1

U.S. Department of Defense 

Department of Defense Fiscal Year 2019

Notification and Federal Employee 

Antidiscrimination and Retaliation Act 

(No FEAR Act Report)

The estimated cost of this report for the Department of Defense is approximately $53,000 in Fiscal 

Years 2018-2019. This includes $450 in expenses and $53,000 in DoD labor. 

Generated on 2020Jan21 Ref ID: E-32BD72B
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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Table of Contents

List of Acronyms ...........................................................................................................................iii

Introduction..................................................................................................................................... 1

Legislative Requirement ................................................................................................................. 1

Results and Data ............................................................................................................................. 1

The Number of Federal Cases and the Disposition of Such Cases..................................... 2

Judgment Fund Reimbursement ......................................................................................... 3

Disciplinary Actions ........................................................................................................... 4

EEO Complaint Data .......................................................................................................... 5

Agency’s Policy................................................................................................................ 12

Agency’s Training Plan .................................................................................................... 12

Analysis............................................................................................................................. 13

Conclusion .................................................................................................................................... 30
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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LIST OF ACRONYMS

CFR Code of Federal Regulations

CPP Civilian Personnel Policy

DEORG Defense Equal Opportunity Reform Group

DoD Department of Defense

DoDD DoD Directive

DoDI DoD Instruction

EEO Equal Employment Opportunity

EEOC Equal Employment Opportunity Commission

FY Fiscal Year

ODEI Office for Diversity, Equity, and Inclusion

U.S.C. United States Code

USD(P&R) Under Secretary of Defense for Personnel and Readiness
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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INTRODUCTION

Public Law 107-174, “The Notification and Federal Employee Antidiscrimination and 

Retaliation (No FEAR) Act of 2002,” and its implementing regulation, title 5, Code of Federal 

Regulations (CFR), section 724.302, require that Federal agencies be accountable for violations 

of antidiscrimination and whistleblower protection laws. Each fiscal year (FY), Executive 

agencies must provide an annual report to Congress on the number and severity of discrimination 

and whistleblower cases brought against them. The No FEAR report for FY 2019 is the second 

annual No FEAR report providing a composite DoD assessment and an analysis of equal 

employment opportunity (EEO) complaint data. 

LEGISLATIVE REQUIREMENT

The No FEAR Act, enacted on May 15, 2002, directed Federal agencies to post quarterly equal 

employment opportunity (EEO) complaint data on their public websites, reimburse the Judgment 

Fund, and submit an annual report to Congress. The reporting obligations of the No FEAR Act1

and its implementing regulation are:

 Number of Federal cases pending or resolved for each FY arising under each of the 

respective provisions of the Federal antidiscrimination laws and whistleblower 

protection laws; 

 Amount of money reimbursed to the Judgment Fund by the agency for payments; 

 Amount of reimbursement to the Judgment Fund for attorney’s fees where such fees 

have been separately designated;

 Number of employees disciplined for discrimination, retaliation, harassment, etc., and 

the disciplinary actions taken, e.g., reprimand, separated by the provision(s) of law 

involved;

 Final year-end data about discrimination complaints for each FY that was posted; 

 Agency policy regarding disciplinary action against employees who violated 

discrimination laws or committed other prohibited personnel practices; 

 Number of employees disciplined with such policy; 

 An examination of trends, causal analysis, experiential knowledge, and actions (taken 

or planned) to improve complaint or civil rights programs; 

 Adjustments to the agency’s budget as a result of Judgement Fund reimbursement 

requirements; and

 The agency’s written plan to train its employees.

RESULTS AND DATA

Section 301 of the No FEAR Act requires each federal agency to post summary statistical data 

pertaining to complaints of employment discrimination filed against it by employees, former 

employees, and applicants for employment under section 1614 of Title 29, CFR. Accordingly, 

DoD Components complete the Equal Employment Opportunity Commission’s (EEOC) Annual 

Federal Equal Employment Opportunity Statistical Report of Discrimination Complaints (Form 

 

1 5 C.F.R. § 724.302.
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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462). In addition, the Components provide ODEI with additional data required under the No 

FEAR Act. For FY 2019, ODEI prepared this Composite Report by compiling and analyzing all 

of the submissions from the Components.

Table 1 indicates the DoD Components who provided data:

TABLE 1: PARTICIPATING COMPONENTS

THE NUMBER OF FEDERAL CASES AND THE DISPOSITION OF SUCH CASES5

The first requirement in the No FEAR Act is to provide the number and status of cases in Federal 

court pending or resolved in each FY that allege a violation of Federal antidiscrimination or 

whistleblower protection laws. The following table provides the total number of cases for FY 

2019:

 

2 The Department of the Air Force provided data for EEO complaints, but not for the other data topics under the No 

FEAR Act.

3 Formerly Defense Security Service.

4 DoDEA provided data for EEO complaints, but not for the other data topics under the No FEAR Act.

5 5 C.F.R. 724.302(a)(1) and 5 C.F.R. 724.302(a)(2)(i).

Military 

Departments

Department of the Army (Army)

Department of the Navy (Navy)

Department of the Air Force (Air Force)2

DoD 

Agencies and 

Field 

Activities

Army and Air Force Exchange Service (AAFES)

Defense Commissary Agency (DeCA)

Defense Contract Audit Agency (DCAA)

Defense Contract Management Agency (DCMA)

Defense Counterintelligence and Security Agency (DCSA)3

Defense Finance and Accounting Service (DFAS)

Defense Human Resources Activity (DHRA)

Defense Intelligence Agency (DIA)

Defense Information Systems Agency (DISA)

Defense Logistics Agency (DLA)

Defense Media Activity (DMA)

Department of Defense Education Activity (DoDEA)4

Defense Threat Reduction Agency (DTRA)

Joint Chiefs of Staff (JCS)

Missile Defense Agency (MDA)

National Geospatial-Intelligence Agency (NGA)

National Security Agency (NSA)

Office of the Inspector General (OIG)

Uniformed Services University of the Health Sciences (USU)

Washington Headquarters Service (WHS)
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TABLE 2: FEDERAL COURT CASES6

Statute

Cases 

Opened in 

FY 20197

Cases Resolved in 

FY 20198

Cases 

Pending at 

Close of 

FY 20199

Settled Other

Title VII, Civil Rights Act of 1964

42 U.S.C. 2000e-16 185 40 109 292

Age Discrimination in Employment Act

29 U.S.C. 631, 633a 59 11 38 93

Fair Labor Standards Act of 1938

29 U.S.C. 206(d) 4 3 1 10

Section 501 of Rehabilitation Act

29 U.S.C. 791 65 14 35 100

Equal Pay Act

29 U.S.C. 206(d) 3 0 2 3

Whistleblower Protection Act

5 U.S.C. 2302(b)(1) 6 1 4 8

Genetic Information 

Nondiscrimination Act of 2008 (GINA)

42 U.S.C. 2000ff

0 1 0 0

TOTAL 322 70 189 506

JUDGMENT FUND REIMBURSEMENT10

The Department of the Treasury, Financial Management Service manages the Judgment Fund, 

which is available to the Federal government for court judgments and Justice Department 

compromise settlements of lawsuits against the Federal Government. The No FEAR Act 

requires that Federal agencies reimburse the Judgment Fund for personnel discrimination 

payments made in accordance with 28 U.S.C. §§ 2414, 2517, 2672, or 2677.11 

For FY 2019, the following DoD Components reimbursed the Judgment Fund as follows:

 

6 Does not include data from Air Force or DoDEA.

7 This column includes the total number of cases that were opened in FY 2019. It is not a sum of cases resolved or 

pending.

8 These columns include any case that was resolved in FY 2019. These cases may have been opened in FY 2019 or 

any previous FY. The case may have been settled (first column), or otherwise resolved, such as withdrawing the 

complaint (second column).

9 This column includes the number of cases that were still pending resolution at the close of FY 2019. These cases 

may have been opened in FY 2019 or during a previous FY.

10 5 C.F.R. 724.302(a)(2)(ii) and 5 C.F.R. 724.302(a)(2)(iii)

11 A payment is a disbursement from the Judgment Fund, on or after October 1, 2003, to an employee, former 

employee, or applicant for Federal employment, in accordance with 28 U.S.C. §§ 2414, 2517, 2672, 2677 or with 31 

U.S.C. § 1304, that involves alleged discriminatory or retaliatory conduct described in 5 U.S.C. § 2302(b)(1) and 

(b)(8) or (b)(9) as applied to conduct described in 5 U.S.C. § 2302(b)(1) and/or (b)(8) or conduct described in 29 

U.S.C. § 206(d), 29 U.S.C. § 631, 29 U.S.C. § 633a, 29 U.S.C. § 791 and 42 U.S.C. § 2000e-16.
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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TABLE 3: JUDGEMENT FUND REIMBURSEMENT

Component $ Reimbursed to 

Judgment Fund

$ Attributed to 

Attorneys’ Fees

Adjustment to Agency 

Budget

Army $522,000 $0 $0

Navy $572,800 $65,000 $637,800

DCSA $10,000 $0 $0

DLA $2,464.69 $0 $0

DTRA $0 $107,867.20 $0

OIG $23,000 $23,000 $23,000

WHS $0 $263,500 $0

TOTAL $1,130,264.69 $459,367.20 $660,800

The remaining DoD Components did not indicate that they made any Judgment Fund 

reimbursements.

DISCIPLINARY ACTIONS12

The Department disciplined 121 DoD employees during FY 2019 in connection with Federal 

court cases or in accordance with agency policies under antidiscrimination or whistleblower 

protection laws. The breakdown of DoD employees who were disciplined during FY 2019 is as 

follows:

TABLE 4: DISCIPLINARY ACTIONS

Statute13

# of Employees Disciplined and Type of Discipline

DoD 

Total

DoD 

Component 

Breakdown

Nature of Discipline

Title VII, Civil Rights Act of 1964

42 U.S.C. § 2000e-16 5

DTRA (1) Suspension (1)

WHS (4)

Disciplinary Warning (1)

Termination (1)

Removal (1)

Suspension (1)

Age Discrimination in Employment 

Act of 1967

29 U.S.C. §§ 631, 633a

3 WHS (3)

Disciplinary Warning (1)

Termination (1)

Suspension (1)

Fair Labor Standards Act of 1938

29 U.S.C. § 201, et seq. 0 - -

 

12 5 C.F.R. 724.302(a)(3) and 5 C.F.R. 724.302(a)(5)

13 Most DoD Components discipline their employees due to inappropriate conduct, inappropriate remarks, and/or 

conduct unbecoming. While, there may be employees that were disciplined for underlying misconduct related to 

discrimination and/or whistleblower protection, but DoD does not have a tracking mechanism to capture this data. 

Accordingly, the data listed in Table 4 may not reflect actual DoD employee discipline connected to one of the listed 

statutes.
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Section 501 of the Rehabilitation 

Act of 1973

29 U.S.C. § 791

4 WHS (4)

Removal (2)

Suspension (1)

Termination (1)

Equal Pay Act of 1963

29 U.S.C. § 206(d) 0 - -

Whistleblower Protection Act of 

2012

5 U.S.C. § 2302(b)(1)

2 Army (2) Removal14

Genetic Information 

Nondiscrimination Act of 2008

42 U.S.C. 2000ff

0 - -

Matters that did NOT result in a 

Federal court case 107

Army (46) Removal15

DeCA (39)

Letter of Concern (2)

Letter of Warning (1)

Removal (5)

Suspension (18)

Termination (3)

DFAS (7)

Reduction-in-Grade16

Reprimand

Suspension

Termination

DLA (11)

Counseling (2)

Letter of Warning (1)

Removal (2)

Suspension (1)

Reprimand (4)

Suspension (1)

Reduction-in-Grade (1)

DMA (4) Reprimand (3)

Suspension (1)

EEO COMPLAINT DATA17

Civilian employees who believe they have experienced work-related discrimination have 

multiple venues to pursue relief, including filing an EEO complaint under the authority of Part 

1614 of Title 29, CFR, and as outlined by EEOC Management Directive 110. When an 

individual first reports a concern to his or her Component’s EEO office, the individual enters the 

pre-complaint phase and is referred to as the aggrieved. The pre-complaint phase is an informal 

phase that allows the EEO professionals to aid the aggrieved in resolving the concern early. This 

can be done through mediation between the aggrieved and responding management official, or 

by simply assisting the complainant to identify options to address his or her concern. 

 

14 Data distinguishing the number of removals was not available.

15 Data distinguishing the number of removals was not available.

16 Data distinguishing the number of terminations, suspensions, reductions-grade, or reprimands was not available.

17 5 C.F.R. 724.302(a)(4)
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If the issue is not resolved during the informal pre-complaint phase, the individual has the option 

to pursue a formal complaint process. If the individual elects to file a formal EEO complaint he 

or she becomes the complainant, and the accepted allegations undergo an investigation to 

develop a complete factual record which will be used by a trier of fact to determine whether the 

allegations are substantiated. The Defense Civilian Personnel Advisory Service Investigations 

and Resolutions Directorate conducts EEO investigations for DoD. 

An EEO complainant must identify the basis18 and issue19 when bringing forward a complaint of 

discrimination. A complainant may allege multiple bases and issues in one complaint. A Final 

Agency Decision (FAD) or Final Order is issued by the Component after reviewing the 

investigative summary and report of investigation. A Final Order occurs after an Administrative 

Judge issues a decision followed by the Component’s decision on whether it will adopt the 

decision of the Administrative Judge.

 

18 The basis of complaints is the reason the complainant believes he or she was discriminated against based on a 

protected class (e.g., race, sex, disability) relating to a term, condition, or benefit of employment. 

19 The issue is the adverse employment action alleged by the complainant. For example, a complainant may allege 

she was denied a promotion because of her gender. The denial of the promotion is the issue and her gender is the 

basis. 
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FIGURE 1: EEO COMPLAINT PROCESS
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According to the Forms 462 filed by the DoD Components for FY 2019, DoD counseled 4,912

individuals in connection with 5,020 pre-complaints in FY 2019. Of the FY 2019 precomplaints, 2,140 were either settled or withdrawn and 1,821 moved into the formal complaint 

phase. The remaining pre-complaints were either pending a decision to file formal or pending at 

another step of the pre-complaint phase.

TABLE 5: PRE-COMPLAINT COUNSELINGS

Pre-Complaint Counselings

Total Pre-Complaints 5,020

On hand at beginning of FY 823

Initiated during FY 4,197

Total Completed during FY 4,073

Settled 418

Withdrawn 1,722

Filed formal 1,821

Decision to file formal pending 112

Pending 947

In FY 2019, DoD had 6,086 total formal complaints. These were either formal complaints that 

rolled over from previous fiscal years, were initiated during the fiscal year, or were remanded to 

the agency for further processing. At the end of the fiscal year, 2,698 had been closed, with 

3,388 pending.

TABLE 6: FORMAL COMPLAINTS TOP LINE RESULTS

Formal Complaints

Top-line Totals 6,086

On hand at beginning of FY 4,098

Filed during FY 1,972

Remanded (not on hand or filed during FY) 16

Closed during FY 2,698

Withdrawn 246

Settled 718

Final Agency Action (FAD or Final Order) 1,734

Pending at end of FY 3,388

In the 1,972 formal complaints newly filed in FY 2019, 10,896 allegations were made. A 

complainant may allege multiple bases for each allegation in a single complaint. The top two 

identified bases of FY 2019 allegations were reprisal (2,405 allegations or 22.1 percent of all 

allegations) and disability (2,180 allegations or 20.0 percent of all allegations). Race (1,821

allegations or 16.7 percent of all allegations) and sex (1,758 allegations or 16.1 percent of all 

allegations) were in the next tier of common bases cited in FY 2019 formal complaints. Table 7 

lists all the allegations by basis.
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TABLE 7: FY 2019 FORMAL COMPLAINT ALLEGATIONS BY BASIS

Formal Complaints

Basis # of Allegations

Race 1,821

Color 689

Religion 188

Reprisal 2,405

Sex 1,758

National Origin 515

Disability 2,180

Age 1,326

GINA20 14

A complainant may also allege multiple issues in a single complaint. The most frequent issue 

identified in the FY 2019 allegations was non-sexual harassment (3,192 allegations, or 29.3

percent of all allegations). Non-sexual harassment was alleged nearly 3.5 times more frequently 

than the next most common issue, which was promotion/non-selection (877 allegations, or 8.1

percent of all allegations). Table 8 lists all the allegations by issue.

TABLE 8: FY 2019 FORMAL COMPLAINT ALLEGATIONS BY ISSUE

Formal Complaints

Issue # of 

Allegations Issue # of Allegations

Appointment/Hire 533 Pay (Including Overtime) 144

Assignment of Duties 776 Promotion/Non-Selection 877

Awards 155 Reassignment – Denied 120

Conversion to Full-Time 6 Reassignment – Directed 240

Discipline – Demotion 65 Reasonable Accommodation 632

Discipline – Reprimand 326 Reinstatement 0

Discipline – Suspension 365 Religious Accommodation 8

Discipline – Removal 268 Retirement 46

Discipline – Other 374 Sex-Stereotyping 3

Duty Hours 155 Telework 117

Evaluation/Appraisal 694 Termination 592

Examination/Test 33 Terms/Conditions of 

Employment

502

Harassment – Non-Sexual 3,192 Time and Attendance 495

Harassment – Sexual 146 Training 263

Medical Examination 29 Other 10

 

20 Title II of the Genetic Information Nondiscrimination Act of 2008 (GINA) prohibits genetic information 

discrimination in employment.
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As shown in Table 6, there were 718 settlements during FY 2019. There were 4,130 allegations 

resolved in those 718 settlements. Tables 9 and 10 identify the bases and issues of those 

resolutions, respectively.

TABLE 9: FY 2019 FORMAL COMPLAINT SETTLED ALLEGATIONS BY BASIS

Formal Complaints

Basis # of Allegations 

Settled

Race 698

Color 241

Religion 79

Reprisal 880

Sex 712

National Origin 220

Age 790

Disability 503

GINA 7

TABLE 10: FY 2019 FORMAL COMPLAINT SETTLED ALLEGATIONS BY ISSUE

Formal Complaints

Issue

# of 

Allegations 

Settled

Issue

# of 

Allegations 

Settled

Appointment/Hire 148 Pay (Including Overtime) 49

Assignment of Duties 299 Promotion/Non-Selection 284

Awards 57 Reassignment – Denied 31

Conversion to Full-Time 0 Reassignment – Directed 60

Discipline – Demotion 7 Reasonable Accommodation 169

Discipline – Reprimand 158 Reinstatement 1

Discipline – Suspension 138 Religious Accommodation 3

Discipline – Removal 63 Retirement 17

Discipline – Other 105 Sex-Stereotyping 11

Duty Hours 58 Telework 62

Evaluation/Appraisal 298 Termination 145

Examination/Test 10 Terms/Conditions of 

Employment

205

Harassment – Non-Sexual 1,364 Time and Attendance 196

Harassment – Sexual 75 Training 98

Medical Examination 14 Other 5

The DoD Components’ Forms 462 identified that there were 28 findings of discrimination in the 

Department in FY 2019. As previously stated, a complaint may have multiple bases or issues. It 

is important to understand that findings are counted per complaint, not per allegation. There 
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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were 73 allegations in those 28 findings. Tables 11 and 12 identify the bases and issues of those 

findings, respectively.

TABLE 11: FY 2019 FORMAL COMPLAINT ALLEGATIONS RECEIVING A FINDING BY BASIS

Formal Complaints

Basis # of Allegations 

Receiving a 

Finding

Race 14

Color 1

Religion 2

Reprisal 19

Sex 5

National Origin 0

Age 29

Disability 3

GINA 0

TABLE 12: FY 2019 FORMAL COMPLAINT ALLEGATIONS RECEIVING A FINDING BY ISSUE

Formal Complaints

Issue

# of 

Allegations 

Receiving 

a Finding

Issue

# of 

Allegations 

Receiving 

a Finding

Appointment/Hire 1 Pay (Including Overtime) 2

Assignment of Duties 0 Promotion/Non-Selection 10

Awards 2 Reassignment – Denied 1

Conversion to Full-Time 1 Reassignment – Directed 2

Discipline – Demotion 1 Reasonable Accommodation 7

Discipline – Reprimand 2 Reinstatement 0

Discipline – Suspension 0 Religious Accommodation 0

Discipline – Removal 9 Retirement 0

Discipline – Other 0 Sex-Stereotyping 0

Duty Hours 2 Telework 0

Evaluation/Appraisal 1 Termination 2

Examination/Test 0 Terms/Conditions of 

Employment

4

Harassment – Non-Sexual 19 Time and Attendance 1

Harassment – Sexual 4 Training 0

Medical Examination 2 Other 0
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AGENCY’S POLICY21

The Department has multiple policies and offices providing oversight to protect against unlawful 

employment discrimination. Specifically, ODEI has two policies within its purview that address 

these issues:

 Department of Defense Directive (DoDD) 1020.02e, “Diversity Management and Equal 

Opportunity in the DoD,” June 8, 2015, incorporating Change 2, effective June 1, 2019:

o Establishes an accountability framework, based on federal laws, regulations, and 

other applicable guidance, that evaluates DoD Components’ efforts to identify 

and eliminate barriers and gaps that inhibit progress of the implementation of 

diversity and inclusion efforts. 

o Prohibits unlawful employment discrimination based on race, sex (including 

pregnancy, gender identity, and sexual orientation when based on sex 

stereotyping), color, national origin, age, religion, disability, genetic information 

or reprisal for previous EEO activity.

o Identifies and eliminates barriers and practices that impede equal opportunity for 

all employees and applicants for employment including harassment in the 

workforce.

 DoDD 1440.1, “DoD Civilian Equal Employment Opportunity (EEO) Program,” May 21, 

1987, certified current November 21, 2003, instructs that the Department:

o Prohibits discrimination based on race, color, religion, sex, national origin, age, 

mental or physical disability, or age.

o Eliminates barriers and practices that impede equal employment opportunity for 

all employees...including sexual harassment in the workforce and at work sites 

and architectural, transportation, and other barriers affecting people with 

disabilities.

In addition to the DoD policies, 21 of the responding Components reported having their own

policies addressing these topics. 

AGENCY’S TRAINING PLAN22

The Department also has two policies that provide oversight for training. ODEI has DoDD 

1440.1, “DoD Civilian Equal Employment Opportunity (EEO) Program,” May 21, 1987, 

certified current November 21, 2003, which instructs the Department to establish a continuing 

EEO educational program (including training in the prevention of sexual harassment) for civilian

and military personnel who supervise civilian employees.

The Office of Civilian Personnel Policy (CPP) has oversight for training specifically related to 

the No FEAR Act. CPP’s Department of Defense Instruction (DoDI) 1400.25, Volume 771, 

“DoD Civilian Personnel Management System: Administrative Grievance System,” December 

26, 2013, directs the DoD Components to “train all of their employees (including supervisors and 

managers) about the rights and remedies available under antidiscrimination laws and 

 

21 5 C.F.R. 724.302(a)(6)

22 5 C.F.R. 724.302(a)(9)
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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whistleblower protection laws.” The policy instructs that employees are trained at a new 

employee orientation program, or within 90 days of the employee’s start date. The policy then 

states that the training will be consistent with section 202 of Public Law 107-174. In addition, 

DoDI 1400.25, Volume 771, instructs the DoD Components to “provide training programs to 

teach employees at all levels how to identify and prevent sexual harassment.”

In addition, 20 of the responding Components reported having their own training plans. 

ANALYSIS

A) Examination of Trends

This FY 2019 Composite report is the first time DoD is able to trend its complaint data. 

1) Pre-Complaints

As previously identified, the Department had 5,020 pre-complaints, settled or had withdrawn 

2,140, and moved 1,821 into the formal complaint phase. The remaining pre-complaints were 

either pending a decision to file formal or pending at another stage of the pre-complaint process

at the close of the fiscal year. The number of FY 2019 pre-complaints decreased from FY 2018 

by approximately 30.7 percent.

FIGURE 2: DISPOSITION OF PRE-COMPLAINTS

The Department encourages resolution at the lowest level and the first opportunity for the 

Department to resolve EEO complaints is through an alternative dispute resolution (ADR) 

process during the pre-complaint phase. For FY 2019, 3,709 pre-complaints were offered ADR 

and 1,467 were accepted. Between FY 2018 and FY 2019, a larger percentage of pre-complaints 

were offered ADR, from 53.7 percent of pre-complaints in FY 2018 to 73.9 percent of precomplaints in FY 2019. However, the percentage of those accepted into the ADR process 

8.3%

34.3%

36.3%

2.2%

18.9%

Disposition of Pre-Complaints

Settled, 418 Withdrawn, 1,722

Filed formal, 1,821 Decision to file formal pending, 112

Pending, 947
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decreased from 62.8 percent in FY 2018 to 39.6 percent. Figure 3 shows the disposition of the 

pre-complaints that were accepted into the ADR process:

FIGURE 3: DISPOSITION OF PRE-COMPLAINTS IN ADR

Using ADR allowed the Department to provide 552 non-monetary benefits to resolve precomplaints. Conversely, there were 33 non-monetary benefits provided to resolve precomplaints that were resolved without ADR. This trend is similar to FY 2018, which also 

demonstrated ADR resolving matters with more non-monetary benefits in the pre-complaint 

process than resolving without ADR. A non-monetary benefit generally consists of the 

organization taking steps to reverse or mitigate an adverse employment action. It does not 

necessarily mean that there was no monetary payment; just that other reparation was provided to 

the aggrieved. Figure 4 shows the differences in the non-monetary benefits between those FY 

2019 settlements that occurred with ADR versus those that did not use ADR.

23.4%

37.2%

37.3%

2.0%

Disposition of Pre-Complaints in ADR

Settled with Benefits ($ and non-$), 523 No formal complaint filed, 830

Formal complaint filed, 833 Pending, 45
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FIGURE 4: NON-MONETARY BENEFITS IN ADR SETTLEMENTS AND NON-ADR SETTLEMENTS -

PRE-COMPLAINTS

Of course, not all settlements resolve without a monetary payment. In FY 2019, 63 precomplaint settlements resulted in the payout of $332,139.42 in compensatory damages, 

backpay/frontpay, lump sum payments, and attorney fees for the aggrieved. This is less than the 

$1,039,485.58 paid in monetary settlements during FY 2018. Again, the ADR process resolved 

significantly more pre-complaints than the non-ADR processes, and also paid out more in 

dollars. Figure 5 and Figure 6 show the breakdown of monetary benefits in ADR settlements, 

first by the number of occurrence, then by amount of dollars.

11

0

2

5

0

2

4

0

3

4

0

2

22

10

14

121

13

28

140

9

38

101

38

18

0 20 40 60 80 100 120 140 160

Hires

Promotions

Expungements

Reassignment

Removals Rescinded

Accommodations

Training

Apology

Disciplinary Action – Rescinded or Modified

Performance Evaluation Modified

Leave Restored

Other

Number of Times Non-Monetary Benefit was Applied

Non-Monetary Settlement

Non-Monetary Benefits in ADR Settlements and Non-ADR Settlements

Pre-Complaints

ADR Settlements

Non-ADR Settlements
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

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FIGURE 5: MONETARY BENEFITS IN ADR SETTLEMENTS AND NON-ADR SETTLEMENTS - PRECOMPLAINTS (NUMBER)

3

1

3

0

6

3

40

7

0 10 20 30 40 50

Compensatory Damages

Backpay/Frontpay

Lump Sum Payments

Attorney Fees

Number of Times Monetary Benefit was Applied

Monetary Benefit

Monetary Benefits in ADR Settlements and Non-ADR Settlements

Pre-Complaints

ADR Settlement with $

Non-ADR Settlement with $
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

17

FIGURE 6: MONETARY BENEFITS IN ADR SETTLEMENTS AND NON-ADR SETTLEMENTS - PRECOMPLAINTS (DOLLARS)

2) Formal Complaints

As previously identified, the Department had 6,086 active formal complaints, and closed 2,698 

during the fiscal year. The remaining 3,388 formal complaints were pending at the close of the 

fiscal year. The number of FY 2019 formal complaints decreased from FY 2018 by 33.4 

percent. While there were fewer complaints that carried over from FY 2018 to FY 2019 (4,098 

complaints) than there were from FY 2017 to FY 2018 (5,933), there were also fewer complaints 

formally filed in FY 2019 (1,972 complaints) than FY 2018 (3,170 complaints). The disposition 

of the FY 2019 formal complaints is demonstrated in Figure 7.

$14,616.00 $15,000.00 $14,616.00

$0.00

$45,192.80

$7,758.20

$214,131.42

$20,825.00

$0.00

$50,000.00

$100,000.00

$150,000.00

$200,000.00

$250,000.00

Benefit Amount in Dollars

Monetary Settlement

Monetary Benefits in ADR Settlements and Non-ADR Settlements

Pre-Complaints

Non-ADR Settlement with $

ADR Settlements with $
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

18

FIGURE 7: DISPOSITION OF FORMAL COMPLAINTS

A complainant may also resolve a formal complaint by employing ADR methods during the 

formal complaint phase. For FY 2019, 360 formal complaints were offered ADR and 213 were 

accepted (59.1 percent). Of those 213, 130 (61.0 percent) were settled or withdrawn. While 

these numbers are less than those in FY 2018, the percentages are similar, with 60.4 percent of 

the complaints offered ADR being accepted and a 61.8 percent of accepted complaints settling or 

being withdrawn. Figure 8 shows the disposition of the FY 2019 formal complaints that were 

accepted into the ADR process.

FIGURE 8: DISPOSITION OF FORMAL COMPLAINTS IN ADR

4.0%

11.8%

55.7% 28.5%

Disposition of Formal Complaints

Withdrawals, 246 Settled, 718 Final Agency Action, 1,734 Pending, 3,388

58.7%

2.3%

36.2%

2.8%

Disposition of Formal Complaints in ADR

Settled with Benefits ($ and non-$), 125 Withdrawn from EEO, 5

No resolution, 77 ADR did not occur, 6
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

19

Using ADR allowed the Department to provide 145 non-monetary benefits to formal complaints 

outside of monetary payments. There were 357 non-monetary benefits to formal complaints that 

were closed without employing ADR. Figure 9 shows the differences in the non-monetary 

benefits between those closures that occurred with ADR versus those that did not use ADR.

FIGURE 9: NON-MONETARY BENEFITS IN ADR CLOSURES AND NON-ADR CLOSURE -

FORMAL COMPLAINTS

6

10

16

66

27

7

46

1

22

24

98

34

6

2

1

44

10

6

23

1

7

6

30

9

0 20 40 60 80 100 120

Hires

Promotions

Expungements

Reassignment

Removals Rescinded

Accommodations

Training

Apology

Disciplinary Action – Rescinded or Modified

Performance Evaluation Modified

Leave Restored

Other

Number of Times Non-Monetary Benefit was Applied

Non-Monetary Benefit

Non-Monetary Benefits in ADR Closures and Non-ADR Closure

Formal Complaints

ADR Closures

Non-ADR Closures
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

20

Of course, not all complaints close without a monetary payment. In FY 2019, 671 occurrences 

of monetary benefits paid out in the closure of a formal complaint, resulting in a total payout of 

$18,755,370.27 in compensatory damages, backpay/frontpay, lump sum payments, and attorney 

fees for the complainant. While the number of occurrences of monetary benefits paid out in FY 

2019 is smaller than that of FY 2018 (828 occurrences), the dollar amount paid in FY 2019 is 

greater than the $17,638,868.61 paid in FY 2018.

FIGURE 10: MONETARY BENEFITS IN ADR CLOSURES AND NON-ADR CLOSURES - FORMAL 

COMPLAINTS (NUMBER)

73

17

355

152

9

6

46

13

0 50 100 150 200 250 300 350 400

Compensatory Damages

Backpay/Frontpay

Lump Sum Payments

Attorney Fees

Number of Times Monetary Benefit was Applied

Monetary Settlement

Monetary Benefits in ADR Closures and Non-ADR Closures

Formal Complaints

ADR Closure with $

Non-ADR Closure with $
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

21

FIGURE 11: MONETARY BENEFITS IN ADR CLOSURES AND NON-ADR CLOSURES - FORMAL 

COMPLAINTS (DOLLARS)

(a) Common Issue Allegations

DoD had 1,972 formal complaints filed during FY 2019, containing 10,896 allegations. As 

previously mentioned, the top two identified bases of FY 2019 allegations were reprisal (2,405 

allegations or 22.1 percent of all allegations) and disability (2,180 allegations or 20.0 percent of 

all allegations). Race (1,821 allegations or 16.7 percent of all allegations) and sex (1,758 

allegations or 16.1 percent of all allegations) were in the next tier of common bases cited in FY 

2019 formal complaints. These common basis are the same as FY 2018, with reprisal and 

disability as the top two identified bases (21.9 percent and 18.6 percent, respectively), with race 

(17.2 percent) and sex (17.1 percent) in the next tier.

The most frequent allegation across all bases was non-sexual harassment, with a total of 3,192

allegations (29.3 percent of all allegations). Figure 12 shows the breakdown of how many nonsexual harassment allegations were made by basis.

$4,526,336.21

$286,145.08

$7,403,286.22

$5,599,351.29

$75,000.00 $24,849.42

$657,517.05

$182,885.00

$0.00

$1,000,000.00

$2,000,000.00

$3,000,000.00

$4,000,000.00

$5,000,000.00

$6,000,000.00

$7,000,000.00

$8,000,000.00

Dollars

Monetary Benefit

Monetary Benefits in ADR Closures and Non-ADR Closures

Formal Complaints

Non-ADR Closure with $

ADR Closure with $
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

22

FIGURE 12: NON-SEXUAL HARASSMENT ALLEGATIONS BY BASIS

This is similar to FY 2018, which also had non-sexual harassment as the most frequent 

allegations (29.7 percent of FY 2018 allegations). There were also similar patterns in the basis 

of these non-sexual harassment allegations between FY 2018 and FY 2019.

Other top issues identified in allegations were assignment of duties, evaluation/appraisal, 

promotion/non-selection, reasonable accommodation, and terms/conditions of employment. 

Figure 13 shows the breakout of the next five top allegations per basis (not including non-sexual 

harassment).

575

210

53

708

544

169

572

357

4

0

100

200

300

400

500

600

700

800

Number of Allegations

Basis

Non-Sexual Harassment Allegations by Basis

Race Color Religion Reprisal Sex National Origin Disability Age GINA
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

23

FIGURE 13: TOP 5 ISSUES (AFTER NON-SEXUAL HARASSMENT) BY BASIS23

These were similar to those identified in FY 2018, with one exception: FY 2018 included 

terms/conditions of employment instead of termination.

Figure 13 demonstrates the top allegations (other than non-sexual harassment) from the total 

allegations. However, allegations based on color, reprisal, sex, or disability, when viewed 

independently, had a significant number of other allegations for different issues than those 

identified in Figure 13. 

Specifically, the list of the top five issues based on color outside non-sexual harassment does not 

include appointment/hire. The top five issues based on color outside non-sexual harassment 

are:24

 Assignment of Duties (55 allegations)

 Evaluation/Appraisal (48 allegations)

 

23 Figure 14 excludes GINA as a basis because the number of allegations was too few to show up on a chart, 

receiving no more than 2 allegations on an issue, at most.

24 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

100

143

127

175

90

31

55 48

65

38

20

11 14 16 12

113

156

183

155

116

70

144

105

137

80

30 34 28

51

37

93

123

97

108

149

75

109

92

168

68

NUMBER OF 

ALLEGATIONS

ISSUE

TOP 5 ISSUES IN ALLEGATIONS (AFTER NONSEXUAL HARASSMENT) BY BASIS

Race Color Religion Reprisal Sex National Origin Disability Age
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

24

 Promotion/Non-Selection (56 allegations)

 Termination (38 allegations)

 Time and Attendance (35 allegations)

The list of the top five issues based on reprisal outside non-sexual harassment does not include 

appointment/hire or termination. The top five issues based on reprisal outside non-sexual 

harassment are: 25

 Assignment of Duties (156 allegations)

 Evaluation/Appraisal (183 allegations)

 Promotion/Non-Selection (155 allegations)

 Terms/Conditions of Employment (120 allegations)

 Time and Attendance (120 allegations)

The list of the top five issues based on sex outside non-sexual harassment does not include 

appointment/hire. The top five issues based on sex outside non-sexual harassment are: 26

 Assignment of Duties (144 allegations)

 Evaluation/Appraisal (105 allegations)

 Harassment – Sexual (121 allegations)

 Promotion/Non-Selection (137 allegations)

 Termination (80 allegations)

The list of the top five issues based on disability outside non-sexual harassment does not include 

appointment/hire. The top five issues based on disability outside non-sexual harassment are: 27

 Assignment of Duties (123 allegations)

 Evaluation/Appraisal (97 allegations)

 Promotion/Non-Selection (108 allegations)

 Reasonable Accommodation (267 allegations)

 Termination (147 allegations)

(b) Common Issue Settlements

In FY 2019, there were 4,130 allegations settled in 718 settlements. The most frequent 

allegation settled across all bases was non-sexual harassment, with a total of 1,675 allegations 

settled (40.6 percent of all settled allegations). Figure 15 shows the breakdown of how many 

non-sexual harassment allegations were made by basis.

 

25 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

26 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

27 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

25

FIGURE 14: NON-SEXUAL HARASSMENT SETTLEMENTS BY BASIS

This is similar to FY 2018, which also had non-sexual harassment as the most frequent allegation 

in settlements (31.8 percent of FY 2018 settled allegations). There were also similar patterns in 

the basis of these non-sexual harassment allegations between FY 2018 and FY 2019.

Other top issues identified in settlements were assignment of duties, evaluation/appraisal, 

promotion/non-selection, terms/conditions of employment, and time and attendance. Figure 15

show the breakout of the next five top allegations per basis (not including non-sexual 

harassment).

259

95

28

287

232

90

219

152

2

0

50

100

150

200

250

300

350

Number of Settlements

Basis

Non-Sexual Harassment Settlements by Basis

Race Color Religion Reprisal Sex National Origin Disability Age GINA
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

26

FIGURE 15: TOP 5 ISSUES SETTLED (AFTER NON-SEXUAL HARASSMENT) BY BASIS28

In FY 2018, the top five issues settled (after non-sexual harassment) included were 

appointment/hire, assignment of duties; evaluation/appraisal, promotion/non-selection, and 

terms/conditions of employment.

Figure 15 demonstrates the top settled allegations from the total allegations. However,

allegations based on race, religion, reprisal, sex, or disability, when viewed independently, had a 

significant number of other allegations for different issues than those identified in Figure 15. 

Specifically, the list of the top five issues based on race outside non-sexual harassment that were 

settled also includes appointment/hire. The top five issues based on race outside non-sexual 

harassment that were allegations involved in settlements are: 29

 Appointment/Hire (30 allegations)

 Assignment of Duties (50 allegations)

 

28 Figure 16 excludes GINA as a basis because the number of allegations was too few to show up on a chart, 

receiving no more than 2 settled allegations on an issue, at most.

29 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

50 53

61

30

37

18 17 17

13 14

4

7

4

6

3

70

80

45

54

43

57 54

48

32 29

10

17

12

18

11

47

34 34

27

39

43

36

61

25

20

NUMBER OF 

SETTLEMENTS

ISSUE

TOP 5 ISSUES SETTLED (AFTER NON-SEXUAL 

HARASSMENT) BY BASIS

Race Color Religion Reprisal Sex National Origin Disability Age
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

27

 Evaluation/Appraisal (53 allegations)

 Promotion/Non-Selection (61 allegations)

 Terms/Conditions of Employment (30 allegations)

 Time and Attendance (37 allegations)

The list of the top five issues based on religion outside non-sexual harassment that were settled

does not include time and attendance. The top five issues based on religion outside non-sexual 

harassment that were allegations involved in settlements are: 30

 Assignment of Duties (4 allegations)

 Discipline-Suspension (4 allegations)

 Duty Hours (6 allegations)

 Evaluation/Appraisal (7 allegations)

 Promotion/Non-Selection (4 allegations)

 Terms/Conditions of Employment (6 allegations)

The list of the top five issues based on reprisal outside non-sexual harassment that were 

allegations involved in settlements does not include time and attendance. The top five issues 

based on sex outside non-sexual harassment that were allegations involved in settlements are: 31

 Assignment of Duties (70 allegations)

 Discipline-Reprimand (44 allegations)

 Evaluation/Appraisal (80 allegations)

 Promotion/Non-Selection (45 allegations)

 Terms/Conditions of Employment (54 allegations)

The list of the top five issues based on sex outside non-sexual harassment that were allegations 

involved in settlements does not include time and attendance. The top five issues based on sex 

outside non-sexual harassment that were allegations involved in settlements are: 32

 Assignment of Duties (57 allegations)

 Evaluation/Appraisal (54 allegations)

 Harassment-Sexual (59 allegations)

 Promotion/Non-Selection (48 allegations)

 Terms/Conditions of Employment (32 allegations)

The list of the top five issues based on national origin outside non-sexual harassment that were 

allegations involved in settlements does not include time and attendance. The top five issues 

 

30 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

31 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

32 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

28

based on national origin outside non-sexual harassment that were allegations involved in 

settlements are: 33

 Assignment of Duties (10 allegations)

 Discipline-Reprimand (11 allegations)

 Evaluation/Appraisal (17 allegations)

 Promotion/Non-Selection (12 allegations)

 Terms/Conditions of Employment (18 allegations)

 Time and Attendance (11 allegations)

The list of the top five issues based on disability outside non-sexual harassment that were 

allegations involved in settlements does not include terms/conditions of employment. The top 

five issues based on disability outside non-sexual harassment that were allegations involved in 

settlements are: 34

 Assignment of Duties (47 allegations)

 Evaluation/Appraisal (34 allegations)

 Promotion/Non-Selection (34 allegations)

 Reasonable Accommodation (135 allegations)

 Time and Attendance (39 allegations)

(c) Common Issue Findings

In FY 2019, there were 28 findings in FADs or final orders involving 73 allegations, which is a 

decrease from the 30 findings in FADs or final orders in FY 2018, but an increase from the 51 

allegations in the findings from FY 2018. The most frequent finding across all bases was for

non-sexual harassment, with a total of 19 allegations receiving a finding (26.0 percent of all 

allegations in findings). Non-sexual harassment was also the most frequent allegation with a 

finding in FY 2018, with it being 31.4 percent of all allegations in findings. Figure 16 shows the 

breakdown of how many non-sexual harassment allegations were addressed in a finding by basis.

 

33 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.

34 The bolded issues in the bulleted lists are the issues that were not in the top five most common issues for DoD as a 

whole.
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

29

FIGURE 16: NON-SEXUAL HARASSMENT FINDINGS BY BASIS35

Reprisal was the most frequent basis of a finding of non-sexual harassment in both FY 2019 and 

FY 2018, with a decrease from FY 2018 (9 out of 16) to FY 2019 (6 out of 19). There was, 

however, an increase in disability as a basis in a finding of non-sexual harassment from FY 2018 

(1 out of 16) to FY 2019 (5 out of 19).

Due to the small number of findings, the actual findings per basis vary greatly in the issue, but 

generally only receiving 1 or 2 findings. The two non-sexual harassment issues that were 

addressed in a finding that stand out are sexual harassment (6 allegations) and reasonable 

accommodation (7 allegations). In addition, the basis that received the most findings for 

discrimination was disability (29 allegations)

B) Actions Planned or Taken for Improvement Measures

The disparity between non-sexual harassment allegations and all the other allegations remains a 

topic of interest to the Department. The Department is aware of harassment concerns among its 

Total Force and considers prevention and response of all harassment a priority. Accordingly, as 

stated in DoD’s FY 2018 report, the Under Secretary of Defense for Personnel and Readiness 

(USD(P&R)) established the Defense Equal Opportunity Reform Group (DEORG) and assigned 

the Executive Director of the Office of Force Resiliency as its chair in July of 2018. The 

DEORG consists of representatives from all DoD stakeholders, including the Military 

 

35 There were no findings for allegations of non-sexual harassment based on religion, national origin, or GINA in 

FY 2018.

3

1 1

6

2

0

5

1

0

0

1

2

3

4

5

6

7

Number of Findings

Basis

Non-Sexual Harassment Findings by Basis

Race Color Religion Reprisal Sex National Origin Disability Age GINA
DEPARTMENT OF DEFENSE FISCAL YEAR 2019 NO FEAR ACT COMPOSITE REPORT

30

Departments, ODEI, and CPP. This collaborative approach aids in developing strategies to 

identify, report, and resolve harassment.

The DEORG established two working groups, one to focus on harassment occurring in the DoD 

civilian employee population, and the other focusing on Service members. In July of 2019, each 

working group proposed solutions to the DEORG which were then reviewed. The Department is 

currently refining these proposed solutions and preparing them for implementation.

CONCLUSION

This FY 2019 No FEAR Act report is the first time the Department is able to trend its complaint 

data. The Department aims to achieve unity of effort and purpose across DoD in the execution 

of unlawful discrimination and harassment prevention initiatives and activities. The Department 

will continue to incorporate insights from its prevention subject matter experts who have 

experience in developing evidence-based prevention methods. The Department will also 

continue to track complaint data to evaluate the effectiveness of current policies and processes in 

addition to making recommendations for the future to ensure a climate of diversity and inclusion 

founded on dignity and respect.