2

DEFENSE THREAT REDUCTION AGENCY

ANNUAL EQUAL EMPLOYMENT 

OPPORTUNITY PROGRAM STATUS REPORT

MANAGEMENT DIRECTIVE 715

FISCAL YEAR (FY) 2018

PREPARED BY

EQUAL OPPORTUNITY AND DIVERSITY PROGRAMS OFFICE
3

TABLE OF CONTENTS

SECTION I:

PARTS A thru D: Agency Information ..............................................................................................4

PART E: Executive Summary ..............................................................................................................9

PART F: Certification of Establishment of Continuing EEO Programs........................................23

PART G: Agency 2.0 Self-Assessment Checklist ...........................................................................25

PART H: Plans for Addressing Deficiencies ...................................................................................41

PART I: Plans for Trigger Identification and Barrier Elimination.............................................57

PART J: Employment Plan for Individuals with Targeted Disabilities .....................................68

Analysis of Workforce Profiles... ..............................................................................................89

SECTION II:

APPENDICES ...........................................................................................................101

Appendix A: MD-715 Definitions and EEO Authorities .......................................................102

Appendix B: DTRA Organization Chart ................................................................................107

Appendix C: Policy Statements ..............................................................................................109

Appendix D: Federal EEO Statistical Report of Discrimination Complaints (Form 462) .....118

Appendix E: Reasonable Accommodation Handbook.............................................121

Appendix F: Individual with Disabilities Working Group Recommendations..................137
4
5

EEOC FORM

715-01

PART A-D

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL

EEO PROGRAM STATUS REPORT

DEFENSE THREAT REDUCTION AGENCY (DTRA) FY 2018

For period covering October 1, 2017 to September 30, 2018

Part A - Department or Agency Identifying Information

Agency

Second 

Level 

Component

Address City State Zip 

Code 

Agency 

Code

FIPS 

Code

DTRA Not 

Applicable

8725 John J. 

Kingman Road

Ft. 

Belvoir VA 22060 DD61

Part B - Total Employment

Total Employment Permanent Workforce Temporary 

Workforce Total Workforce

Number of Employees 1347 18 1365

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

Agency Leadership Name Title

Head of Agency Mr. Vayl S. Oxford Director

Head of Agency 

Designee Mr. Vayl S. Oxford Director

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

EEO Program 

Staff Name Title Series 

Pay 

Plan 

and 

Grade 

Phone 

Number Email Address

Principal EEO 

Director/Official Willisa Donald Director 0260 GS-15 571-616-4544

Willisa.m.Don

ald.civ@mail.

mil

Affirmative 

Employment 

Program 

Manager

Denise Lewis EO Manager 0260 GS-14 571-616-

6597

Denise.a.lewis

12.civ@mail.m

il
6

Complaint 

Processing 

Program 

Manager

Phil Ellis

Complaint 

Program 

Manager

0260 GS-13 571-616-

6251

Phillip.t.ellis.ci

v@mail.mil

Diversity & 

Inclusion Officer Denise Lewis Program Manager 0260 GS-14 571-616-6597

Denise.a.lewis

12.civ@mail.m

il

Hispanic 

Program 

Manager 

(SEPM)

James Jones Program 

Manager 0260 GS-13 505-853-0648

James.a.jones1

25.civ@mail.m

il

Women's 

Program 

Manager 

(SEPM)

Denise Lewis EO Manager 0260 GS-14 571-616-

6597

Denise.a.lewis

12.civ@mail.m

il

Disability 

Program 

Manager 

(SEPM)

Cheryl B. WilliamsPayton

Disability

Program 

Coordinator

GS-12 571-616-

6422

Cheryl.b.willia

mspayton.civ@m

ail.mil

Special 

Placement 

Program 

Coordinator 

(Individuals with 

Disabilities)

Cheryl B. WilliamsPayton

Disability 

Program 

Coordinator

GS-12 571-616-

6422

Cheryl.b.willia

mspayton.civ@m

ail.mil

Reasonable 

Accommodation 

Program 

Manager

Mary Lewandowski RA Program 

Manager 201 GS-12 571-616-4802

Mary.h.lewand

owski.civ@mai

l.mil

Anti-Harassment 

Program 

Manager

Claudette Persaud

AntiHarassment 

Program 

Manager

260 GS-13 571-616-

5112

Claudette.p.per

saud.civ@mail.

mil

ADR Program 

Manager Phil Ellis

ADR 

Program 

Manager

260 GS-13 571-616-

6251

Phillip.t.ellis.ci

v@mail.mil

Compliance 

Manager Marilyn Whitley Compliance Manager 260 GS-14 571-616-4926

Marilyn.j.whitl

ey.civ@mail.m

il
7

Principal MD715 Preparer Denise Lewis Program 

Manager 260 GS-14 571-616-6597

Denise.a.lewis

12.civ@mail.m

il

FEVS/Climate 

Assessments Kenneth Edwards Program Manager 260 GS-13 571-616-5709

Kenneth.j.edwa

rds16.civ@mai

l.mil

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

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

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

Subordinate Component City State Country 

(Optional)

Agency 

Code 

FIPS

Codes

Not Applicable

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

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

Did the agency submit the following mandatory documents? Please respond Yes 

or No Comments

Organizational Chart YES

EEO Policy Statement YES

Strategic Plan YES

Anti-Harassment Policy and Procedures YES

Reasonable Accommodation Procedures YES

Personal Assistance Services Procedures NO

Alternative Dispute Resolution Procedures YES

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

Did the agency submit the following optional documents? Please respond

Yes or No Comments

Federal Equal Opportunity Recruitment Program (FEORP) 

Report YES

Disabled Veterans Affirmative Action Program (DVAAP) 

Report YES
8

Operational Plan for Increasing Employment of Individuals with 

Disabilities under Executive Order 13548 YES

Diversity and Inclusion Plan under Executive Order 13583 NO

Diversity Policy Statement YES

Human Capital Strategic Plan NO

EEO Strategic Plan YES

Results from most recent Federal Employee Viewpoint Survey 

or Annual Employee Survey YES
9
10

EEOC FORM

715-01

PART E

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL

EEO PROGRAM STATUS REPORT

For the period covering October 1, 2017 to September 30, 2018

EXECUTIVE SUMMARY

Part E.1 - Executive Summary: Mission

AGENCY MISSION

The Defense Threat Reduction Agency (DTRA) enables DoD, the U.S. Government (USG), and 

International Partners to counter and deter weapons of mass destruction (WMD) and improvised 

threat networks. As a Combat Support Agency, DTRA’s expertise and global perspective uniquely 

posture us to provide rapid solutions to Combatant Command mission requirements, ensuring our 

programs, expertise, and capabilities are aligned to warfighter needs. DTRA’s analysts, planners, 

scientists, and program managers work with the interagency to anticipate, illuminate, and proactively 

disrupt threat networks using our wide range of capabilities. DTRA conducts network analysis to 

identify critical links and nodes between people, places, and things. DTRA maintains global 

situational awareness of countering WMD and improvised threat networks and facilitates information 

sharing across communities of action. DTRA applies tools such as Building Partnership Capacity 

and Cooperative Threat Reduction to strengthen and expand international partnerships and drive 

interagency and partner nation actions to counter malign foreign influence. DTRA delivers both 

offensive and defensive capabilities to enable combatant commanders to counter adversaries’ warfare 

competencies, disruptive technologies, and emergent trends. DTRA enables the national nuclear 

posture to counter adversaries across three levels of conflict: competition below armed conflict, 

conventional armed conflict, and nuclear armed conflict. DTRA enables the credibility of our 

nuclear forces through training the joint force, conducting mission assurance assessments, and 

exercising nuclear survivability. Enabling a safe, secure, and reliable nuclear deterrent impacts the 

calculus of competitor threat networks and the nuclear intentions and capabilities of near-peer 

nations, their proxy networks, aspiring rogue states, or and non-state actors. Collectively these key 

elements enable DTRA to support U.S. and partners’ efforts to compete below the threshold of armed 

conflict in addressing National Defense Strategy adversaries in an era of Great Power Competition.

DTRA is organized into nine Directorates (Joint Improvised-Threat Defeat Directorate (JD), 

Research and Development Directorate (RD), Combat Support Directorate (CZ), On-Site Inspection 

and Building Capacity Directorate (OB), Nuclear Enterprise Directorate (NE), Cooperative Threat 

Reduction Directorate (CT), Acquisition, Contracts, and Logistics Directorate (AL), Information 

Integration and Technology Services Directorate (IT), Human Resources Directorate (HR) and its 

supporting Staff Offices. DTRA’s Headquarters is located at Fort Belvoir, Virginia. The Agency 

also has Regional Offices located throughout various geographical locations. 

Part E.2 - Executive Summary: Essential Element A - F

EQUAL OPPORTUNITY & DIVERSITY PROGRAMS OFFICE MISSION
11

The Equal Opportunity and Diversity Programs Office’s (EO) mission is to create and sustain an 

inclusive work environment that aligns with DTRA’s mission.

Our Strategic Goals and Objectives are to:

Goal 1: Improve focus beyond compliance

• Integrate EEO into the workforce

• Improve program execution and customer service

Goal 2: Leverage and expand collaboration with internal and external partners.

• Establish new relationships, to include non-traditional partners

• Enhance effectiveness of internal relationships

Goal 3: Facilitate Innovation

• Become a catalyst for change

• Encourage leaders to support innovation and creativity

Goal 4: Educate and advise DTRA Leadership and staff

• Create a shared understanding of how EEO contributes to DTRA Mission

• Provide tailored consultative supportive services

EO serves as advisors for employees, managers, and supervisors seeking information on, or dealing 

with the following program activities: Affirmative Employment; Alternative Dispute Resolution 

(ADR); Complaints and Compliance (C&C); Diversity and Inclusion (D&I); Federal Employee 

Viewpoint Survey (FEVS), Anti-Harassment Program (AHP), Special Emphasis Programs (SEP),

EEO/EO Training; Sexual Assault Prevention and Response (SAPR), and Disability. The current 

staff consists of an EO Director, two EEO Managers, and five EEO specialists. 

SIX ESSENTIAL ELEMENTS ACCOMPLISHMENTS

The following six essential elements below are a Model Equal Employment Opportunity Program, to 

include the Agency’s noteworthy accomplishments in Fiscal Year 2018 (FY18). During FY18, 

DTRA addressed initiatives toward program deficiencies reported from prior years to achieving a 

model EEO program.

Essential Element A:

DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

Leadership is instrumental in ensuring viable and effective equal employment opportunity programs. 

The Director, Deputy Director, Vice Directors, and Senior Officials support Equal Opportunity and 

Diversity programs. Seven Agency-wide EEO Policy Statements were signed and distributed to new 

employees during the Newcomer’s Orientation session (Civilian Equal Employment Opportunity, 

Diversity and Inclusion, Employment and Advancement of Individuals with Disabilities, Harassment 

in the Workplace, Military Equal Opportunity, Prevention of Sexual Harassment, and Sexual Assault 

Prevention and Response)(Appendix C). This information is also available for employees on our 

Intranet, the DTRA1 Portal. 

Mentoring Program: The Agency Mentoring Program continued to be the DoD model. With a 

high level of enthusiasm from mentors and mentees, the FY18 program consisted of 92 civilian 

employees with 8 Senior Executive Service (SES) serving as Mentors. DTRA Senior Leaders were 
12

committed to supporting the program by serving as mentors and/or attending key activities. One 

example is the "Knowledge Sharing Through Speed Mentoring" event, whereby senior leaders 

participate in an open discussion sharing their expertise and experiences in an informal and relaxed 

environment. The senior leaders also hosted thirteen brown bags, centered on the featured book 

“Leaders Eat Last,” by Simon Sinek. HR hosted a workshop, “Leading Across Generations,” to 

explore ways to positively leverage the differences among generations, incorporating relevant points 

from the featured book. The DTRA Director showed his support by inviting mentees to attend a 

senior-level staff meeting and met with participants on a regular basis to provide mission updates and 

give them the opportunity to ask questions in a casual setting, all of which helped participants gain a

sense of connection to DTRA.

Leadership Development Program (LDP): In FY18, DTRA’s senior leaders were provided funds 

for general leadership training, enabling them to take ownership and manage their organization’s 

leadership development needs. The centralized LDP competitive programs complement the general 

leadership development training. The LDP competitive programs supported 41 civilian employee 

participants, with a 100% success rate. Participants undergo a rigorous application and vetting

process before being selected for the competitive programs. Applicants obtain supervisor and 

executive leader endorsements for their application. DTRA’s Leadership Development Council 

(LDC) are representatives from each of the DTRA Directorates as well as an advisor from the EO 

Office. The council reviews, rates, and ranks application packages based on standardized evaluation 

criteria. The top candidates identified are then interviewed with a panel of senior executive leaders. 

Candidates who are not selected have the option to engage with the LDC or an interview panel 

representative for feedback on their application. This process provides the opportunity for DTRA’s 

senior leaders to invest and engage directly in the future corporate leadership of DTRA. It also 

provides candidates with the opportunity to directly engage with senior leaders; learning from their 

experiences and breaking down barriers to senior leader engagement. 

Federal Employee Viewpoint Survey (FEVS): Management and oversight of the Federal 

Employee Viewpoint Survey (FEVS) transitioned from the HR Directorate to the EO office. EO 

quickly began reviewing and analyzing the FY18 results and engaged with DTRA senior leaders and 

Directorates to communicate the Agency’s recent survey results. The results indicated a participation

success rate of 45.9%. This result demonstrates a desired commitment from our workforce to 

improve the Agency. The DTRA strengths, according to the FEVS, include support for work/life 

programs, support for employee development, and success at accomplishing the mission. Our 

challenges include, but are not limited to, opportunity for advancement/promotions and pay raises 

within the organization. The DTRA Director applauded the workforce for their hard work and 

commitment in improving and fulfilling the Agency’s mission and values. 

Essential Element B: 

INTEGRATION OF EEO INTO THE AGENCY’S STRATEGIC MISSION

Minority Serving Institutions: In FY18, the Office of the Director established a DTRA Internship 

for Diversity (DID) at Pacific Northwest National Laboratory (PNNL). This internship program 

targets undergraduate students at Minority Serving Institutions (MSI) who are excited to tackle hard 

problems countering and deterring weapons of mass destruction and improvised threats networks. 

DID is an 8-12 week summer internship which exposes undergraduate students to initiatives that are 

important to the Agency. Additionally, through this program, PNNL will engage with 
13

MSI/Universities to promote, not only the DID, but also opportunities at DTRA as they become 

available. This supports DTRA’s overall mission to recruit diverse talent (with expertise) to make 

our nation safer and stronger. 

EO Director Involvement: The EO Director continued to build relationships with Senior Leaders 

on strategies which promote an environment free from personal, social, or institutional barriers that 

prevent employees from rising to their highest potential. The EO Director attended weekly 

Director’s staff meetings and continued to participate in various forums throughout the Agency, e.g.,

the Director’s Intelligence Brief (DIB) and the Human Resources Policy Board (HRPB), creating a

more engaged working relationship with senior leaders. EO briefed at the Director’s All Hands and 

provided training (i.e., Sexual Harassment) for specific offices as needed. The Agency continued to 

provide funding to ensure compliance on EEO programs such as Special Emphasis, Diversity and 

Inclusion, Sign Language Interpreters (SLI), staff training, and contracts for Investigations and Court 

Reporting services. 

Section 508: The IT Directorate continues to support the Reasonable Accommodations (RA)

Program with their IT support requests, to include purchasing a video phone for individuals when the 

Computer/Electronic Accommodations Program (CAP) office exhausted its funding in FY18. The IT

department manages the Agency's internal Section 508 site on a situational basis to ensure 508 

information and resources are readily available for DTRA personnel. Internal sites, training 

materials, videos are periodically reviewed to ensure 508 compliance. IT also met with Microsoft on 

their Artificial Intelligence (AI) initiatives to discover how to leverage assistance with 508 initiatives. 

The 508 Program Manager was asked to sponsor a proposal where Agency employees can participate

in the Federal IT Leaders Group, a project to automate the process for scanning internal 

Web/SharePoint sites for 508 compliance. In addition, IT outsourced videos of interest to the DTRA 

community to be closed captioned. The Agency is also researching avenues to develop an in-house 

capability and begun discussions with Defense Logistics Agency (DLA) to utilize their closed 

captioning resources for internally produced videos. 

Historically Black Colleges & Universities/Minority Serving Institutions (HBCUs/MSIs): The 

RD Directorate, Chemical Biological Technologies Department (RD-CB) conducted two HBCU/MSI 

workshops that delivered information pertaining to research opportunities. The RD Test Science and 

Technology Department (RD-TST) and Diagnostics Division (RD-TSD) participated in the 

Discovery Festival in Albuquerque, NM in November 2018. The Discovery Festival was a free, oneday event where over 3,500 kids (K-12), from New Mexico (37 schools) explored careers in Science, 

Technology, Engineering, Arts, and Mathematical (STEAM) fields in an exciting, hands-on 

experience. DTRA's exhibit included representatives from RD-CB and RD-TS and the Agency won 

the "Best Hands-on Demo" Award. The Chief of Scientist and Innovation Department (RD-ST)

kicked off a Post-Doctoral Scholars program with the National Strategic Research Institute (NSRI). 

This program teaches highly technical post-doctorate scholars the skills of a Government program 

manager. In FY18, RD-ST began planning to transition the Agency’s basic research program toward 

a University Partnership model; plans included a University Day in early 2019 to outreach to the 

community, encourage and facilitate the inclusion of HBCU/MSI members into the partnership. A 

principal goal for this model is future workforce development in critical scientific fields relevant to 

CWMD. 
14

Essential Element C: 

MANAGEMENT AND PROGRAM ACCOUNTABILITY 

Disabled Veterans Affirmative Action Program (DVAAP): The report was submitted on October 

28, 2018, to the Defense Civilian Personnel Advisory Service. The following accomplishments were 

highlighted in the report:

• 30% or more Disabilities: Progress is made each year for hiring disabled veterans with 30% or 

more disabilities. There were 80 Veterans hired in FY18, of which 39 were identified as 30% or 

more disabled. 

• Special Hiring Authorities: Continued to educate selecting officials and hiring managers during 

strategic conversations on Schedule A and other special hiring authorities in support of 

recruitment efforts. 

• Used USAJOBS.gov for all external and internal competitive vacancy announcements which 

included information on special hiring authorities for recruitment and selection of disabled 

veterans. Specific hiring initiatives for the employment of disabled veterans include the 

Veteran's Recruitment Authority and Wounded Warrior Program. 

• Maintained an internal database of Schedule A applicants, disabled veterans applying for 

positions with the Agency, and ongoing outreach to find highly qualified veterans with 

disabilities.

• Reasonable Accommodation (RA): Ensured RA and work-life information was available to 

Individuals with Targeted Disabilities (IwTD) and disabled veteran applicants upon initial 

employment.

• Sign Language Interpreter (SLI): Ensured SLI services were available to the workforce for

meetings, conferences, training and special events. EO office received and submitted 281 SLI

requests.

• Job Accommodation Network (JAN): Provided expert accommodation information before, 

during, and after the recruitment process. JAN is a confidential service that allows a manager or 

employee an opportunity to receive individualized information on an accommodation issue.

• CAP: A centrally funded program that provided Assistive Technology (AT) for RA, Individuals 

with Disabilities (IwDs), and disabled veterans.

Federal Equal Opportunity Recruitment Program (FEORP): The EO Office and HR 

Directorate collaborated on the FEORP submission in November 2018. The report included the 

Agency’s promising practices, strategies, and activities related to Hiring Authorities, Hispanic 

Employment, Mentoring, Training, Career Development, and Recruitment of Individuals with 

Disabilities. The following accomplishments were highlighted.

• Diversify DTRA’s Workforce through Active Recruitment: The HR Directorate developed

and implemented broad outreach strategies to attract leaders from a diverse applicant pool which 

are consistent with merit system principles. Utilized various special hiring authorities as 

supplements to the competitive hiring processes and partnered with diverse organizations and 

institutions to help recruit from all segments of society.

• Special Hiring Authorities: The Agency hired three Workforce Recruitment Program (WRP) 

students and five Schedule A interns throughout the Agency and at various geographical 

locations. HR coordinated recruitment opportunities to a broad range of individuals by attending 
15

veteran and minority-supported career fairs and sought partnerships with organizations that 

provided diverse and qualified applicants.

• Training: EO hosted four Civil Treatment Training Sessions targeting supervisors, managers,

and the workforce in the National Capital Region (NCR), Kirtland AFB, New Mexico, and other 

geographic locations with a total of 80 attendees. The Civil Treatment Training focused on 

workplace behaviors and the fair treatment of individuals in the work place.

Disability Employment Initiatives: In FY18, the following accomplishments were highlighted.

• Processed 18 RA requests, which included a combination of assistive technologies, sit/stand 

workstations, chairs, keyboards, flexible work schedules, and medical telework. The IT 

Directorate and Building Manager approved the following accommodations: three sit/stand 

workstations, three heaters, and one ergonomic chair.

• Implemented a Policy Statement on Employment and Advancement of IwDs.

• Maintained Sign Language Interpreter (SLI) tracking log and kept track of expenditures. 

• Served as advisor and participated in Section 508 Accessibility Team meetings. 

• Provided guidance to the Emergency Plan Team concerning evacuation procedures. 

Special Emphasis Program Events: The EO Offices within the McNamara Complex including 

DTRA, DLA, Defense Contract Audit Agency (DCAA), and the Defense Technical Information 

Center (DTIC) co-sponsored 11 Special Emphasis Program events to educate and inform the 

workforce. DTRA sponsored the following two events:

• National Disability Employment Awareness Month: The theme was “America’s Workforce: 

Empowering All.” The guest speaker was George Dennehy. Mr. Dennehy shared with the 

audience his life experiences growing up without arms and how he learned to play guitar with his 

feet. He spoke of his personal struggles in a Romanian orphanage and his adoption at the age of 

one by his U.S. family. He shared that every individual has a purpose and absolutely anything is 

possible. 

• National Hispanic Heritage Month: The theme was “One Endless Voice to Enhance Our 

Traditions.” The guest speaker was Mr. Luis E. Borunda, Maryland Deputy Secretary of State. 

Mr. Borunda began his career in politics by forming a Hispanic committee to support the 

successful candidacy program. He shared his successful career, leadership style, and spoke of his 

life as a Hispanic. 

Essential Element D: 

PROACTIVE PREVENTION OF UNLAWFUL DISCRIMINATION

Anti-Harassment Program: In FY18, the EO Office established its Proactive Prevention Team to 

develop the Agency’s Anti-Harassment Program (AHP). The AHP operates independently from the 

EEO Complaint Process (29 C.F.R. §1614). The team engaged with Managers and Supervisors for 

the purpose of conducting fact-findings allegations of harassment and to prohibit harassment by or of 

any employee, supervisor, manager, and contractor. The purpose of the Agency’s AHP is to support 

the commitment to maintain a work environment free from harassment and provide training for the 

Agency workforce. The AHP Procedures was revised to promptly and effectively address allegations 

of workplace harassment within the DTRA workforce.
16

EEO Training: In FY18, EO proactively engaged in various training efforts such as mandatory 

Notification and Federal Employee Anti-Discrimination and Retaliation Act (No FEAR). There were 

776 employees who received No FEAR training. 883 employees took the online Prevention of 

Sexual Harassment training. Nearly 543 participants received EEO classroom training, 144 SAPR

and 80 managers and supervisors received Civil Treatment training. EO continues to train new 

managers and supervisors to address challenges they may encounter and provided the knowledge, 

skills, and tools necessary to successfully manage a diverse workforce.

Inspector General (IG) Office: In FY18, IG assisted employees with allegations of possible 

climate, diversity, or discrimination concerns and held discussions with EO to address related cases. 

IG received 142 contacts, of which, 26 were EO-related issues or concerns. The Agency Director 

approved the completion of a Special Assessment that involved EO and climate concerns. In 

addition, IG instituted monthly “Blotter” updates for the Director and respective Directorate leaders 

where IG-related activities were addressed to included matters involving climate, diversity, and/or 

discrimination. IG also conducted monthly meetings with EO, General Counsel (GC), Vice Director 

for Plans and Programs, Security and Counterintelligence Department (PP-SC), and HR to review 

personnel concerns that potentially contained an EO nexus and met to ensure there was a process to 

elevate internal investigations to DTRA Leadership.

Essential Element E: 

EFFICIENCY

Complaints & Compliance: In FY18, EO worked diligently to increase the level of efficiencies in 

its operations, with focus placed not only on complaints, compliance, and legal requirements, but on 

proactive prevention. EEO training was deployed, which focused on areas the Commission requires 

the Agency to address with the workforce, (e.g., educating the workforce on complaint process 

procedures, Alternative Dispute Resolution (ADR), educating supervisors on their role and 

responsibilities as supervisors, and employees on their rights and responsibilities in the workplace).

IComplaints Data Base Tracking System: The Agency has procured the MicroPact Complaints 

Tracking System (iComplaints). This system is entirely web based. Once complaint data is entered 

into the system, it will provide the necessary capability to collect, track, manage, process, and 

generate reports for all DTRA complaints. The complaint information entered into the system 

(organizations, status, claims, issues, etc.) is stored on a Central DTRA system and not on individual 

PC hard drive. 

In FY18, the EO office handled 61 complaints. Thirty-three informal complaints were filed 

during this reporting period. Eleven individuals either withdrew or did not file formal; four

complaints were settled by an informal settlement agreement. Twenty individuals filed formal 

complaints of discrimination. DTRA received a remand from Department of Army; increasing

the number of formal complaints to 21. 

Out of the 21 formal complaints, 4 complaints were closed, 1 was settled by a Negotiated 

Settlement Agreement (NSA), and the other 3 were dismissed in accordance with 29 C.F.R. 

1614.107, bringing the remainder of complaints filed in FY18 to 17. (See Figure 1) 
17

Figure 1: Number of Formal Complaints Filed FY14 - FY18

The top five bases cited this reporting period were sex (24%), age (22%), reprisal (17%), race 

(17%), and color (8%). Sex and age were cited most often. Reprisal and race were tied. Sex 

remained the same as it was in FY17. Age as a basis increased because it was not cited in FY17. 

(See Figure 2)

Figure 2: Basis of Discrimination FY17 - FY18

In FY18, the top three frequently used issues by complainants were (1) harassment (non-sexual and 

sexual) which was cited 16 times, (one complainant cited both sexual and non-sexual harassment) 

(2) disciplinary actions, cited six times, and (3) reassignment, cited four times. 

In FY17, there were 21 allegations of harassment (20 were non-sexual and 2 were sexual). There 

was a decrease in allegations in both sexual and non-sexual harassment in FY18. Normally, if there 

are allegations of harassment, reprisal would also be cited; Even though there was 50% increase in 

reprisal this fiscal year, it was not raised as many times in the cases that alleged harassment. This 

could be an anomaly or it could be that there were incidents that were not articulated or identified. 

Termination, awards, appraisal, telework, and reasonable accommodation were all cited at one time. 

Disability (mental and physical), and non-selection/non-promotion were cited two times in this 

reporting period. 

The Alternative Dispute Resolution (ADR) Coordinator and Complaints Manager were designated 

as advisors for ADR. Both were responsible for educating the workforce on the use of ADR, the 

purpose and process of ADR and the ability to use ADR at any stage of the complaint process. EO 

11

8 8 9

21

0

5

10

15

20

25

FY 2014 FY 2015 FY 2016 FY2017 FY 2018

Number of Formal Complaints Filed

FY14 - FY18

3

9 9

0 1 0 0 0

6 6

9 8

2 2 3

0

0

5

10

Reprisal Race Sex Age Disability National

Origin

Color Religion

BASIS OF DISCRIMINATION

FY17 - FY18

FY 2017

FY 2018
18

continues to incorporate an explanation of ADR and its benefits into EO related materials, notices 

and training in order to raise awareness. In FY18, we increased our efforts in offering ADR to the 

workforce. The lack or ineffective marketing of this product is most likely the cause. Employees 

and leaders are usually not interested in putting in the time, if they do not understand the benefits. 

In FY18, EO did a better job at promoting ADR and the usefulness of the tool. 

In FY18, the EO made a concerted effort to offer ADR at the informal and formal stage. Zero 

mediations were conducted in FY17. In FY18, 10 mediations were conducted and 5 were settled. 

In FY19, EO will increase marketing and promotion by building a campaign around why ADR is a 

business necessity. 

Essential Element F:

RESPONSIVENESS AND LEGAL COMPLIANCE 

EO fully complied with all laws, including EEOC regulations, Orders, Decisions, and Settlement 

Agreements. The EO Director and Complaints Manager met with the Agency’s Employment Law 

Attorney (GC) on matters of mutual interest and each sought the advice of each other’s expertise

when dealing with unique situations. Because of this effective collaboration between EO and GC, 

all documents requiring legal sufficiency reviews were reviewed and sent forward. There is a 

firewall in the GC Office to ensure the Counsel consulted to assist EO with Acceptance and 

Dismissal letters is separate from the EO litigation Counsel. 

EO ensured compliance with EEOC Administrative Judges and/or Office of Federal Operations

Decisions. The Agency’s Settlement Agreement process ensured timely compliance with all terms 

and conditions of such Agreements to include an appropriate clause regarding breaches and/or other 

non-compliance. In cases where there was a lapse in timeframes the agency demonstrated a 

concerted effort to comply. 

Formal Complaints: EO continues to promote how Leadership’s early involvement with conflict 

resolution allows creative solutions for resolving workplace disputes quickly, efficiently, and at a 

substantial monetary savings, especially if resolution is achieved prior to litigation. ADR was 

utilized this FY in both the informal or formal arena and the savings to the Agency revealed less time 

and resources than pursuing the adjudicative processes. (See Figure 3)

COMPLAINT PROCESSING EXPENSE FY18

INVESTIGATIONS MEDIATIONS FADS Court 

Reporting

$86,059.00 $6,547.50 $5,700.00 $1,952.32

TOTAL EXPENSE $100,258.82 Figure 3: Complaint Processing Expense FY18

There were 11 complaints closed in FY18; 1 formal settlement, 5 final Agency Actions, 4 Final 

Agency Decisions, and 1 Final Agency Order with an Administrative Judge. There were two 

formal complaints that were pending investigation at the end of the reporting period. DTRA 

received a remand from Department of Army, and there were complaints, which should have 

been processed in the previous FYs, that contributed to the substantial increase of formal 

complaints in FY18. EO did not meet EEOC’s required time lines in the processing of our 
19

complaints. For the Agency to improve on meeting these requirements, there is a need to 

overhaul the complaints and compliance program to improve efficiencies in processing 

complaints. Ensuring a strong informal process is the foundation in which to keep the process on 

track. Once we build a solid foundation, only then can we achieve an efficient and compliant 

EEO complaints process. To include, moving Final Agency Decision and Final Agency Orders 

to meet the 40 calendar day requirement. Improving on our services to employees using the 

complaints process and the aggressive use of mediation as an avenue of redress could possibly 

lead to quicker resolutions of complaints. To improve these services, moving from a compliance 

metric to a performance metric would better serve us in eliminating deficiencies realized in FY18. 
20

WORKFORCE DATA HIGHLIGHTS: DTRA’s workforce analysis provides information 

regarding the current composition and trends impacting the workforce. The U.S. Census Bureau 

2010 Civilian Labor Force (CLF) census data was used as a benchmark.

At the end of FY18, the total workforce (permanent and temporary) was comprised of 1,365 civilians 

spanning 14 locations worldwide. The total population increased from 1,340 to 1,365 representing a 

positive net change of 25 (1.87%). The overall workforce consists of 894 (65.49%) Males and 

471(34.51%) Females. This is an increase of 1.08% for Male and a decrease of 1.08% for Female

representation. [According to the 2010 Civilian Labor Force (CLF), the percentage of Males is 

51.84% and Females is 48.14%]. The population of Females has steadily declined since 2012. 

DTRA Permanent Workforce Compared to CLF:

Race/Ethnicity Total % Male

Total % FemaleTotal % CLF %

Hispanic 36 2.67 19 1.41 17 1.26 9.96

White 947 69.38 669 49.01 278 20.37 72.36

Black 231 16.92 118 8.76 113 8.28 12.02

Asian 61 4.46 35 2.56 26 1.90 3.90

Native Hawaiian/Other Pacific Islander 4 0.29 1 0.07 3 0.22 0.14

American Indian/Native American 4 0.44 3 0.22 1 0.07 1.08

Two or More Races 82 6.01 49 3.59 33 2.42 0.54

Total 1365 100.00 894 65.49 471 34.51 100

DTRA Current Workforce by Sex:

Additionally, Hispanics, White Females, Blacks, Asian, Native Hawaiian Males, and American 

Indians currently have low participation rates when compared to the CLF. (Table A1)

1.41%

49.07%

8.76%

2.6% 0.07% 0.22% 3.49% 1.26%

20.12%

8.31%

1.93% 0.22% 0.07% 2.45%

9.96%

72.36%

12.02%

3.9% 0.14% 1.08% 0.54%

Hispanic White Black Asian Native Hawaiian American Indian Two or More

Races

DTRA 2018 Workforce by Sex

Male Female CLF%
21

Summary of Agency Accomplishments are as follows:

PART H Summary: Based on the new 2.0 Part G Self-Assessment review, the Agency now has a 

total of seven deficiencies, of which three are new. 

# Element 

# Deficiencies

1 B.3.a

Are EEO program officials present during agency deliberations prior to decisions 

regarding recruitment strategies, vacancy projections, succession planning, selections 

for training/career development opportunities, and other workforce changes?

2

C.2.a.5

Does the agency conduct a prompt inquiry (beginning within 10 days of notification) 

of all harassment allegations, including those initially raised in the EEO complaint 

process?

C.2.a.6 Do the agency’s training materials on its anti-harassment policy include examples of 

disability-based harassment? [see 29 CFR 1614.203(d)(2)]

E.4.a.6

The processing of complaints for the anti-harassment program? [see EEOC 

Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.2]

3

C.4.e.2 Does the Agency track recruitment efforts and analyze efforts to identify potential 

barriers in accordance with MD-715 standards?

E.4.a.3 Does the Agency have systems in place to accurately collect, monitor and analyze the 

following data: Recruitment activities?

4 D.1.c

Does the agency conduct exit interviews or survey that include questions on how the 

agency could improve the recruitment, hiring, inclusion, retention and advancement of 

individuals with disabilities? [see 29 CFR 1614.203(d)(1)(iii)(C)

5

D.2.a Does the agency have a process for analyzing the identified triggers to find possible 

barriers?

D.2.d

Does the agency regularly review the following sources of information to find barriers: 

complaint/grievance data, exit surveys, employee climate surveys, focus groups, 

affinity groups, union, program evaluations, anti-harassment program, special 

emphasis programs, reasonable accommodation program; anti-harassment program; 

and/or external special interest groups?

6

E.5.a Does the agency monitor trends in its EEO program to determine whether the agency 

is meeting its obligations under the statutes EEOC enforces.

E.5.b Does the agency review other agencies’ best practices and adopt them, where 

appropriate, to improve the effectiveness of its EEO program?

E.5.c Does the agency compare its performance in the EEO process to other federal agencies 

of similar size?

PART I Summary: The Agency will continue seeking methods to enforce the implementation 

of the Action Plans based on each groups final recommendations. In FY19, the Agency will 

establish Employee Resource Groups (ERGs) to continue to examine employment-related issues 

and to further enhance the Agency‘s current activities to attract, develop and engage DTRA’s 

employees. 

PART J Summary: IwDs recruitment and retention remains an area requiring continued 

improvement to increase the hiring of IwDs. The Agency reviewed its IwDs action plan. This action 

plan addresses potential barriers and determines how to increase the agency’s efforts to recruit, hire, 

and retain IwDs. In collaboration with HR, EO is making concerted efforts to increase the number 

and percentages of employees hired with severe/targeted disabilities and fully accommodate them to 

ensure that they have opportunities for career development and promotions.
22

CONCLUSION: Although the Agency has made progress, the vision of a workforce in 

which Women, Hispanics, and IwDs are fully represented and utilized has not been wholly 

achieved. DTRA will continue to sustain efforts to recruit highly-qualified Women,

Hispanics, and other minorities. The focus is on: increasing employee engagement and 

retention and enhancing employee development programs. Moreover, the Agency remains 

agile in engaging all employees and managers to explore methods to enhance DTRA as a 

model Agency. 
23
24
25
26

MD-715 - PART G

Agency Self-Assessment Checklist

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

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

and a discrimination-free workplace.

Compliance 

Indicator 

Measures

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

statement.

Measure 

Met?

YES

During EO Newcomer’s 

monthly training and EO 

for Supervisors quarterly 

training

A.1.a

Does the agency annually issue a signed and dated EEO policy 

statement on agency letterhead that clearly communicates the 

agency’s commitment to EEO for all employees and applicants? If 

“yes”, please provide the annual issuance date in the comments 

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

YES

A.1.b

New

Does the EEO policy statement address all protected bases (age, 

color, disability, sex (including pregnancy, sexual orientation and 

gender identity), genetic information, national origin, race, religion, 

and reprisal) contained in the laws EEOC enforces? [see 29 CFR § 

1614.101(a)] 

YES

Compliance 

Indicator 

Measures

A.2 – The agency has communicated EEO policies and 

procedures to all employees.

Measure 

Met?

YES

During EO Training; All 

EO policies and 

procedures are on the 

DTRA1 portal

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

procedures to all employees:

A.2.a.1

New Anti-harassment policy? [see MD 715, II(A)] YES

A.2.a.2

New

Reasonable accommodation procedures? [see 29 C.F.R § 

1614.203(d)(3)] YES

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

throughout the workplace and on its public website: 

A.2.b.1

New

The business contact information for its EEO Counselors, EEO 

Officers, Special Emphasis Program Managers, and EEO Director? 

[see 29 C.F.R § 1614.102(b)(7)]

NO

EO will work with PA to 

create an external 

website

A.2.b.2

Written materials concerning the EEO program, laws, policy 

statements, and the operation of the EEO complaint process? [see 29 

C.F.R § 1614.102(b)(5)]

NO

EO will work with PA to 

create an external 

website

A.2.b.3

Reasonable accommodation procedures? [see 29 C.F.R. § 

1614.203(d)(3)(i)] If so, please provide the internet address in the 

comments column.

YES

http://www.dtra.mil/Car

eers/Onboarding/Sponso

r-Program/ReasonableAccomodation/

A.2.c Does the agency inform its employees about the following topics: 

A.2.c.1 EEO complaint process? [see 29 CFR §§ 1614.102(a)(12) and 

1614.102(b)(5)] If “yes”, please provide how often. YES

A.2.c.2

New

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

how often. YES During the informal and formal process.
27

A.2.c.3 Reasonable accommodation program? [see 29 CFR § 

1614.203(d)(7)(ii)(C)] If “yes”, please provide how often. YES Posted on internal DTRA1 portal

A.2.c.4

New

Anti-harassment program? [see EEOC Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by 

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

YES During EO Training

A.2.c.5

Behaviors that are inappropriate in the workplace and could result in 

disciplinary action? [5 CFR § 2635.101(b)] If “yes”, please provide 

how often.

YES Addressed in Agencywide Ethics Training

Compliance 

Indicator 

Measures

A.3 – The agency assesses and ensures EEO principles are part 

of its culture.

Measure 

Met?

YES

Assessments are done 

via Federal Viewpoint 

Survey (FEVS) and 

Climate Assessments

A.3.a

New

Does the agency provide recognition to employees, supervisors, 

managers, and units demonstrating superior accomplishment in 

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

“yes”, provide one or two examples in the comments section.

NO

EO will work with HR 

to create an EO annual 

recognition program

A.3.b

New

Does the agency utilize the Federal Employee Viewpoint Survey or 

other climate assessment tools to monitor the perception of EEO 

principles within the workforce? [see 5 CFR Part 250]

YES

Essential Element B: INTEGRATION OF EEO INTO THE AGENCY’S STRATEGIC MISSION

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

discrimination and support the agency’s strategic mission.

Compliance 

Indicator 

Measures

B.1 - The reporting structure for the EEO program provides the 

principal EEO official with appropriate authority and resources 

to effectively carry out a successful EEO program.

Measure 

Met?

YES

EO Director reports 

directly to the Agency 

Head

B.1.a

Is the agency head the immediate supervisor of the person (“EEO 

Director”) who has day-to-day control over the EEO office? [see 29 

CFR §1614.102(b)(4)]

YES

B.1.a.1

New

If the EEO Director does not report to the agency head, does the 

EEO Director report to the same agency head designee as the 

mission-related programmatic offices? If “yes,” please provide the 

title of the agency head designee in the comments.

YES

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

structure for the EEO office? [see 29 CFR §1614.102(b)(4)] YES

B.1.b

Does the EEO Director have a regular and effective means of 

advising the agency head and other senior management officials of 

the effectiveness, efficiency and legal compliance of the agency’s 

EEO program? [see 29 CFR §1614.102(c)(1); MD-715 Instructions, 

Sec. I] 

YES

B.1.c

During this reporting period, did the EEO Director present to the 

head of the agency, and other senior management officials, the 

"State of the agency" briefing covering the six essential elements of 

the model EEO program and the status of the barrier analysis 

process? [see MD-715 Instructions, Sec. I)] If “yes”, please provide 

the date of the briefing in the comments column. 

NO

The MD-715 staff was 

newly appointed and 

was unable to upload the 

report in FEDSEP
28

B.1.d

New

Does the EEO Director regularly participate in senior-level staff 

meetings concerning personnel, budget, technology, and other 

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

YES

Compliance 

Indicator

Measures

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

program.

Measure 

Met?

YES

Complaints, Alternate 

Dispute Resolution, 

Affirmative 

Employment, Diversity 

and Anti-Harassment

B.2.a

Is the EEO Director responsible for the implementation of a 

continuing affirmative employment program to promote EEO and to 

identify and eliminate discriminatory policies, procedures, and 

practices? [see MD-110, Ch. 1(III)(A); 29 CFR §1614.102(c)] 

YES

B.2.b

New

Is the EEO Director responsible for overseeing the completion of 

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

B.2.c

New

Is the EEO Director responsible for overseeing the fair and thorough 

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

[This question may not be applicable for certain subordinate level 

components.]

YES

B.2.d

New

Is the EEO Director responsible for overseeing the timely issuance 

of final agency decisions? [see 29 CFR §1614.102(c)(5)] [This 

question may not be applicable for certain subordinate level 

components.]

YES

B.2.e Is the EEO Director responsible for ensuring compliance with EEOC 

orders? [see 29 CFR §§ 1614.102(e); 1614.502] YES

B.2.f

New

Is the EEO Director responsible for periodically evaluating the entire 

EEO program and providing recommendations for improvement to 

the agency head? [see 29 CFR §1614.102(c)(2)]

YES

B.2.g

New

If the agency has subordinate level components, does the EEO 

Director provide effective guidance and coordination for the 

components? [see 29 CFR §§ 1614.102(c)(2) and (c)(3)]

YES

Compliance 

Indicator

Measures

B.3 - The EEO Director and other EEO professional staff are 

involved in, and consulted on, management/personnel actions.

Measure 

Met?

NO

Part H initiated 

B.3.a

Do EEO program officials participate in agency meetings regarding 

workforce changes that might impact EEO issues, including strategic 

planning, recruitment strategies, vacancy projections, succession 

planning, and selections for training/career development 

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

NO Part H

B.3.b

New

Does the agency’s current strategic plan reference EEO / diversity 

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

identify the EEO principles in the strategic plan in the comments 

column.

NO EO will collaborate to 

incorporate language

Compliance 

Indicator

Measures

B.4 - The agency has sufficient budget and staffing to support 

the success of its EEO program.

Measure 

Met?

YES

EO hired 4 new 

employees; two 

permanent and two 

temporary
29

B.4.a

Pursuant to 29 CFR §1614.102(a)(1), has the agency allocated 

sufficient funding and qualified staffing to successfully 

implement the EEO program, for the following areas: 

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

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

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

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

B.4.a.3

to timely, thoroughly, and fairly process EEO complaints, including 

EEO counseling, investigations, final agency decisions, and legal 

sufficiency reviews? [see 29 CFR § 1614.102(c)(5) & 1614.105(b) – (f); MD-110, Ch. 1(IV)(D) & 5(IV); MD-715, II(E)]

YES

B.4.a.4

to provide all supervisors and employees with training on the EEO 

program, including but not limited to retaliation, harassment, 

religious accommodations, disability accommodations, the EEO 

complaint process, and ADR? [see MD-715, II(B) and III(C)] If not, 

please identify the type(s) of training with insufficient funding in the comments column. 

YES

B.4.a.5

to conduct thorough, accurate, and effective field audits of the EEO 

programs in components and the field offices, if applicable? [see 29 

CFR §1614.102(c)(2)]

YES

B.4.a.6

to publish and distribute EEO materials (e.g. harassment policies, 

EEO posters, reasonable accommodations procedures)? [see MD-

715, II(B)]

YES

B.4.a.7

New

to maintain accurate data collection and tracking systems for the 

following types of data: complaint tracking, workforce 

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

please identify the systems with insufficient funding in the 

comments section.

YES

B.4.a.8

to effectively administer its special emphasis programs (such as, 

Federal Women’s Program, Hispanic Employment Program, and 

People with Disabilities Program Manager)? [5 USC § 7201; 38 

USC § 4214; 5 CFR § 720.204; 5 CFR § 213.3102(t) and (u); 5 CFR 

§ 315.709]

YES

B.4.a.9

New

to effectively manage its anti-harassment program? [see MD-715 

Instructions, Sec. I); EEOC Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment by Supervisors (1999), 

§ V.C.1]

YES

B.4.a.10 to effectively manage its reasonable accommodation program? [see 

29 CFR § 1614.203(d)(4)(ii)] YES

B.4.a.11

New

to ensure timely and complete compliance with EEOC orders? [see 

MD-715, II(E)] YES

B.4.b

New

Does the EEO office have a budget that is separate from other 

offices within the agency? [see 29 CFR § 1614.102(a)(1)] YES

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

[see MD-110, Ch. 1(III)(A), 2(III), & 6(III)] YES

B.4.d

Does the agency ensure that all new counselors and investigators, 

including contractors and collateral duty employees, receive the 

required 32 hours of training, pursuant to Ch. 2(II)(A) of MD-110?

YES

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

investigators, including contractors and collateral duty employees, YES
30

receive the required 8 hours of annual refresher training, pursuant to 

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

Compliance 

Indicator 

Measures

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

supervisors and managers who have effective managerial, 

communications, and interpersonal skills.

Measure 

Met?

YES

B.5.a

Pursuant to 29 CFR § 1614.102(a)(5), have all managers and 

supervisors received training on their responsibilities under the 

following areas under the agency EEO program:

NO

Not all supervisors were 

trained but training is

provided

B.5.a.1

New EEO Complaint Process? [see MD-715(II)(B)] YES

Managers and 

supervisors sign up for 

training at their 

discretion 

B.5.a.2 Reasonable Accommodation Procedures? [see 29 C.F.R. § 

1614.102(d)(3)] YES Provided in HR for Supervisors Training

B.5.a.3

New Anti-Harassment Policy? [see MD-715(II)(B)] YES Provided during EO for Supervisors Training

B.5.a.4

New

Supervisory, managerial, communication, and interpersonal skills in 

order to supervise most effectively in a workplace with diverse 

employees and avoid disputes arising from ineffective 

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

YES Provided during Civil 

Training for Supervisors

B.5.a.5

ADR, with emphasis on the federal government’s interest in 

encouraging mutual resolution of disputes and the benefits 

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

YES Provided during EO for 

Newcomers Training

Compliance 

Indicator 

Measures

B.6 – The agency involves managers in the implementation of its 

EEO program.

Measure 

Met?

YES

Senior leaders 

participate in working 

groups. Currently, no 

identified action plans

B.6.a

New

Are senior managers involved in the implementation of Special 

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

Senior Leaders 

participates in Special 

Observance Programs

B.6.b Do senior managers participate in the barrier analysis process? [see 

MD-715 Instructions, Sec. I] YES

B.6.c

When barriers are identified, do senior managers assist in 

developing agency EEO action plans (Part I, Part J, or the Executive 

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

YES

B.6.d

Do senior managers successfully implement EEO Action Plans and 

incorporate the EEO Action Plan Objectives into agency strategic 

plans? [29 CFR § 1614.102(a)(5)]

YES

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY

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

the effective implementation of the agency’s EEO Program and Plan.
31

Compliance 

Indicator 

Measures

C.1 – The agency conducts regular internal audits of its 

component and field offices.

Measure 

Met?

YES

EO Director visits

remote sites annually

C.1.a

New

Does the agency regularly assess its component and field offices for 

possible EEO program deficiencies? [see 29 CFR §1614.102(c)(2)]

If ”yes”, please provide the schedule for conducting audits in the 

comments section.

YES

ABQ - 02/18; 

Travis - 09/18;

Germany - 01/18

C.1.b

New

Does the agency regularly assess its component and field offices on 

their efforts to remove barriers from the workplace? [see 29 CFR 

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

conducting audits in the comments section.

YES

New EO specialist in 

ABQ will conduct 

analysis

C.1.c

New

Do the component and field offices make reasonable efforts to 

comply with the recommendations of the field audit? [see MD-715, 

II(C)] 

YES

Compliance 

Indicator 

Measures

C.2 – The agency has established procedures to prevent all 

forms of EEO discrimination.

Measure 

Met?

YES

Posters are disseminated 

throughout the Agency. 

Also, there is an active 

internal process

C.2.a

New

Has the agency established comprehensive anti-harassment policy 

and procedures that comply with EEOC’s enforcement guidance?

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

Liability for Unlawful Harassment by Supervisors (Enforcement 

Guidance), EEOC No. 915.002, § V.C.1 (June 18, 1999)]

NO

New Anti-Harassment 

Manager came onboard 

on August 6, 2018

C.2.a.1

New

Does the anti-harassment policy require corrective action to prevent 

or eliminate conduct before it rises to the level of unlawful 

harassment? [see EEOC Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment by Supervisors (1999), 

§ V.C.1]

YES

C.2.a.2

New

Has the agency established a firewall between the Anti-Harassment 

Coordinator and the EEO Director? [see EEOC Report, Model EEO 

Program Must Have an Effective Anti-Harassment Program (2006]

YES

The EO Director do not 

make Final Agency 

Decisions for AntiHarassment matters

C.2.a.3

New

Does the agency have a separate procedure (outside the EEO 

complaint process) to address harassment allegations? [see 

Enforcement Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (Enforcement Guidance), 

EEOC No. 915.002, § V.C.1 (June 18, 1999)]

YES

There is a Proactive 

Prevention Team and a 

separate Complaints 

Team in the EO office

C.2.a.4

New

Does the agency ensure that the EEO office informs the antiharassment program of all EEO counseling activity alleging 

harassment? [see Enforcement Guidance, V.C.]

YES

C.2.a.5

New

Does the agency conduct a prompt inquiry (beginning within 10 

days of notification) of all harassment allegations, including those 

initially raised in the EEO complaint process? [see Complainant v. 

Dep’t of Veterans Affairs, EEOC Appeal No. 0120123232 (May 21, 

2015); Complainant v. Dep’t of Defense (Defense Commissary 

Agency), EEOC Appeal No. 0120130331 (May 29, 2015)] If “no”, 

NO PART H
32

please provide the percentage of timely-processed inquiries in the 

comments column.

C.2.a.6

New

Do the agency’s training materials on its anti-harassment policy 

include examples of disability-based harassment? [see 29 CFR 

1614.203(d)(2)]

NO PART H

C.2.b

New

Has the agency established disability reasonable accommodation 

procedures that comply with EEOC’s regulations and guidance? [see 

29 CFR 1614.203(d)(3)]

YES

C.2.b.1

Is there a designated agency official or other mechanism in place to 

coordinate or assist with processing requests for disability 

accommodations throughout the agency? [see 29 CFR 

1614.203(d)(3)(D)]

YES

C.2.b.2

New

Has the agency established a firewall between the Reasonable 

Accommodation Program Manager and the EEO Director? [see MD110, Ch. 1(IV)(A)]

YES RA is handled in the HR 

Office

C.2.b.3

New

Does the agency ensure that job applicants can request and receive 

reasonable accommodations during the application and placement 

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

YES

RA information is 

provided with each job 

posting

C.2.b.4

New

Do the reasonable accommodation procedures clearly state that the 

agency should process the request within a maximum amount of 

time (e.g., 20 business days), as established by the agency in its 

affirmative action plan? [see 29 CFR 1614.203(d)(3)(i)(M)]

YES Per the Agency RA

Handbook

C.2.b.5

Does the agency process all accommodation requests within the time 

frame set forth in its reasonable accommodation procedures? [see 

MD-715, II(C)] If “no”, please provide the percentage of timelyprocessed requests in the comments column.

YES

C.2.c

New

Has the agency established procedures for processing requests for 

personal assistance services that comply with EEOC’s regulations, 

enforcement guidance, and other applicable executive orders, 

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

YES Agency RA Handbook

C.2.c.1

New

Does the agency post its procedures for processing requests for 

Personal Assistance Services on its public website? [see 29 CFR § 

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

the comments column.

YES

http://www.dtra.mil/Car

eers/Onboarding/Sponso

r-Program/ReasonableAccommodation/

Compliance 

Indicator 

Measures

C.3 - The agency evaluates managers and supervisors on their 

efforts to ensure equal employment opportunity.

Measure 

Met?

YES

DPMAP provides 

mandatory EEO 

elements for Supervisors

C.3.a

New

Pursuant to 29 CFR §1614.102(a)(5), do all managers and 

supervisors have an element in their performance appraisal that

evaluates their commitment to agency EEO policies and principles 

and their participation in the EEO program?

YEYES

C.3.b

Does the agency require rating officials to evaluate the 

performance of managers and supervisors based on the 

following activities:

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

participation in ADR proceedings? [see MD-110, Ch. 3.I] YES
33

C.3.b.2

Ensure full cooperation of employees under his/her supervision with 

EEO officials, such as counselors and investigators? [see 29 CFR 

§1614.102(b)(6)]

YES

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

including harassment and retaliation? [see MD-715, II(C)] YES

C.3.b.4

Ensure that subordinate supervisors have effective managerial, 

communication, and interpersonal skills to supervise in a workplace 

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

YES

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

not cause an undue hardship? [see 29 CFR §1614.102(a)(7)] YES

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

not cause an undue hardship? [ see 29 CFR §1614.102(a)(8)] YES

C.3.b.7

New

Support the EEO program in identifying and removing barriers to 

equal opportunity. [see MD-715, II(C)] YES

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

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

C.3.b.9

New

Comply with settlement agreements and orders issued by the 

agency, EEOC, and EEO-related cases from the Merit Systems 

Protection Board, labor arbitrators, and the Federal Labor Relations 

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

YES

C.3.c

New

Does the EEO Director recommend to the agency head 

improvements or corrections, including remedial or disciplinary 

actions, for managers and supervisors who have failed in their EEO 

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

YES

C.3.d

New

When the EEO Director recommends remedial or disciplinary 

actions, are the recommendations regularly implemented by the 

agency? [see 29 CFR §1614.102(c)(2)]

YES

Compliance 

Indicator 

Measures

C.4 – The agency ensures effective coordination between its 

EEO programs and Human Resources (HR) program.

Measure 

Met?

NO

PART H was established 

to address effectiveness

C.4.a

New

Do the HR Director and the EEO Director meet regularly to assess 

whether personnel programs, policies, and procedures conform to 

EEOC laws, instructions, and management directives? [see 29 CFR 

§1614.102(a)(2)]

YES

EO and HR will begin 

quarterly meetings in 

2019

C.4.b

Has the agency established timetables/schedules to review at regular 

intervals its merit promotion program, employee recognition awards 

program, employee development/training programs, and 

management/personnel policies, procedures, and practices for 

systemic barriers that may be impeding full participation in the 

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

YES

C.4.c

New

Does the EEO office have timely access to accurate and complete 

data (e.g., demographic data for workforce, applicants, training 

programs, etc.) required to prepare the MD-715 workforce data 

tables? [see 29 CFR §1614.601(a)]

YES

C.4.d

New

Does the HR office timely provide the EEO office with access to 

other data (e.g., exit interview data, climate assessment surveys, and 

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

YES
34

C.4.e

New

Pursuant to Section II(C) of MD-715, does the EEO office 

collaborate with the HR office to:

C.4.e.1

New

Implement the Affirmative Action Plan for Individuals with 

Disabilities? [see 29 CFR §1614.203(d); MD-715, II(C)] NO Will address in Part J

C.4.e.2

New

Develop and/or conduct outreach and recruiting initiatives? [see 

MD-715, II(C)] NO PART H

C.4.e.3

New

Develop and/or provide training for managers and employees? [see 

MD-715, II(C)] YES

C.4.e.4

New

Identify and remove barriers to equal opportunity in the workplace? 

[see MD-715, II(C)] YES

C.4.e.5

New

Assist in preparing the MD-715 report? [see MD-715, II(C)] YES

Compliance 

Indicator 

Measures

C.5 – Following a finding of discrimination, the agency explores 

whether it should take a disciplinary action.

Measure 

Met?

YES

Findings of 

discrimination are 

discussed with the 

Agency Head, GC and 

EO

C.5.a

Does the agency have a disciplinary policy and/or table of penalties 

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

see also Douglas v. Veterans Administration, 5 MSPR 280 (1981)]

YES

C.5.b

When appropriate, does the agency discipline or sanction managers 

and employees for discriminatory conduct? [see 29 CFR 

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

disciplined/sanctioned individuals during this reporting period in the 

comments.

YES

Zero findings of 

discrimination in FY 

2018

C.5.c

New

If the agency has a finding of discrimination (or settles cases in 

which a finding was likely), does the agency inform managers and 

supervisors about the discriminatory conduct? [see MD+-715, II(C)]

YES

Compliance 

Indicator 

Measures

C.6 – The EEO office advises managers/supervisors on EEO 

matters.

Measure 

Met?

YES

EO Director promotes 

supervisor engagement

C.6.a

Does the EEO office provide management/supervisory officials with 

regular EEO updates on at least an annual basis, including EEO 

complaints, workforce demographics and data summaries, legal 

updates, barrier analysis plans, and special emphasis updates? [see 

MD-715 Instructions, Sec. I] If “yes”, please identify the frequency 

of the EEO updates in the comments column.

YES

During the Director’s 

Staff Meetings

C.6.b

New

Are EEO officials readily available to answer managers’ and 

supervisors’ questions or concerns? [see MD-715 Instructions, Sec. 

I]

YES

Essential Element D: PROACTIVE PREVENTION

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

and eliminate barriers to equal employment opportunity.
35

Compliance 

Indicator 

Measures

D.1 – The agency conducts a reasonable assessment to monitor 

progress towards achieving equal employment opportunity 

throughout the year.

Measure 

Met?

YES

The EO office conducts

an offsite to plan every 

year

D.1.a

New

Does the agency have a process for identifying triggers in the 

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

D.1.b

New

Does the agency regularly use the following sources of 

information for trigger identification: workforce data; 

complaint/grievance data; exit surveys; employee climate 

surveys; focus groups; affinity groups; union; program 

evaluations; special emphasis programs; reasonable 

accommodation program; anti-harassment program; and/or 

external special interest groups? [see MD-715 Instructions, 

Sec. I]

NO

EO prepares an end of 

the year report to 

review trend analysis 

and action plans are 

prepared to establish 

an EO annual work 

plan. This information 

will be assessed to 

eliminate triggers and

counter climate 

concerns.

D.1.c

New

Does the agency conduct exit interviews or surveys that 

include questions on how the agency could improve the 

recruitment, hiring, inclusion, retention and advancement of 

individuals with disabilities? [see 29 CFR 

1614.203(d)(1)(iii)(C)]

NO PART H

Compliance 

Indicator 

Measures

D.2 – The agency identifies areas where barriers may exclude 

EEO groups (reasonable basis to act.)

Measure 

Met?

NO

EO is working on 

establishing ERGs.

D.2.a

New

Does the agency have a process for analyzing the identified triggers 

to find possible barriers? [see MD-715, (II)(B)] NO PART H

D.2.b

Does the agency regularly examine the impact of 

management/personnel policies, procedures, and practices by race, 

national origin, sex, and disability? [see 29 CFR §1614.102(a)(3)]

YES

D.2.c

Does the agency consider whether any group of employees or 

applicants might be negatively impacted prior to making human 

resource decisions, such as re-organizations and realignments? [see 

29 CFR §1614.102(a)(3)]

YES EO coordinates on all

reorganizations.

D.2.d

New

Does the agency regularly review the following sources of 

information to find barriers: complaint/grievance data, exit surveys, 

employee climate surveys, focus groups, affinity groups, union, 

program evaluations, anti-harassment program, special emphasis 

programs, reasonable accommodation program; anti-harassment 

program; and/or external special interest groups? [see MD-715 

Instructions, Sec. I] If “yes”, please identify the data sources in the 

comments column.

NO PART H
36

Compliance 

Indicator 

Measures

D.3 – The agency establishes appropriate action plans to remove 

identified barriers.

Measure 

Met?

YES

Action plans and 

working groups were 

established

D.3.a.

New

Does the agency effectively tailor action plans to address the 

identified barriers, in particular policies, procedures, or practices?

[see 29 CFR §1614.102(a)(3)]

YES

D.3.b

New

If the agency identified one or more barriers during the reporting 

period, did the agency implement a plan in Part I, including meeting 

the target dates for the planned activities? [see MD-715, II(D)] 

YES

D.3.c

New

Does the agency periodically review the effectiveness of the plans? 

[see MD-715, II(D)] YES

Compliance 

Indicator 

Measures

D.4 – The agency has an affirmative action plan for people with 

disabilities, including those with targeted disabilities.

Measure 

Met?

NO

EO will formulate an

affirmative action plan 

for IwDs and IwTDs

D.4.a

New

Does the agency post its affirmative action plan on its public 

website? [see 29 CFR 1614.203(d)(4)] Please provide the internet 

address in the comments.

NO

EO will ensure the 

action plan is published 

in FY 2019

D.4.b

New

Does the agency take specific steps to ensure qualified people with 

disabilities are aware of and encouraged to apply for job vacancies? 

[see 29 CFR 1614.203(d)(1)(i)]

YES

D.4.c

New

Does the agency ensure that disability-related questions from 

members of the public are answered promptly and correctly? [see 29 

CFR 1614.203(d)(1)(ii)(A)]

YES

D.4.d

New

Has the agency taken specific steps that are reasonably designed to 

increase the number of persons with disabilities or targeted 

disabilities employed at the agency until it meets the goals? [see 29 

CFR 1614.203(d)(7)(ii)]

YES WRP and Schedule A

Essential Element E: EFFICIENCY

This element requires the agency head to ensure that there are effective systems for evaluating the impact and 

effectiveness of the agency’s EEO programs and an efficient and fair dispute resolution process.

Compliance 

Indicator 

Measures

E.1 - The agency maintains an efficient, fair, and impartial 

complaint resolution process.

Measure 

Met?

YES

There is an informal and 

formal complaints 

manager

E.1.a Does the agency timely provide EEO counseling, pursuant to 29 

CFR §1614.105? YES

E.1.b

Does the agency provide written notification of rights and 

responsibilities in the EEO process during the initial counseling 

session, pursuant to 29 CFR §1614.105(b)(1)?

YES

E.1.c

New

Does the agency issue acknowledgment letters immediately upon 

receipt of a formal complaint, pursuant to MD-110, Ch. 5(I)? YES

E.1.d

New

Does the agency issue acceptance letters/dismissal decisions within 

a reasonable time (e.g., 60 days) after receipt of the written EEO YES 45 days of less
37

Counselor report, pursuant to MD-110, Ch. 5(I)? If so, please 

provide the average processing time in the comments.

E.1.e

New

Does the agency ensure all employees fully cooperate with EEO 

counselors and EEO personnel in the EEO process, including 

granting routine access to personnel records related to an 

investigation, pursuant to 29 CFR §1614.102(b)(6)? 

YES

E.1.f Does the agency timely complete investigations, pursuant to 29 CFR 

§1614.108? YES

E.1.g

New

If the agency does not timely complete investigations, does the 

agency notify complainants of the date by which the investigation 

will be completed and of their right to request a hearing or file a 

lawsuit, pursuant to 29 CFR §1614.108(g)?

YES

E.1.h

When the complainant does not request a hearing, does the agency 

timely issue the final agency decision, pursuant to 29 CFR 

§1614.110(b)?

NO Issued but not timely

E.1.i

Does the agency timely issue final actions following receipt of the 

hearing file and the administrative judge’s decision, pursuant to 29 

CFR §1614.110(a)?

YES

E.1.j

If the agency uses contractors to implement any stage of the EEO 

complaint process, does the agency hold them accountable for poor 

work product and/or delays? [See MD-110, Ch. 5(V)(A)] If “yes”, 

please describe how in the comments column.

N/A

E.1.k

New

If the agency uses employees to implement any stage of the EEO 

complaint process, does the agency hold them accountable for poor 

work product and/or delays during performance review? [See MD110, Ch. 5(V)(A)]

YES

E.1.l

New

Does the agency submit complaint files and other documents in the 

proper format to EEOC through the Federal Sector EEO Portal 

(FedSEP)? [See 29 CFR § 1614.403(g)]

YES

Compliance 

Indicator 

Measures

E.2 – The agency has a neutral EEO process.

Measure 

Met?

YES

EEOC administrative 

processes are followed

E.2.a

New

Has the agency established a clear separation between its EEO 

complaint program and its defensive function? [see MD-110, Ch. 

1(IV)(D)] 

YES

E.2.b

When seeking legal sufficiency reviews, does the EEO office have 

access to sufficient legal resources separate from the agency 

representative? [see MD-110, Ch. 1(IV)(D)] If “yes”, please 

identify the source/location of the attorney who conducts the legal 

sufficiency review in the comments column. 

YES

E.2.c

New

If the EEO office relies on the agency’s defensive function to 

conduct the legal sufficiency review, is there a firewall between the 

reviewing attorney and the agency representative? [see MD-110, Ch. 

1(IV)(D)]

YES

E.2.d

Does the agency ensure that its agency representative does not 

intrude upon EEO counseling, investigations, and final agency 

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

NO

GC and EO agreed to 

have a different attorney 

review Final Agency 
38

Decisions beginning 

April 2019

E.2.e

If applicable, are processing time frames incorporated for the legal 

counsel’s sufficiency review for timely processing of complaints? 

[see EEOC Report, Attaining a Model Agency Program: Efficiency

(Dec. 1, 2004)]

YES

Compliance 

Indicator 

Measures

E.3 - The agency has established and encouraged the widespread 

use of a fair alternative dispute resolution (ADR) program.

Measure 

Met?

YES

ADR was aggressively 

encouraged in FY 2018

E.3.a

Has the agency established an ADR program for use during both the 

pre-complaint and formal complaint stages of the EEO process? [see 

29 CFR §1614.102(b)(2)]

YES

E.3.b Does the agency require managers and supervisors to participate in 

ADR once it has been offered? [see MD-715, II(A)(1)] YES

E.3.c Does the agency encourage all employees to use ADR, where ADR 

is appropriate? [see MD-110, Ch. 3(IV)(C)] YES

E.3.d

New

Does the agency ensure a management official with settlement 

authority is accessible during the dispute resolution process? [see 

MD-110, Ch. 3(III)(A)(9)]

YES

E.3.e

Does the agency prohibit the responsible management official 

named in the dispute from having settlement authority? [see MD110, Ch. 3(I)]

YES

E.3.f

New

Does the agency annually evaluate the effectiveness of its ADR 

program? [see MD-110, Ch. 3(II)(D)] YES

Compliance 

Indicator 

Measures

E.4 – The agency has effective and accurate data collection 

systems in place to evaluate its EEO program.

Measure 

Met?

NO

E.4.a Does the agency have systems in place to accurately collect, 

monitor, and analyze the following data:

E.4.a.1

Complaint activity, including the issues and bases of the complaints, 

the aggrieved individuals/complainants, and the involved 

management official? [see MD-715, II(E)]

YES

Currently collecting 

information on a 

spreadsheet; 

iComplaints purchased

E.4.a.2 The race, national origin, sex, and disability status of agency 

employees? [see 29 CFR §1614.601(a)] YES

E.4.a.3 Recruitment activities? [see MD-715, II(E)] NO PART H

E.4.a.4

New

External and internal applicant flow data concerning the applicants’ 

race, national origin, sex, and disability status? [see MD-715, II(E)] NO

New EO program 

manager trained by 

OPM on Applicant Flow 

Data

E.4.a.5

New

The processing of requests for reasonable accommodation? [29 CFR 

§ 1614.203(d)(4)] YES

E.4.a.6

New

The processing of complaints for the anti-harassment program? [see 

EEOC Enforcement Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), § V.C.2]

NO PART H
39

E.4.b

New

Does the agency have a system in place to re-survey the workforce 

on a regular basis? [MD-715 Instructions, Sec. I] YES FEVS and Climate Survey

Compliance 

Indicator 

Measures

E.5 – The agency identifies and disseminates significant trends 

and best practices in its EEO program.

Measure 

Met?

NO

E.5.a

Does the agency monitor trends in its EEO program to determine 

whether the agency is meeting its obligations under the statutes 

EEOC enforces? [see MD-715, II(E)] If “yes”, provide an example 

in the comments.

NO

Part H

Currently using the EO 

Dashboard

E.5.b

Does the agency review other agencies’ best practices and adopt 

them, where appropriate, to improve the effectiveness of its EEO 

program? [see MD-715, II(E)] If “yes”, provide an example in the 

comments.

NO Part H

E.5.c Does the agency compare its performance in the EEO process to 

other federal agencies of similar size? [see MD-715, II(E)] NO Part H

Essential Element F: RESPONSIVENESS AND LEGAL COMPLIANCE

This element requires federal agencies to comply with EEO statutes and EEOC regulations, policy 

guidance, and other written instructions.

Compliance 

Indicator 

Measures

F.1 – The agency has processes in place to ensure timely and full 

compliance with EEOC Orders and settlement agreements.

Measure 

Met?

YES

Formal Complaints 

Manager monitor and 

assess

F.1.a

Does the agency have a system of management controls to ensure 

that its officials timely comply with EEOC orders/directives and 

final agency actions? [see 29 CFR §1614.102(e); MD-715, II(F)]

YES

F.1.b

Does the agency have a system of management controls to ensure 

the timely, accurate, and complete compliance with 

resolutions/settlement agreements? [see MD-715, II(F)]

YES

F.1.c Are there procedures in place to ensure the timely and predictable 

processing of ordered monetary relief? [see MD-715, II(F)] YES

F.1.d Are procedures in place to process other forms of ordered relief 

promptly? [see MD-715, II(F)] YES

F.1.e

When EEOC issues an order requiring compliance by the agency, 

does the agency hold its compliance officer(s) accountable for poor 

work product and/or delays during performance review? [see MD110, Ch. 9(IX)(H)]

YES

Compliance 

Indicator 

Measures

F.2 – The agency complies with the law, including EEOC 

regulations, management directives, orders, and other written 

instructions.

Measure 

Met?

YES

Formal Complaints 

Manager monitor and 

assess

F.2.a Does the agency timely respond and fully comply with EEOC 

orders? [see 29 CFR §1614.502; MD-715, II(E)] YES
40

F.2.a.1

When a complainant requests a hearing, does the agency timely 

forward the investigative file to the appropriate EEOC hearing 

office? [see 29 CFR §1614.108(g)]

YES

F.2.a.2

When there is a finding of discrimination that is not the subject of an 

appeal by the agency, does the agency ensure timely compliance 

with the orders of relief? [see 29 CFR §1614.501]

YES

F.2.a.3

New

When a complainant files an appeal, does the agency timely forward 

the investigative file to EEOC’s Office of Federal Operations? [see 

29 CFR §1614.403(e)]

YES

F.2.a.4 Pursuant to 29 CFR §1614.502, does the agency promptly provide 

EEOC with the required documentation for completing compliance? YES

 Compliance 

Indicator

 Measures

F.3 - The agency reports to EEOC its program efforts and 

accomplishments.

Measure 

Met?

YES

No Fear, 462 Report, 

DVAAP, and FEORP 

are timely submitted

F.3.a

New

Does the agency timely submit to EEOC an accurate and complete 

No FEAR Act report? [Public Law 107-174 (May 15, 2002), 

§203(a)]

YES

F.3.b

New

Does the agency timely post on its public webpage its quarterly No 

FEAR Act data? [see 29 CFR §1614.703(d)] NO Will comply in FY 2019
41
42

MD-715 – Part H - 1

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Defense Threat Reduction Agency 

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency -

Type of Program 

Deficiency Brief Description of Program Deficiency

B.3.a

Are EEO program officials present during agency deliberations prior to 

decisions regarding recruitment strategies, vacancy projections, succession 

planning, selections for training/career development opportunities, and other 

workforce changes?

Objective(s) and Dates for EEO Plan

Date 

Initiated Objective Target Date 

Modified 

Date 

Date 

Completed 

October 

2017

EO will collaborate with HR regarding 

Strategic Workforce Planning groups; Vacancy 

Planning, Recruitment/Outreach Planning and 

Training/Career Development Planning and 

other workforce changes.

12/2020 1/2019

Responsible Official(s)

Title Name

Performance 

Standards Address the 

Plan?

(Yes or No)

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald NO

Director, Human Resource Directorate Jamie S. Millsaps, Colonel 

USAF NO

Planned Activities Toward Completion of Objective
43

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

11/2017

HR and EO will establish points of contact 

(POCs) to participate on standing meetings for 

recruitment strategies, vacancy projections, 

succession planning, training and career 

planning.

YES 03/2018

11/2017

HR POC will ensure EO is invited to participate 

and collaborate on Strategic Workforce 

Planning initiatives.

YES 01/2018

01/2018 EO will conduct an in-processing brief for all 

new employees during On-Boarding. YES Ongoing

01/2018

HR will ensure EO is invited to participate as an 

Advisor on the Leadership Development 

Programs (LDP). 

YES 02/2018

05/2018

HR will provide EO the annual outreach 

schedule to solicit participation of EO subject 

matter experts (i.e., schools and organizations). 

YES

06/2018

EO and HR Directors will meet quarterly to 

discuss Agency recruitment efforts and review 

results.

YES

07/2018

EO will develop a diversity and inclusion 

strategic plan to address the agency’s human 

capital needs from an EEO, diversity and 

inclusion perspective. The plan will include: 

recruitment, workforce planning, employee 

development, and leadership development. 

YES

10/2018

HR and EO will track and analyze recruitment

efforts to identify potential barriers for the 

employment of Women, Hispanics and 

Individual with Disabilities.

YES

Report of Accomplishments

Fiscal 

Year Accomplishments

FY2018 HR and EO established respective points of contact and scheduled regular meetings to discuss 

MD-715 initiatives.
44

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

In FY 2018, HR streamlined the Onboarding process by using the USA Staffing (USAS) 

portal for maintaining a paperless process for all new hires to the Agency. The paperless 

process and completion of forms in the USAS portal resulted in a smooth transition of 

scanning required documents to electronic routing directly to the employees official personnel 

file eOPF. HR maintains a robust orientation to all new employees to the Agency from 

October 2017 to September 2018. EO participated in the bi-weekly scheduled and 

coordinated briefings for all new onboarding employees. All new employees were provided 

with policies, procedures, and point of contact information for their respective Directorate.

The DTRA Leadership Development Program (LDP) supports the overall Agency Strategic 

Plan. Programs within the LDP offer opportunities for interagency relationship building, 

facilitate innovation, reduce barriers to managing DTRA talent and, by developing leaders, 

support delegation of decision authorities to lowest possible levels. 

The program supports deliberate development through progressive opportunities. The LDP 

structure is based on the DoD Leader Development Continuum/Competencies and is designed 

to prepare Agency employees for leadership positions. 

DTRA’s Leadership Development Council (LDC) (formerly the Workforce Development 

Council), consists of representatives from each of DTRA’s subordinate Directorates and an 

advisor from the EO office. HR seeks the advice and input of the LDC in evaluating new and

ongoing programs. The LDC also reviews, rates and ranks application packages for DTRA’s 

competitive leadership development programs.
45

MD-715 – Part H - 2

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Defense Threat Reduction Agency 

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Elements Deficiency

Type of Program 

Deficiency Brief Description of Program Deficiency

C.2.a.5

Does the agency conduct a prompt inquiry (beginning within 10 days of 

notification) of all harassment allegations, including those initially raised in the 

EEO complaint process? [see Complainant v. Dep’t of Veterans Affairs, EEOC 

Appeal No. 0120123232 (May 21, 2015); Complainant v. Dep’t of Defense 

(Defense Commissary Agency), EEOC Appeal No. 0120130331 (May 29, 

2015)] If “no”, please provide the percentage of timely-processed inquiries in 

the comments column.

C.2.a.6 Do the agency’s training materials on its anti-harassment policy include 

examples of disability-based harassment? [see 29 CFR 1614.203(d)(2)]

E.4.a.6

The processing of complaints for the Anti-harassment program? [see EEOC 

Enforcement Guidance on Vicarious Employer Liability for Unlawful 

Harassment by Supervisors (1999), V.C.2]

Objective(s) and Dates for EEO Plan

Date 

Initiated Objective Target Date 

Modified 

Date 

Date 

Completed 

09/01/2018

Create an effective Anti-Harassment Program 

in compliance with EEOC guidance and 

communicate the anti-harassment policy to 

prevent and eliminate all types of harassment.

10/18/2019

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Anti-Harassment Manager Claudette Persaud Yes

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald Yes
46

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Planned Activities Toward Completion of Objective

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

03/31/2019

Revise the DTRA Anti-Harassment Instruction 

to include the timeframes and the complaint’s 

process.

YES

06/1/2019 Publish the Anti-Harassment policy and 

instruction. YES

04/15/2019 Provide Anti-Harassment training to managers, 

supervisors and DTRA employees. YES

01/03/2022

Ensure all inquiries for allegation of harassment 

are addressed within 10 days of notification and 

track.

YES

03/31/2019

Establish an effective Anti-Harassment 

process/procedures and ensure there is a

protection against retaliation. 

YES

10/31/2018 Track harassment inquires and investigation. YES

Report of Accomplishments 

Fiscal Year Accomplishments

2018

EO established its Anti-Harassment Program (AHP) in October 2018. An AntiHarassment tracking tool was created to track all incoming claims of harassment

(hostile work environment and/or bullying).

Since October 2018, the Anti-Harassment Team conducted approximately 10 AntiHarassment Counseling Sessions and met with Management Officials and provided 

briefings and information on the AHP and procedures. The Anti-Harassment Directive 

1020.03 is currently being revised.

The team also created marketing and promotional materials such as an informational 

brochure, a flyer and a training presentation. AHP training will be provided to the 

DTRA workforce in FY19. EO will also host a Harassment Free Zone week to educate 

and provide awareness to the workforce. 
47

MD-715 – Part H - 3

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Defense Threat Reduction Agency 

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency

Type of Program 

Deficiency Brief Description of Program Deficiency

C.4.e.2 Does the Agency EO Office collaborate with the HR Directorate to develop and/or 

conduct outreach and recruitment initiatives in accordance with MD-715 standards?

E.4.a.3 Does the Agency have systems in place to accurately collect, monitor, and analyze 

the following data: Recruitment activities? [see MD-715, II(E)]

Objective(s) and Dates for EEO Plan

Date 

Initiated Objective Target Date 

Modified 

Date 

Date 

Completed 

10/2017

Establish a Recruitment Strategy/Plan to 

address low participation rates for Minorities, 

Women, and IwD within the Agency.

12/2019 12/2018

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Director, Equal Opportunity 

and Diversity Programs Office Willisa Donald YES

Director, Human Resource 

Directorate

Jamie S. Millsaps, Colonel 

USAF YES

Planned Activities Toward Completion of Objective

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

01/2018 EO will identify POC(s) to participate in HR 

recruitment efforts. YES
48

02/2018 HR will invite EO to participate in the 

development of the annual Outreach YES

05/2018

EO will provide a list of colleges and 

universities for recruitment efforts; provide 

recommendations, and share recruitment best 

practices for Hispanics, Women and IwD (30% 

or more Disabled Vets) in government.

YES

10/2018

EO in collaboration with HR, will track Agency 

recruitment efforts by applicant groups using 

applicant flow data reports provided by the 

DLA.

YES

10/2018 EO in collaboration with HR, will analyze 

recruitment efforts to identify potential barriers. YES

11/2018

EO will conduct data analysis by using 

appropriate comparators and statistical methods

for recruitment efforts.

YES

Report of Accomplishments

Fiscal 

Year Accomplishments

2018

Subject planning sessions have resulted in HR and EO identifying key outreach events 

to participate in each year. Such events include job fairs at various colleges and 

universities targeted in the science, technology, engineering, and math (STEM)

academic areas: job fairs focusing on hiring veterans; job fairs focused upon hiring 

individuals with disabilities; and job fairs within the NCR or Albuquerque area. 

Members of HR and EO also discuss who would participate in the outreach event, and 

how managers would benefit in participating at the event. Subject outreach events in 

FY18 resulted in numerous resumes collected, along with successfully branding 

DTRA to the public. 

Schools/events targeted in 2018 by HR include (not all-inclusive):

•Hiring Heroes Event, Military in Transition/Spouses, San Antonio, TX

•5th Annual Warrior Community Integration Symposium, Military in 

Transition/Spouses, Atlanta, GA

•Veterans Job Fair at the Air Force Academy, Military in Transition/Spouses, Denver, 

CO

• Hiring Our Heroes, Wounded Warriors, Fort Dix/McGuire, NJ
49

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

• Disabled American Veterans (DAV) Career Fair/Reserve Officer Training Corps 

(ROTC) Visit, Military in Transition/Spouses, St Louis, MO

• Hiring Heroes Career Fair, Camp Pendleton, CA

• Wounded Warriors, San Diego, CA 

• Hiring Heroes Career Fair, Ft. Campbell Wounded Warriors, Nashville, TN 

• Hiring Heroes Career Fair, Military in Transition/Spouses, Fort Riley, KS 

• Hiring Heroes Career Fair, Wounded Warriors, Houston, TX

• Veterans at University of New Mexico Job Fair

• Stanford University, Stanford, CA 

• Arizona State University, Tempe, AZ

• New Mexico Tech, Socorro, NM

• University North Texas, Denton, TX
50

MD-715 – Part H - 4

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Defense Threat Reduction Agency

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency

Type of Program 

Deficiency Brief Description of Program Deficiency

D.1.c

Does the agency conduct exit interviews or survey that include questions on how 

the agency could improve the recruitment, hiring, inclusion, retention and 

advancement of individuals with disabilities? [see 29 CFR 1614.203(d)(1)(iii)(C)

Objective(s) and Dates for EEO Plan

Date 

Initiated Objective Target Date Modified Date Date Completed 

01/15/19

Ensure exit interviews and survey includes 

questions to improve recruitment, hiring, 

inclusion, retention and advancement with 

IwDs.

12/2020

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan?

(Yes or No)

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald NO

Director, Human Resource 

Directorate

Jamie S. Millsaps, Colonel 

USAF NO

Planned Activities Toward Completion of Objective

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

04/15/19 Collaborate with HR to develop exit interview 

and survey questions. YES
51

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

05/30/19

Ensure questions target recruitment, hiring, 

inclusion, retention and advancement with 

IwDs.

YES

06/30/19 Release revised exit survey questions. YES

07/31/19 Track and evaluation survey results. YES

10/2018 EO in collaboration with HR, will analyze 

recruitment efforts to identify potential barriers. YES

11/2018

EO will conduct data analysis by using 

appropriate comparators and statistical methods

for recruitment efforts.

YES

Report of Accomplishments

Fiscal 

Year Accomplishments

2018 EO and HR will collaborate on this deficiency in FY19.
52

MD-715 – Part H - 5

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Defense Threat Reduction Agency 

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency

Type of 

Program 

Deficiency

Brief Description of Program Deficiency

D.2.a Does the agency have a process for analyzing the identified triggers to find possible 

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

D.2.d

Does the agency regularly review the following sources of information to find 

barriers: complaint/grievance data, exit surveys, employee climate surveys, focus 

groups, affinity groups, union, program evaluations, anti-harassment program, special 

emphasis programs, reasonable accommodation program; anti-harassment program; 

and/or external special interest groups? [see MD-715 Instructions, Sec. I] If “yes”, 

please identify the data sources in the comments column.

Objective(s) and Dates for EEO Plan

Date 

Initiated Objective Target Date

Modified 

Date 

Date 

Completed

10/2017

Develop a process to collect data and conduct 

a trend analysis for management/personnel 

policies and practices by race, national origin, 

sex and disability.

12/2020 12/2019

Responsible Official(s)

Title Name

Performance 

Standards 

Address the 

Plan?

(Yes or No)

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald NO

Director, Human Resource Directorate Jamie S. Millsaps, Colonel USAF NO

Planned Activities Toward Completion of Objective
53

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

10/2018

EO will review all policies, practices and 

procedures for any hidden impediments to equal 

opportunity.

YES

05/2018

09/2018

02/2019

06/2019

EO will schedule quarterly reviews to determine 

if any hidden impediments or disparities exist, 

impacting employees based on race, ethnicity, 

sex, or disability.

YES

06/2018

10/2018

02/2019

06/2019

EO will provide input and/or recommended 

changes to policies, practices and procedures, as 

appropriate.

YES

06/2018

10/2018

02/2019

06/2019

EO will monitor recommendations until 

implementation is complete and routinely assess 

as needed.

YES

03/20/2019

Conduct workforce analysis and identify triggers 

to find barriers and improve deficiency in the 

Agency.

YES

06/20/2019

Collect information from Employee Climate 

Survey responses to identify and address barriers 

in the Agency.

YES

02/21/2019 Conduct complaint trends analysis using 

iComplaints tracking system. YES

01/15/2019

Review EEO complaint activity to determine 

potential barriers and correct any undesired 

conditions.

YES

04/04/2019 Collect data an Anti-harassment to identify 

trends. YES

09/2018 Identify and analyze DTRA management 

personnel policies and procedures. YES

07/2018

Review and conduct a trend analysis to 

determine if disparity exists based on race, sex, 

and/or disability.

YES

10/2018 Update dashboard and examine data trends. YES

Report of Accomplishments
54

Fiscal 

Year Accomplishments

2018

SEPM: In FY18, EO Offices within the complex partnered and co-sponsored 11 SEP 

events. DTRA sponsored the National Disability Employment Awareness Month and 

(approximately 95 employees were in attendance) and the National Hispanic Heritage 

Month (approximately 50 employees were in attendance). EO will continue to 

monitor the impact of these events in FY19.

AHP: The AHP was recently established to maintain a harassment free work 

environment and to provide awareness to the Agency workforce. To date, the team 

has drafted the AHP instruction which is pending approval. 

Dashboards and Reports: In FY18, EO continued to collaborate with HR and the

Information Integration and Technology Services (IT) Directorate to upgrade of the 

internal EEO Dashboard (Business Intelligence Solution). The Dashboard was 

reconfigured to include the new EEOC requirement for MD-715 Data tables. 

Specifically, the B tables were significantly impacted by the format change requesting 

different categories of information.

The A tables continues to support EEOC’s current dashboard format but the B tables 

will be calculated, and populated manually for the FY18 submission. During FY19, 

EO, HR, and IT will continue to work on data collection, calculation, and formatting 

to fulfill the needs of the newly formatted data tables from EEOC.

Data Management/Automation: The current data management/automation process 

works for the previous format of the MD-715 data tables. However, improvements 

can be made on the loading of the data. HR, and IT are in the process of taking the 

two independent data collection efforts and ensure both efforts can be met through a 

single, more comprehensive data collection effort. This will reduce the time and 

effort it takes to load both sources as well as focus all data cleansing activities to 

ensure the source data reflects what has actually occurred on a monthly basis.
55

MD-715 – Part H - 6

Agency EEO Plan to Attain the Essential Elements of a Model EEO Program

Defense Threat Reduction Agency 

Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.

 If the agency did not address any deficiencies during the reporting period, please check the box.

Statement of Model Program Essential Element Deficiency

Type of 

Program 

Deficiency

Brief Description of Program Deficiency

E.5.a Does the agency monitor trends in its EEO program to determine whether the agency 

is meeting its obligations under the statutes EEOC enforces?

E.5.b Does the agency review other agencies’ best practices and adopt them, where 

appropriate, to improve the effectiveness of its EEO program?

E.5.c Does the agency compare its performance in the EEO process to other federal 

agencies of similar size?

Objective(s) and Dates for EEO Plan

Date 

Initiated Objective Target Date

Modified 

Date 

Date 

Completed

01/30/2019

Monitor the EEO program trends to ensure 

Agency obligations; review other agencies best 

practices to improve effectiveness and 

compare Agency’s performance to similar 

federal agencies.

02/15/2020

Responsible Official(s)

Title Name

Performance 

Standards 

Address the 

Plan?

(Yes or No)

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald YES

Planned Activities Toward Completion of Objective
56

Target 

Date Planned Activities

Sufficient 

Funding & 

Staffing? 

(Yes or No)

Modified 

Date 

Completion 

Date 

04/2019

Examine EEO program trends to determine 

whether the agency is meeting its obligations 

under the statutes EEOC enforces

YES

04/2019

Identify Federal agencies of similar size and 

determine programs that are congruent and 

implement new strategies and ideas. 

YES

07/2019 Research and implement best practices to 

improve the EEO program effectiveness.

YES

09/2019 Incorporate practices that will improve our EEO 

process

YES

Report of Accomplishments

Fiscal 

Year Accomplishments

2018

For FY19, EO have identified benchmarking opportunities with several federal agencies of 

similar size to compare their Diversity and Inclusion, Disability, Employee Resource Groups 

efforts. We are scheduled to visit Internal Revenue Services, Human Health Services, the 

State Department, United States Coast Guard and Department of Homeland Security to 

discuss their experiences establishing their programs, lesson learned and pitfalls.
57
58

MD-715 – Part I

Agency EEO Plan to Eliminate Identified Barrier

DTRA FEMALE WORKFORCE

Please describe the status of each plan that the agency implemented to identify possible barriers in policie 

procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the box.

Statement of Condition That Was a Trigger for a Potential Barrier:

Source of the 

Trigger

Specific 

Workforce 

Data Table 

Narrative Description of Trigger

DTRA 

Female 

Workforce

Table A1 Overall, the Agency total workforce for FY18 participation rate for 

Females was 471 (34.51%). This is below the 2010 CLF of 48.16%.

Workforce 

GS-14 thru 

SES

Table A4

GS-14 Females were 107 (29.72%) in FY18 vs. 108 (31.49%) FY 

2017.

GS-15 Females were 44 (21.36%) in FY18 vs. 38 (17.92%) FY 2017.

SES Females were 3 (21.43%) in FY18 an increase from 3 (18.75%) in 

FY17. 

New Hires Table A-8 The Agency hired 168 new employees of which 77 (45.83%) were 

Females. 

Career

Development Table A-12

The Agency offered Competitive Professional Development Programs 

(CPDPs) in FY18.

GS-05 thru GS-12: Overall Females participation were 6 (50%).

GS-13 and GS-14: Overall Females participation were 11 (36.67%).

GS 15 and SES: Overall Female participation was 1 (25.00%). 

Separation Table A-14

142 employees separated the Agency. Females were separated at a rate 

of 53 (36.30%) while they represent only 34.51% of the overall DTRA 

population.

EEO Group(s) Affected by Trigger

EEO Group

All Women
59

Barrier Analysis Process

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables NO Previously collected data from several federal agencies 

to identify barriers

Complaint Data (Trends) NO Previously collected complaints data from FY12 –

FY15.

Grievance Data (Trends) NO

Findings from Decisions 

(e.g., EEO, Grievance, 

MSPB, Anti-Harassment 

Processes) 

NO

Climate Assessment 

Survey (e.g., FEVS) YES Reviewed the Agency’s FEVS and conducted a Climate 

Survey - FY18

Exit Interview Data NO Previously reviewed the Agency’s exit interview data 

from FY12 – FY15.

Focus Groups NO

Previously a group of 10 individuals including a Senior 

Leader Champion and two Chairpersons facilitated the 

focus groups to identify and address the barriers – FY15.

Interviews NO

Previously conducted Agency-wide interviews of 

supervisors, managers and the workforce for views of 

the Agency’s workforce - FY15.

Reports (e.g., Congress, 

EEOC, MSPB, GAO, 

OPM)

NO Previously the workgroup reviewed the EEOC Women’s 

report and other supporting documents – FY15

Other (Please Describe)

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

YES YES
60

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

DTRA’s Policies and procedures are reviewed regularly by the EO Office to ensure that the content 

provides equitable opportunity. DTRA must sustain efforts to recruit highly–qualified women. 

Women low representation and advancement in DTRA have been identified as a trigger. 

Develop and implement strategies for the recruitment and selection of highly qualified women for 

positions at the highest levels.

Objective(s) and Dates for EEO Plan

Objective Date 

Initiated 

Target 

Date 

Sufficient 

Funding 

& 

Staffing?

(Yes or No)

Modified 

Date 

Date 

Completed 

Identify the cause(s) of 

potential barriers for

recruiting women.

04/14/2019 09/30/2020 YES

Responsible Official(s)

Title Name

Performance Standards 

Address the Plan? 

(Yes or No)

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald YES

Director, Human Resource 

Directorate Jamie S. Millsaps, Colonel USAF YES

Planned Activities Toward Completion of Objective

Target Date Planned Activities Modified Date Completion Date 

Trigger Identification 

In 2016, the Agency established the Women’s Working Group and develop recommendations that 

was presented to Senior Leadership.

03/30/2015

Hosted quarterly “Women in the 

Workplace Brown Bags” session to discuss 

women’s issues, challenges, issues and 

successes.

06/30/2016
61

Target Date Planned Activities Modified Date Completion Date 

05/15/2015 Obtained a SES Champion to establish the 

Women’s Working Group (WWG). 09/30/2016

06/15/2015

Developed a WWG to address areas of 

Recruitment and Hiring, Career 

Development and Retention.

07/31/2015

07/15/2015 Developed a comprehensive internal and 

external data collection plan. 08/15/2015

07/30/2015 Examined Female Data and Trends 09/30/2015

10/15/2015 Provided Final WWG Report of results and 

fact-finding. 09/30/2016

Barrier Analysis

02/15/2018

Finalize Employee Resource Group (ERG)

Charter and guidance to establish new 

working groups to examine perceived 

barriers

03/05/2019

Establish the Women’s ERG (W/ERG) to 

address the low participation of Women in 

the Agency.

04/30/2019 Select a SES sponsor (Champion) to play 

an active role within the W/ERG.

06/08/2019

Hold W/ERG monthly meetings to 

collaborate on targeted outreach strategies

and diversity-related matters.

08/29/2019

Develop and provide workshops, brown 

bags and seminars to promote cultural 

awareness for Women.

09/01/2019

Develop partnerships with women’s 

organizations, colleges, and universities

within the DC Metro area

10/15/2019

Target recruitment efforts towards women 

from diverse backgrounds (including 

veterans) through networking/partnerships 

with women’s and veterans’ organizations.
62

Target Date Planned Activities Modified Date Completion Date 

11/01/2019

Develop recruitment strategies to improve 

female participation in critical mission 

occupation.

12/30/2019

Conduct an analysis to determine retention 

issues within the Agency (i.e., exit survey, 

OPM Employee Viewpoint Survey). 

Report of Accomplishments

Fiscal Year Accomplishments

FY 2018

In FY18, HR continued partnerships and alliances with diverse professional 

organizations and educational institutions. The EO Office will collaborate with HR 

to increase the number of minority and female candidates applying for positions 

suitable for recruitment by:

• Assessing DTRA- wide recruitment activities

• Coordinating EEO Office participation in recruitment events

• Working with minorities institutions to deliver informational outreach sessions 

on job opportunities at DTRA

• Facilitate transition for female veterans into the civilian workforce

• Continue to offer a formal detail/rotation process and current opportunity to 

promote career advancement

• Develop a comprehensive recruitment strategy and best practices for Hispanics, 

Women, Veterans, STEM, Individual with Disability and Mission Critical 

Occupation

• Adopt and tailor OPM Recruitment, Engagement, Diversity and Inclusion 

Program (REDI) roadmap for ideas

• Increase retention of Women in the Agency 
63

MD-715 – Part I

Agency EEO Plan to Eliminate Identified Barrier

DTRA HISPANIC WORKFORCE

Please describe the status of each plan that the agency implemented to identify possible barriers in 

policies, procedures, or practices for employees and applicants by race, ethnicity, and gender. 

 If the agency did not conduct barrier analysis during the reporting period, please check the box.

Statement of Condition That Was a Trigger for a Potential Barrier:

Source of 

the 

Trigger

Specific 

Workforce 

Data Table 

Narrative Description of Trigger

DTRA 

Hispanic 

Workforce

Table A-1

Using the 2010 CLF of 9.96% (Hispanic Males were 5.17% and 

Hispanic Females were 4.79%) as a benchmark, Hispanics had a low 

participation rate of 2.64% (Hispanic Males 1.39% and Hispanic 

Females 1.25%) in the overall workforce. 

Senior 

Executive 

Service

Table A-4

The participation rate of Hispanics males and females in the total 

workforce at the Senior Executive Service (SES) at DTRA is 0%. 

During the FY18, there were no Hispanics selected for the SES.

New Hires Table A-8 The Agency hired one (0.60%) Hispanic Male employee. 

Separation Table A-14 

Three Hispanics separated from DTRA during FY18. Males separated 

at a rate of 0.70% and females separated at a rate of 1.41% while they 

represented only 2.64% the overall DTRA population.

EEO Group(s) Affected by Trigger

EEO Group

Hispanic or Latino Males Hispanic or Latino Females

Barrier Analysis Process

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables NO Previously collected data from several federal agencies 

to identify barriers – FY12

Complaint Data (Trends) NO Previously collected complaints data from FY10 –

FY14.
64

Sources of Data

Source 

Reviewed?

(Yes or No)

Identify Information Collected

Grievance Data (Trends) NO

Findings from Decisions 

(e.g., EEO, Grievance, 

MSPB, Anti-Harassment 

Processes) 

NO

Climate Assessment Survey 

(e.g., FEVS) YES Reviewed the Agency’s FEVS and Climate Surveyfrom FY17 – FY18.

Exit Interview Data NO Previously reviewed the Agency’s exit interview data 

from FY10 – FY14.

Focus Groups NO

Previously a group of 12 individuals including a Senior 

Leader Champion and two Chairpersons facilitated the 

focus groups to identify and address barriers – FY12.

Interviews NO

Previously conducted Agency-wide interviews of 

supervisors, managers and the workforce for their

views of the Agency’s workforce – FY12.

Reports (e.g., Congress, 

EEOC, MSPB, GAO, 

OPM)

NO

Other (Please Describe)

Status of Barrier Analysis Process

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

YES YES

Statement of Identified Barrier(s)

Description of Policy, Procedure, or Practice

The Agency continued to work on the low participation rates of Hispanics. In FY18, the EO

Office with the support of HR was committed to identify and minimize potential barriers to 

improve the representation of Hispanics at DTRA. 

Objective(s) and Dates for EEO Plan
65

Objective Date 

Initiated 

Target 

Date 

Sufficient 

Funding 

& 

Staffing?

(Yes or No)

Modified 

Date 

Date 

Completed 

Identify and address all 

potential barriers for 

Hispanics/Latino within 

DTRA’s workforce.

12/04/2018 12/15/201

9 YES

Responsible Official(s)

Title Name

Performance 

Standards Address the 

Plan? 

(Yes or No)

Director, Equal Opportunity and 

Diversity Programs Office Willisa Donald YES

Director, Human Resource 

Directorate

Jamie S. Millsaps, Colonel 

USAF YES

Planned Activities Toward Completion of Objective

Target Date Planned Activities Modified Date Completion Date 

Trigger Identification

In 2014, the Agency established the Hispanic Working Group and develop recommendations that 

was presented to Senior Leadership.

03/30/2012 Developed a charter to establish the roles 

and responsibilities of the HWG. 09/20/2013

04/15/2013 Developed an Hispanic Action Plan in 

collaboration with HR. 09/30/2014

05/15/2014 Obtained a SES Champion to establish the 

Hispanic Working Group (HWG). 09/15/2015

07/01/2014 Developed a comprehensive internal and 

external data collection plan. 01/30/2015

07/30/2014 Examined Hispanics Data and Trends 09/30/2014

10/01/2014 Provided Final HWG Report of results and 

fact-finding. 06/30/2015
66

Target Date Planned Activities Modified Date Completion Date 

Barrier Analysis

02/05/2019

Finalize the ERG Charter and guidance to 

establish new working group to examine 

perceived barriers.

03/05/2019 Establish a Hispanic ERG (H/ERG).

04/15/2019 Select a SES sponsor (Champion) who will 

play an active role within the H/ERG.

06/30/2019

Hold H/ERG monthly meetings to 

collaborate on targeted outreach strategies

and diversity-related matters.

07/15/2019

Conduct in-depth barrier analysis in 

collaboration with H/ERG to identify 

policies and practices that may prevent 

advancement in the representation of 

Hispanics at DTRA.

08/29/2019

Develop and provide workshops, brown 

bags and seminar to promote cultural 

awareness in working with Hispanics.

09/30/2019

Conduct Federal Agency research of Best 

Practices for Hispanic recruitment, 

retention, and fostering professional 

development opportunities targeting the 

Hispanic workforce and develop a report 

regarding findings.

10/01/2019

Identify separate committees within the 

HWG to work on specific strategies of the 

plan.

11/15/2019

Review hiring, promotion, and career 

development programs of other Federal 

Agencies and private sector companies to 

benchmark best practices.

12/11/2019 Conduct a Climate Survey of the DTRA 

Albuquerque facility.

01/15/2020

Conduct Awareness Sessions for Agency 

employees and discuss ways to enhance 

opportunities for Hispanics. 
67

Target Date Planned Activities Modified Date Completion Date 

Report of Accomplishments

Fiscal Year Accomplishments

FY 2018

DTRA reviewed and modified outreach and recruitment strategies to ensure a 

diverse applicant pool that includes qualified Hispanics. Efforts included 

outreach at conferences, colleges/universities and information briefs at local 

schools colleges and community events with large Hispanic populations. In 

addition, special recruitment teams were established for engineering and 

scientist positions specifically targeted to Hispanic/Latino Americans seeking 

employment. Partnerships with professional Hispanic affinity organizations 

provides DTRA with the opportunity to market the Agency as an employer of 

choice.

In FY18 EO and HR continues to educate manager, through supervisory training 

sessions and other venues on workforce demographics, diversity goals and 

objectives and the benefits of diversity in the workforce. Senior Leaders will 

continue to receive EEO, D&I training and to increase participation in Diversity 

activities and actions. 
68
69

MD-715 – Part J

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

Retention of Persons with Disabilities

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

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

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

of applicants and employees with disabilities. All agencies, regardless of size, must complete this 

Part of the MD-715 report.

Section I: Efforts to Reach Regulatory Goals

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

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

government. 

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

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

box.

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

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

The percentage of PWDs in the GS-1 to GS 10 cluster was 0.95% (13) for FY18, which falls 

below the goal of 12%

The percentage of PWDs in the GS-11 to SES cluster was 12.16.% (166)in FY18, which is 

above the goal of 12%

The overall PWDs percentage is 13.11% (179).

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

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

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

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

The percentage of PWTDs in the GS-1 to 10 cluster was 0.146% (2) in FY18, which is below the 

goal of 2%.

The percentage of PWTDs in the GS-11 to SES cluster was 1.098% (15) in FY18, which is 

below the goal of 2%.

The overall PWTDs percentage is 1.245% (17).

Describe how the agency has communicated the numerical goals to the hiring managers and/or 

recruiters.

DTRA’s participation rate has increased from FY17 0.82% (11) for PWTDs. The Agency 

hired five PWTDs in FY18 increasing our percentage to 1.245% (17). In addition, 12 PWDs 
70

were hired in FY18. The Agency continues to promote special hiring authorities by educating 

hiring officials and hiring managers.

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. 

PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR THE DISABILITY 

PROGRAM

Has the agency designated sufficient qualified personnel to implement its disability program during 

the reporting period? If “no”, describe the agency’s plan to improve the staffing for the upcoming 

year.

Yes X No 

In FY18, an employee, from another Directorate, was detailed and later became a permanent member 

to the EO Office. She assisted the EO Director with office administrative functions, Special Emphasis 

Programs and the Workforce Recruitment Program. She was instrumental in bringing onboard three 

interns for the WRP program. 

Identify all staff responsible for implementing the agency’s disability employment program by the 

office, staff employment status, and responsible official.

Disability Program Task

# of FTE Staff by 

Employment Status Responsible Official

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

Processing applications from 

PWD and PWTD 0 0 0

Charletta R. Anderson

Human Resource Specialist,

charletta.r.anderson.civ@mail.mil

Answering questions from the 

public about hiring authorities 

that take disability into account

1 0 0

Cheryl Williams-Payton, Disability 

Program Coordinator, Equal 

Opportunity and Diversity Programs 

Office, 

Cheryl.b.williams6.civ@mail.mil

Processing reasonable 

accommodation requests from 

applicants and employees

1 0 0

Mary Lewandowski, Reasonable 

Accommodation Coordinator, 

Human Resources, 

Mary.h.lewandowski.civ@mail.mil

Section 508 Compliance 1 0 0

Robert R. Bleck, Team Lead, DTRA 

508 Program Coordinator,

Information Resources Department,

robert.r.bleck.civ@mail.mil
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Architectural Barriers Act 

Compliance 1 0 0

Patrick Bass, Team Lead, Facilities 

Plans and Space Management, ALELF,

patrick.r.bass.civ@mail.mil

Special Emphasis Program for 

PWD and PWTD 1 0 0

Cheryl Williams-Payton, Disability 

Program Coordinator, Equal 

Opportunity and Diversity Programs 

Office, 

Cheryl.b.williams6.civ@mail.mil

Has the agency provided disability program staff with sufficient training to carry out their 

responsibilities during the reporting period? If “yes”, describe the training that disability program 

staff have received. If “no”, describe the training planned for the upcoming year.

Yes X No 

The Disability Coordinator attended a Special Emphasis Manager Training course and is 

scheduled to attend additional training in FY19.

PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM

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

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

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

Yes X No 

The Agency currently has a Sign Language Interpreter (SLI) agreement with the Defense 

Logistics Agency to support the needs of employees requesting SLI. SLIs were available for 

meetings, trainings, brown bags, and special emphasis observances.

Section III: Plan to Recruit and Hire Individuals with Disabilities

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

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

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

PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES

Describe the programs and resources the agency uses to identify job applicants with disabilities, 

including individuals with targeted disabilities. 

Workforce Recruitment Program is a DOL/DoD recruitment initiative which helps DTRA 

identify qualified students with disabilities for summer employment and potentially provide the 

opportunity to retain the students by offering permanent positions.

PLAN:
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• Marketing efforts through flyers, postcards, and digital signage to increase awareness and 

participation; bring on board at least 14 interns for FY19 and offer interns permanent 

positions using Schedule A hiring authority.

• Partner with HR to ensure processes and WRP Action Plan is adhered to.

• Host at least two sessions to kick-off the WRP to educate managers and provide 

awareness on the hiring process.

• Create WRP Blog and submit article in HR Connection to advertise the program.

• Conduct Disability etiquette training for supervisors and managers.

• Conduct mandatory training during orientation and establish training day for interns to 

complete mandatory on-line training.

• Plan and organize WRP intern meet and greet.

• Host WRP farewell ceremony for interns, their supervisors and co-workers.

• Develop and distribute exit survey for WRP students to determine their overall 

experience working at DTRA.

Pursuant to 29 C.F.R. § 1614.203(a)(3), describe the agency’s use of hiring authorities that take 

disability into account (e.g., Schedule A) to recruit PWD and PWTD for positions in the permanent 

workforce. 

SCHEDULE A allows DTRA to hire qualified PWDs and PWTDs non competitively using 5 

CFR § 213.3102 (u). The Disability Coordinator and HR will continue to implement Schedule A 

based on the following.

PLAN:

• Maintain Schedule A database repository for resumes.

• Educate hiring managers and supervisors on the use and advantages of the Schedule A 

appointment authority for hiring.

• Serve as a resource to PWDs/PWTDs seeking information about current job 

opportunities.

• Create a Schedule A Information Sheet and include Frequently Asked Questions.

DISABLED VETERANS PROGRAM ensures compliance with the EO13548 for Federal 

agencies to hire more Veterans. DTRA is committed to seek ways to increase the hiring of 

Veterans, especially those who are 30% or more disabled. Approximately 24.62% of DTRAs 

workforce comprised of disable veterans, of which 20.37% were veterans with a disability rate of 

30% or higher.

PLAN:

• Collaborate with HR and Wounded Warrior representatives to discuss effective ways to 

hire Veterans.

• Develop a list of outreach resources of Veterans, Vocational Rehabilitation Centers, and 

PWDs/PWTDs organizations.

• Build partnerships to help expand disability outreach efforts.

• Attend career fairs and other opportunities to recruit and obtain applications for veterans.

• Assist with matching Wounded Warrior candidates with DTRA job vacancies.
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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. 

 The EO office maintains a database with resumes and Schedule A certification letters obtained 

by the candidate in compliance with the Schedule A hiring authority. Based on the occupation 

being hired, EO provide resumes and Schedule A letters to HR upon request to provide to 

supervisors and hiring managers. During the hiring process, supervisors meet with HR (strategic 

conversation) to provide information on the disability program and the use of Schedule A.

Has the agency provided training to all hiring managers on the use of hiring authorities that take 

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

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

Yes X No N/A 

The Agency currently conducts a mandatory training – “Roadmap to Success: Hiring People 

with Disability”. This one hour online training is available to the workforce. In addition, HR 

provides awareness to all hiring managers on the use of hiring authorities that is inclusive to 

PWDs and PWTDs.

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. 

DTRA participated in the Workforce Recruitment Program (WRP) and hired four summer

interns. In FY19, the Agency is scheduled to visit the Fort Belvoir Wounded Warrior Office, and

Vocational Rehabilitation Centers to establish and build collaborative relationships and to 

promote programs for PWDs and PWTDs.

PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING)

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

and/or PWTD among the new hires in the permanent workforce? If “yes”, please describe the triggers 

below.

a. New Hires for Permanent Workforce (PWD) Yes X No 

b. New Hires for Permanent Workforce (PWTD) Yes No X

Among the new hires in the permanent workforce, triggers exist for PWD 5.98% (10), this falls 

below the benchmark of 12%. Among PWTDs 2.395% (4) were new hires and this percentage is 

above the 2% benchmark. DTRA hired 167 new employees in the permanent workforce.
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Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among 

the new hires for any of the mission-critical occupations (MCO)? If “yes”, please describe the 

triggers below.

a. New Hires for MCO (PWD) Yes X No 

b. New Hires for MCO (PWTD) Yes X No 

EO and HR is working on identifying Agency MCOs.

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

the qualified internal applicants for any of the mission-critical occupations (MCO)? If “yes”, please 

describe the triggers below.

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

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

In FY19, EO will coordinate with HR/IT data team to obtain data on qualified internal applicants 

identified as a PWDs or PWTDs for the mission-critical occupational groups.

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

employees promoted to any of the mission-critical occupations (MCO)? If “yes”, please describe the 

triggers below.

a. Promotions for MCO (PWD) Yes X No 

b. Promotions for MCO (PWTD) Yes X No 

EO and HR is working on identifying Agency MCOs.

Section IV: Plan to Ensure Advancement Opportunities for Employees 

with Disabilities 

Pursuant to 29 C.F.R §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement 

opportunities for employees with disabilities. Such activities might include specialized training and 

mentoring programs, career development opportunities, awards programs, promotions, and similar 

programs that address advancement. In this section, agencies should identify, and provide data on 

programs designed to ensure advancement opportunities for employees with disabilities.

ADVANCEMENT PROGRAM PLAN

Describe the agency’s plan to ensure PWD, including PWTD, have sufficient opportunities for 

advancement.

At this time, we don’t have any programs designated specifically for PWDs/PWTDs. This item 

will be addressed in the action plan.
75

CAREER DEVELOPMENT OPPORTUNITIES

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

DTRA provides comprehensive individual, leadership and professional development programs to 

its employees and military members. Programs include individual and group training, a multitrack leadership development program with both competitive and non-competitive elements, a 

mentoring program, a career broadening program, programs supporting pursuit of academic 

degrees and other developmental programs. All programs are fully compliant with CFR Title 5, 

parts 410 and 412 and are accessible and open to all employees, including PWDs/PWTDs. 

Reasonable accommodations are always provided.

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

competition and/or supervisory recommendation/approval to participate. [Collection begins with the 

FY18 MD-715 report, which is due on February 28, 2019.]

Career Development 

Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%)

Selectees 

(%)

Applicants 

(%)

Selectees

(%)

Internship Programs N/A N/A N/A N/A N/A N/A

Fellowship Programs 3 2 0 0 0 0

Mentoring Programs 37 37 2 2 1 1

Coaching Programs N/A N/A N/A N/A N/A N/A

Training Programs 36 31 4 4 1 1

Detail Programs N/A N/A N/A N/A N/A N/A

Other Career 

Development Programs 19 16 1 1

Do triggers exist for PWD among the applicants and/or selectees for any of the career development 

programs? (The appropriate benchmarks are the relevant applicant pool for the applicants and the 

applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box.

a. Applicants (PWD) Yes X No 

b. Selections (PWD) Yes X No 

In FY18, 7.36% (7) of the applicants were PWDs and 8.1% (7) were selectees for the career 

development programs. 5.4% (2) of PWDs were selected for the mentoring program and 12.9% 

(4) of PWDs were selected for the training programs.
76

Do triggers exist for PWTD among the applicants and/or selectees for any of the career development 

programs identified? (The appropriate benchmarks are the relevant applicant pool for applicants and 

the applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box. 

Applicants (PWTD) Yes X No 

Selections (PWTD) Yes X No 

In FY18, 2.10% (2) were PWTDs applicants for the career development programs and 2.32% (2) 

PWTDs were selected. There is a need in FY19 to enhance participation of PWTDs.

AWARDS

Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or 

PWTD for any level of the time-off awards, bonuses, or other incentives? If “yes”, please describe 

the trigger(s) in the text box.

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

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

Time-off and cash awards were provided to 2113 employees in FY18. 300 (14.19%) of PWDs 

received time-off and cash awards, which is above the inclusion rate of 12%. Twenty (20)

(0.94%) of PWTDs received time-off and cash awards, which is below the inclusion rate of 2%.

Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or 

PWTD for quality step increases or performance-based pay increases? If “yes”, please describe the 

trigger(s) in the text box.

a. Pay Increases (PWD) Yes X No 

b. Pay Increases (PWTD) Yes No X

Eighty-two employees (67 QSIs) and (15 performance base) received other awards in FY18. 

Two PWDs and two PWTDs (2.43%) received QSIs in FY18.

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. 

Determine if PWD are nominated and selected -

a. Other Types of Recognition (PWD) Yes No N/A X

b. Other Types of Recognition (PWTD) Yes No N/A X
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PROMOTIONS

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.

o SES

 Qualified Internal Applicants (PWD) Yes X No 

 Internal Selections (PWD) Yes X No 

o Grade GS-15

 Qualified Internal Applicants (PWD) Yes X No 

 Internal Selections (PWD) Yes X No 

o Grade GS-14 

 Qualified Internal Applicants (PWD) Yes No X

 Internal Selections (PWD) Yes No X

o Grade GS-13 

 Qualified Internal Applicants (PWD) Yes No X

 Internal Selections (PWD) Yes No X

There were no SES PWDs promoted in FY18. However, there were 13 SES internal applications 

and 1 new hire.

There were 24 (11.65%) of PWDs applications for promotion out of 206 GS-15 employees 

(applicants) promoted (8 new hires).

There were 45 (12.50%) PWDs applications for promotion out of 360 GS-14 employees/ 

applicants for promotion (internal and new hires applicants).

There were 50 (12.03%) PWDs applications for promotion out of 360 GS-13 employees/ 

applicants for promotion.
78

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.

o SES

 Qualified Internal Applicants (PWTD) Yes X No 

 Internal Selections (PWTD) Yes X No 

o Grade GS-15

 Qualified Internal Applicants (PWTD) Yes X No 

 Internal Selections (PWTD) Yes X No 

o Grade GS-14 

 Qualified Internal Applicants (PWTD) Yes X No 

 Internal Selections (PWTD) Yes X No 

o Grade GS-13 

 Qualified Internal Applicants (PWTD) Yes X No 

 Internal Selections (PWTD) Yes X No

 

There were no SES PWTDs promoted in FY18. However, there were 13 SES internal 

applications and 1 new hire.

There were 1 (8.33%) of PWTDs applications for promotion out of 206 GS-15 employees 

(applicants) promoted (8 new hires).

There were 3 (1.01%) PWDs applications for promotion out of 360 GS-14 employees/applicants 

for promotion (internal and new hires applicants).

There were 8 (1.65%) PWDs applications for promotion out of 360 GS-13 employees/applicants 

for promotion.

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.

• New Hires to SES (PWD) Yes X No 

• New Hires to GS-15 (PWD) Yes X No 

• New Hires to GS-14 (PWD) Yes X No 

• New Hires to GS-13 (PWD) Yes X No 

There were 7 executives identified and 1 new hire. There were 0 PWDs identified/hired. In the 

GS-15, GS-14, and GS-13 category there were 57 new hires and 3 (5.26%) new hires which 

causes a trigger.
79

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

PWTD among the new hires to the senior grade levels? For non-GS pay plans, please use the 

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

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

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

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

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

There were 7 executives identified and 1 new hire. There were 2 PWTDs identified/hired. In the 

GS-15, GS-14, and GS-13 category there were 57 new hires and 2 (3.50%) new hires which 

causes a trigger.

Does your agency have a trigger involving PWD among the qualified internal applicants and/or 

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant 

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If 

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

a. Executives

i. Qualified Internal Applicants (PWD) Yes X No 

ii. Internal Selections (PWD) Yes X No 

b. Managers

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

c. Supervisors 

i. Qualified Internal Applicants (PWD) Yes No X

ii. Internal Selections (PWD) Yes No X

There were 0 internal SES selection. Among the managers there were 5 (19.23%) PWDs out of 

the 26 internal selections. Among the supervisors there were 2 (13.33) PWDs out of the 15 

internal selections.
80

Does your agency have a trigger involving PWTD among the qualified internal applicants and/or 

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant 

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If 

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

a. Executives

i. Qualified Internal Applicants (PWTD) Yes X No 

ii. Internal Selections (PWTD) Yes X No 

b. Managers

i. Qualified Internal Applicants (PWTD) Yes X No 

ii. Internal Selections (PWTD) Yes X No 

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Yes X No 

ii. Internal Selections (PWTD) Yes X No 
81

There were 0 internal SES internal selection. Among the managers there were 0 PWTDs out 26 

internal selections. Among the supervisors there were 0 PWTDs out of 15 internal selections. 

Identifying triggers for all internal selections.

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.

• New Hires for Executives (PWD) Yes X No 

• New Hires for Managers (PWD) Yes X No 

• New Hires for Supervisors (PWD) Yes No X

There were 0 PWDs new hires for executives. Among the managers there were 3 (5.26%) PWDs 

selected for new hires. Among the supervisors there were 2 (13.33%) PWDs new hires.

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.

• New Hires for Executives (PWTD) Yes X No 

• New Hires for Managers (PWTD) Yes No X

• New Hires for Supervisors (PWTD) Yes X No 

There were 0 PWTDs new hires for executives. Among the managers there were 2 (3.51%) 

PWTDs selected for new hires. Among the supervisors there were 0 PWTDs selected for new 

hires.

Section V: Plan to Improve Retention of Persons with Disabilities

To be a model employer for persons with disabilities, agencies must have policies and programs in 

place to retain employees with disabilities. In this section, agencies should: (1) analyze workforce 

separation data to identify barriers retaining employees with disabilities; (2) describe efforts to 

ensure accessibility of technology and facilities; and (3) provide information on the reasonable 

accommodation program and workplace personal assistance services.

VOLUNTARY AND INVOLUNTARY SEPARATIONS

In this reporting period, did the agency convert all eligible Schedule A employees with a disability 

into the competitive service after two years of satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If 

“no”, please explain why the agency did not convert all eligible Schedule A employees.

Yes No X N/A 
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The Agency do not consistently track the use of Schedule A Hiring Authority and conversions to 

permanent status after the 2-year probation status. In FY19, EO will collaborate with HR to 

identify a process to remind managers and supervisors when a Schedule A employee is eligible for 

conversion. 

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.

• Voluntary Separations (PWD) Yes X No 

• Involuntary Separations (PWD) Yes X No 

Using the inclusion rate, PWDs 22 (25.28%) voluntarily separated from the agency, as compared 

to the rate of individuals without disabilities 87 (59.58%).

Using the inclusion rate, PWDs 8 (13.55%) who involuntarily separated from the agency, as 

compared to the rate of individuals without disabilities 59 (40.41%).

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.

• Voluntary Separations (PWTD) Yes X No 

• Involuntary Separations (PWTD) Yes X No 

Using the inclusion rate, triggers does exist for PWTD (1) 0.71% who involuntarily separated 

from the agency, as compared with the goal of 2%.

Using the inclusion rate, triggers does not exist for PWTD (0.0%) who involuntarily separated 

from the agency, as compared to the rate of persons without disabilities (0) (85.00%).

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.

We believe triggers may exist involving the separations of PWD and PWTD at DTRA, there are 

inconsistencies in the data. EO in collaboration with HR will work to identify and develop a 

plan for addressing these inconsistencies by reviewing the exit interview and results. These steps 

will allow us to ascertain more detailed information on triggers impacting separations among 

PWDs and PWTDs.
83

ACCESSIBILITY OF TECHNOLOGY AND FACILITIES

Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform applicants and 

employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), 

concerning the accessibility of agency technology, and the Architectural Barriers Act of 1968 (42 

U.S.C. § 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are 

required to inform individuals where to file complaints if other agencies are responsible for a 

violation. 

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. 

Currently, the Agency does not have a public website that explain employees’ and applicants’ 

rights under the Section 508 of the Rehabilitation Act nor how to file a complaint. 

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.

Currently, the Agency does not have a public website that explain employees’ and applicants’ 

rights under the Architectural Barrier Act nor how to file a complaint.

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.

• DTRA and DLA discussed the possibility of sharing resources to provide in-house closed 

captioning services. We are also investigating the tools that Microsoft may be able to provide 

via its cloud services.

• The DTRA members of the Federal IT leaders group were unsuccessful in finding a common 

tool used among the represented agencies, we have since been in discussions with partnering 

with DLA.

• DTRA is now participating in the DLA/DISA 508 working group who meet once a month.

• The Agency have scheduled a vendor presentation of the end of February and a 45 day trial 

version of their software to test our internal, soon to be deployed, internal SharePoint site.

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.
84

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.)

Responses to RA requests for information will be provided no later than 15 calendar days after 

receipt and a decision will be provided within 30 calendar days of receiving all requested 

information. 

Describe the effectiveness of the policies, procedures, or practices to implement the agency’s 

reasonable accommodation program. Some examples of an effective program include timely 

processing requests, timely providing approved accommodations, conducting training for managers 

and supervisors, and monitoring accommodation requests for trends.

The processing of reasonable accommodations are conducted in timely manner. Every other 

month reasonable accommodations are discussed with the hiring managers. The process is also 

conducted one on one with Supervisors upon their request. 

PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are 

required to provide personal assistance services (PAS) to employees who need them because of a 

targeted disability, unless doing so would impose an undue hardship on the agency. 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS 

requirement. Some examples of an effective program include timely processing requests for PAS, 

timely providing approved services, conducting training for managers and supervisors, and 

monitoring PAS requests for trends.

PAS requirement has not been requested but the request will follow the same procedures as 

reasonable accommodations and will include timely processing of approved services. These 

procedures have been updated in the DTRA’s Reasonable Accommodation Handbook,

(Appendix E).

The Agency will conduct training for managers and supervisors, and continue to monitor PAS 

requests for trends. A PAS fact sheet will be created and posted on the public website as well as 

on its internal DTRA1 portal.

Section VI: EEO Complaint and Findings Data

EEO COMPLAINT DATA INVOLVING HARASSMENT –

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

harassment, as compared to the government-wide average? 

Yes No X N/A 
85

• During the last fiscal year, did any complaints alleging harassment based on disability status 

result in a finding of discrimination or a settlement agreement?

Yes No X N/A 

• 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.

No findings of Discrimination involving Harassment in FY18.

EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION

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

alleging failure to provide a reasonable accommodation, as compared to the government-wide 

average? 

Yes No X N/A 

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

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

Yes No X N/A 

• 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.

No findings of Discrimination involving Reasonable Accommodation in FY18.

Section VII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a 

policy, procedure, or practice may be impeding the employment opportunities of a protected EEO 

group.

• Has the agency identified any barriers (policies, procedures, and/or practices) that affect 

employment opportunities for PWD and/or PWTD? 

Yes No X

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

Yes No X N/A 

• 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. 
86

Trigger 1

DTRA exceeded the 12% representation goals for PWDs 13.11% (179) but did 

not exceed the 2% goal 1.25% (17) for PWTDs. 

Of the 167 new hires, 5.98% (10) were PWDs, and 2.395% (4) were PWTDs. 

There were one executive hired and 3 PWDs hired in GS-15, GS-14 and GS-13 

while 2 PWTDs were hired in the GS-15, GS-14 and GS-13.

Twenty two (25.28%) PWDs voluntarily separated from the agency, while 

13.55% (8) PWDs involuntarily separated from the agency, as compared to the 

rate of individuals without disabilities 40.41% (59). One PWD involuntarily 

separated and one PWTD resigned from the Agency.

Barrier(s) The permanent workforce participation rate of 1.25% (17) for PWTDs was 

lower than 2% (Table B1)

Objective(s) Increase the participation, advancement and retention rate of PWTDs within the 

Agency to meet or exceed the DoD 2% by 2020.

Responsible Official(s)

Performance Standards Address the 

Plan?

(Yes or No)

Director, Equal Opportunity and Diversity Programs 

Office YES

Director, Human Resource Directorate YES

Barrier Analysis Process Completed?

(Yes or No)

Barrier(s) Identified?

(Yes or No)

YES YES

Sources of Data

Sources 

Reviewed?

(Yes or No)

Identify Information Collected

Workforce Data Tables YES Table B - Disability

Complaint Data (Trends) NO Previously reviewed Agency Wide 

Complaints Data - FY17

Grievance Data (Trends) NO

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

NO

Climate Assessment Survey (e.g., 

FEVS) NO Previously reviewed Annual FEVS Report – FY17

Exit Interview Data NO Previously reviewed Exit Interview Data 

– FY17

Focus Groups NO Previously held focus groups – FY17

Interviews NO Previously interviewed managers and 

individual workforce – FY17.

Reports (e.g., Congress, EEOC, 

MSPB, GAO, OPM) NO

Other (Please Describe)
87

Target Date Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified 

Date

Completion 

Date

Trigger Identification

In 2015 the PWDs/PWTDs Working Group developed recommendations to address identified triggers

(Appendix F). Some of the recommendations includes:

• Develop disability etiquette standards, i.e. understand the norms and communicate to workforce.

• Emphasize to supervisors and managers the options and benefits of hiring Schedule A, disabled vets and 

Workforce Recruitment Program (WRP) candidates.

• Conduct Barrier Analysis by examining PWTDs data and trends.

• Prepare job announcement specifically targeting Schedule A prospects. 

• Expended use of mentoring/brown bags for PWDs and PWTDS. 

Conduct Barrier Analysis

02/15/2018 Finalize ERG Charter and guidance YES

03/12/2019

Establish the Individual with 

Disabilities ERG (PWDs/ERG) to 

address the low participation of PWDs 

in the Agency.

YES

04/30/2019

Select a SES sponsor (Champion) to 

play an active role within the 

PWDs/ERG.

YES

04/08/2019

Hold monthly PWDs/ERG meetings to 

collaborate on targeted outreach 

strategies and diversity-related matters.

YES

04/30/2019 Ensure diverse outreach strategies are in 

place to recruit PWDs. YES

07/15/2019

Conduct in-depth barrier analysis in 

collaboration with PWDs/ERG to 

identify policies and practices that may 

prevent advancement in the 

representation of PWDs at DTRA.

YES

08/29/2019

Develop and provide workshops, brown 

bags and seminar to promote cultural 

awareness in working for PWDs.

YES

09/30/2019

Conduct Awareness Sessions for 

employees to discuss ways to enhance 

opportunities for PWDs. 

YES

10/15/2019

Monitor tracking and reporting (i.e., 

Form 256 Self-Identification of 

Disability, RA Log, and Applicant Flow 

Data)

YES

11/15/2019 Review and analyze potential resources 

for PWD and PWTDs; YES

12/15/2019 Create list of colleges/universities for 

PWD and PWTDs YES

03/15/2020 Deliver annual RA training to 

employees and managers. YES
88

01/30/2020 Develop recruiting strategies for PWDs 

and PWTDs YES

03/15/2020

Develop an action plan to ensure PWDs 

and PWTDs have sufficient 

opportunities for advancement.

YES

Fiscal Year Accomplishments

2018

The Agency will continue its partnership with the Virginia Rehabilitation Services and 

Department of Transportation Selection Placement Program Coordinator to obtain 

resumes of PwDs for Schedule A hiring.

In FY18, EO collaborated with HR to increase opportunities for PwDs through the use 

of Schedule A Hiring Authority, Veterans programs such as Wounded Warriors and the 

WRP. The Agency hired 14 college interns for temporary summer employment and 

processed hiring actions to permanently hire one interns in FY18. 

During the hiring process, supervisors met with HR and provided information about the 

use of Schedule A. EO maintained a database with resumes and Schedule A letters. 

Based on the occupation being hired, EO provided resumes to HR, upon request, for 

supervisors and hiring managers.

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

activities.

Factors that prevented the Agency from timely completing the planned activities for PwDs was due 

to the lack of experienced personnel and resources. The FY18, a detailee, from another division,

came on board as the new disability coordinator. With training and on the job experience, she is 

now able to manage the disability program.

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

toward eliminating the barrier(s).

The agency has not had sufficient time to assess the impact of the planned activities. 

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 has not had sufficient time to assess the impact of the planned activities. 
89
90

Agency Total Workforce

In FY18, the DTRA civilian workforce was 1,365, an increase of 25 from FY17. Of the total 

workforce, 1,347 were permanent employees and 18 were temporary. The permanent workforce 

increased by 25 and the temporary workforce increased by 8. The Agency hired 168 new permanent 

employees and there were 146 voluntary separations.

The participation rate for White employees slightly decreased from 69.40% to 69.38%. Black 

employee participation rates decreased from 17.32% to 16.92 %. Hispanic employee participation 

rates also decreased from 2.91% to 2.64%. Asian employee participation rates slightly increased 

from 4.18% to 4.46%. There was no increase in the representation of Native Hawaiian or Other 

Pacific Islander.

FY17 FY18 2010 

CLF

# % # % %

MALES 892 66.57 894 65.49 51.84

FEMALES 448 33.43 471 34.51 48.16

HM 20 1.49 19 1.39 5.17

HF 19 1.42 17 1.25 4.79

WM 677 50.52 669 49.01 38.33

WF 253 18.88 278 20.37 34.03

BM 116 8.66 118 8.64 5.49

BF 116 8.66 113 8.28 6.53

AM 31 2.31 35 2.56 1.97

AF 25 1.87 26 1.90 1.93

NH/PI M 1 0.07 1 0.07 0.07

NH/PI F 3 0.22 3 0.22 0.07

AI/AN M 3 0.22 3 0.22 0.55

AI/AN F 2 0.15 1 0.07 0.53

TWO OR MORE RACES MALES 44 3.28 49 3.59 0.26

TWO OR MORE RACES 

FEMALES 30 2.24 33 2.42 0.28

HM=Hispanic Males; HF=Hispanic Females; WM=White Males; WF=White Females; BM=Black Males; BD=Black Females

AM=Asian Males; AF=Asian Females; NHOPIM= Native Hawaiian or Other Pacific Islander Males; NHOPIF= Native Hawaiian or Other 

Pacific Islander Females; AIANM=American Indian or Alaska Native Males; AIANF=American Indian or Alaska Native Females

The CLF participation rate for Females was 48.14%. DTRA’s overall Females FY18 participation 

rate was (34.51%) below the CLF. Hispanic participation rate (2.64%) were well below the CLF 

(9.96%), White Females (20.37%) are still below of the CLF (34.03%), Native Hawaiian Males are at 

the CLF (0.07%) and American Indian/Native Males and Females (0.22%) were below their 

respective CLF (1.08%). DTRA’s Male participation rate decreased slightly from 66.57% in FY17 to 

65.49% in FY18 and remained above the CLF (51.84%). 

The chart below identifies the Agency’s Females:

FY15 FY16 FY17 FY18

2010 

CLF

# % # % # % # % %

FEMALES 474 36.83 414 36.41 448 33.43 471 34.51 48.16
91

Hispanic participation rates slightly decrease from 2.91% in FY17 to 2.64% in FY18, well below the 

CLF of 9.96%. 

The chart below identifies the trend of low participation for Hispanics:

FY15 FY16 FY17 FY18 2010 

CLF

# % # % # % # % %

HISPANIC 

MALES 23 1.79 18 1.58 20 1.49 19 1.39 5.17

HISPANIC 

FEMALES

21 1.63 18 1.58 19 1.42 17 1.25 4.79

DTRA Directorates

DIR– Office of the Director

The Office of the Director, which includes the Command Group, the Chief of Staff, and the 

Staff Offices, makes up 5.27 % of the Agency’s civilian workforce; 43.06% were Male and 

56.94% were Female. Race/National Origins were represented in DIR with the exception of 

Native Hawaiian/Other Pacific Islander (0.00%). There is a low participation rate of Hispanic 

1.39%, and there were no Asian, and American Indian or Native American in DIR. 

There were 9 PWD and one PWTD in DIR.

HR - Human Resources Directorate

• The HR Directorate makes up 5.27% of the Agency’s civilian workforce; 28.89% were 

Male and 71.11% were Female. 

• Hispanics had a low participation rate of 2.22%. There were no Native Hawaiians and 

American Indian or Native in the HR Directorate all at 0.00%. 

• There were six PWD and one PWTD with a 2.22% participant rate in the HR Directorate.

NE-Nuclear Enterprise Support Directorate

• The NE Directorate makes up 8.13% of the Agency’s civilian workforce; 85.59% were 

Male and 14.41% were Female. 

• Hispanics had a low participation rate of 3.60%. There were no Native Hawaiians and 

American Indian or Native American in NE Directorate. Asian low participation rate was 

at 2.70%. 

• There were 20 PWDs and 3 PWTDs with a 2.70.91% participant rate in the NE 

Directorate.

PP – Plans and Programs Directorate

• The PP Directorate makes up 20.07% of the Agency’s civilian workforce; 48.91% were 

Male and 51.09% were Female. 

• The following categories have low participation rates: Hispanics at 2.19%, White 

Females at 27.37%, and Blacks at 18.61%, Asians at 5.83%, and Native Hawaiians or 

Other Pacific Islanders at 0.73%. There were no American Indians or Natives American. 

• There were 31 PWDs and two PWTDs with a 0.74% participation rate in the PP 

Directorate. 
92

AL - Acquisition, Finance & Logistics Directorate 

• The AL Directorate makes up 10.99% of the Agency’s civilian workforce, 50.67% were 

Male and 49.33% were Female.

• Hispanic participation rate was low at 4.40%. There is no Male Native Hawaiians or 

Other Pacific Islanders and American Indian or Native Americans in this Directorate. 

• There were 22 PWDs and no PWTDs within the AL Directorate. 

IT- Information Integration & Technology Services Directorate 

• The IT Directorate makes up 5.64% of the Agency’s civilian workforce, 64.94% were 

Male and 35.06% were Female. 

• Hispanic had a low participation rate of 5.20%. There were no Native Hawaiians or Other 

Pacific Islanders or American Indian or Native American in this Directorate. 

• There were 11 PWDs and no PWTDs within the IT Directorate. 

RD - Research and Development Directorate

• The RD Directorate makes up 17.88% of the Agency’s civilian workforce, 75.41% were 

Male and 24.59% were Female. 

• White Female participation rate was low at 17.21%. Hispanics had a low participation 

rate of 1.64%. Black or African American had a low participation rate of 6.15%. There 

was no Male nor Female Native Hawaiians or Other Pacific Islanders.

• There was one PWTD with a 0.41% participant rate, in the RD Directorate

JD-Joint Improvised-Threat Defeat Directorate

• The JD Directorate makes up 12.89% of the Agency’s civilian workforce, 80.68% were 

Male and 19.32% were Female.

• Hispanics participation rate was low at 2.27%. Asians had a low participation rate of 

1.70% 

• There were 27 PWDs and five PWTDs with a 2.86% participant rate, in the JD 

Directorate

CT-Cooperative Threat Reduction Directorate

• The CT Directorate makes up 5.35% of the Agency’s civilian workforce, 72.60% were 

Male and 27.40% were Female.

• Hispanics, Native Hawaiian or Other Pacific Islander, American Indian or Alaska Native 

and Two or more races participation rate was low at 0.00%. Asians had a low 

participation rate of 1.37% for both Male and Female

• There were 7 PWDs and zero PWTDs with a 0.00% participant rate, in the CT Directorate

CZ-Combat Support Directorate

• The CZ Directorate makes up 1.90% of the Agency’s civilian workforce, 88.46% were 

Male and 11.54% were Female.

• Hispanics, Native Hawaiian or Other Pacific Islander and American Indian or Alaska 

Native participation rate was low at 0.00%. Asians had a low participation rate of 3.85% 

• There were five PWDs and one PWTDs with a 3.85% participant rate, in the CZ 

Directorate
93

OB-On-Site Inspection and Building Capacity Directorate 

• The OB Directorate makes up 8.57% of the Agency’s civilian workforce, 79.49% were 

Male and 20.51% were Female.

• Native Hawaiian or Other Pacific Islander, American Indian or Alaska Native and 

Hispanics Female participation rate was low at 0.00%. Hispanics Male and Asians 

participation rate was low at 5.13 and 2.56%. 

• There were 17 PWDs and one PWTDs with a 0.85% participant rate, in the OB 

Directorate.

The following table identifies DTRA’s Civilian Workforce by Race/National Origin:

DIR HR NE PP OB

# % # % # % # % # %

HM 0 0.00 0 0.00 2 1.80 2 0.73 6 5.13

HF 1 1.39 1 2.22 2 1.80 4 1.46 0 0.00

WM 22 30.56 7 15.56 69 62.16 104 37.96 71 60.68

WF 24 33.33 12 26.67 10 9.01 75 27.37 14 11.97

BM 7 9.72 5 11.11 14 12.61 14 5.11 13 11.11

BF 13 18.06 13 28.89 1 0.90 37 13.50 8 6.84

AM 0 0.00 0 0.00 2 1.80 5 1.82 2 1.71

AF 0 0.00 1 2.22 1 0.90 11 4.01 1 0.85

NH/PI M 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00

NH/PI F 0 0.00 0 0.00 0 0.00 2 0.73 0 0.00

AI/AN M 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00

AI/AN F 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00

TWO OR 

MORE RACES 

MALES

2 2.78 1 2.22 8 7.21 9 3.28 1 0.85

TWO OR

MORE RACES 

FEMALES

3 4.17 5 11.11 2 1.80 11 4.01 1 0.85

TOTAL 72 100 45 100 111 100 274 100 117 100

PWTDs 1 1.49 1 2.27 3 2.70 2 0.74 1 0.85
94

The following table identifies DTRA’s Civilian Workforce by Race/National Origin (Cont’d):

Major Occupations

The Agency monitored eight major occupations based on their relationship to the DTRA missions 

and population size – Security, Social Science, Miscellaneous Administration, Management Program 

Analyst, Contracting, Physical Science, Engineering, and Information Technology Management. The 

following are snapshots of these major occupations and identified potential trigger points for barrier 

analysis and action planning.

Security 

• The participation rate for Females in this major occupation was 33.87% compared to the 

Occupational Civilian Labor Force (OCLF) of 77.20%.

• Black Females had low participation rates at 9.68% compared to their OCLF of 27.20%. 

• There were 8 (12.50%) PWDs and one (1.56%) PWTDs in this major occupation. 

CT CZ AL IT RD JD

# % # % # % # % # % # %

HM 0 0.00 0 0.00 2 1.33 2 2.60 2 0.82 3 1.70

HF 0 0.00 0 0.00 4 2.67 2 2.60 2 0.82 1 0.57

WM 43 58.90 16 61.54 43 28.67 36 46.75 147 60.25 111 63.07

WF 18 24.66 1 3.85 44 29.33 15 19.48 42 17.21 23 13.07

BM 9 12.33 4 15.38 24 16.00 7 9.09 5 2.05 16 9.09

BF 1 1.37 1 3.85 18 12.00 6 7.79 10 4.10 5 2.84

AM 1 1.37 1 3.85 3 2.00 2 2.60 16 6.56 3 1.70

AF 1 1.37 0 0.00 3 2.00 3 3.90 5 2.05 0 0.00

NH/PI M 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 1 0.57

NH/PI F 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 1 0.57

AI/AN M 0 0.00 0 0.00 0 0.00 0 0.00 2 0.00 1 0.57

AI/AN F 0 0.00 0 0.00 1 0.67 0 0.00 0 0.00 0 0.00

TWO OR 

MORE 

RACES 

MALES

0 0.00 2 7.69 4 2.67 3 3.90 12 4.92 7 3.98

TWO OR

MORE 

RACES 

FEMALES

0 0.00 0 0.00 1 0.67 0 0.00 1 0.41 4 2.27

TOTAL 73 100 26 100 150 100 77 100 244 100 176 100

PWTDs 0 0.00 1 3.85 0 0.00 0 0 2 0.84 5 2.86
95

Social Science 

• The participation rate for Females in this major occupation was 21.70% compared to the 

OCLF of 51.60%. The participation rate for Males in this major occupation was 78.30%, 

above the OCLF of 48.30%.

• White and Black Females fall below their OCLF with a participation rate of 16.98% for 

White Females compared to their OCLF of 34.03% and 0.94% for Black Females compared 

to 6.53%.

• There were 8 (8.51%) PWDs and two (2.13%) PWTDs in this major occupation. 

Misc. Administration 

• The participation rate for Females in this major occupation was 21.58% compared to the 

OCLF of 24.50 %. The participation rate for Males in this occupation is 78.42%, above the 

OCLF of 74.50%.

• Hispanic Females fall below their respective OCLF with a participation rate of 00% for 

Hispanic Females compared to the OCLF of 7.40% and Asian Females with a low 

participation rate of 1.22% compared to the OCLF of 1.25%. 

• There were 52 PWDs (16.00%) and five (1.54%) PWTDs in this major occupation. 

Management/Program Analyst 

• The participation rate for Males in this occupation was 60.00% compared to the OCLF of 

58.40%. The Female participation rate was 40.0%, below the OCLF of 41.60%

• Hispanic and Asian Males fall below their OCLF with a participation rate of 0.00% for 

Hispanic Males compared to their OCLF of 2.60% and 0.00% for Asian Males compared to 

1.10%. 

• There were 10 (15.38%) PWDs one (1.54%) PWTD in this major occupation. 

Physical Science 

• The participation rate for Females in this major occupation was 20.61% compared to the 

OCLF of 41.60%. The Agency participation rate for Males within this major occupation was 

79.39%, above their respective OCLF of 60.90%.

• White and Black Females fall below their OCLF with a participation rate of 15.27% for 

White Females compared to their OCLF of 32.60% and 2.29% for Black Females compared 

to 6.53%. 

• There were two (1.60%) PWTDs in this major occupation. 

Contracting

• The participation rate for Females in this major occupation was 62.20% compared to the 

OCLF of 48.16%. The Agency participation rate for Males in this same major occupation 

was 37.80%, below their respective OCLF of 85.50%.

• Hispanic and Black Females was above their OCLF with a participation rate of 2.44% for 

Hispanic Females compared to their OCLF of 0.00% and 12.20% for Black Females 

compared to 0.00%. 

• There were 7 (8.43%) PWDs no PWTDs in this major occupation. 
96

Engineering (0800)

• The participation rate for Females in this major occupation was 16.00% compared to the 

OCLF +

• Specifically, Black Females fall below their respective OCLF with a participation rate of 

0.00% compared to 0.6.53%, Asian Females at 1.33% compared to 1.93%. 

• There were 5 (13.89%) PWDs one (1.33%) PWTD in this major occupation. 

Information Technology Management 

• The participation rate for Females in this major occupation was 26.25% compared to the 

OCLF of 48.16%. The participation rate for Males in this same major occupation was 

73.75%, above their respective OCLF of 51.84%.

• Specifically, Hispanic Males fall below their respective OCLF with a participation rate of 

5.00% compared to 5.49%, Black Males at 6.25% compared to 5.19%. 

• There were 7 (8.43%) PWDs and no PWTD in this major occupation. 

Participation for General Schedule Grades

• The majority of employees, 65.63%, were in Grades 11 through 15. 

• Males have a higher participation rate in Grades, 11 through 15, with a participation rate of 

62.16% as compared to Females in the same grades with a participation rate of 37.84%, with 

the most significant participation rate in Grade 15 with Males at 78.64% and Females at 

21.43%

• Whites have a higher participation rate in Grades 11 through 15, with a participation rate of 

69.19.%, Hispanics at 2.67%, Blacks at 17.07%, Asians at 4.53%, Native Hawaiians or Other 

Pacific Islanders at 0.29% and American Indians or Alaska Natives at 0.29%.

• There were no PWDs or PWTDs in Grades 11 through 15. 

Applicant Flow Data 

• In FY18, EO received access to USA Staffing data and have been able to receive Applicant 

“Flow” Data (Race and National Origin (RNO)) from DLA, Human Resources Center (DLAHRC). The Agency acquired access to the applicant flow data directly from the OPM’s USA 

Staffing Manager system and no longer receives data from DLA-HRC and will continue 

analysis in FY19.

New Hires (From Table A-8)

• 168 new civilian employees joined the Agency during FY18 either by external hiring, 

transfer, or reinstatement actions. Overall, Females accounted for a lower number than males 

(45.83% for Females compared to 54.17% for Males). 91 Males and 77 Females were added 

to DTRA’s permanent workforce; and 9 Males and 18 Females were added to the temporary 

numbers. White males were hired at a rate of 41.67%. 13 Black females were hired a rate of 

7.74%. There was 12 (6.19%) PWDs and 5 (4.01%) PWTDs hired in FY18. 
97

The chart below identifies hires in FY18

FY18

Permanent 2010 CLF Temporary

# % %

MALES 91 54.17 9 33.33 51.84

FEMALES 77 45.83 18 66.67 48.16

HM 1 0.60 0 0.00 5.17

HF 0 0.00 0 0.00 4.79

WM 70 41.67 7 25.93 38.33

WF 50 29.76. 13 48.15 34.03

BM 9 5.36 0 0.00 5.49

BF 13 7.74 3 11.11 6.53

AM 5 2.98 0 0.00 1.97

AF 7 4.17 1 3.70 1.93

NH/PI M 0 0.00 0 0.00 0.07

NH/PI F 0 0.00 0 0.00 0.07

AI/AN M 0 0.00 0 0.00 0.55

AI/AN F 0 0.00 0 0.00 0.53

TWO OR MORE RACES 

MALES 6 3.57 2 7.41 0.26

Non-Competitive Promotions – Time in Grade in Excess of the Minimum

No data was available to analyze this category.

Internal Selections for Senior Level Positions (GS-13 and -14, GS-15 and SES) 

No data was available to analyze this category.

Participation in Career Development 

The data below reflects the 125 employees who participated in the Agency’s Competitive 

Professional Development and Mentoring Programs as follows: 

• In grades GS-5 through GS-12, 12. Of the 12, 6 were female and 6 were male; 9 were 

White, 1 were Black and 2 were two or more races. 

• In grades GS-13&14, 30 of the 30, 11 were female, 19 were male; 21 were White, 1 were 

Hispanic, 7 were Black, 1 were Asian. 

• In grades GS-15 and SES, 4. Of the 4, 1 were female, 3 were male, 4 were White. There 

were no PWTD.

Employee Recognition and Awards 

• During FY18, 74 employees received Time-Off Awards of 1 to 9 hours; 47.30% were Male 

and 52.70% were Female (which is above their population rate). There was 1 Female 

Native Hawaiians/Other Pacific Islanders 1.35% and 1 Native Indians or Native Americans 

1.35% given awards in this category. There were 8 (23.54%) PWDs and one (2.94%)

PWTDs who received awards in this category.
98

• 1,138 employees received Time-Off Awards of 9+ hours; 64.15 % were Male and 35.85 

were Female. Awards in this category were given across the board to all groups.

• 538 incentive cash awards in amounts ranging from $100 to $500 were given to employees. 

Of those, 60.59% were Male and 39.41% were Female. Whites received the majority of the 

awards in this category with a percentage of 68.33%. Awards in this category were given 

across the board to all groups. There were 37 (14.40%) PWDs and two (0.78%) PWTDs

who received awards in this category.

• 210 incentive cash awards in the amounts of $501+ were given to employees. Of those, 

Males received a higher percentage of the awards at a rate of 68.10% compared to their 

population of 65.49%. Females received this award at a rate of 31.90% compared to their 

population of 34.51%. Hispanic received awards in this category at a lower rate of 0.81% 

compared to their population of 2.64% and Asian received awards in this category at a rate 

of 3.33% compared to their population of 4.46%, and Blacks received awards at a rate of 

11.43% compared to their population of 16.92%. There were 14 (15.05%) PWDs and three 

(3/23%) PWTDs who received awards in this category. 

• There were 67 Quality Step Increases (QSIs) given in FY18 based on the FY17 

performance cycle. Of those, 61.19% were Males and 39.29% were Females. There were 

no Native Hawaiians/Other Pacific Islanders and Native Indians or Native American given 

awards in this category. There were 8 (11.94%) PWDs and two (2.99%) PWTDs who 

received awards in this category.

Separations

• 146 employees separated from the Agency during FY18. Women separated at a rate of 

36.30%, while they represented only 34.51% of the overall DTRA population. Of the 146 

total separations, 142 were voluntary. There were 4 involuntary separations, 2 White 

Males, 1 Black Male and 1 two or more races Male. There were 29 PWDs and three

PWTDs who separated from the Agency.
99

The chart below identifies the Agency’s voluntary and involuntary separations.

Voluntary Involuntary

Agency 

Work

Force

# % # % %

MALE 89 62.68 4 100.00 66.57

FEMALE 53 37.32 0 0.00 33.43

HM 1 0.70 0 0.00 1.49

HF 2 1.41 0 00.00 1.42

WM 74 52.11 2 50.00 50.52

WF 27 19.01 0 0.00 18.88

BM 8 5.63 1 25.00 8.66

BF 13 9.15 0 0.00 8.66

AM 2 1.41 0 0.00 2.31

AF 5 3.52 0 0.00 1.87

NH/PI M 0 0.00 0 0.00 0.07

NH/PI F 0 0.00 0 0.00 0.22

AI/AN M 0 0.00 0 0.00 0.22

AI/AN F 0 0.00 0 0.00 0.15

TWO OR MORE RACES MALES 4 2.82 1 25.00 3.28

TWO OR MORE RACES FEMALES 6 4.23 0 0.00 2.24
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SECTION II - APPENDICES

Appendix A: MD 715 Definitions and EEO Authorities

Appendix B: DTRA Organization Chart

Appendix C: Policy Statements

Appendix D: Federal EEO Statistical Report of Discrimination Complaints (EEOC Form 462)

Appendix E: Reasonable Accommodation

Appendix F: IWDs Working Group Recommendations
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MD-715 Definitions and EEO Authorities

The following definitions apply to MD 715: 

• Applicant: A person who applies for employment. 

• Applicant Flow Data: Information reflecting characteristics of the pool of individuals applying 

for an employment opportunity. 

• Barrier: An agency policy, principle, practice or condition that limits or tends to limit 

employment opportunities for members of a particular gender, race or ethnic background or for 

an individual (or individuals) based on disability status. 

• Disability: For the purpose of statistics, recruitment, and targeted goals, the number of 

employees in the workforce who have indicated having a disability on an Office of Personnel 

Management Standard Form (SF) 256. For all other purposes, the definition contained in 29 

C.F.R. § 1630.2 applies. 

• Civilian Labor Force: Persons 16 years of age and over, except those in the armed forces, who 

are employed or are unemployed and seeking work. 

• EEO Groups: Members of groups protected under Title VII of the Civil Rights Act and other 

Federal guidelines. Includes: White Men, White Women, Black Men, Black Women, Hispanic 

Men, Hispanic Women, Asian Men, Asian Women, Native American Men, Native American 

Women, and Persons with Disabilities. 

• Employees: Members of the agency's permanent or temporary work force, whether full or parttime and whether in competitive or excepted service positions. 

• Employment Decision: Any decision affecting the terms and conditions of an individual's 

employment, including but not limited to hiring, promotion, demotion, disciplinary action and 

termination. 

• Feeder Group or Pool: Occupational group(s) from which selections to a particular job are 

typically made. 

• Federal Categories (Fed9): EEOC is requiring agencies to report their workforce data by 

aggregating it into nine employment categories. These categories are more consistent with those 

EEOC uses in private sector enforcement and will permit better analysis of trends in the federal 

workplace than previous categories used. The Commission has created a Census/OPM 

Occupation Cross-Classification Table by OPM Occupational Code (crosswalk) which assists 

agencies in determining the category in which to place a position through use of the position's 

OPM or SOC codes or the OPM or Census Occupation Title. The crosswalk may be accessed at 

the Commission's website: http://www.eeoc.gov/federal/715instruct/00-09opmcode.html. This 

crosswalk is intended as general guidance in cross-classifying OPM occupational codes to the 

EEO nine categories. Agencies are encouraged to contact EEOC with specific questions about 

what category might be appropriate for their particular occupations.
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The nine job category titles are: 

• Officials and Manager - Occupations requiring administrative and managerial personnel who set 

broad policies, exercise overall responsibility for execution of these policies, and direct individual 

offices, programs, divisions or other units or special phases of an agency's operations. In the 

federal sector, this category is further broken out into four sub-categories: (1) Executive/SeniorLevel, (2) Mid-Level, (3) First-Level and (4) Other. When an employee is classified as a 

supervisor or manager, that employee should be placed in the Officials and Managers category 

rather than in the category in the crosswalk that they would otherwise be placed in based on their 

OPM occupational code. Those employees classified as supervisors or managers who are at the 

GS-12 level or below should be placed in the First-Level sub-category of Officials and Managers, 

those at the GS-13 or 14 should be in the Mid-Level sub-category and those at GS-15 or in the 

SES should be in the Executive/Senior-Level sub-category. An agency may also choose to place 

employees who have significant policy-making responsibilities, but do not supervise other 

employees, in these three sub-categories. The fourth sub-category, called "Other” contains 

employees in a number of different occupations which are primarily business, financial and 

administrative in nature, and do not have supervisory or significant policy responsibilities. For 

example, Administrative Officers (OPM Code 0341) are appropriately placed in the "Other” subcategory. 

• Professionals - Occupations requiring either college graduation or experience of such kind and 

amount as to provide a comparable background. Includes: accountants and auditors, airplane 

pilots and navigators, architects, artists, chemists, designers, dietitians, editors, engineers, 

lawyers, librarians, mathematicians, natural scientists, registered professional nurses, personnel 

and labor relations specialists, physical scientists, physicians, social scientists, teachers, 

surveyors, and kindred workers.

• Technicians - Occupations requiring a combination of basic scientific knowledge and manual 

skill which can be obtained through two years of post-high school education, such as is offered in 

many technical institutes and junior colleges, or through equivalent on-the-job training. Includes: 

computer programmers, drafters, engineering aides, junior engineers, mathematical aides, 

licensed, practical or vocational nurses, photographers, radio operators, scientific assistants, 

technical illustrators, technicians (medical, dental, electronic, physical science), and kindred 

workers. 

• Sales - Occupations engaging wholly or primarily in direct selling. Includes: advertising agents 

and sales workers, insurance agents and brokers, real estate agents and brokers, stock and bond 

sales workers, demonstrators, sales workers and sales clerks, grocery clerks, and 

cashiers/checkers, and kindred workers.

• Administrative Support Workers - Includes all clerical-type work regardless of level of 

difficulty, where the activities are predominantly non-manual though some manual work not 

directly involved with altering or transporting the products is included. Includes: bookkeepers, 

collectors (bills and accounts), messengers and office helpers, office machine operators 

(including computer), shipping and receiving clerks, stenographers, typists and secretaries, 

telegraph and telephone operators, legal assistants, and kindred workers. 
105

• Craft Workers (skilled) - Manual workers of relatively high skill level having a thorough and 

comprehensive knowledge of the processes involved in their work. Exercise considerable 

independent judgment and usually receive an extensive period of training. Includes: the building 

trades, hourly paid supervisors and lead operators who are not members of management, 

mechanics and repairers, skilled machining occupations, compositors and typesetters, electricians, 

engravers, painters (construction and maintenance), motion picture projectionists, pattern and 

model makers, stationary engineers, tailors, arts occupations, hand painters, coaters, bakers, 

decorating occupations, and kindred workers. 

• Operatives (semi-skilled) - Workers who operate machine or processing equipment or perform 

other factory-type duties of intermediate skill level which can be mastered in a few weeks and 

require only limited training. Includes: apprentices (auto mechanics, plumbers, bricklayers, 

carpenters, electricians, machinists, mechanics, building trades, metalworking trades, printing 

trades, etc.), operatives, attendants (auto service and parking), blasters, chauffeurs, delivery 

workers, sewers and stitchers, dryers, furnace workers, heaters, laundry and dry cleaning 

operatives, milliners, mine operatives and laborers, motor operators, oilers and greasers (except 

auto), painters (manufactured articles), photographic process workers, truck and tractor drivers, 

knitting, looping, taping and weaving machine operators, welders and flame cutters, electrical and 

electronic equipment assemblers, butchers and meat cutters, inspectors, testers and graders, hand 

packers and packagers, and kindred workers. 

• Laborers (unskilled) - Workers in manual occupations which generally require no special 

training who perform elementary duties that may be learned in a few days and require the 

application of little or no independent judgment. Includes: garage laborers, car washers and 

greasers, grounds keepers and gardeners, farm workers, stevedores, wood choppers, laborers 

performing lifting, digging, mixing, loading and pulling operations, and kindred workers. 

• Service workers - Workers in both protective and non-protective service occupations. Includes: 

attendants (hospital and other institutions, professional and personal service, including nurse’s 

aides, and orderlies), barbers, char workers and cleaners, cooks, counter and fountain workers, 

elevator operators, firefighters and fire protection, guards, door-keepers, stewards, janitors, police 

officers and detectives, porters, waiters and waitresses, amusement and recreation facilities 

attendants, guides, ushers, public transportation attendants, and kindred workers.

Fiscal Year: The period from October 1 of one year to September 30 of the following year.

Goal: Under the Rehabilitation Act, an identifiable objective set by an agency to address or 

eliminate barriers to equal employment opportunity or to address the lingering effects of past

discrimination. 

Major Occupations: Agency occupations that are mission related and heavily populated, relative to 

other occupations within the agency. 

Onsite Program Review: Visit by EEOC representatives to an agency to evaluate the agency's 

compliance with the terms of this Directive and/or to provide technical assistance.
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Reasonable Accommodation (RA): Generally, any modification or adjustment to the work 

environment, or to the manner or circumstances under which work is customarily performed, that 

enables an individual with a disability to perform the essential functions of a position or enjoy equal 

benefits and privileges of employment as are enjoyed by similarly situated individuals without a 

disability. For a more complete definition, see 29 C.F.R. § 1630.2(o). See also, EEOC's Enforcement 

Guidance on Reasonable Accommodation and Undue Hardship under the Americans with 

Disabilities Act, No. 915.002 (October 17, 2002). 

Relevant Labor Force: The source from which an agency draws or recruits applicants for 

employment or an internal selection such as a promotion. 

Section 501 Program: The affirmative program plan that each agency is required to maintain under 

Section 501 of the Rehabilitation Act to provide individuals with disabilities adequate hiring, 

placement, and advancement opportunities. 

Section 717 Program: The affirmative program of equal employment opportunity that each agency 

is required to maintain for all employees and applicants for employment under Section 717 of Title 

VII. 

Selection Procedure: Any employment policy or practice that is used as a basis for an employment 

decision. 

Special Recruitment Program: A program designed to monitor recruitment of, and track 

applications from, persons with targeted disabilities. 

Targeted Disabilities: Disabilities that the Federal Government, as a matter of policy, has identified 

for special emphasis in affirmative action programs. They are: 1) deafness; 2) blindness; 3) missing 

extremities; 4) partial paralysis; 5) complete paralysis; 6) convulsive disorders; 7) mental retardation; 

8) mental illness; and 9) distortion of limb and/or spine. 

Technical Assistance: Training, assistance or guidance provided by the EEOC in writing, over the 

telephone or in person. 

Under representation: Result of conditions in which the representation of EO groups is lower than 

expected. 
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DTRA Organizational Chart

December 7, 2018
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122

Defense Threat Reduction Agency

Reasonable Accommodation 

Program

DESK REFERENCE GUIDE

Issued November 2018

HUMAN RESOURCES DIRECTORATE
123

Reasonable Accommodation

TABLE OF CONTENTS

INTRODUCTION..........................................................................................................................2

REFERENCES...............................................................................................................................2

DISCUSSION ................................................................................................................................ 3

Program Coverage ........................................................................................................................3

Eligibility ......................................................................................................................................3

Reporting.......................................................................................................................................3

PROCEDURES ............................................................................................................................. 4

Designation of RA coordinator ....................................................................................................4

Requesting RA .............................................................................................................................4

Processing the RA Request for Employees..................................................................................5

Processing the RA Requests for Applicants Seeking Employment .............................................6

Engaging in the Interactive Process .............................................................................................6

Reasonable Accommodation Review Board ...............................................................................7

Requesting and Safeguarding Medical Information.....................................................................7

Timeframes for Processing RA Requests.....................................................................................8

Reassignment ...............................................................................................................................9

Vacant Position Searches .............................................................................................................9

Decision to Grant a RA Request ..................................................................................................9

Decision to Deny a RA Request.................................................................................................10

Tracking and Reporting Requirements.......................................................................................10

Making a Request for PAS.........................................................................................................11

Denying a Request for PAS .......................................................................................................11

Confidentiality Requirements for PAS ......................................................................................12

Reporting Requirements for PAS...............................................................................................12

ACRONYMS ............................................................................................................................... 13

DEFINITIONS ............................................................................................................................ 13

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INTRODUCTION

The Defense Threat Reduction Agency (DTRA) Reasonable Accommodation (RA) program is 

designed to remove any barrier(s) which prevent individuals with disabilities (permanent or 

temporary) who are employees or applicants from applying for or performing jobs for which they 

are qualified. Equally important is to empower individuals with disabilities to maximize 

employment, economic self-sufficiency, and inclusion into society. This guide provides 

procedures for participation in the DTRA RA program.

The information in this guide applies to all civilian employees and applicants seeking 

employment within DTRA and takes precedence over all related internal standard operating 

procedures or guidance.

References

Chapter 126 of Title 42, United States Code (U.S.C.)

Deputy Secretary of Defense Memorandum, “Access for People with Disabilities,” 

October 31, 2008

DoD Manual 8400.01, “Accessibility of Information and communications Technology (ICT),” 

November 14, 2017

DTRA Instruction 1100.2, “Telework Program, August 21, 2013, as amended

DTRA Instruction 5505.3, “Defense Threat Reduction Agency Reasonable Accommodation,” 

December 10, 2007, hereby cancelled

EEOC “ADA Amendments Act of 2008,” September 25, 2008

EEOC “Enforcement Guidance: Reasonable Accommodation and Undue Hardship Under the 

American's with Disabilities Act,” October 17, 2002

EEOC “Questions and Answers: Federal Agencies' Obligation to Provide Personal Assistance 

Services (PAS) under Section 501 of the Rehabilitation Act,” September 18, 2017

Executive Order 13164, “Requiring Federal Agencies to Establish Procedures to Facilitate the 

Provision of Reasonable Accommodation,” July 26, 2000

Public Law 93-112, “Rehabilitation Act of 1973,” as amended

Public Law 110-325, “ADA Amendments Act of 2008,” September 25, 2008 

Section 552a of Title 5, U.S.C.

Sections 701, Section 791, and Section 1630.1(c)(4) of Title 29, U.S.C.

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DISCUSSION

Program Coverage

The DTRA RA program provides modification(s) to the work environment that allows an 

employee to perform the essential functions of his or her position and/or to enjoy equal access to 

benefits and privileges of employment. The DTRA RA program also provides for modification 

to the application process allowing qualified individuals with a disability to apply for positions 

without barriers.

The DTRA RA program complies with United States Equal Employment Opportunity 

Commission (EEOC) regulations and federal law prohibiting federal agencies from 

discriminating against qualified individuals with disabilities. A qualified individual with a 

disability refers to an individual who satisfies the requisite skill, experience, education and other 

job-related requirements of the employment position such individual holds or desires; and who, 

with or without reasonable accommodation, can perform the essential functions of such position. 

Effective January 3, 2018, the EEOC amended Section 501 of the Rehabilitation Act of 1973, 

requiring all federal agencies, to include DTRA, to offer Personal Assistance Services (PAS) to 

assist with daily living activities (i.e., putting on clothing, eating, using the restroom) for 

employees with “targeted disabilities” (i.e., blindness, deafness, spinal cord injury, etc.).

Eligibility

Eligibility to participate in the DTRA RA program is limited to permanent full-time and parttime Federal civilian employees or civilian applicants seeking employment within DTRA.

Military members assigned to DTRA seeking a RA must follow his/her Service specific rules for 

making such a request.

Contractor personnel are not eligible to participate in DTRA’s RA program. Contractors should 

contact his/her employer if he/she feels a RA is needed.

Reporting

The Director, Human Resources Directorate (HR), has overall responsibility for DTRA guidance 

and reporting requirements related to the RA program. HR will compile and maintain RA data to 

evaluate the Agency’s performance in responding to requests for RA, ensure compliance with 

EEOC regulations and federal laws, and submit report(s) to the EEOC, as appropriate.

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PROCEDURES

Designation of RA coordinator

The Director, HR designates a RA coordinator to serve as the program lead. The RA coordinator 

is responsible for reviewing all RA requests for employees and applicants; ensuring 

completeness of RA requests; determining whether an employee or applicant meets the definition 

of a qualified individual with a disability; consulting with Directorates and Staff Offices as 

necessary; and, providing guidance to all parties.

Requesting RA

The RA process begins when employees or applicants with a disability request an adjustment or 

modification to the work environment or application process that will enable the employee or 

applicant to perform the essential functions of their position, to complete the application process, 

and/or to enjoy equal access to benefits and privileges of employment (e.g., Agency sponsored 

events, training).

A request for a RA may be made orally or in writing by an employee or applicant, or the

employee or applicant’s family member, health care professional or authorized representative. 

The individual making the request need only indicate the need for assistance based on a medical 

condition. The use of special words is not required (e.g., “accommodation,” “disability,” or 

“rehabilitation”).

When a request is made by someone other than an employee or applicant, the RA coordinator 

will confirm the request with the employee or applicant. In the event a third party acts as a 

representative for the affected individual, the third party must have written designation 

authorizing him or her to work on the requestor’s behalf.

Types of RA may include, but are not limited to:

• Ensuring facilities used by employees and applicants for employment are readily 

accessible and usable by individuals with disabilities;

• Restructuring jobs and/or modifying work schedules;

• Reassigning current employees to vacant positions;

• Acquiring or modifying equipment or devices;

• Making appropriate modifications to examinations, training materials, or policies; or

• Providing qualified readers or interpreters and/or other similar assistance.

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Processing the RA Request for Employees

A RA request may be submitted in writing or orally to an employee’s supervisor, another 

supervisor in the employee’s chain of command, or to the RA coordinator. The initial RA 

request may be made verbally; however, the RA request must be later documented using DTRA 

Form 123 found in the DTRA1 Forms Library SharePoint site: 

https://dtra1/j6/RFM/DTRA%20Forms%20Libraary/Forms/Forms%20By%20Number.aspx

When a RA request requires review or consultation, the supervisor will ensure the RA request is 

forwarded to the RA coordinator within 7 calendar days of receipt.

If an employee’s need for RA is not obvious or otherwise known, the employee may be asked to 

provide supporting medical documentation. The supervisor will identify the essential functions 

of the employee’s position. The supporting medical documentation will determine what the 

employee can or cannot perform because of the disability. Medical documentation in support of 

a RA request must come from an appropriate healthcare professional and must include sufficient 

information regarding the employee’s medical condition(s) and the functional limitation(s). The 

RA should explain:

• The past, present and expected future nature, severity, and duration of the employee’s 

impairment (e.g. functional limitation, symptoms, side effects of any treatments).

• The on-the-job activity or activities that the impairment limits, and the extent to which 

the impairment limits the employee’s ability to perform the activity or activities.

• The medical basis for any opinion that the employee requires a RA and how the RA will 

assist the employee in the performance of the essential functions of the position.

• Specific limitations associated with each major life activity (i.e., performing 

manual tasks, walking, standing, reaching, sitting, lifting, etc.).

• If teleworking addresses the medical condition sufficiently for the employee to continue 

performing the essential functions of the position, the RA must define the parameters of 

telework. (Note: If the RA request involves “full-time telework,” then the employee 

must complete an additional coordination, requiring approval of the Director, HR, per 

DTRA Instruction 1100.2).

• How the RA will assist in the performance of the essential functions of the position or to 

enjoy equal access to benefits and privileges of employment (e.g., Agency sponsored 

events, training).

Failure on the part of the employee, or the employee’s designee, to cooperate in this process or 

provide sufficient documentation on whether he or she has a disability can result in a denial of 

RA.

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Generally, an employee who has already been determined eligible for a RA will not be required 

to submit a separate written request for each subsequent occasion in which they will need the

same or similar RA. If the RA is needed on a recurring basis, the supervisor will ensure 

arrangements are made without requiring a request in advance of each occasion. A supervisor 

and RA coordinator may reevaluate a RA based on non-permanent conditions and make 

modifications per the medical documentation, as necessary.

If an employee needs PAS, the employee will describe the kind of assistance needed to 

perform activities of daily living for their “targeted disability” and will refer to “Making a 

Request for PAS” section of this Handbook for procedural guidance.

Processing the RA Request for Applicants Seeking Employment

Applicants seeking employment within DTRA may direct their RA request to the RA 

coordinator, designee, or to the individual contacting the applicant for an interview.

RA requests should include the applicant’s name, name of the hiring organization, a description 

of the RA being requested, and a brief description of the reason for the RA request which may be 

documented on the DTRA Form 123.

Engaging in the Interactive Process

An employee is not entitled to the exact RA he/she requests. The RA must allow the requesting 

employee to perform the essential function of his/her position that the employee is no longer able 

to perform. Therefore, once the RA request is made by the employee or applicant, he or she will 

work with the supervisor or hiring manager to identify potential RAs and explore the various 

options. The supervisor will engage the RA coordinator once the documentation (i.e., supporting 

medical documentation, DTRA Form 123, DTRA Form 259, Request for RA, description of RA 

for applicants, etc.) is gathered.

The requester, RA coordinator, supervisor or hiring manager will collaborate throughout the 

process. Failure on the part of the requester to cooperate in the interactive process can result in a 

denial of the RA request. Failure on the part of supervisor to participate in the interactive 

process may potentially result in Agency liability.

The RA coordinator advises the supervisor and/or hiring manager; however, the 

supervisor makes the final decision on the RA for an employee and the hiring manager 

provides written communication to the applicant on his/her RA decision. Depending on the 

nature of the RA request, the RA coordinator, will consult with the Office of the General 

Counsel, DTRA’s Senior Medical Officer, and/or other Directorates and Staff Offices, as needed, 

to execute RAs. The RA coordinator will collaborate with the supervisor or hiring manager to 

promptly, effectively, and reasonably to accommodate a qualified employee with a disability. In 

extenuating circumstances, clearly visible or known disabilities will be evaluated expeditiously 

and given priority.

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Reasonable Accommodation Review Board

The employee who is denied an RA, or is not given the RA he/she requests, may choose 

to appeal the decision to the Reasonable Accommodation Review Board (RARB).

Since each RA is unique and often requires guidance from various Directorates and Staff 

Offices, RARB members include, but is not limited to:

• Chief, Management and Employee Relations Division;

• RA Coordinator;

• Senior Medical Officer; and

• The Office of the General Counsel.

The Chief, Management and Employee Relations Division serves as the RARB chair and 

will determine if ad hoc membership is required.

Requesting and Safeguarding Medical Information

The RA coordinator may request additional medical information if the medical documentation 

does not clearly explain the nature of the disability, the need for RA, or how the RA will assist 

the employee in performing the essential functions of the job, enjoying the privileges of the 

workplace, or assisting an applicant with the application process. The RA coordinator may ask 

the employee, or employee’s designee, to provide medical documentation in support of a RA.

If the RA coordinator needs additional medical information in order to process a RA request, the 

RA coordinator must provide the employee or applicant with a written explanation of why the 

submitted medical documentation is insufficient and a description of what is needed.

At a minimum, acceptable medical documentation must establish the nature of the medical 

condition, the limitations the medical condition imposes, and the causal connection between the 

medical condition and the inability to meet workplace expectations.

When additional medical documentation is needed, the RA coordinator can allow the individual 

an opportunity to provide the information from their personal healthcare professional. The RA 

coordinator may ask the individual to sign a limited release and then either submit a list of 

specific questions to the individual’s health care professional or have DTRA’s Senior Medical 

Officer contact the individual’s healthcare professional. If this does not result in sufficient 

information, the Agency may require the individual to submit to an independent medical 

examination by a healthcare professional of the Agency’s choice and at the Agency’s expense.

Individuals should respond to requests for medical documentation within 15 calendar days after 

receipt of the RA request. An additional 15 calendar days may be granted for extenuating 

circumstances.

All medical information obtained in connection with the RA process must be kept confidential, 

must not be shared with others unless on a need-to-know basis, and must be appropriately

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protected from unlawful disclosure. Any employee who obtains or receives such information is 

strictly bound by these confidentiality requirements. Restrictions apply to information and 

documents. The only circumstances under which medical information may be disclosed are:

• Providing identification of an employee’s functional limitations and what RAs have been 

approved to those who have a need-to-know;

• Providing pertinent information to first aid and emergency personnel if the 

impaired individual requires emergency treatment; or

• Providing investigative services to ensure DTRA is in compliance with EEOC

regulations.

Medical information or documentation of an employee’s impairment, disability, or RA, must be 

kept in a separate file from normal personnel records and be properly secured when not in use by 

the authorized parties. Records pertaining to RA requests are maintained for a period of 3 years. 

If the RA is needed on a recurring basis, then the RA records will be maintained for as long as 

the case is active.

Timeframes for Processing RA Requests

Responses to RA requests for information will be provided by the RA coordinator, as soon as 

possible, absent extenuating circumstances, not later than 15 calendar days after receipt.

Absent extenuating circumstances, requests for RA will be processed and a decision on the 

request will be provided within 30 calendar days of receiving all requested information. If there 

is a delay in issuing a written determination, the individual requesting RA must be issued written 

notification of the reasons for the delay.

If a request for a RA can be processed without supporting medical information, and there are no 

other extenuating circumstances, determinations will be made within 30 calendar days from the 

date the request is received. When extenuating circumstances are present, such as failure to 

provide requested medical information or the information specified, or where independent 

medical review is necessary, the time for processing a RA request will be extended as reasonably 

necessary. If the delay exceeds 45 calendar days from the date of the employee’s initial request, 

he or she will be notified in writing. Unnecessary delays may result in Agency liability and can 

also result in a violation of the Americans with Disabilities Act (ADA).

If the RA cannot be provided immediately, the supervisor, in coordination with the RA 

coordinator, should inform the requester in writing of the projected timeframe for providing the 

RA. Temporary measures must be explored when there may be a delay in processing a request 

or implementing a RA. If a temporary accommodation is provided, the employee must be 

informed the accommodation is being provided only on a temporary, interim basis.

In special circumstances expedited processing of a RA request may be required. Examples 

include when the RA is needed to enable an individual to apply for a job, to participate in a 

specific activity that is scheduled to occur on a specified date, or in cases involving safety issues.

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Reassignment

Reassignment to a vacant position is a potential RA. In general, reassignment should be 

considered as a “last resort,” only when RA within the individual's current position is not 

possible, or would pose an undue hardship to the Agency. Reassignment is not available to 

applicants. In accordance with EEOC regulatory guidance, reassignment will be considered for 

an employee when:

• The employee, because of a disability, can no longer perform the essential functions of 

the position he or she holds, with or without RA.

• There is no available RA that would enable the employee to perform the essential 

functions of the position or if the only effective accommodation would cause undue 

hardship to the Agency.

• There is a vacant position for which the employee is qualified. The vacant position must 

be equivalent to the employee’s current position in terms of pay, grade, benefits, 

geographical location, etc., unless the employee consents to being placed in a lower 

graded position and/or placed in a different geographical location.

Vacant Position Searches

Searches for vacant positions will be handled by the RA coordinator in coordination with the HR 

Services Division. The search will include positions that are anticipated to be vacant within 60 

calendar days of the initial request for a RA. This search does not obligate DTRA to wait 60 

calendar days to take appropriate action, only to consider vacancies that have been forecasted 

within 60 calendar days.

Decision to Grant a RA Request

When it is determined that a RA will be provided, the decision will be communicated in writing 

to the requesting individual and his or her authorized representative if one has been identified. 

If the supervisor grants a RA that was not agreed upon during the interactive process, the notice 

should explain the reason(s) for the denial of the requested RA and the reason(s) that he or she 

believes the chosen RA is more effective.

A supervisor is not required to provide the precise RA requested so long as the alternative 

accommodation is effective and does not create an undue hardship to the Agency, per EEOC 

regulations.

The RA coordinator will follow up with the employee or applicant to ensure the effectiveness of 

the RA.

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Decision to Deny a RA Request

When the supervisor, in coordination with the RARB, determines that a RA request will be 

denied, this will be communicated in writing to the requesting individual, and his or her 

authorized representative. The explanation for the denial will be written clearly stating the 

specific reason(s) for the denial. All denial notices will be coordinated with the RARB and sent 

to the requesting individual by the RA coordinator.

The reason(s) for the denial of a RA request may include, but are not limited to, the following:

• The requested accommodation would not be effective and an effective alternate RA 

was not identified.

• The requested accommodation would result in undue hardship and an effective alternate 

RA was not identified.

• The submitted medical documentation does not establish that the individual has 

a disability or needs a RA.

• The requested accommodation would require the removal of an essential function and 

an effective alternate RA was not identified.

• The requested accommodation would require the lowering of a performance 

or production standard and an effective alternate RA was not identified.

• The employee is successfully completing all the essential elements of his/her position and 

is therefore not a “qualified” individual with a disability.

The supervisor, in coordination with the RA coordinator, will provide a written notice of denial 

to inform the individual of his or her right to file an appeal. The individual may file an appeal 

with the RARB. If the individual believes the Americans with Disabilities Act was violated, 

he/she may file a complaint with DTRA’ Equal Opportunity and Diversity Programs Office.

Tracking and Reporting Requirements

The RA coordinator will gather, track, and report:

• The number and types of RAs that have been requested, and whether those requests 

have been granted or denied.

• The jobs, to include occupational series, grade level, position titles, etc., for which 

RAs have been requested.

• The reasons for denial of requests for RA.

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• The amount of time taken to process each RA request.

• The sources of technical assistance that have been consulted in trying to identify 

possible RAs.

Making a Request for Personal Assistance Services (PAS)

An employee may request a PAS by informing a supervisor, the RA coordinator, or other 

suitable representative that he or she needs assistance with daily life activities because of a 

medical condition. The employee does not need to mention Section 501 or EEOC regulations 

explicitly, or use terms such as “PAS” or “affirmative action” to trigger DTRA’s obligation to 

consider the request.

The RA coordinator will work with the employee to define PAS parameters to include:

• The employee’s targeted disability which makes him or her eligible for PAS.

• The type(s) of PAS (i.e., assistance with removing and putting on clothing, eating, using 

the restroom, pushing a wheelchair, etc.) required because of his or her targeted disability 

as defined by the treating health care provider.

• The extent to which PAS is needed for job-related travel, if applicable, but not including 

the commute to and from work, which is not covered under EEOC regulations.

• The extent to which PAS is needed for teleworking, if applicable.

• The extent to which PAS is needed for employer-sponsored trainings and events.

• The extent to which a RA is needed to supplement the PAS, if applicable.

• The employee’s preference to a specific PAS provider, if applicable.

Denying a Request for PAS

DTRA is only required to provide PAS if the requesting employee is entitled under the EEOC’s 

affirmative action ruling. Therefore, DTRA will deny a request for PAS if:

• The requestor is not a DTRA employee;

• The requestor does not have a targeted disability;

• The targeted disability does not create a need for PAS;

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• The requestor is not able to perform the essential functions of the job, even with PAS and 

any RAs;

• The requestor would create a direct threat to safety on the job, even with PAS and any 

RAs; or

• Providing PAS would impose undue hardship on DTRA.

Confidentiality Requirements for PAS

All medical information obtained in connection with PAS requests must be kept confidential 

and appropriately protected from unlawful disclosure. PAS requests must be kept confidential 

and must not be shared with others unless on a need-to-know basis. Any employee who obtains 

or receives such information is strictly bound by these confidentiality requirements per EEOC

regulation and federal laws. The RA coordinator must maintain records for a period of 3 years. 

If the RA is needed on a recurring basis, then the RA records will be maintained for as long as 

the case is active.

Reporting Requirements for PAS

HR will compile and maintain PAS data to evaluate the Agency’s performance in responding to 

requests for PAS, ensure compliance with EEOC regulations and federal laws, and submit 

report(s) to the EEOC, as appropriate.

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ACRONYMS

ADA 

DTRA 

EEOC

Americans with Disabilities Act 

Defense Threat Reduction Agency

United States Equal Employment Opportunity Commission

HR 

PAS 

RA

RARB

Human Resources Directorate 

Personal Assistance Services 

Reasonable Accommodation

Reasonable Accommodation Review Board

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DEFINITIONS

Disability. Per ADA Amendments Act of 2008, the basic definition of "disability" is 

an impairment that substantially limits one or more major life activities, a record of 

such an impairment, or being regarded as having such an impairment.

Essential Functions. The essential functions of a job are those job duties that are so 

fundamental to the position that the individual cannot do the job without being able to perform 

them. A function can be "essential" if, among other things: (a) the position exists specifically 

to perform that function, (b) there are a limited number of other employees who could perform 

the function if it were assigned to them or (c) the function is specialized and the incumbent is 

hired based on his/her ability to perform it.

Individual with a Disability. An individual with a disability is a person who (a) has a 

physical or mental impairment that substantially limits one or more of major life activities; 

(b) has a record of such impairment, or (c) is regarded as having such impairment.

Personal Assistant Services (PAS). PAS means assistance with performing activities of daily 

living that an individual would typically perform if he or she did not have a disability, and that 

is not otherwise required as a reasonable accommodation.

Qualified Individual with a Disability. A qualified individual with a disability is a person who

(a) satisfies the requisite skill, experience, education, and other job-related requirements of 

the position such individual holds or desires and (b) can perform the essential functions of 

the position, with or without reasonable accommodation.

Reasonable Accommodation (RA). RA is a modification or adjustment to a position, the 

work environment, or the application process that enables a qualified individual with a 

disability to attain the same level of performance of the essential duties of the job or to enjoy 

equal benefits and privileges of employment as are available to a similarly situated employee 

without a disability.

Reassignment. Reassignment is a form of RA that, absent undue hardship, is provided to 

employees (not applicants) who, because of a disability, can no longer perform the essential 

functions of the job, with or without RA. Reassignments are made only to vacant positions 

and for employees who are qualified for the new position, when no other RA exists.

Targeted Disabilities. Targeted disabilities are a subset of conditions that would be 

considered disabilities under the Rehabilitation Act. Qualified individuals with certain 

disabilities (e.g., paralysis due to spinal cord injury, blindness, missing limbs) face significant 

barriers to employment, which for some people may include lack of access to PAS in the 

workplace, that are above and beyond the barriers faced by people with the broader range of 

disabilities.

Undue Hardship. Undue hardship generally refers to a specific accommodation that requires 

the DTRA to incur significant difficulty or expense. Determinations are made on a case-bycase basis, considering the nature and cost of the accommodation needed and the impact of the

accommodation on the operations of the DTRA.

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