percent.

GS-15

New Hires: For GS-15 new hires, the participation rate for Women applicants 

was 31.65 percent, which reduced to 31.03 percent at the qualified stage of the 

application process. The participation rate for Women increased at the referred 

stage of the process to 35.94 percent. The participation rate for Women 

increased at the interviewed stage of the process (50.00 percent) and dropped 

again to 46.50 percent at the selected stage.

Internal Competitive Promotions: For GS-15 internal competitive promotions, the 

participation rate for Women applicants was 49.55 percent, and increased to 

52.73 percent at the qualified stage. The participation rate increased again to 

54.07 percent at the referred stage and decreased at the interviewed stage (35.71 

percent). The participation rate increased at the selection stage to 62.50 percent.

SES

New Hires: For SES new hires, the participation rate for Women applicants was 

33.31 percent, which reduced to 32.63 percent at the qualified stage of the 

application process. The participation rate for Women continued to decrease at the 

referred stage of the process where the participation rate for Women was 30.35 

percent. The participation rate for Women increased at the interviewed stage of the 

process (55.26 percent) and dropped again to 45.24 percent at the selected stage.

A8: A review of new hire workforce data shows that in FY 2019, 60.35 percent of 

Treasury new hires were Women, falling below the RCLF availability rate of 64.98 

percent. 

A8S: A review of new hire data by those major occupations identified in the A6 and A4-1 

shows that:

• 0301: Miscellaneous Administration and Program

At the GS-13, 14, 15, and SES grade levels, the participation rates for Women 

new hires (58.82 percent, 16.67 percent, 30.77 percent, and 15.00 percent 

respectively) fall below the OCLF availability rate of 63.30 percent. 
62 I FY 2021 MD-715 REPORT 

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

• 0340: Program Management

In FY 2019, all hires in the 0340 series were at the SES grade level. Of those hires, 

23.08 percent were Women, falling below the OCLF availability rate of 63.30 percent.

• 0512: Internal Revenue Agent

At the GS-13 grade level, the participation rate for Women new hires (61.40 

percent) fell below the OCLF availability rate of 64.20 percent. There were no hires 

for the GS-14 and above grade levels.

• 0570: Financial Institution Examining 

At the GS-13 equivalent grade level, the participation rate for Women new hires 

(50.00 percent) exceeded the OCLF availability rate (45.30 percent). At the GS-14 and 

15 equivalent grade levels, the participation rate for Women new hires (20.00 percent 

and 0.00 percent respectively) fell below the OCLF availability rate (45.30 percent).

• 1169: Internal Revenue Officer

In FY 2019, the participation rate for Women new hires (60.00 percent) fell below 

the OCLF availability rate of 64.20 percent.

A14: Review of separation data for the Treasury workforce shows that 70.59 percent 

of all Involuntary separations were Women, exceeding the workforce availability rate of 

61.56 percent. Similarly, 64.72 percent of all voluntary separations were Women, which 

also exceeds the workforce availability rate (61.56 percent). 

A14S2: A review of new separation data by those major occupations identified in the A6 

and A4-1 shows that:

• 0301: Miscellaneous Administration and Program

At the GS-13, 14, 15, and SES grade levels, the participation rates for separations 

of Women (55.88 percent, 52.78 percent, 48.72 percent, and 25.00 percent 

respectively) fell below the availability rate of 60.18 percent. 

• 0340: Program Management

At the GS-13, 14, and SES grade levels, the participation rates for separations of 

Women (75.00 percent, 66.67 percent, and 62.50 percent respectively) exceeded 

the availability rate of 58.36 percent. At the GS-15 grade levels, the participation 

rate for separations (48.78 percent) fell below the availability rate (58.36 percent).

• 0512: Internal Revenue Agent

At the GS-13 and 14 grade levels, the participation rate for separations (45.24 

percent and 48.85 percent) fell below the availability rate of 53.24 percent. At the 

GS-15 grade level, the participation rate for separations (100.00 percent) exceeded 

the availability rate of 53.24 percent.

• 0570: Financial Institution Examining*

At the GS-13, 14, 15, and SES grade levels, the participation rates for separations 

(39.68 percent, 41.38 percent, 38.89 percent, and 66.67 percent respectively) 

exceed the availability rate (38.38 percent). 
FY 2021 MD-715 REPORT I 63

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

• 0962: Contact Representative

In FY 2019, all separations in the 1169 series were in the GS-11 and below grade 

levels.

• 1169: Internal Revenue Officer

At the GS-13 grade level, the participation rate for separations of Women (44.19 

percent) fell below the availability rate (57.95 percent); however, at the GS-14 and 

15 grade levels, the participation rate for separations (66.67 percent and 100.00 

percent respectively) exceeded the availability rate (57.95 percent).

Complaint Data (Trends) Yes FY 2019

In FY 2019, 395 formal complaints were filed with the Department; of those 395, 85 

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

In FY 2019, of the 76 complaints that reached Settlement, 16 (21.05 percent) identified 

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

FY 2020

In FY 2020, 334 formal complaints were filed with the Department; of those 334, 68 

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

In FY 2020, of the 93 complaints that reached Settlement, 23 (24.73 percent) identified 

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

In FY 2020, there were no findings of discrimination on the basis of Sex (Female).

Grievance Data (Trends) No

Findings from Decisions 

(e.g., EEO, Grievance, 

MSPB, Anti-Harassment 

Processes) 

No

Climate Assessment 

Survey (e.g., FEVS)

Yes Of those Treasury respondents in the FY 2019 FEVS, 58% were Female. 

Men Women

Overall New IQ 66.52% 62.24%

Fairness 56.16% 50.34%

Open-Minded 66.35% 60.48%

Cooperative 63.75% 61.40%

Supportive 84.66% 80.50% 

 Empowerment 61.70% 58.48%

Among the overall New IQ scores, and the scores for each category (Fairness, Openminded, Cooperative, Supportive, and Empowerment), Women positive scores fell below 

Men positive scores in the overall score and each of the categories. 

For item number 34, “Policies and programs promote diversity in the workplace (for 

example, recruiting minorities and women, training in awareness of diversity issues, 

mentoring),” Treasury scored 59.9%, which falls below the “positive” threshold of 65%. 

Treasury Women scored 57.5% while Treasury Men scored 66.1%.

For item 37, “Arbitrary action, personal favoritism and coercion for partisan political 

purposes are not tolerated,” Treasury scored 59.0%, which falls below the “positive” 

threshold of 65%. Treasury Women scored 57.4% while Treasury Men scored 64.3%.
64 I FY 2021 MD-715 REPORT 

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

For item 38, “Prohibited Personnel Practices (for example, illegally discriminating 

for or against any employee/applicant, obstructing a person’s right to compete for 

employment, knowingly violating veterans’ preference requirements) are not tolerated,” 

Treasury scored 69.3%, which exceeds the “positive” threshold of 65%. Treasury 

Women scored 67.7% while Treasury Men scored 74.7%.

For item 45, “My supervisor is committed to a workforce representative of all segments 

of society,” Treasury scored 75.8%, which exceeds the “positive” threshold of 65%. 

Treasury Women scored 74.5% while Treasury Men scored 80.1%.

For item 49, “My supervisor treats me with respect,” Treasury scored 85.8%, which 

exceeds the “positive” threshold of 65%. Treasury Women scored 85.2% while Treasury 

Men scored 88.4%.

For item 55, “Supervisors work well with employees of different backgrounds,” Treasury 

scored 69.4%, which exceeds the “positive” threshold of 65%. Treasury Women scored 

67.9% while Treasury Men scored 74.2%

Exit Interview Data Yes FY 2015

In FY 2015, Treasury received Exit Survey responses from 1232 Women (permanent). 

The majority of separating women were employed for More than 25 years (57.22% 

or 705), followed by 13-15 years (17.29% or 213), 4-6 years (11.12% or 137), 7-9 

years (5.93% or 73), 1-3 years (4.06% or 50), 10-12 years (3.57% or 44), and less 

than 1 year (0.81% or 10). Of the respondents, 85.23% (1050) were GS or equivalent; 

of the “Other” pay systems, 55.42% (97) were IR and 40.57% (71) were NB. Of the 

respondents, 33.93% (418) were 13-15 or equivalent, 32.71% (403) were 9-12 or 

equivalent, 29.06% (358) were 5-8 or equivalent, 3.33% (41) were 1-4 or equivalent, 

and 0.97% (12) were SES or equivalent.

The majority of respondents, 11.12% (127) were 0592: Tax Examining, followed by 

9.09% (112) were 0962: Contact Representative, 7.79% (96) were 0512: Internal 

Revenue Agent, 7.55% (91) were 0501: Financial Administration & Program, and 6.25% 

(77) were 2210: Information Technology Management. 

Of the respondents, 44.97% (554) were 60 and Over, 33.12% (408) were 50-59, 

9.25% (114) were 30-39, 7.55% (93) were 40-49, and 4.79% (59) were 18-29.

Retirement accounted for 72.72% (896) of the respondents; of those retiring, 33.37% 

(299) were eligible for less than 1 year, 21.65% (194) were eligible for 1-2 years, 

20.65% (185) were eligible for 3-4 years, 16.29% (146) were eligible for 5-7 years, 

5.02% (45) were eligible for 10+ years, and 3.01% (27) were eligible for 8-9 years.

The factors most frequently cited as having an impact on the decision to separate 

were Job-Related Stress, Office Morale, Resources available to do the job, the Office’s 

organization and alignment with regard to effective and efficient service, resources 

available to do job, and ability to participate in decision-making.

The majority of female respondents, 82.39% (1015), stated that their work experience 

was generally positive and 59.90% (738) stated that they would return to work for 

Treasury. Of the respondents, 71.10% (876) stated that they would recommend 

Treasury as a good place to work.
FY 2021 MD-715 REPORT I 65

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

FY 2016

In FY 2016, Treasury received Exit Survey responses from 1136 Women (permanent). 

The majority of separating women were employed for More than 25 years (57.66%, 

or 655), followed by 13-25 years (16.55% or 188), 7-9 years (9.15% or 104), 4-6 

years (6.07% or 69), 10-12 years (5.02% or 57), 1-3 years (3.61% or 41), and less 

than 1 year (1.94% or 22). Of the respondents, 85.83% (975) were GS or equivalent; 

of the “Other” pay systems, 64.33% (101) were IR and 33.76% (53) were NB. Of the 

respondents, 34.24% (389) were 13-15 or equivalent, 32.22% (366) were 9-12 or 

equivalent, 28.35% (322) were 5-8 or equivalent, 4.40% (50) were 1-4 or equivalent, 

and 0.79% (9) were SES or equivalent. 

The majority of respondents, 11.53% (131) 0592: Tax Examining, followed by 9.51% 

(108) were 0962: Contact Representative, 9.33% (106) were 0343: Management & 

Program Analysis, 7.04% (80) were 0501: Financial Administration & Program, and 

6.34% (72) were 2210: Information Technology Management.

Of the respondents, 46.57% (59) were 60 and Over, 31.51% (358) were 50-59, 

10.04% (114) were 30-39, 7.83% (89) were 40-49, and 3.70% (42) were 18-29.

Retirement accounted for 72.45% (823) of the respondents; of those retiring, 30.98% 

(255) were eligible for less than 1 year, 23.82% (196) were eligible for 1-2 years, 

18.83% (155) were eligible for 3-4 years, 15.19% (125) were eligible for 5-7 years, 

7.17% (59) were eligible for 10+ years, and 4.01% (33) were eligible for 8-9 years.

The factors most frequently cited as having an impact on the decision to separate were 

Job-Related Stress, Office Morale, Ability to participate in decision-making, the Office’s 

organization and alignment with regard to effective and efficient service, and access to 

developmental opportunities. 

The majority of respondents, 85.92% (976) stated that their work experience was 

generally positive and 63.20% (718) stated that they would return to work for Treasury. 

Of the respondents, 74.65% (848) stated that they would recommend Treasury as a 

good place to work.

FY 2017

In FY 2017, Treasury received Exit Survey responses from 1078 Women (permanent). 

The majority of separating women were employed for More than 25 years (61.78%, or 

666), followed by 13-25 years (14.56%, or 157), 7-9 years (6.77%, or 73), 10-12 years 

(5.38%, or 58), 4-6 years (4.64%, or 50), less than 1 year (3.62%, or 39), and 1-3 years 

(3.25%, or 35). Of the respondents, 83.95% (905) were GS or equivalent; of the “Other” 

pay systems, 67.86% (114) were IR and 29.76% (50) were NB. Of the respondents, 

33.02% (356) were 9-12 or equivalent, 31.73% (342) were 5-8 or equivalent, 31.45% 

(339) were 13-15 or equivalent, 3.06% (33) were 1-4 or equivalent, and 0.74% (8) were 

SES or equivalent.

The majority of respondents, 11.60% (125) were 0592: Tax Examining, followed by 

11.32% (122) were 0962: Contact Representative, 8.72% (94) were 0501: Financial 
66 I FY 2021 MD-715 REPORT 

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

Administration & Program, 6.49% (70) were 1169: Internal Revenue Officer, 6.22% (67) 

were 0343: Management & Program Analysis, and 6.22% (67) were 2210: Information 

Technology Management.

Of the respondents, 46.85% (505) were 60 and Over, 32.84% (354) were 50-59, 

8.91% (96) were 30-39, 6.68% (72) were 40-49, and 3.80% (41) were 28-29.

Retirement accounted for 73.84% (796) of the respondents; of those retiring, the 

majority, 29.02% (231) were eligible for less than 1 year, followed by 22.99% (183) 

eligible for 1-2 years, 18.22% (145) eligible for 5-7 years, 17.59% (140) eligible for 3-4 

years, 7.41% (59) eligible for 10+ years, and 4.77% (38) eligible for 8-9 years.

The factors most frequently cited as having an impact on the decision to separate are 

Job-Related Stress, Office Morale, Reasonableness of Workload, Ability to Participate 

in Decision-Making, Resources Available to do Job, and Pay Level in Relation to Job 

Responsibilities and Performance.

The majority of respondents, 82.75% (892) stated that their work experience was 

generally positive and 61.04% (658) stated that they would return to work for Treasury. 

Of the respondents, 72.36% (780) stated that they would recommend Treasury as a 

good place to work.

FY 2018

In FY 2018, Treasury received Exit Survey responses from 1131 Women (permanent). 

The majority of separating women were employed for More than 25 years (61.10%, or 

691), followed by 13-25 years (18.21% or 206), 7-9 years (6.37% or 72), 10-12 years 

(6.01% or 68), 1-3 years (4.16% or 47) 4-6 years (2.92% or 33), and less than 1 year 

(1.24% or 14). Of the respondents, 87.27% (987) were GS or equivalent; of the “Other” 

pay systems, 61.43% (86) were IR, and 32.86% (46) were NB. Of the respondents, 

34.39% (389) were 13-15 or equivalent, 32.45% (367) were 9-12 or equivalent, 

27.59% (312) were 5-8 or equivalent, 4.95% (56) were 1-4 or equivalent, and 0.62% (7) 

were SES or equivalent.

The majority of respondents, 10.96% (124) were 0962: Contact Representative, 

10.43% (118) were 0592: Tax Examining, 9.37% (106) were 0501: Financial 

Administration & Program, 7.78% (88) were 0512: Internal Revenue Agent, 6.90% (78) 

were 0343: Management & Program Analysis, and 6.56% (73) were 2210: Information 

Technology Management. 

Of the respondents, 48.19% (545) were 60 and Over, 34.22% (387) were 50-59, 

7.25% (82) were 30-39, 6.90% (78) were 40-49, and 2.65% (30) were 18-29.

Retirement accounted for 76.13% (861) of the respondents; of those retiring, the 

majority, 30.78% (265) were eligible for less than 1 year, 21.95% (189) were eligible for 

1-2 years, 19.40% (167) were eligible for 3-4 years, 17.07% (147) were eligible for 5-7 

years, 6.27% (54) were eligible for 10+ years, and 4.53% (39) were eligible for 8-9 years.
FY 2021 MD-715 REPORT I 67

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

The factors most frequently cited as having an impact on the decision to separate were 

Job-Related Stress, Office Morale, Ability to Participate in Decision-Making, Access to 

Developmental Opportunities, and Reasonableness of Workload.

The majority of respondents, 82.67% (935) stated that their work experience was 

generally positive and 58.53% (662) stated that they would return to work for Treasury. 

Of the respondents, 71.97% (814) stated that they would recommend Treasury as a 

good place to work.

FY 2019

In FY 2019, Treasury received Exit Survey responses from 940 Women (permanent). 

The majority of separating women were employed for More than 25 years (55.53%, or 

522), followed by 13-25 years (19.47%, or 183), 10-12 years (6.91%, or 65), 1-3 years 

(5.85%, or 55), 7-9 years (5.43%, or 51), 4-6 years (4.15%, or 39), and less than 1 year 

(2.66%, or 25). Of the respondents, 86.91% (817) were GS or equivalent and 0.53% (5) 

were WG or equivalent; of the “Other” pay systems, 53.91% (62) were IR, and q45.22% 

(52) were NB. Of the respondents, 35.32% (332) were 13-15 or equivalent, 32.23% 

(303) were 9-12 or equivalent, 26.49% (249) were 5-8 or equivalent, 5.74% (54) were 

1-4 or equivalent, and 0.21% (2) were SES or equivalent.

The majority of respondents, 11.60% (109) were in 0592: Tax Examining, 9.04% (85) 

were 0962: Contact Representative, 8.51% (80) were 0501: Financial Administration 

& Program, 6.91% (65) were 0343: Management & Program Analysis, and 6.38% (60) 

were 2210: Information Technology Management.

Of the respondents, 45.64% (429) were age 60 and Over, 32.77% (308) were 50-59, 

9.36% (88) were 30-39, 8.19% (77) were 40-49, and 2.98% (28) were 18-29.

Retirement accounted for 71.17% (669) of the respondents; of those retiring, the 

majority, 30.79% (206) were eligible for less than 1 year, 24.22% (162) were eligible for 

1-2 years, 18.54% (124) were eligible for 3-4 years. 15.10% (101) were eligible for 5-7 

years, 6.73% (45) were eligible for 10+ years, and 4.63% (31) were eligible for 8-9 years.

The factors most frequently cited as having an impact on the decision to separate were 

Job-Related Stress, Office Morale, Resources available to do Job, Ability to Participate in 

Decision-Making, and Reasonableness of Workload.

The majority of respondents, 84.04% (790) stated that their work experience was 

generally positive and 60.32% (567) stated that they would return to work for Treasury. 

Of the respondents, 75.53% (710) stated that they would recommend Treasury as a 

good place to work.

FY 2020

In FY 2020, Treasury received Exit Survey responses from 786 Women (permanent). 

The majority of separating women were employed for More than 25 years (58.27% or 

458), followed by 13-25 years (16.03% or 126), 10-12 years (7.51% or 59), Less than 
68 I FY 2021 MD-715 REPORT 

Sources of Data Source 

Reviewed? 

(Yes or No)

Identify Information Collected

1 year (5.47% or 43), 4-6 years (4.45% or 35), 7-9 years (4.20% or 33), and 1-3 years 

(4.07% or 32). Of the respondents, the majority, 85.11% (669), were GS or equivalent; 

of the “Other” pay systems, 51.33% (58) were IR, 47.79% (54) were NB, and 0.88% 

(1) was TR. Of the separations, 39.82% (313) were from 13-15 or equivalent grades, 

30.53% (240) were 9-12 or equivalent, 25.70% (202) were 5-8 or equivalent, 3.31% 

(26) were 1-4 or equivalent, and 0.64% (5) were SES or equivalent. 

The majority of respondents (74, or 9,41%) were in 0512 Internal Revenue Agent, 

followed by 0962: Contact Representative (73, or 9.29%), 0592: Tax Examining 

(69, or 8.78%), 0343: Management & Program Analysis (65, or 8.27%), 0501: 

Financial Administration & Program (59, or 7.51%), and 2210: Information Technology 

Management (48, or 6.11%).

Of the respondents, 44.40% (349) were age 60 and Over, 33.72% (265) were 50-59, 

9.54% (75) were 30-39, 7.25% (57) were 40-49, and 2.94% (31) were 3.94% (31) 

were 18-29.

Retirement accounted for 63.49% (499) of the respondents; of those retiring, the 

majority, 30.46% or 152, were eligible for less than 1 year, followed by 22.44% (112) 

eligible for 1-2 years, 18.64% (93) eligible for 3-4 years, 16.42% (82) eligible for 5-7 

years, 7.01% (35) eligible for 10+ years, and 5.01% (25) eligible for 8-9 years. 

The factors most frequently cited as having an impact on the decision to separate 

from the agency were Job-Related Stress, Office Morale, Pay Level in Relation to 

Job Responsibilities and Performance, Access to Developmental Opportunities, and 

Reasonableness of Workload.

The majority of respondents (86.39%, or 679) stated that their work experience was 

generally positive, and 63.61% (500) stated they would return to work for Treasury. Of 

the respondents, 79.26% (623) stated that they would recommend Treasury as a good 

place to work.

Focus Groups No

Interviews No

Reports (e.g., Congress, 

EEOC, MSPB, GAO, 

OPM)

No

Other (Please Describe) No
FY 2021 MD-715 REPORT I 69

Status of Barrier Analysis Process 

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

No No

Statement of Identified Barrier(s) 

Description of Policy, Procedure, or Practice

Barrier not yet identified.

Objective(s) and Dates for EEO Plan 

Objective Date Initiated 

(mm/dd/yyyy)

Target Date 

(mm/dd/yyyy)

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified Date 

(mm/dd/yyyy)

Date 

Completed 

(mm/dd/yyyy)

Increase participation rates for Women in 

the GS-13 through 15 and SES grade levels.

09/01/2019 09/30/2021 Yes

Responsible Official(s) 

Title Name Performance Standards Address the Plan? 

(Yes or No)

Acting Director, OCRD Snider Page Yes

Planned Activities Toward Completion of Objective 

Target Date 

(mm/dd/yyyy)

Planned Activities Modified Date 

(mm/dd/yyyy)

Completion 

Date (mm/dd/

yyyy)

12/30/2019 Reach out to EEO Officers for those bureaus (DO and IRS) with noted 

decrease in the participation rate of Women in SES and GS-15 feeder 

pools to request a barrier analysis study be implemented in FY 2020.

12/20/2019

06/30/2020 Review Exit Interview and FEVS data results for FY 2015 through FY 

2020 to identify trends for Women perceptions in the workforce.

12/30/2020

09/30/2020 Identify a high-level Treasury Barrier Analysis Team, a working group that 

leverages the expertise of members of the OCRD, Human Resources, 

and Bureau EEO Offices to more closely identify barriers to Women 

participation in the GS-13 and above grade levels.

09/30/2020

12/30/2020 Treasury Barrier Analysis Team will create a plan that guides critical 

phases (analysis, methods, resources, senior leadership support). 

03/10/2021

03/30/2021 Treasury Barrier Analysis Team will implement plan. 03/10/2021

05/31/2021 Treasury Barrier Analysis Team will collect data. 04/21/2021

07/30/2021 Treasury Barrier Analysis Team will analyze and report data. 05/13/2021
70 I FY 2021 MD-715 REPORT 

06/31//2021 Treasury Barrier Analysis Team will create additional action plan to 

eliminate identified barrier(s). 

06/09/2021

03/31/2022 Bureau sub-committees will be formed with relevant parties. 

06/30/2022 Bureau sub-committees will review policies, procedures, practices, and 

conditions relevant to the occupation.

09/30/2022 Bureaus will have a bureau-specific action plan developed to eliminate 

identified barrier(s).

Report of Accomplishments 

Fiscal Year Accomplishments

FY 2020 The Barrier Analysis Working Group (BAWG) was formed in September 2020, consisting of members from 

each bureau. Treasury Female exit survey responses were reviewed.

FY 2021 In FY 2021, the BAWG identified a plan for addressing lower than expected participation rates for Women in 

the GS 13-15 and SES grades. 

Because each bureau has a different mission, each bureau’s workforce is also different, and therefore, each 

bureau has different conditions, practices, and policies that affect each bureau individually. Each bureau 

reviewed workforce data and identified one or two mission-critical and/or most populous occupations where 

female participation rates at the GS-13 and above grade levels consistently falls below the respective availability 

rate. In FY 2021, most bureaus have formed sub-working groups consisting of sub-component EEO personnel 

(if applicable), HR, and hiring managers/supervisors. Bureaus are analyzing their data to identify triggers within 

various phases of employment, including recruitment and outreach. 

The Treasury-wide BAWG meets monthly to discuss plans and progress, as well as to identify any challenges to 

completing the barrier analysis efforts. 
FY 2021 MD-715 REPORT I 71

MD-715 – Part J

Special Program Plan for the Recruitment, Hiring, 

Advancement, and Retention of Persons with Disabilities

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

(PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 require agencies to describe how their plan will 

improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities. All agencies, 

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

Section I: Efforts to Reach Regulatory Goals

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

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

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

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

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

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

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.

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

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

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.

The Department of the Treasury issued a memorandum on or around September 25, 2017, to Human Resources’ (HR) staff 

and hiring managers, describing the Department’s commitment to meeting the numerical goals set forth under Section 501. 

The memorandum emphasized improving hiring efforts in the mission-critical occupations: IT Management; Program Analyst; 

Accounting; and Financial Management Analysis. Additionally, the Department provides Treasury’s leadership updates on the 

participation, grade distribution, hiring, and separations of people with disabilities (PWD) and people with targeted disabilities 

(PWTD), allowing leadership to make informed decisions on how the Department is doing towards meeting the established goals 

for PWD and PWTD. 
72 I FY 2021 MD-715 REPORT 

Section II: Model Disability Program

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

persons with disabilities and persons with targeted disabilities, administer the reasonable accommodation program and 

special emphasis program, and oversee any other disability hiring and advancement program the agency has in place. 

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

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

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

 Yes X No 0

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

employment status, and responsible official.

Disability Program Task

# of FTE Staff by Employment Status Responsible Official

(Name, Title, Office, Email)

Full Time Part Time Collateral 

Duty

Processing applications from PWD and PWTD 60 14 20 See specific bureau PART J’s.

Answering questions from the public about hiring 

authorities that take disability into account

55 1 20 See specific bureau PART J’s.

Processing reasonable accommodation requests from 

applicants and employees

46 2 12 See specific bureau PART J’s.

Section 508 Compliance 207 0 2 See specific bureau PART J’s.

Architectural Barriers Act Compliance 19 1 319 See specific bureau PART J’s.

Special Emphasis Program for PWD and PWTD 15 0 5 See specific bureau PART J’s.

NOTE: Treasury provides a consolidated count where applicable; however, due to its size, a notation “See specific bureau PART J’s” 

was added to assist in identifying bureau responsible official. 

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

during the reporting period? If “yes”, describe the training that disability program staff have received. If “no”, 

describe the training planned for the upcoming year. 

 Yes X No 0

In Fiscal Year (FY) 2021, the Office of Civil Rights and Diversity (OCRD) provided training sessions to the bureaus’ staff on an asneeded basis regarding the PARTJ and use of the new MD-715 V2 workforce data tables. OCRD and the bureau’s Disability Program 

Managers also participated in the quarterly Federal Exchange on Employment and Disability (FEED) meetings, hosted by the Equal 

Employment Opportunity Commission (EEOC) and Department of Labor (DOL), which educates attendees on various issues and topics 

related to disability. 

The bureau Disability Program Managers and Reasonable Accommodation Coordinators received refresher training on the new 

Reasonable Accommodation (RA) Tracking System that was deployed in FY 2020. Ongoing private sessions are offered on an asneeded basis. 

Annually, all HR professionals are required to complete online courses related to veteran’s employment, which include disability 

components. This training, provided by the Department, is mandated by Executive Order (EO) 13518. 
FY 2021 MD-715 REPORT I 73

B. Plan to Ensure Sufficient Funding for the Disability Program

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

reporting period? If “no”, describe the agency’s plan to ensure all aspects of the disability program have sufficient funding and 

other resources.

 Yes X No 0

Section III: Plan to Recruit and Hire Individuals with Disabilities

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

hiring of individuals with disabilities. The questions below are designed to identify outcomes of the agency’s recruitment 

program plan for PWD and PWTD. 

A. Plan to Identify Job Applicants with Disabilities

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

individuals with targeted disabilities. 

The Workforce Recruitment Program (WRP) is continually promoted as a source for recruiting students and graduating seniors with 

disabilities, including disabled veterans.

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

Outreach efforts with Disability and Military Student offices are routinely conducted to promote internship opportunities.

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

Consortium, the DOL’s WRP Training, Treasury sponsored Bender Consulting Job Fair, and the Treasury Department’s Veteran 

Employment Summit to market Treasury and its job opportunities.

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. 

The Schedule A Hiring Authority is promoted and available for use along with Veterans Appointment Authorities to non-competitively 

appoint PWD/PWTD and veterans with a service-connected disability rating of 30% or more. The agency has incorporated the use of 

non-competitive hiring authorities into management discussions and training, and strongly encourages the use of non-competitive hiring 

authorities under both Schedule A for Individuals with Disabilities and the 30% or More Disabled Veterans authority for recruiting PWD 

and PWTD in the permanent workforce. The Human Resources Office forwards qualified applicant resumes from the Special Placement 

Program Coordinator to hiring officials for review and consideration.

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.
74 I FY 2021 MD-715 REPORT 

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

1) An application qualification review process – conducted by the servicing HR Specialist who confirms that the applicants meet 

the qualification requirements of the announced position and have provided required proof of disability; and 

2) Applicant referral - individuals deemed qualified are referred to the hiring manager on a Schedule A certificate of eligibility with 

guidance on selection procedures, this includes the application of veterans’ preference, when applicable. Managers have the option 

to interview and/or hire from the Schedule A certificate or to consider other candidates from other issued certificates (Merit 

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

Alternatively, when individuals submit their resumes directly to the Treasury or Internal Revenue Service (IRS) Special Placement 

Program Coordinator (SPPC) for vacant positions, the SPPC refers the resumes to the designated servicing HR Specialist. The HR 

Specialist reviews the resumes to determine qualifications. If qualifications and Schedule A eligibility are met, the resumes are then 

forwarded to the hiring manager for consideration, with guidance on selection procedures, including the application of veterans’ 

preference, when applicable. 

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

into account (e.g., Schedule A)? If “yes”, describe the type(s) of training and frequency. If “no”, describe the 

agency’s plan to provide this training.

 Yes X No 0 N/A 0

All Treasury managers, supervisors, and selected HR professionals are required to complete veteran’s employment online training 

provided through the Treasury’s Integrated Talent Management System (ITMS). Disability training, such as Americans with Disability 

Act: An Overview for Managers and a Manager’s Guide to Diversity, Inclusion and Accommodations, along with other hiring 

manager tools are also available through the ITMS. 

B. Plan to Establish Contacts with Disability Employment Organizations

Describe the agency’s efforts to establish and maintain contacts with organizations that assist PWD, including PWTD, in 

securing and maintaining employment. 

The Department engages with varied organizations such as Department of Vocational Rehabilitation Centers (DVRC), Veterans 

Administration (VA), and DOL Employment Service by partnering, providing lectures, and attending on-site presentations and 

classroom visits to develop stronger relationships with college students and professors, and with college campus clubs and groups 

that maintain focus on students with disabilities.

Meetings with professional organizations such as Wounded Warriors and DVRC are held periodically to share Treasury’s process 

for providing vacancy announcements, and share information about opportunities, including career development tracks. Continue to 

coordinate and participate in career job fairs with organizations i.e., Bender Consulting who provides opportunities for hiring persons 

with disabilities. 

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.

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

• New Hires for Permanent Workforce (PWTD) Yes 0 No X
FY 2021 MD-715 REPORT I 75

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.

• New Hires for MCO (PWD) Yes X No 0

• New Hires for MCO (PWTD) Yes X No 0

Data from the Treasury Workforce Analytics (WA) Table B6 V2 (permanent workforce): New hires by Occupational Series and 

Monster Table B6 V2 (permeant workforce) (mission-critical occupations) were analyzed to identify triggers among the following 

new hires:

FY 2021 New Hires Qualified vs. New Hires Qualified vs. New Hires

0110 (21) PWD: 10.11% - 4.76%** PWTD: 6.74% - 0.00%**

0301 (55) PWTD: 8.31% - 16.36%**

0340 (4) PWD: 32.69% - 0.00%*** PWTD: 15.38% - 0.00%***

0343 (26) PWTD: 11.87% - 7.69%**

0501 (84) PWTD: 12.84% - 9.52%**

0511 (13) PWD: 19.71% - 7.69%*** PWTD: 6.45% - 0.00%***

0905 (47) PWD: 11.74% - 2.13%** PWTD: 5.30% - 0.00%**

1811 (89) PWD: 9.52% - 3.37%* PWTD: 3.17% - 0.00%* 

*The 1811 or Criminal Investigators occupation, limits the employment opportunities available for PWTD based on the Office of 

Personnel Management (OPM)’s established medical requirements for the position. Therefore, we would expect the hiring of PWD 

and PWTD to be limited in this series and do not consider the lack of participation to be a trigger.

**Triggers were noted when comparing the qualified applicant flow data with the new hires for PWD and PWTD in the 0110, 

0301,0340, 0343, 0501, 0511, 0905, 1811, and occupational series. For the Treasury bureaus that noted the same triggers 

in their workforce evaluation, these triggers are noted in their PART J. Plans to improve hiring for PWD/PWTD within the major 

occupations listed are detailed in their specific bureau’s PART J. Treasury will monitor the Part J developed by each bureau to 

ensure appropriate plans are developed to eliminate any identified barrier(s). 

*** When there is limited hiring there cannot be a realistic expectation that all groups (PWD and PWTD) would be hired at rates 

comparable to their qualification rates. Therefore, Treasury determined a threshold of 50 new hires. Any hire rate less than 50, will 

not support a statistically significant outcome. The occupations with limited hiring, 0110, 0340, 0343, 0511 and 0905, did not 

have enough hires to determine if there is an actual trigger. 

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers 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. The OCRD requested the bureaus to complete 

detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline, or glass wall; and based 

on their findings, develop plans to eliminate identified barriers. 

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

qualified internal applicants for any of the mission-critical occupations (MCO)? If “yes”, please describe the 

triggers below.

• Qualified Applicants for MCO (PWD) Yes 0 No X

• Qualified Applicants for MCO (PWTD) Yes 0 No X
76 I FY 2021 MD-715 REPORT 

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.

• Promotions for MCO (PWD) Yes X No 0

• Promotions for MCO (PWTD) Yes X No 0

Data from the Treasury WA Table B6 V2 (permanent workforce): by Occupational Series and Monster Table B6 V2 (permanent 

workforce) (mission-critical occupations) were analyzed to identify promotions, indicating the following results: 

FY 2021 Promotions 

to MCOs

Qualified Applicants 

vs. Internal Promotions

Qualified Applicants

vs. Internal Promotions

0301 (21) PWD: 44.85% - 23.81% PWTD: 20.96% - 9.52%*

0340 (13) PWD: 51.09% - 46.15% PWTD: 18.48%-15.38% *

0343 (71) PWD: 41.64% - 25.35% PWTD: 18.19%-11.27%

0501 (166) PWD: 32.88% - 21.69% PWTD: 14.46% - 9.64%

0570 (71) PWD: 13.64% - 7.04% PWTD: 3.03% - 1.46%

1169 (88) PWD: 22.33% - 18.18% PWTD: 10.69 - 11.36%

1811 (12) PWTD: 0.00% - 0.00% *

2210 (121) PWD: 38.20% - 31.40% PWTD: 17.91% - 17.36%

The following triggers were identified:

Treasury noted a trigger between the qualified applicants and the actual promotions in all occupational series, except in the series 

1811 for PWD and 1169 for PWTD. Those Treasury bureaus that noted triggers in their workforce evaluation are noted in their 

PART J reporting. Plans to improve hiring for PWD/PWTD within the major occupations listed are detailed in the specific bureau’s 

PART J. Treasury will monitor the Part J developed by each bureau to ensure appropriate plans are developed to eliminate any 

identified barriers. 

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

comparable to their qualification rates. Therefore, Treasury determined a threshold of 50 hires or less is not enough hires to 

expect that all groups would be hired at rates comparable to their qualification rates. For those occupations (1811) with limited 

hiring, there were not enough hires resulting in internal promotions to determine if there is an actual trigger.
FY 2021 MD-715 REPORT I 77

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities 

Pursuant to 29 C.F.R §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement opportunities 

for employees with disabilities. Such activities might include specialized training and mentoring programs, career 

development opportunities, awards programs, promotions, and similar programs that address advancement. In this 

section, agencies should identify, and provide data on programs designed to ensure advancement opportunities for 

employees with disabilities.

A. Advancement Program Plan

Describe the agency’s plan to ensure PWD, including PWTD, have sufficient opportunities for advancement.

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

offers non-competitive opportunities to streamline the hiring process to fill critical and non-critical positions quickly (e.g., details, 

including positions that can lead to promotion). 

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

for general schedule (GS)-12 to senior executive service (SES) employees; Executive Readiness (XR), and Candidate Development 

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

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

programs through employee resource groups (ERGs), such as the Adelante’ which is a Hispanic ERG and the VERG which is the 

Veteran’s ERG. There are a host of other communication venues throughout the agency. Developmental opportunities are broadly 

communicated to all employees through internal weekly and monthly newsletters, internet website postings, and shared by ERGs.

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

PWD/PWTD for development opportunities as part of their Individual Development Planning (IDP) process. All development 

opportunity announcements are posted on the Treasury’s internal website.

In conjunction with available training, Treasury will explore over the next two years, the development of a committee composed of 

bureau diversity, equity inclusion, and accessibility (DEIA) representatives to explore additional opportunities (e.g., mentoring) to the 

disabled community.

B. Career Development Opportunities

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

The Department does not have a formal Career Development Program. However, Treasury bureaus have established varied 

opportunities to further develop the careers of all employees, including PWD and PWTD. The below, highlights some programs 

offered. To view the exhaustive list, please see bureau specific reports. 

The Treasury Executive Institute (TEI) offers Departmental Offices (DO) employees the opportunity for individual coaching services 

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

challenges, and develop leadership attributes.The Bureau of Engraving and Printing (BEP) offers a series of programs for GS 7-15 

employees or equivalent. Programs include:

• The New Leaders Program (GS 7-11 employees or equivalent). This program focuses on developing future public service 

leaders and includes leadership self-assessments, experiential learning, and individual development opportunities integrated 

into a competency-based learning approach. 

• The Executive Leadership Program (GS 12-13 employees or equivalent). This program enhances support to organizational 

mission and goals, focusing specifically on the competency of “leading people” through developmental activities and experiences.

• The Executive Potential Program (GS 14-15 employees or equivalent), a competency-based leadership program that prepares 

high-potential employees to focus on leading change effectively at the senior level. 
78 I FY 2021 MD-715 REPORT 

• The Career Development Program (GS-11 and below or equivalent) provides upward mobility via defined career training using 

individual career development plans for training and other opportunities to employees, who positions offer limited promotion 

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

Bureau of Fiscal Service (FS) encourages all employees to take advantage of the 40 hours of training available to all employees as 

supported by the service wide training budget and the individual Assistant Commissioner’s training budget. The Commissioner’s 

Scholarship Program and the Certification Exam Program are available to all employees. Managers are required to create 

Individual development plans (IDPs) to expand and build upon each of their employees’ strengths. Managers are reminded to 

consider permanently assigned PWD/PWTD for development opportunities as part of their IDP process. FS offers career 

development opportunities to all employees via notices of opportunities, non-competitive details, and promotions, e.g., career-ladder 

positions, competitive details, and merit promotions. In addition, FS has a Mentoring Program with platforms to meet the needs 

of PWD, PWTD, and veterans. Developmental opportunities will continue to be broadly communicated to all employees through 

internet website postings.

IRS offers mentoring and career development programs throughout the Agency to support development of employees in both 

technical and leadership competencies. Career development tools include but are not limited to: 

Details offered through the Service-wide Opportunity Listing website; Career Learning Plans (CLP) jointly developed by employees 

and their managers; Leadership Succession Review (LSR) process, which provides the opportunity for all employees interested 

in becoming managers to become actively involved with their development; Front Line Readiness Program (FLRP), designed 

to develop employees for front line manager positions; Senior Manager Readiness Program (SMRP), designed to develop 

competencies and skills necessary to prepare participants for Senior Manager (SM) positions; Senior Executive Service (SES) 

CDP, used to identify and hire career executives; Self-directed, Mentor web-based program pairs a more experienced person with 

someone interested in career development; and the Taxpayer Advocate Service (TAS) Intake Leadership Development Program 

(ILDP), designed to provide an opportunity for intake advocates and lead intake advocates to develop their leadership skills.

IRS-Chief Counsel (IRS-CC) solicited participants for the Executive Leadership and Development Program (ELDP) in December 

2021. The ELDP will take place in FY 2022. The Human Resources Investment Fund (HRIF) training dollars were made available in 

FY 2021 for employees to use towards outside, job-related training.

The United States Mint (Mint) offers the following career development opportunities to its regional employees throughout: 

Operator Certification Apprenticeship Program (OCAP) (San Francisco): OCAP ensures consistent and accurate training while 

strengthening the relationship between employee and supervisor through designed interaction. The training is structured 

and integrated to focus on developing Mint personnel to be competitive with Mint’s manufacturing industry. Those employees 

who complete the Program will receive a nationally recognized certificate of apprenticeship that not only increases their 

competitiveness within Treasury, but it can be used within the industry. 

The Manufacturer Certification Apprenticeship Program (MCAP) (Philadelphia and Denver): MCAP is a competency-based training 

and development program that allows employees to acquire the experience, knowledge, and skills necessary to perform the varied 

duties directly related to the manufacturing of coins and dies at the Mint. In short, it’s cross-training. MCAP participants also 

receive a nationally recognized certificate, and the Program provides career growth and advancement opportunities.

The Office of Comptroller of the Currency (OCC) career development programs include:

• The EXCEL I Program, sponsored by the Large Bank Supervision (LBS) department, provides bank examiners in pay band NB-V 

the opportunity to develop expertise in one of eight specialty areas.
FY 2021 MD-715 REPORT I 79

• The EXCEL II Program expands professional development opportunities for bank examiners in pay band NB-IV in the eight 

specialty areas of the EXCEL I Program.

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

legal skills and experiences across multiple legal practices areas.

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

targeted to employees at the NB-V to NB-VI.2 levels, to help develop specific competencies aligned to skills and abilities needed 

at the team leader and/or manager level.

• The Entry-Level Examiner Program, sponsored by Midsize and Community Bank Supervision, is a recruitment and career 

development program for entry-level bank examiner positions in pay bands NB-III and NB-IV. Assignments cover all areas of 

banking, including loans, interest rate risk, capital, liquidity, consumer protection programs, and compliance with banking laws 

and regulations. Through a program of continuing education and career development, OCC entry-level examiners expand their 

knowledge and skills in preparation for certification to National Bank Examiner at the pay band NB-V.

• The MCBS NB-V UCE Recognition Events for Bank Examiners provides bank examiners exposure to the career options 

available in the various bank supervision lines of business; resources and factors to consider when making career decisions; 

and the ability to learn more about leadership development.

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

• Temporary details and short–term work assignments are advertised to all employees on the agency’s Opportunities Board.

The Financial Crimes Enforcement Network (FinCEN) offers career development opportunities to all employees via non-competitive 

details and promotions, e.g., career-ladder positions, competitive details, and merit promotions. Leadership development 

opportunities exist for all qualified employees through such programs as the New Leader Program, Executive Leadership Program, 

Executive Potential Program, Mentoring Program, FinCEN Career Development Toolkit, Leadership Development Program Guide, 

and the Women’s Leadership Series (WLS).

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

supervisory recommendation/approval to participate. 

Career Development 

Opportunities*

Total Participants PWD PWTD

Applicants (#) Selectees (#) Applicants 

(%)

Selectees (%) Applicants 

(%)

Selectees (%)

Internship Programs

Fellowship Programs

Mentoring Programs

Coaching Programs

Training Programs

Detail Programs

Other Career Development 

Programs

*For bureau specific career development opportunities, see bureau PART J’s. Treasury has engaged business partners to consider 

taking necessary steps to create a plan of action to track the above requested data. 
80 I FY 2021 MD-715 REPORT 

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.

• Applicants (PWD) Yes 0 No X

• Selections (PWD) Yes 0 No X

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.

• Applicants (PWTD) Yes 0 No X

• Selections (PWTD) Yes 0 No X

 C. Awards

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for any 

level of the time-off awards, bonuses, or other incentives? If “yes”, please describe the trigger(s) in the text box.

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

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

The Department analyzed data from the Treasury WA Table B9-2 against the inclusion rate indicating a continued trend with the 

following triggers: 

The inclusion rate for PWD (11.65%) and PWTD (12.88%) in Time Off Awards (1-10 hours), was below the inclusion rate for 

employees with no disability (13.27%). 

The inclusion rate for PWD (8.49%) and PWTD (9.51%) in Time Off Awards (11-20 hours), was below the inclusion rate for 

employees with no disability (10.51%). 

The inclusion rate for PWD (4.89%) and PWTD (5.05%) in Time Off Awards (21-30 hours), was below the inclusion rate for 

employees with no disability (5.66%). 

The inclusion rate for PWD (13.17%) in Time Off Awards (31-40 hours), was below the inclusion rate for employees with no 

disability (13.80%). 

The inclusion rate for PWD (20.96%) and PWTD (22.96%) in Cash Awards ($1000-$1999), was below the inclusion rate for 

employees with no disability (25.12%). 

The inclusion rate for PWD (12.16%) and PWTD (14.10%) in Cash Awards ($2000-$2999), was below the inclusion rate for 

employees with no disability (14.87%). 
FY 2021 MD-715 REPORT I 81

The inclusion rate for PWD (5.12%) and PWTD (5.49%) in Cash Awards ($3000-$3999), was below the inclusion rate for 

employees with no disability (10.15%). 

The inclusion rate for PWD (0.35%) and PWTD (0.34%) in Cash Awards ($4000-$4999), was below the inclusion rate for 

employees with no disability (0.78%). 

The inclusion rate for PWD (0.19%) and PWTD (0.19%) in Cash Awards ($5000 or more), was below the inclusion rate for 

employees with no disability (0.62%). 

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. 

• Pay Increases (PWD) Yes X No 0

• Pay Increases (PWTD) Yes X No 0

The inclusion rate for PWD (2.68%) and PWTD (2.99%) in Quality Step Increases (QSIs), was below the inclusion rate for employees with 

no disability (3.58%). 

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.

• Other Types of Recognition (PWD) Yes 0 No 0 N/A X

• Other Types of Recognition (PWTD) Yes 0 No 0 N/A X

D. Promotions

1. Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees 

for promotions to the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for 

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

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

a. SES

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

ii. Internal Selections (PWD) Yes X No 0

 b. Grade GS-15

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

ii. Internal Selections (PWD) Yes X No 0
82 I FY 2021 MD-715 REPORT 

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 0 No X

ii. Internal Selections (PWD) Yes X No 0

Data from the Treasury WA Table B7 Applicants and Promotion by Disability and the Monster (M) B7 – Applicants and Promotions 

by Senior Grade Levels were analyzed to identify qualified internal applicants and/or selectees for promotion to senior grade levels 

with disabilities, indicating the following results: 

Internal Applicant vs. Qualified Internal Applicant vs. Internal Selections

 GS-13 PWD: 32.86% - 32.95% - 21.16% 

GS-14 PWD: 35.84% - 35.43% - 16.67% 

GS-15 PWD: 44.47% - 42.77% - 15.38% 

SES PWD: 60.14% - 61.42% - 34.48% 

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

of the Qualified Applicant Pool, the Selection and the Promotions are the result of existing employees who applied to not only 

internal vacancy announcements, but to all status vacancy announcements open to all Federal employees in FY 2021. This will also 

result in differences between internal/external selections and promotions rates. 

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline, or glass wall; 

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

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.
FY 2021 MD-715 REPORT I 83

a. SES

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

ii. Internal Selections (PWTD) Yes X No 0

 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 0 No X

ii. Internal Selections (PWTD) Yes X No 0

Data from the Treasury WA Table B7 Applicants and Promotion by Disability and the Monster (M) B7 – Applicants and Promotions 

by Senior Grade Levels were analyzed to identify qualified internal applicants and/or selectees for promotion to senior grade levels 

with disabilities, indicating the following results: 

Internal Applicant vs. Qualified Internal Applicant vs. Internal Selections

GS-13 PWTD: 14.86% - 15.36% - 10.05% 

GS-14 PWTD: 17.28% - 16.64% - 6.14% 

GS-15 PWTD: 18.68% - 17.61% - 0.00% 

SES PWTD: 23.31% - 23.22% - 13.79% 

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

of the Qualified Applicant Pool, the Selection and the Promotions are the result of existing employees who applied to not only 

internal vacancy announcements, but to all status vacancy announcements open to all Federal employees in FY 2021. This will also 

result in differences between internal/external selections and promotions rates. 

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline, or glass wall; 

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

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.
84 I FY 2021 MD-715 REPORT 

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

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

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

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

Data from the Treasury WA Table B7 Applicants and New Hires by Disability and the Monster (M) B7 – Applicants and New Hires 

by Senior Grade Levels were analyzed to identify qualified internal applicants and/or selectees for new hires to senior grade levels 

with disabilities, indicating the following results: 

External Applicant vs. New Hires 

 GS-13 PWD: 17.43% - 23.86% 

GS-14 PWD: 21.07% - 19.33% 

GS-15 PWD: 26.43% - 5.26% 

SES PWD: 25.91% - 24.14% 

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline, or glass wall; 

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

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 X

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

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

d. New Hires to GS-13 (PWTD) Yes 0 No X
FY 2021 MD-715 REPORT I 85

Data from the Treasury WA Table B7 Applicants and New Hires by Disability and the Monster (M) B7 – Applicants and New Hires 

by Senior Grade Levels were analyzed to identify qualified internal applicants and/or selectees for new hires to senior grade levels 

with disabilities, indicating the following results: 

External Applicant vs. New Hires 

GS-13 PWTD: 7.78% - 11.68% 

GS-14 PWTD: 9.67% - 10.08% 

GS-15 PWTD: 13.21% - 5.26% 

SES PWTD: 12.75% - 13.79% 

 NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline, or glass wall; 

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

5. Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for 

promotions to supervisory positions? (The appropriate benchmarks are the relevant applicant pool for qualified 

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

 a. Executives

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

ii. Internal Selections (PWD) Yes X No 0

 b. Managers

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

ii. Internal Selections (PWD) Yes X No 0

 c. Supervisors

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

ii. Internal Selections (PWD) Yes X No 0
86 I FY 2021 MD-715 REPORT 

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

Occupational Series) Applicants and Hires were analyzed to identify qualified internal applicants and/or selectees for promotion to 

supervisory positions, with disabilities, indicating the following results: 

Supervisory positions Internal Applicants Qualified Applicants Internal Promotions

Executives PWD: 58.63% 59.71% 31.43%

Managers PWD: 6.67% 0.00% 0.00%

Supervisors PWD: 66.67% 66.67% 0.00%

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline, or glass wall; 

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

6. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for 

promotions to supervisory positions? (The appropriate benchmarks are the relevant applicant pool for qualified 

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

 a. Executives

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

ii. Internal Selections (PWD) Yes X No 0

 b. Managers

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

ii. Internal Selections (PWD) Yes X No 0

 c. Supervisors

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

ii. Internal Selections (PWD) Yes X No 0
FY 2021 MD-715 REPORT I 87

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

Occupational Series) Applicants and Hires were analyzed to identify qualified internal applicants and/or selectees for promotion to 

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

Supervisory positions Internal Applicants Qualified Applicants Internal Promotions

Executives PWTD: 22.48% 22.30% 11.43%

Managers PWTD: 6.67% 0.00% 0.00%

Supervisors PWTD: 0.00% 0.00% 0.00%

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline or glass wall; 

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

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

selectees for new hires to supervisory positions? If “yes”, describe the trigger(s) in the text box. 

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

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

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

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

Occupational Series) Applicants and Hires were analyzed to identify qualified external applicants and/or selectees for new hires to 

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

Supervisory positions Qualified External Applicants New Hires

Executives PWD: 24.59% 18.42%

Managers PWD: 35.10% 31.82%

Supervisors PWD: 22.22% 0.00%

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline or glass wall; 

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

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 X No 0

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

c. New Hires for Supervisors (PWTD) Yes X No 0
88 I FY 2021 MD-715 REPORT 

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

Occupational Series) Applicants and Hires were analyzed to identify qualified external applicants and/or selectees for new hires to 

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

Supervisory Positions Qualified External Applicants New Hires

Executives PWTD: 12.52% 10.53%

Managers PWTD: 12.91% 0.00%

Supervisors PWTD: 0.00% 0.00%

NOTE: It is important to note that when the Department looks at Treasury-wide data as a whole, the progress noted may not be an 

accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential barriers still 

exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible glass ceilings, 

blocked pipelines and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus requirements to 

complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked pipeline or glass wall; 

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

Section V: Plan to Improve Retention of Persons with Disabilities

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

employees with disabilities. In this section, agencies should: (1) analyze workforce separation data to identify barriers 

retaining employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) 

provide information on the reasonable accommodation program and workplace personal assistance services.

A. Voluntary and Involuntary Separations

1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability into the competitive 

service after two years of satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If “no”, please explain why the agency 

did not convert all eligible Schedule A employees.

 Yes 0 No X N/A 0

 In FY 2021, Treasury did not convert all eligible Schedule A employees to competitive appointments.

FINCEN did not timely convert an eligible Schedule A employee due to a management oversight while the employee was on 

extended leave.

IRS had 36 conversions and two non-conversions. One non-conversion was due to the employee’s decline in performance; 

therefore, performance period was extended 90 days for observation. The other non-converted employee had extensive LWOP 

and awaiting guidance from the policy office to determine how the LWOP affects the conversion date. 

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 (7.19%) exceeded the inclusion rate of persons with no disability (1.19%) for voluntary separations. 

The inclusion rate for PWD (7.53%) exceeded the inclusion rate of persons with no disability (1.19%) for involuntary separations.
FY 2021 MD-715 REPORT I 89

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

separations exceed that of persons without targeted disabilities? If “yes”, describe the trigger below.

a. Voluntary Separations (PWTD) Yes X No 0

b. Involuntary Separations (PWTD) Yes X No 0

The inclusion rate for PWTD (27.74%) exceeded the rate of persons with no disability (1.2%) for voluntary separations. The 

inclusion rate for PWTD (23.06%) exceeded the rate of persons with no disability (1.2%) for involuntary separations. 

4. If a trigger exists involving the separation rate of PWD and/or PWTD, please explain why they left the agency using 

exit interview results and other data sources.

When evaluating the types of voluntary separations, we noted that 13.95 percent were due to retirement, 21.75 percent were 

transfers, 11.81 percent were resignations, and 25.09 percent were due to death. Of the voluntary separations, 36.61 percent 

were disabled veterans. 

Based on the comments in the FY 2021 Treasury Employee Exit Survey, Treasury does not consider any of the voluntary 

separations showing a trigger. Each bureau where a trigger has been identified will be asked to evaluate those voluntary 

separations due to retirements, transfers, and resignations, along with information gleaned from their exit survey, to determine 

if these triggers are a potential barrier.

During the period of October 1, 2020, through September 30, 2021, 168 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, the factor most frequently cited as impacting a PWD’s decision to 

leave was job stress (64.88%) followed by office morale (44.65%); responses for my ability to participate in decision making 

(45.83 %) was an additional factor for PWD.

Additional responses specified that 73.21 percent of the respondents indicated their work experience was generally positive; 

62.50 percent stated they would be interested in returning to work for Treasury; and 68.45 percent stated they would 

recommend Treasury as a good place to work. 

 B. Accessibility of Technology and Facilities

Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform applicants and employees of their 

rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), concerning the accessibility of agency 

technology, and the Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of 

agency facilities. In addition, agencies are required to inform individuals where to file complaints if other agencies are 

responsible for a violation. 

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

applicants’ rights under Section 508 of the Rehabilitation Act, including a description of how to file a complaint. 
90 I FY 2021 MD-715 REPORT 

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

with resources for Persons with Disabilities.

Information on how to file a complaint can be found at: https://www.treasury.gov/about/organizational-structure/offices/Mgt/

Pages/discrimination-complaint.aspx. 

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

under Section 508 of the Rehabilitation Act: https://home.treasury.gov/utility/accessibility/web-accessibility. 

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/organizational-structure/offices/Mgt/Documents/Section508_

Complaint_Processing.pdf.

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

applicants’ rights under the Architectural Barriers Act, including a description of how to file a complaint.

Regarding physical accessibility, the following address is located under the “Accessibility” page on the public Treasury.gov website: 

https://home.treasury.gov/utility/accessibility/physical-accessibility. 

Additionally, the following link (which is also located on the “Accessibility” page) provides information regarding how to file a 

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

3. Describe any programs, policies, or practices that the agency has undertaken, or plans on undertaking over the 

next fiscal year, designed to improve accessibility of agency facilities and/or technology.

In FY 2021, the OCRD Audit Program, which includes Accessibility Reviews for Treasury bureau-occupied buildings, continued with 

an audit of DO. OCRD reviewed the accessibility of six DO buildings. A report listing the areas of noncompliance was forwarded to 

the appropriate officials to achieve full compliance.

 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.)
FY 2021 MD-715 REPORT I 91

Each bureau is responsible for independently processing their requests for reasonable accommodations. The average time frame 

(number of days) for processing within the bureaus for FY 2021 are:

BEP 10

DO 9

FinCEN 0 – No RA requests to process in FY 2021

FS 10

Mint 11

IRS 58

IRS-CC 20

OCC 10

The overall average for processing the Departments initial requests for reasonable accommodations is 18.47 business days. The 

Department recognizes the high average for IRS which is currently reviewing its methodology for calculating “average days for 

providing reasonable accommodations.” This FY the IRS reduced their processing time from 89 to 58 days.

Treasury implemented a Treasury-wide reasonable accommodation tracking system that will eliminate the need to manually 

calculate processing timeframes. IRS is scheduled to transitioned to the system in FY 2022. 

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency’s reasonable 

accommodation program. Some examples of an effective program include timely processing requests, timely 

providing approved accommodations, conducting training for managers and supervisors, and monitoring 

accommodation requests for trends.

The Department has an effective Disability Program, supported by various policies, procedures, and practices, as evidenced 

by overall timely processing requests for accommodations. Mandatory training for new managers and supervisors includes 

responsibilities on providing reasonable accommodations. Throughout FY 2021, bureaus provided reasonable accommodations 

guidance via training courses, newsletters, and postings on its intranet websites (see specific bureau submission for details). 

Bureaus are responsible for monitoring reasonable accommodation data for trends relating to the workforce. 

 D. Personal Assistance Services Allowing Employees to Participate in the Workplace

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required to provide 

personal assistance services (PAS) to employees who need them because of a targeted disability, unless doing so would 

impose an undue hardship on the agency. 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. Some 

examples of an effective program include timely processing requests for PAS, timely providing approved services, 

conducting training for managers and supervisors, and monitoring PAS requests for trends.

Treasury established its PAS policy and procedures during FY 2018 and procured a Treasury-wide PAS contract. This contract 

allows its bureaus to establish a blanket purchase agreement (BPA) against the Treasury-wide base contract. Training for PAS 

requests was provided to all managers, supervisors, and selected HR Professionals in FY 2019. Since 2019, PAS training has 

been included in the employee orientation of all newly-hired and -promoted managers. 
92 I FY 2021 MD-715 REPORT 

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 (19.69 %)? 

 Yes 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 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.

There was one complaint with a finding of discrimination without a hearing. The following corrective action was taken by the agency:

• monetary benefits issued to Complainant, 

• mandatory training completed by management official, and

• posting notice of violation.

 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 (13.53 %)? 

 Yes 0 No X N/A 0

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

finding of discrimination or a settlement agreement?

 Yes X No 0 N/A 0

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation 

during the last fiscal year, please describe the corrective measures taken by the agency.

Same as above

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
FY 2021 MD-715 REPORT I 93

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

 Yes 0 No 0 N/A X

3. Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), objective(s), responsible 

official(s), planned activities, and, where applicable, accomplishments. 

Trigger 1 Note: The following bureaus have identified triggers and initiated the barrier analysis process for PWD and 

PWTD: BEP, DO, FS, IRS, IRS-CC, and OCC. Each bureau is required to report independently, its plan to address 

their deficiencies. 

Barrier(s)

Objective(s)

Responsible Official(s) Performance Standards Address the Plan?

(Yes or No)

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

Sources of Data Sources 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables 

Complaint Data (Trends)

Grievance Data (Trends)

Findings from Decisions (e.g., EEO, Grievance, MSPB, AntiHarassment Processes) 

Climate Assessment Survey (e.g., FEVS)

Exit Interview Data

Focus Groups

Interviews

Reports (e.g., Congress, EEOC, MSPB, GAO, OPM)

Other (Please Describe)

Target Date

(mm/dd/yyyy)

Planned Activities Sufficient 

Staffing & 

Funding

(Yes or No)

Modified Date

(mm/dd/yyyy)

Completion Date

(mm/dd/yyyy)

Fiscal Year Accomplishments
94 I FY 2021 MD-715 REPORT 

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

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

be an accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential 

barriers still exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible 

glass ceilings, blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus 

requirements to complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked 

pipeline, or glass wall; and based on their findings, develop plans to eliminate identified barriers.

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

eliminating the barrier(s). 

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

be an accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential 

barriers still exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible 

glass ceilings, blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus 

requirements to complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked 

pipeline, or glass wall; and based on their findings, develop plans to eliminate identified barriers.

6. If the planned activities did not correct the trigger(s) and/or barrier(s), please describe how the agency intends to 

improve the plan for the next fiscal year. 

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

be an accurate reflection of the true progress of each bureau. The consolidated view of the data may mask where potential 

barriers still exist within some of the bureaus. Therefore, a detailed barrier analysis based on bureau specific data into possible 

glass ceilings, blocked pipelines, and glass walls must be conducted by each of the bureaus. OCRD expressed to the bureaus 

requirements to complete detailed analyses to determine if any PWD or PWTDs are facing a potential glass ceiling, blocked 

pipeline, or glass wall; and based on their findings, develop plans to eliminate identified barriers.
FY 2021 MD-715 REPORT I 95
96 I FY 2021 MD-715 REPORT