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Affirmative Action 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 affirmative action plan will 

improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities.

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 CFR §1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation 

of persons with disabilities and persons with targeted disabilities in the federal government

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving PWD by grade level cluster in the 

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

a. Cluster GS-1 to GS-10 (PWD) Answer No

b. Cluster GS-11 to SES (PWD) Answer No

There is a higher percent of PWD in the GS1-10 cluster than in the GS 11-SES cluster. The percent of PWD for those in the GS 11-

SES positions shows strongly and is close to the 12% benchmark, whereas the GS 1-10 cluster is above the benchmark. NASS has 

made strides to increase its permanent workforce statistics for PWD and PWTD. In FY 2018, NASS increased the percent for the 

GS1-10 cluster to 15.5% for PWD and rose to 5.6% for PWTD in the GS1-10 cluster. NASS also showed progress and improved 

the Agency’s PWD percent to 8.9% and the PWTD percent to 1.6% in the GS 11-SES cluster; both up from FY17.

*For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, as set forth in 29 C.F.R. § 1614.203(d)(7). For all 

other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the Washington, DC 

metropolitan region.

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by grade level cluster in the 

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

a. Cluster GS-1 to GS-10 (PWTD) Answer No

b. Cluster GS-11 to SES (PWTD) Answer Yes

There is a higher percent of PWTD in the GS1-10 cluster than in the GS 11-SES cluster. The percent of PWTD for those in the GS 

11-SES positions is close to the 2% benchmark, whereas the GS 1-10 cluster is above the goal. The agency in total is slightly above 

the 2% goal for PWTD. The agency has just come off a hiring freeze, and there is low turnover rate, but efforts continue to recruit 

and retain both PWD and PWTD.

Grade Level Cluster(GS or Alternate Pay 

Planb)

Total Reportable Disability Targeted Disability

# # % # %

Numarical Goal -- 12% 2%

Grades GS-1 to GS-10 142 22 15.49 8 5.63

Grades GS-11 to SES 742 66 8.89 13 1.75

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.
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During FY 2018, NASS focused on the recruitment, hiring and retention of employees with disabilities in an effort to increase the 

numbers within its workforce. A hiring manager course on reasonable accommodations’ provisions was again scheduled during the 

year. This course included review of the use of special hiring authorities. Senior leaders and hiring managers are briefed quarterly 

through the use of an MD-715 Executive Summary. These senior staff also receive the full quarterly and annual MD-715 reports. 

NASS also participates in the Workforce Recruitment Program, and participates fully with the interagency working group, Federal 

Exchange on Employment and Disability (FEED). CRO also circulated agency-wide the U.S. Department of Labor memo looking 

for federal employees to act as volunteer recruiters for the Workforce Recruitment Program (WRP). NASS Staff attended the 

Federal Exchange on Employment and Disability (FEED) meeting: "Using Special Hiring Authorities to Advance Federal 

Employment of People with Disabilities"; the OPM webinar: Effective Skills for Successful Federal Recruiters (Parts I and II); the 

EARN webinar: Reasonable Accommodations: The Foundation for a Disability-Inclusive Federal Workforce; EEOC webinar: 

Reasonable Accommodation Case Law Update – a case law update on recent EEOC decisions on reasonable accommodations 

tailored to provide greater understanding of how to properly accommodate individuals with disabilities; and the WRP webinar on 

summer internship hiring of qualified, Schedule A-eligible candidates through WRP; and the EEOC webinar: Q&A/MD-715 Part J 

Affirmative Action Plans

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.

Answer Yes

NASS did conduct a disability recertification initiative in FY 2018. NASS staff were notified that the CRO currently collects, 

monitors, and analyzes workforce statistics to ensure the Agency is making progress in the recruitment, advancement, and retention 

of women, minorities, and individuals with disabilities. Staff were advised that OPM had recently updated the Federal list of 

disability and serious health conditions codes; and this presented a good opportunity to have staff review current disability status 

and update codes if necessary using the self-service feature in the National Finance Center (NFC) Employee Personal Page. It was 

initially demonstrated that after the recertification effort, the needle had only moved slightly; changes in percent of PWD and 

PWTD were much less than anticipated. However, upon closer inspection, it appears that the disability coding in the NFC system is 

INCONSISTENT with the data tables produced for NASS for MD 715 analysis. It was discovered that a person who showed up at a 

certain GS level with a specific targeted disability on NFC records did not always appear correctly on Table B4. There is also some 

confusion on some of the disability codes being targeted versus non-targeted at OPM. For instance, on SF-256, Code 40 is a listed 

as targeted disability, but on the current OPM Data, Analysis, and Documentation page on the OPM Data Standards tab, Code 40, 

nor any code, has no identifier of either targeted or non-targeted disability. Formerly, the out of data OPM Data Standards tab listed 

codes as either targeted or non-targeted. Perhaps this is the source of some of the confusion. USDA is currently investigating the 

anomaly. There is suspicion that the changeover to the new OPM disability codes has not been complete in all the different areas 

and programs that access and make available the disability data. It is believed that NASS staff did make changes to disability codes 

as asked, but not all updates are being represented on the current data tables.

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 

Full Time Part Time Collateral Duty Email)

Processing applications from PWD and PWTD 5 0 0 ARS, HR Office
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Disability Program Task

# of FTE Staff By Employment Status Responsible Official 

(Name, Title, Office 

Full Time Part Time Collateral Duty Email)

Answering questions from the public about 

hiring authorities that take disability into 

account

5 0 0 ARS, HR Office

Processing reasonable accommodation requests 

from applicants and employees

1 0 0 Tonya Morris

ARS

Section 508 Compliance 1 0 0 Sue King,

NASS PAO

Architectural Barriers Act Compliance 1 0 0 USDA

Special Emphasis Program for PWD and 

PWTD

1 0 0 June Turner,

NASS CRO

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.

Answer Yes

Program staff regularly attend seminars sponsored by FEED, EARN, and JAN. OPM has also sponsored training sessions on 

disability hiring and retention, which NASS staff have attended. NASS staff participates in the Workforce Recruitment Program, 

and participates fully with the interagency working group, FEED. CRO also circulated agency-wide the U.S. Department of Labor 

memo looking for federal employees to act as volunteer recruiters for the Workforce Recruitment Program (WRP). NASS staff 

attended the FEED meeting: "Using Special Hiring Authorities to Advance Federal Employment of People with Disabilities"; the 

OPM webinar: Effective Skills for Successful Federal Recruiters (Parts I and II); the EARN webinar: Reasonable Accommodations: 

The Foundation for a Disability-Inclusive Federal Workforce; EEOC webinar: Reasonable Accommodation Case Law Update – a 

case law update on recent EEOC decisions on reasonable accommodations tailored to provide greater understanding of how to 

properly accommodate individuals with disabilities; and the WRP webinar on summer internship hiring of qualified, Schedule Aeligible candidates through WRP. NASS will have challenges analyzing some of the data until the Department resolves the issues of 

producing accurate and useful applicant flow tables. In FY 2019, the Department is procuring a new system (USA Staffing) to get 

better analyses tables for applicant flow.

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.

Answer Yes

Section III: Program Deficiencies In The Disability Program

Section IV: 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 APPLICATIONS WITH DISABILITIES
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1. Describe the programs and resources the agency uses to identify job applicants with disabilities, including individuals with 

targeted disabilities.

While USDA is just beginning to recover from a hiring freeze, current budget conditions have added constraints which have slowed 

NASS’s ability to hire, NASS does use the Schedule A Hiring Authority to appoint eligible people and Veterans with disabilities 

into positions when available at the agency. NASS is also involved yearly with the WRP. The agency participates in the program by 

sending a recruiter to various colleges and university to interview recent graduates and college students with disabilities for summer 

and permanent jobs.

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

Managers with hiring authority both in Headquarters and in the 12 Regional Field Offices attend numerous job and career fairs at 

colleges and universities throughout the year to recruit potential candidates for employment. Many of these institutions have 

Veterans and students with disabilities. As mentioned in the previous question, NASS participations in the Office of Personnel 

Management’s (OPM) Workforce Recruitment Program as well as, working closely with the agency’s Disability Program Manager 

to help identify resources to hiring people with disabilities.

3. When individuals apply for a position under a hiring authority that takes disability into account (e.g., Schedule A), explain 

how the agency (1) determines if the individual is eligible for appointment under such authority; and, (2) forwards the 

individual's application to the relevant hiring officials with an explanation of how and when the individual may be 

appointed.

NASS predominately uses OPM’s USA Jobs to recruit potential candidates and works closely with its Human Resource Office to 

determine Schedule A eligibility if people and veterans with disabilities apply. These lists of qualified Schedule A applicants are 

referred to management when positions become available.

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.

Answer Yes

Hiring managers and Senior leadership receive annual reasonable accommodation which includes Special Hiring Authorities 

overview and hope to use them.

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.

NASS will continue to partner with various colleges and universities to recruit qualified persons with disabilities. In addition, the 

agency will continue to participate in the Workforce Recruitment Program, which targets students and recent graduates with 

disabilities and the disabled veterans. NASS has also begun to plan to work more closely with both EARN and JAN. Since JAN is 

headquartered in WV, NASS staff are planning a site visit in Spring, 2019, to meet face to face and develop a working relationship 

with JAN staff. Information and resources shared at FEED meetings has also beneficial.

C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING)

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

the new hires in the permanent workforce? If “yes”, please describe the triggers below.

a. New Hires for Permanent Workforce (PWD) Answer No
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b. New Hires for Permanent Workforce (PWTD) Answer No

NASS had only one (1) new hire for all of FY 2018. This new hire was a PWTD; therefore, the percent for new hire PWD is 100% 

and the percent for new hire PWTD is also 100%. Currently, in the Mission Critical Occupations (GS 1529, 1530, and 2210), the 

Agency has a rate of 9.2% PWD and 1.7% PWTD in these three job series – improved from the FT 2018 levels. Hiring officials in 

the 12 Regional Field Offices have been instructed to make contact with their State Vocational Rehabilitation agencies and create 

dialog in the hopes that NASS can have more hiring opportunities in the future.

New Hires Total

Reportable Disability Targeted Disability

Permanent 

Workforce

Temporary 

Workforce

Permanent 

Workforce

Temporary 

Workforce

(#) (%) (%) (%) (%)

0

0

1 100.00 0.00 100.00 0.00

% of Total 

Applicants

% of Qualified 

Applicants

% of New Hires

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. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for MCO (PWD) Answer No

b. New Hires for MCO (PWTD) Answer No

With only one new hire for FY 2018, there is not enough data to answer this question. It is worth noting again that the one NASS 

new hire self-identified as a PWTD.

New Hires to 

Mission-Critical 

Occupations

Total

Reportable Disability Targetable Disability

Qualified 

Applicants New Hires Qualified Applicants New Hires

(#) (%) (%) (%) (%)

Numerical Goal -- 12% 2%

1529MATHEMATICAL 

STATISTICS

122 0.00 0.82 0.00 0.82

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. Select “n/a” if 

the applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Qualified Applicants for MCO (PWD) Answer No

b. Qualified Applicants for MCO (PWTD) Answer No

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. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Promotions for MCO (PWD) Answer No

b. Promotions for MCO (PWTD) Answer No
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Section V: 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.

Through the use of the MD-715 B Table analyses, NASS will monitor the recruitment, retention, and advancement of those 

employees self-identifying as PWD and PWTD. The NASS Civil Rights Office prepares both quarterly and an annual MD-715. 

From this report, a special briefing is prepared for the Senior Executive Team. Contained within this briefing are highlights of 

findings, analyses of trends both negative and positive, and triggers that might have been identified that could cause barriers to 

employment or advancement. Both A Tables and B Table findings are summarized in the briefing. NASS staff attended the USDA/

AMS Mentoring Program, “Overcoming Barriers to Employment - Resume Building” webinar workshop that provided techniques 

and skills on improving resume writing, the federal resume template, and interviewing techniques for applying to federal jobs.

B. CAREER DEVELOPMENT OPPORTUNITES

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

NASS convened a Career Path Team, which in turn created Career Path Guides for the first three mission critical occupational 

series, followed by seven additional job series. These guides describe suggested career paths for each series within NASS. Each 

guide provides a “roadmap to success” to help employees plan their professional development and achieve career goals within the 

agency. NASS also promotes intra-and inter-Agency details for employees as a tool for career enhancement when considering the 

training and developmental aspects of the assignment. The NASS Special Emphasis Program Manager position is a collateral duty 

assignment, with a focus on inclusion. Two programs were sponsored by NASS during FY 2018 for Disabilities Awareness Month: 

Understanding Reasonable Accommodation and a guided tour of the South Building TARGET Center. NASS staff attended the 

USDA, Office of Human Resources Management, National Disability Employment Awareness Month observance where the guest 

speaker leverages employment of people with disabilities to advance corporate success. The title of the presentation was Inclusion 

Drives Innovation. All NASS staff were invited to attend OPM’s training session, The Executive Core Qualifications - Preparing for 

Application to the Senior Executive Service, which targeted Agency employees aspiring and preparing to apply to the SES, as well 

as those applying to the SES Candidate Development Program (CDP) candidates preparing their ECQs for review.

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

Coaching Programs

Detail Programs

Mentoring Programs 29 29 3 3

Training Programs 127 127 14 14 3 3

Other Career Development 

Programs

18 18 2 2
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3. Do triggers exist for PWD among the applicants and/or selectees for any of the career development programs? (The 

appropriate benchmarks are the relevant applicant pool for the applicants and the applicant pool for selectees.) If “yes”, 

describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWD) Answer No

b. Selections (PWD) Answer No

4. Do triggers exist for PWTD 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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWTD) Answer No

b. Selections (PWTD) Answer No

C. AWARDS

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for any level of 

the time-off awards, bonuses, or other incentives? If “yes”, please describe the trigger(s) in the text box.

a. Awards, Bonuses, & Incentives (PWD) Answer No

b. Awards, Bonuses, & Incentives (PWTD) Answer No

Time-Off Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Time-Off Awards: 1-9 hours : 

Total Time-Off Awards Given

19 21.05 78.95 5.26 15.79

Time-Off Awards: 9+ hours : 

Total Time-Off Awards Given

2 0.00 100.00 0.00 0.00

Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $100 - $500: Total 

Cash Awards Given

542 11.99 88.01 2.21 9.78

Cash Awards: $501+: Total Cash 

Awards Given

760 7.50 92.50 1.97 5.53

2. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for quality step 

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

a. Pay Increases (PWD) Answer No

b. Pay Increases (PWTD) Answer No
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Other Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Quality Step Increases (QSI): 

Total QSIs Awarded

7 14.29 85.71 0.00 14.29

Performance Based Pay Increase 0 0.00 0.00 0.00 0.00

3. If the agency has other types of employee recognition programs, are PWD and/or PWTD recognized disproportionately 

less than employees without disabilities? (The appropriate benchmark is the inclusion rate.) If “yes”, describe the 

employee recognition program and relevant data in the text box.

a. Other Types of Recognition (PWD) Answer No

b. Other Types of Recognition (PWTD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

b. Grade GS-15

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

c. Grade GS-14

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

d. Grade GS-13

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and 

describe your plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No
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b. Grade GS-15

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

c. Grade GS-14

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

d. Grade GS-13

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

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. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWD) Answer No

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

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

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

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. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWTD) Answer No

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

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

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

There is no trigger as there are so few new hires to NASS in the last three fiscal years. The only trigger has been the hiring freeze 

and flat budget for the Agency.

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. Select “n/a” if the applicant data is not 

available for your agency, and describe your plan to provide the data in the text box.

a. Executives
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i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

b. Managers

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

c. Supervisors

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer No

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. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

b. Managers

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

c. Supervisors

i. Qualified Internal Applicants (PWTD) Answer No

ii. Internal Selections (PWTD) Answer No

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. Select “n/a” if the applicant data is 

not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWD) Answer No

b. New Hires for Managers (PWD) Answer No

c. New Hires for Supervisors (PWD) Answer No

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. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWTD) Answer No
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b. New Hires for Managers (PWTD) Answer No

c. New Hires for Supervisors (PWTD) Answer No

Section VI: Plan to Improve Retention of Persons with Disabilities

To be 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 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.

Answer Yes

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) Answer No

b.Involuntary Separations (PWD) Answer No

Seperations Total # Reportable Disabilities %

Without Reportable 

Disabilities %

Permenant Workforce 884 10.07 89.93

Total Separations 58 10.34 89.66

Voluntary Separations 56 10.71 89.29

Involuntary Separations 2 0.00 100.00

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) Answer No

b.Involuntary Separations (PWTD) Answer No

Seperations Total # Targeted Disabilities %

Without Targeted Disabilities 

%

Permenant Workforce 884 2.26 97.74

Total Separations 58 0.00 100.00

Voluntary Separations 56 0.00 100.00

Involuntary Separations 2 0.00 100.00

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.
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B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES

Pursuant to 29 CFR §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.

https://www.ocio.usda.gov/policy-directives-records-forms/section-508 NASS currently defers to the Departmental Section 508 

Regulation. While there is no formal Section 508 complaint process within USDA, these complaints would be referred thought the 

regular EEO complaint process. The Office of the Assistant Secretary for Civil Rights is also not equipped to handle Section 508 

complaints, but is currently reviewing and mediating complaints based on Section 504 of the Rehabilitation Act.

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.

https://www.ocio.usda.gov/policy-directives-records-forms/section-508 This file can be accessed on the NASS website homepage 

through the USDA Policies Link/USDA Accessibility Statements.

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.

At this time, the Agency has not needed to improve accessibility to any facilities – the facilities that NASS occupies either fall 

under USDA or rented GSA facilities which are 508 compliant.

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.)

NASS does have a policy in place and the average processing time is two days. Upon receipt, all supervisors review reasonable 

accommodation requests immediately. Once approved, these requests are forwarded to USDA ARS AFM, Tonya Morris, 

Reasonable Accommodations Manager, which is the Agency that handles HR functions for the REE Mission Area under which 

NASS is organized.

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.

All reasonable accommodations requests are processed and implemented in a timely fashion.

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE
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Pursuant to 29 CFR §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.

NASS is creating a personal assistance services (PAS) training module that will be made available for all employees during FY 

2019. The nature and family culture of most of the employees at NASS ensures that personal services would be offered to those in 

need regardless of an official PAS request. The Agency is waiting for USDA to publish a Department-wide RA/PAS policy 

statement (which is somewhat past the originally planned publishing due date), therefore, NASS is adhering to the ARS approved 

RA/PAS plan submitted for the mission area..

Section VII: 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 governmentwide average?

Answer No

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?

Answer No

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.

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?

Answer No

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?

Answer No

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation 

during the last fiscal year, please describe the corrective measures taken by the agency.

Section VIII: 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?
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Answer Yes

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD?

Answer Yes

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

STATEMENT OF 

CONDITION THAT WAS A 

TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at issue.

How was the condition 

recognized as a potential barrier?

Low participation in the target disabilities (GS-11 – SES)

STATEMENT OF BARRIER 

GROUPS:

Barrier Group

People with Disabilities

BARRIER ANALYSIS:

Provide a description of the steps 

taken and data analyzed to 

determine cause of the condition.

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement of 

the agency policy, procedure

or practice that has been 

determined to be the barrier of the 

undesired condition.

Currently, the Agency is under budgetary restraints an environment similar to a hiring freeze. NASS has low 

turnover at senior levels. In addition the mission critical position (statistical/mathematical series) are difficult to fill.

Objective Train, mentor and coach the mission critical employees that are in the GS 1 – 10 (4% of employees in this category 

have PWTD)

Date Objective 

Initiated

Sep 20, 2018

Target Date For 

Completion Of 

Objective

Sep 20, 2018

Responsible Officials June Turner Director of Civil Right

Target Date

(mm/dd/yyyy)

Planned Activities Sufficient

Staffing &

Funding

(Yes or No)

Modified

Date

(mm/dd/yyyy)

Completion

Date

(mm/dd/yyyy)

09/20/2018 Promote greater use of mentoring and coaching. Continue to train 

managers and supervisors on reasonable accommodations and 

target goals for PWD.

Yes

Fiscal Year Accomplishments

2012 Training for hiring managers on use of special hiring authorities

Training for supervisors on handling reasonable accommodations efficiently and effectively

4. Please explain the factor(s) that prevented the agency from timely completing any of the planned activities.
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Planned activities included attending career fairs at colleges and universities and using special hiring authorities - all activities were 

completed in a timely manner.

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

barrier(s).

Better understanding on the use of special hiring authorities and good grasp of the sensitivity issues associated with the handling of 

a reasonable accommodation.

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.

The Agency will move ahead with all plans to hire PWD and PWTD once a more fiscally stable allows more hiring. Again, the 

Agency was able to hire one individual in FY 2018, and that individual was a PWTD. That should speak to the positive effort of 

creating an inclusive and supportive environment.