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# Barrier Analysis: Questions to Guide the Process

Office of Federal Operations Equal Employment Opportunity Commission

January 18, 2017

## Preface

To assist federal agencies in identifying barriers to equal employment opportunities, the Office of Federal Operations (OFO) at the Equal Employment Opportunity Commission (EEOC) has created the following list of questions to guide the barrier analysis process. The goal of barrier analysis under EEOC Management Directive 715 is to identify the root causes of disparities in equal employment opportunities so that federal agencies can take action to remedy the policies, procedures, and practices that lead to such disparities. To assist the Office of Personnel Management's (OPM's) Hispanic Council on Federal Employment, OFO released this version of the Barrier Analysis: Questions to Guide the Process tool for use in agencies' analysis of Hispanics in the senior grade levels (GS-12 to SES), as described in a [date] memorandum jointly issued by OPM and EEOC. OFO plans to convert future versions of these questions to guide the barrier analysis process into a more efficient digital tool for agencies to analyze all triggers in their workforce.

These barrier analysis questions identify five critical phases of the employment life cycle for analysis: 1) Recruitment; 2) Hiring; 3) Training and Development; 4) Promotions; and 5) Separations. OFO designed the questions to analyze disparities in a single occupation; however, they can be used to analyze overall disparities within an agency. Some questions specifically refer to workforce data, such as that reported in MD-715 reports. Others refer to results from the Federal Employee Viewpoint Survey (FEVS). Having such data available is useful when conducting barrier analysis.

## How To Use This Document

OFO does not expect an agency's barrier analysis to answer every question in this document. Rather, we encourage agencies to first identify where in the employment life-cycle statistical disparities exist in their workforces and use the questions relevant to that life-cycle stage to help identify the reason for the statistical disparity. For example, if an employer's statistical analysis of its workforce shows that GS-11 Hispanic men are promoted to GS-13 positions with further promotion potential at a significantly lower rate than other groups, then the agency should refer to the "Promotions" section of this tool to find questions that may help identify the root cause of the disparity.

Just as agencies need not answer every question in this tool, they also are not limited to the questions or issues that it contains when conducting barrier analysis. These questions are not agency specific and will not pinpoint every trigger, or red flag, that indicates a policy, procedure, or practice that may cause inequalities in employment opportunities. Agencies should treat this list as a starting point. Individual agencies should customize and add to these questions as needed in order to fit their unique needs and potential barriers.

## Table of Contents

Preface

How To Use This Document

Recruitment

Preliminary Questions

Applicant Flow Data

Trigger Identification

Alternatives to Numeric Applicant Flow Data

Agency Reputation

Recruitment Plan

Recruitment Process

Job Qualifications

Vacancy Announcements

Application Process

Hiring

Preliminary Questions

Applicant Flow Data

Trigger Identification

Selection Process Accountability

Training the Hiring and Selection Officials

Rating and Ranking Applicants Stage

Interviews and Selection Panels

Selection Factors

Issues Raised About Selections

Training and Development

Preliminary Questions

Individual Development Plans

Needs and Resources for Training and Development

Training and Development Announcements

Application Rates for Training and Development

Selection Procedures for Training and Development

Interviews for Training and Development

Selection Rates for Training and Development

Results of Training and Development Opportunities

Promotions

Preliminary Questions

Applicant Data

Vacancy Announcements

Rating and Ranking Applicants Stage

Interviews and Selection Panels

Selection Factors

Training for the Hiring and Selecting Officials

Promotion Process Accountability

Issues Raised about Promotions

Separations

Preliminary Questions

Data Collection

Trigger Identification

Exit Interviews

Involuntary Separations

Reductions in Force

Disciplinary Removals

Constructive Discharge

Voluntary Separations

Employee Viewpoints and Voluntary Separations

## Recruitment

### Preliminary Questions

                              - 1) What is the name of your agency?
                              - 2) What occupation are you analyzing?
                              - 3) Has the agency filled any positions for this occupation during the last three years?

### Applicant Flow Data

                              - 1) Does the agency collect applicant flow data for this occupation?                                    - a) If yes, go to the  Trigger Identification  sub-section of the  Recruitment  section
                                - b) If no, skip to the  Alternatives to Numeric Applicant Flow Data  sub-section of the  Recruitment  section

### Trigger Identification

                              - 1) Which EEO groups are underrepresented among applicants for this occupation when compared to their availability in the occupational CLF?
                              - 2) Which EEO groups are underrepresented among qualified applicants for this occupation when compared to their availability in the occupational CLF?

### Alternatives to Numeric Applicant Flow Data

                              - 1) Has the agency attempted to learn about the interest of underrepresented EEO groups in this occupation by doing any of the following?                                    - a) Conducting focus groups with potential applicants from underrepresented EEO groups
                                - b) Interviewing applicable affinity groups
                                - c) Meeting with hiring officials
                                - d) Reviewing exit interview results
                              - 2) If so, have any policies, procedures, or practices been identified as possible barriers? Please describe.

### Agency Reputation

                              - 1) Do you currently have FEVS data for your agency, and are they broken down by demographic group?                                    - a) I have FEVS data broken down by demographic groups.                                      - i) Go to Question 2
                                - b) I either do not have FEVS data, or they are not broken down by demographic group                                      - i) Skip to Question 3
                              - 2) Examine your agency's demographic breakdown of responses to the following FEVS questions for the most recent year(s) available. If you see that certain demographic groups respond substantially more negatively than others do, please look into why those demographic groups responded more negatively.                                    - a) "My work unit is able to recruit people with the right skills." [FEVS Q21]
                                - b) "I recommend my organization as a good place to work." [FEVS Q40]
                                - c) "I have a high level of respect for my organization's senior leaders." [FEVS Q61]
                                - d) "How satisfied are you with the policies and practices of your senior leaders?" [FEVS Q66]
                                - e) "Considering everything, how satisfied are you with your job?" [FEVS Q71]
                              - 3) If your agency uses a climate assessment survey other than the FEVS, are any of the questions similar to those in Question 2? If so, please describe any demographic disparities in the results.
                              - 4) Does the agency have a good reputation for diversity among its constituents?

### Recruitment Plan

                              - 1) Does the agency recruit for this occupation?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Job Qualifications  sub-section of the  Recruitment  section.
                              - 2) Does the agency have a recruitment plan (or recruitment schedule) for this occupation?                                    - a) If yes, go to Question 3
                                - b) If no, skip to the  Recruitment Process  sub-section of the  Recruitment  section
                              - 3) Is the same recruitment plan for this occupation used agency-wide?                                    - a) If yes, skip to Question 5
                                - b) If no, go to Question 4
                              - 4) Are there subcomponents/offices that do not use a recruitment plan for this occupation?
                              - 5) Are the triggers for this occupation specific to particular subcomponents/offices?                                    - i) If yes, go to Question 6
                                - ii) If no, skip to Question 7
                              - 6) Do the subcomponents/offices that do not use a recruitment plan for this occupation have more triggers or more severe triggers than other subcomponents/offices?
                              - 7) Are any of the following statements about your recruitment plan true for this occupation?                                    - a) The EEO office participated in the development of this plan.
                                - b) The recruitment plan targets underrepresented EEO groups.
                              - 8) Has the agency established a recruitment goal for underrepresented EEO groups in the recruitment plan?

### Recruitment Process

                              - 1) At which geographic level does the agency target its recruitment efforts for this occupation?                                    - a) National
                                - b) Regional
                                - c) Local
                              - 2) Does the applicant pool for this occupation reflect the labor market from which you recruit?
                              - 3) Does the agency utilize paper recruitment materials (e.g. brochures, flyers) when recruiting for this occupation?
                              - 4) Does the agency utilize the agency website when recruiting for this occupation?
                              - 5) Does the agency utilize recruiters when recruiting for this occupation?

Only answer Questions 6 through 11 if you use paper recruitment materials for this occupation.
                              - 6) Does your agency update the paper recruitment materials for this occupation at least annually?
                              - 7) Are your agency's paper recruitment materials sensitive to different cultural, racial, ethnic, gender, and disability statuses?
                              - 8) Are the HR staff/recruiters/hiring officials aware of the paper recruitment materials?
                              - 9) Do the HR staff/recruiters/hiring officials use the paper recruitment materials?
                              - 10) Has the EEO office reviewed and provided feedback on the recruitment materials?
                              - 11) If so, did the agency implement the EEO office's recommendations?

Only answer Questions 12 through 17 if you use your agency website to recruit for this occupation.
                              - 12) Does your agency update the recruitment section of the website at least annually?
                              - 13) Is the recruitment section of your agency website sensitive to different cultural, racial, ethnic, gender, and disability statuses?
                              - 14) Does the recruitment section of your agency website include a link to the reasonable accommodation procedures?
                              - 15) Does the recruitment section of your agency website have sufficient and accurate information?
                              - 16) Has the EEO office reviewed and provided feedback on the recruitment section?
                              - 17) If so, did the agency implement the EEO office's recommendations?

Only answer Questions 18 through 22 if you use recruiters to recruit for this occupation.
                              - 18) Does your agency train its recruiters on the following?                                    - a) Diversity principles
                                - b) The agency's recruitment goals
                                - c) The agency's hiring principles
                              - 19) Are the recruiters diverse?
                              - 20) Do the recruiters select the type of and location for recruitment activities?
                              - 21) Has the EEO office reviewed and provided feedback on the recruitment activities?
                              - 22) If so, did the agency implement the EEO office's recommendations?

### Job Qualifications

                              - 1) Does the agency review the qualification requirements for this occupation annually to determine whether they are still current and necessary?
                              - 2) Do the selecting officials add additional requirements beyond OPM's description of the occupation?
                              - 3) Does the vacancy announcement for this occupation contain any of the following qualification requirements?                                    - a) Specialized degrees (e.g., Masters, Doctorate, etc.). If so, are they truly necessary to perform the job well?
                                - b) Specialized licenses (e.g., Bar, Accountant, Nursing, etc.). If so, are they truly necessary to perform the job well?
                                - c) Technical qualifications. If so, are they truly necessary to perform the job well?
                                - d) Specialized experience. If so, is it truly necessary to perform the job well?
                                - e) Grade level. If so, is it truly necessary to perform the job well?
                                - f) Any other qualification requirements. If so, are they truly necessary to perform the job well? Please describe these other qualification requirements.

### Vacancy Announcements

                              - 1) Does the agency use USA Jobs to advertise vacancies for this occupation?
                              - 2) Does the agency use specific professional societies and associations to advertise vacancies for this occupation? If so,                                    - a) Does your agency know the demographics of the professional societies and associations through which you advertise vacancies? If so,                                      - i) Think about your workforce-based triggers for this occupation and the demographic make-up of professional societies and organizations through which you advertise vacancies. Are the EEO groups with low participation rates in this occupation well represented in these professional societies and associations?
                                - b) Do any of these societies and associations focus on members of EEO groups with low participation rates in your agency?
                              - 3) Does the agency use specific colleges and universities to advertise vacancies for this occupation? If so,                                    - a) Does the agency know the demographic profile of the students in majors related to this occupation at the colleges and universities through which you advertise vacancies? If so,                                      - i) Think about your workforce-based triggers for this occupation and the demographic make-up of the colleges and universities through which you advertise vacancies. Are the EEO groups with low participation rates in this occupation well represented in these institutions?
                                - b) Are any of the colleges and universities through which you advertise vacancies Historically Black Colleges or Universities (HBCU)?
                                - c) Are any of the colleges and universities through which you advertise vacancies Minority Serving Institutions (MSI)?
                                - d) Are any of the colleges and universities through which you advertise vacancies Historically Deaf Colleges (HDC)?
                              - 4) Does the agency use any specific journals and newspapers to advertise vacancies for this occupation? If so,                                    - a) Does the agency know the demographic profile of the subscribers for the journals and newspapers in which you place vacancy announcements? If so,                                      - i) Think about your workforce-based triggers for this occupation and the demographic make-up of the subscribers for the journals and newspapers in which you advertise vacancies. Are the EEO groups with low participation rates in this occupation well represented among subscribers?
                                - b) Do any of the journals and newspapers in which you advertise vacancies focus on members of underrepresented EEO groups?
                              - 5) Does the agency use social media to advertise vacancies for this occupation? If so,                                    - a) Does the agency know the demographic profile of the users of the social media outlets that you use to advertise vacancies for this occupation? If so,                                      - i) Think about your workforce-based triggers for this occupation and the demographic make-up of the users of the social media outlets that you use to advertise vacancies for this occupation. Are the EEO groups with low participation rates in this occupation well represented among the social media users?
                                - b) Do any of the social media sites that you use for advertising vacancies for this occupation focus on members of underrepresented EEO groups?
                              - 6) Does the agency use particular places of employment (e.g., the military) to advertise vacancies for this occupation? If so,                                    - a) Does the agency know the demographic profile of the places of employment used to advertise vacancies for this occupation? If so,                                      - i) Think about your workforce-based triggers for this occupation and the demographic make-up of the places of employment through which you advertise vacancies for this occupation. Are the EEO groups with low participation rates in this occupation well represented in these places of employment?
                              - 7) Does the agency use job fairs to advertise vacancies for this occupation? If so,                                    - a) Does the agency know the demographic profile of the participants at the job fairs where you advertise vacancies for this occupation? If so,                                      - i) Think about your workforce-based triggers for this occupation and the demographic make-up of the job fairs through which you advertise vacancies for this occupation. Are the EEO groups with low participation rates in this occupation well represented at these job fairs?
                                - b) Do any of the job fairs where you advertise vacancies for this occupation focus on members of underrepresented EEO groups?
                              - 8) Does the agency use word of mouth to advertise vacancies for this occupation?

### Application Process

                              - 1) Is the application process for this occupation clear and easy to follow?
                              - 2) Does the application ask how the applicant learned about the job opening?                                    - a) If yes, go to Question 3
                                - b) If no, skip to the  Hiring  section
                              - 3) Does the agency track how applicants learned about the vacancy?                                    - a) If yes, go to Question 4
                                - b) If no, skip to the  Hiring  section
                              - 4) Has the agency changed its recruitment efforts based on information on how applicants from underrepresented EEO groups learned about job openings for this occupation?

## Hiring

### Preliminary Questions

                              - 1) What is the name of your agency?
                              - 2) What occupation are you analyzing?
                              - 3) Has the agency hired any new employees for this occupation in the last three years?

### Applicant Flow Data

                              - 1) Does the agency collect applicant flow data for qualified applicants and selectees for this occupation?                                    - a) If yes, go to the  Trigger Identification  sub-section of the  Hiring  section
                                - b) If no, skip to the  Selection Process Accountability  sub-section of the  Hiring  section

### Trigger Identification

                              - 1) Are there any EEO Groups underrepresented among new hires (selectees) for this occupation compared to their availability among qualified applicants?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Preliminary Questions  sub-section of the  Training and Development  section
                              - 2) Which EEO Groups are underrepresented among selectees when compared to their availability among qualified applicants?
                              - 3) Is the selection rate also below the EEO group's availability in the occupational CLF?
                              - 4) Does the selection rate trigger for this occupation impact the entire agency?
                              - 5) Is the selection rate trigger specific to particular offices or programs?
                              - 6) Is the selection rate trigger specific to particular selecting officials?

### Selection Process Accountability

                              - 1) Does the agency review the selection process periodically to ensure equal treatment for all protected EEO groups?
                              - 2) Do the EEO office and personnel offices review the selection process collaboratively?
                              - 3) Does the EEO office provide regular feedback to the personnel staff regarding the demographics of the selectees for this occupation?
                              - 4) Does the agency have a hiring goal for persons with targeted disabilities?                                    - a) If yes, go to Question 5
                                - b) If no, skip to Question 8
                              - 5) Are hiring and selection officials informed of the importance of achieving this hiring goal?
                              - 6) Is the hiring goal part of the performance standards of hiring and selection officials?
                              - 7) Are hiring and selection officials held accountable if they do not meet the hiring goal?
                              - 8) Does the agency utilize a hiring goal for any other protected EEO group?

### Training the Hiring and Selection Officials

                              - 1) Are hiring and selection officials required to receive training on interviewing skills?
                              - 2) Are they skilled in interviewing people from various EEO groups?
                              - 3) Are they aware of the agency's hiring priorities?
                              - 4) Are they aware of the agency's hiring authorities, including Schedule A if applicable?
                              - 5) If Schedule A is an option for the agency, do they regularly utilize this hiring authority?

### Rating and Ranking Applicants Stage

                              - 1) Has the agency established a "blind" hiring process for this occupation?
                              - 2) Does the agency remove the names of the applicants from resumes and other documents before submitting the best-qualified list to the hiring and selection officials?
                              - 3) Does the agency conduct any skill-based testing for this occupation prior to the interview stage?                                    - a) If yes, go to Question 4
                                - b) If no, skip to Question 5
                              - 4) Could this test result in disparities in the scores among protected EEO groups?
                              - 5) Does the agency conduct any background, credit, or similar inquiries prior to the interview stage?                                    - a) If yes, go to Question 6
                                - b) If no, skip to the  Interviews and Selection Panels  sub-section of the  Hiring  section
                              - 6) Could these background checks, credit checks, or similar inquiries result in disparities in the representation of protected EEO group among interviewees?
                              - 7) Are the background checks, credit checks, or similar inquiries critical for this occupation?

### Interviews and Selection Panels

                              - 1) Do the hiring and selection officials conduct interviews and/or selection panels for this occupation?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Selection Factors  sub-section of the  Hiring  section.
                              - 2) Do the interviews and/or selection panels occur in-person?
                              - 3) If an in-person interview or selection panel is not possible, will the hiring and selection officials schedule a video conference?
                              - 4) Do the hiring and selections officials develop interview questions prior to meeting the applicants?
                              - 5) Does the EEO or personnel staff review the questions prior to the interviews?
                              - 6) Do the hiring and selection officials prepare a point-based scoring sheet for each of the questions?
                              - 7) Do the hiring and selection officials ask the same questions in each interview?
                              - 8) Do the hiring and selection officials objectively grade the applicants' responses?

Only answer Questions 9 through 15 if selection panels are used for this occupation.
                              - 9) How does the agency decide who serves on the selection panels?
                              - 10) Is the same panel used for many or most of the vacancies involving this occupation?
                              - 11) Are the members of the selection panel diverse?
                              - 12) Is the EEO office consulted about panel composition?
                              - 13) Does each member of the panel rate and rank the applicants?
                              - 14) Does the panel have to reach a unanimous consensus on the selectee?
                              - 15) If not, who makes the final decision on the selectee?

### Selection Factors

                              - 1) Do hiring and selection officials choose selectees based solely on their resumes and supporting documents?
                              - 2) Does one or more of the following factors influence the hiring and selection officials' hiring choices?                                    - a) Educational background                                      - i) Degrees
                                  - ii) Colleges or universities attended
                                - b) Work history, including breaks in employment
                                - c) Years of experience
                                - d) Prior places of employment
                                - e) Specialized experience
                                - f) Responses to technical qualifications
                                - g) Current salary
                                - h) Current grade level
                                - i) Writing samples
                                - j) Recommendations
                                - k) Performance appraisals
                                - l) Personality/rapport
                                - m) Other
                              - 3) Are all of the factors involved in hiring and selection officials' hiring decisions necessary for one to perform well in this occupation?
                              - 4) Could the consideration of unnecessary factors involved in hiring decisions cause disparities among EEO groups?

### Issues Raised About Selections

                              - 1) Are there any EEO complaints with non-selection identified as the issue?
                              - 2) Are there any grievances with non-selection identified as the issue?
                              - 3) Has the union, the ombudsman, an advocacy group, a special emphasis group, or another group expressed concern regarding recent selections?                                    - a) If yes, go to Question 4
                                - b) If no, skip to the  Training and Development  Section
                              - 4) Did the agency respond to these concerns?
                              - 5) Did the agency establish an action plan?
                              - 6) Has the agency implemented the action plan?

## Training and Development

### Preliminary Questions

                              - 1) What is the name of your agency?
                              - 2) What occupation are you analyzing?
                              - 3) Does the agency offer training and development opportunities to its employees? (e.g., career development programs, job shadowing, details, special assignments, other)                                    - a) If yes, continue this section
                                - b) If no, skip to the  Promotions  section

### Individual Development Plans

                              - 1) Are employees required to complete an Individual Development Plan (IDP)?                                    - a) If yes, proceed to Question 2
                                - b) If no, skip to the  Needs and Resources for Training and Development  subsection of the  Training and Development  section
                              - 2) Do IDPs provide development objectives linked to the work unit's mission/goals/objectives?
                              - 3) Does the agency develop and offer training and development opportunities after an assessment of the employees' IDPs that are linked to development objectives?
                              - 4) Does the supervisor/employee evaluate the usefulness of training experiences?
                              - 5) Are IDPs being used effectively?

### Needs and Resources for Training and Development

                              - 1) Does the agency survey its employees to ensure that their current skills will meet agency mission needs?
                              - 2) Does the agency assess employees' personal training and development needs?
                              - 3) Does the agency have a budget dedicated to providing training and development opportunities?
                              - 4) Does the agency track whether the budget is utilized for training and developmental opportunities?

### Training and Development Announcements

                              - 1) Does the agency have a standard operating procedure (SOP) for announcing training and development opportunities?                                    - a) If so, does the agency always follow the SOP for announcing each training and development opportunity?
                              - 2) Does the agency announce training and development opportunities to all employees?
                              - 3) Could some employees not receive the training and development announcements due to the nature of their job, their job location, their access to email or bulletin boards, or other reasons?
                              - 4) Has the union, an advocacy group or any other interested stakeholder expressed concern over the way in which the agency announces these opportunities?                                    - a) If so, did the agency address these concerns?

### Application Rates for Training and Development

                              - 1) Do employees have to apply to be selected for any training and development opportunities?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Selection Procedures for Training and Development  sub-section of the  Training and Development  section
                              - 2) Does the agency track the application rates for training and development opportunities by EEO groups?
                              - 3) Do members of certain EEO groups apply to participate for training and development opportunities at rates lower than their representation among eligible employees?
                              - 4) Has the agency obtained feedback from EEO groups who apply at low rates as to why they are not applying for the training and development opportunities?
                              - 5) Is there a perception among certain EEO groups that they will not be selected for the training and development opportunities?
                              - 6) Has the union, an advocacy group or another interested stakeholder expressed concern over the application process for the training and development opportunities?                                    - a) If so, did the agency address these concerns?

### Selection Procedures for Training and Development

                              - 1) Does the agency have a standard operating procedure (SOP) for selecting employees to participate in training and development opportunities?                                    - a) If yes, go to Question 2
                                - b) If no, skip to Question 4
                              - 2) Does the agency always follow the SOP for each training and development opportunity?
                              - 3) Does the SOP address whether diverse employees should review, interview, and select the applicants?
                              - 4) Are the employees who review, interview and select applicants diverse?
                              - 5) Do the selecting officials receive diversity and inclusion training?
                              - 6) Prior to reviewing the applications, do the selecting officials establish objective criteria for choosing the applicants?
                              - 7) Do the selecting officials utilize the objective criteria to evaluate the applicants for training and development opportunities?

### Interviews for Training and Development

                              - 1) Does the agency interview the applicants prior to selecting participants for training and development opportunities?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Selection Rates for Training and Development  sub-section of the  Training and Development  section
                              - 2) If the agency interviews the applicants, does the agency develop standard questions prior to conducting the interviews?
                              - 3) During the interviews, does the agency ensure that all of the applicants receive the same questions?
                              - 4) Prior to the interviews, does the agency establish an objective scoring sheet for each of the interview questions?
                              - 5) Following the interviews, does the agency ensure that the applicants' responses to the questions are evaluated using the objective scoring sheet?
                              - 6) Does the agency rotate the individuals who review, interview and select applicants for training and development opportunities?
                              - 7) If the agency uses a rotation, does the agency compare the diversity of the training and development participants based on the individuals who reviewed, interviewed, and selected the participants?

### Selection Rates for Training and Development

                              - 1) Does the agency track the number of applications and selection rates for training and development programs for EEO groups?                                    - a) If so, was the selection rate of any EEO group for training and development opportunities substantially lower than their application rate?
                              - 2) Do certain job series, grade levels, and/or offices receive a higher percentage of the training and development opportunities?                                    - a) If so, are any EEO groups underrepresented in the job series, grade levels, and/or offices that receive a higher percentage of the training and development opportunities?
                              - 3) Do certain job series, grade levels, and/or offices receive a higher percentage of management and executive training and development opportunities?                                    - a) If so, are any EEO groups underrepresented in the job series, grade levels, and/or offices that receive a higher percentage of the management and executive training and development opportunities?
                              - 4) Are there any EEO complaints or grievances wherein developmental opportunities, such as denial of training or non-selection for a detail, are identified as the issue?                                    - a) If so, is there an identifiable trend in these complaints or grievances involving a particular EEO group, job series, office, or geographic location?
                              - 5) Has the union, an employee group, a special emphasis group or another interested stakeholder expressed concern regarding the distribution of training and development opportunities?                                    - a) If so, did the agency address these concerns?

### Results of Training and Development Opportunities

                              - 1) Does participation in the training and development opportunities lead to career advancement within the agency?
                              - 2) Is there a perception among certain EEO groups that their participation in the training and development opportunities will not improve their career advancement efforts?
                              - 3) Examine your agency's demographic breakdown of responses to the following FEVS questions for the most recent year available. If you see that certain demographic groups responded substantially more negatively than others do, please look into why those demographic groups responded more negatively.                                    - a) "I am given a real opportunity to improve my skills in my organization." [FEVS Q1]
                                - b) "My training needs are assessed." [FEVS Q18]
                                - c) "Supervisors in my work unit support employee development." [FEVS Q47]
                                - d) "How satisfied are you with the training you receive for your present job?" [FEVS Q68]
                              - 4) If your agency uses a climate assessment survey other than FEVS, are any of the questions similar to those in question (3)? If so, please describe the results.

## Promotions

### Preliminary Questions

                              - 1) What is the name of your agency?
                              - 2) What occupation are you analyzing?

### Applicant Data

                              - 1) Does your agency collect demographic information on employees eligible for internal promotions?                                    - a) If so, for this occupation, are there any EEO Groups underrepresented among those receiving internal promotions based on their availability in the occupational CLF?                                      - i) If yes, go to Question 2
                                  - ii) If no, skip to the  Separations  section
                              - 2) Does your agency collect data concerning the applicants, qualified applicants, and selectees for internal promotions?                                    - a) If yes, go to Question 3
                                - b) If no, skip to Question 6
                              - 3) Is the percentage of workers belonging to the underrepresented EEO group who applied for a promotion to this occupation lower than their availability in the relevant applicant pool (i.e., those who are eligible to apply)?
                              - 4) Is the percentage of workers belonging to the underrepresented EEO group who applied and were deemed "qualified" for this occupation lower than their availability in the applicant pool?
                              - 5) Is the selection rate of workers from the underrepresented EEO group lower than their availability in the qualified applicant pool?
                              - 6) Are there feeder groups (e.g., particular occupations, grade levels, etc.) for this occupation?                                    - a) If so, are those feeder groups substantially similar to the occupational civilian labor force benchmark?
                              - 7) Are there career ladder positions that bridge to higher grades?
                              - 8) Are the triggers that are based on applicant data specific to a particular office or program?
                              - 9) Are the triggers that are based on applicant data specific to particular selecting officials?

### Vacancy Announcements

                              - 1) Does the agency review the qualification requirements for this occupation annually to determine whether they are still current and necessary?
                              - 2) Do the selecting officials add additional requirements beyond OPM's description of the occupation?
                              - 3) Does the vacancy announcement for this occupation contain any of the following qualification requirements?                                    - a) Specialized degrees (e.g., Masters, Doctorate, etc.). If so, are they truly necessary to perform the job well?
                                - b) Specialized licenses (e.g., Bar, Accountant, Nursing, etc.). If so, are they truly necessary to perform the job well?
                                - c) Technical qualifications. If so, are they truly necessary to perform the job well?
                                - d) Specialized experience. If so, is it truly necessary to perform the job well?
                                - e) Grade level. If so, is it truly necessary to perform the job well?
                                - f) Any other qualification requirements. If so, are they truly necessary to perform the job well? Please describe these other qualification requirements.

### Rating and Ranking Applicants Stage

                              - 1) Has the agency established a "blind" promotions process for this occupation?
                              - 2) Does the agency remove the names of the applicants from resumes and other documents before submitting the best-qualified list to the hiring and selection officials?
                              - 3) Does the agency conduct any skill-based testing for this occupation prior to the interview stage?                                    - a) If so, could this test result in disparities in the scores among protected EEO groups?

### Interviews and Selection Panels

                              - 1) Do the hiring and selection officials conduct interviews and/or selection panels for this occupation?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Selection Factors  sub-section of the  Promotions  section
                              - 2) Do the interviews and/or selection panels occur in-person?
                              - 3) If an in-person interview or selection panel is not possible, will the hiring and selection officials schedule a video conference?
                              - 4) Do the hiring and selections officials develop interview questions prior to meeting the applicants?
                              - 5) Do EEO or personnel staff review the questions prior to the interviews?
                              - 6) Do the hiring and selection officials prepare a point-based scoring sheet for each of the questions?
                              - 7) Do the hiring and selection officials ask the same questions in each interview?
                              - 8) Do the hiring and selection officials objectively grade the applicants' responses?

Only answer Questions 9 through 15 if the agency uses selection panels for this occupation.
                              - 9) How does the agency decide who serves on the selection panels?
                              - 10) Is the same panel used for many or most of the vacancies involving this occupation?
                              - 11) Are the members of the selection panel diverse?
                              - 12) Is the EEO office consulted about panel composition?
                              - 13) Does each member of the panel rate and rank the applicants?
                              - 14) Does the panel have to reach a unanimous consensus on the selectee?
                              - 15) If not, who makes the final decision on the selectee?

### Selection Factors

                              - 1) Do hiring and selection officials choose selectees based solely on their resumes and supporting documents?
                              - 2) Does one or more of the following factors influence the hiring and selection officials' promotion choices?                                    - a) Educational background                                      - i) Degrees
                                  - ii) Colleges or universities attended
                                - b) Work history, including breaks in employment
                                - c) Years of experience
                                - d) Prior places of employment
                                - e) Specialized experience
                                - f) Responses to technical qualifications
                                - g) Current salary
                                - h) Current grade level
                                - i) Writing samples
                                - j) Recommendations
                                - k) Performance appraisals
                                - l) Responses to interview questions
                                - m) Personality and/or rapport
                                - n) Other
                              - 3) Are all of the factors involved in hiring and selection officials' hiring decisions necessary for one to perform well in this occupation?
                              - 4) Could the consideration of unnecessary factors involved in hiring decisions cause disparities among EEO groups?
                              - 4) Does the agency prefer to fill vacancies for this occupation with external hires?                                    - a) If yes, go to Question 5
                                - b) If no, skip to the  Training the Hiring and Selecting Officials  sub-section of the  Promotions  section
                              - 5) Has the agency evaluated whether the performance of new hires in this occupation exceeds that of employees who received an internal promotion?                                    - a) If yes, go to Question 7.
                                - b) If no, skip to the  Training the Hiring and Selecting Officials  sub-section of the  Promotions  section
                              - 6) Has the agency determined that new hires for this occupation are more successful than employees who received an internal promotion?                                    - a) If yes, go to Question 8.
                                - b) If no, skip to the  Training the Hiring and Selecting Officials  sub-section of the  Promotions  section
                              - 7) Has the agency identified skill deficits for the employees who received an internal promotion?                                    - a) If yes, go to Question 9.
                                - b) If no, skip to the  Training the Hiring and Selecting Officials  sub-section of the  Promotions  section
                              - 8) Has the agency developed a training program to address the skill deficits before the employees seek promotion to this occupation?

### Training for the Hiring and Selecting Officials

                              - 1) Are hiring and selecting officials required to receive training on interviewing skills?
                              - 2) Are they skilled in interviewing people from various EEO groups?
                              - 3) Are they aware of the agency's hiring priorities?
                              - 4) Are they aware of the agency's hiring authorities, including Schedule A if applicable?
                              - 5) If Schedule A is an option for the agency, do they regularly utilize this hiring authority?

### Promotion Process Accountability

                              - 1) Does the agency review the promotion process periodically to ensure equal treatment for all protected EEO groups?
                              - 2) Do the EEO office and personnel offices review the promotion process collaboratively?
                              - 3) Does the EEO office regularly provide feedback to the personnel staff regarding the demographics of the selectees for this occupation?
                              - 4) Does the agency have a hiring goal for persons with targeted disabilities?                                    - a) If yes, go to Question 5
                                - b) If no, skip to Question 8
                              - 5) Are hiring and selecting officials informed of the importance of achieving this hiring goal?
                              - 6) Is the hiring goal part of the performance standards of hiring and selection officials?
                              - 7) Are hiring and selecting officials held accountable if they do not meet the hiring goal?
                              - 8) Does the agency utilize a hiring goal for any other protected EEO group?

### Issues Raised about Promotions

                              - 1) Examine your agency's responses to the following FEVS questions for the most recent year(s) available. How do your agency's responses differ from the government-wide average? Is there variation within your agency? Do certain demographic groups respond substantially more negatively than others do? If so, please look into why your agency or any groups might respond more negatively.                                    - a) "Promotions in my work unit are based on merit." [FEVS Q22]
                                - b) "How satisfied are you with your opportunity to get a better job in your organization?" [FEVS Q67]
                              - 2) Are there any EEO complaints with promotions identified as the issue?
                              - 3) Are there any grievances with promotions identified as the issue?
                              - 4) Has the union, the ombudsman, an advocacy group, a special emphasis group, or another group expressed concern regarding recent promotions?                                    - a) If yes, go to Question 5
                                - b) If no, skip to the  Separations  Section
                              - 5) Did the agency respond to these concerns?
                              - 6) Did the agency establish an action plan?
                              - 7) Has the agency implemented the action plan?

## Separations

### Preliminary Questions

                              - 1) What is the name of your agency?
                              - 2) What occupation are you analyzing?

### Data Collection

                              - 1) Does the agency track employee separations, including disability retirement, by grade, occupation, office, race, sex, national origin, and disability?                                    - a) If yes, go to the  Trigger Identification  sub-section of the  Separations  section
                                - b) If no, skip to the  Exit Interviews  sub-section of the  Separations  section

### Trigger Identification

                              - 1) Did a particular EEO group separate from the agency at a higher rate than their participation rate in the permanent workforce?
                              - 2) Did a particular EEO group voluntarily separate from the agency at a higher rate than their availability in the permanent workforce?
                              - 3) Did a particular EEO group involuntarily separate from the agency at a higher rate than their availability in the permanent workforce?
                              - 4) For each EEO group with a trigger involving their separation rate, can the agency identify a trend as to why they left the agency that is related to any of the following elements?                                    - a) Grade level
                                - b) Occupation
                                - c) Supervisor status
                                - d) Office
                                - e) Region
                              - 5) Has the union, ombudsman, an employee advocacy group, special emphasis group, or any other interested stake holder expressed any concerns about the separation rate for a particular EEO group?                                    - a) If so, did the agency address the concerns?

### Exit Interviews

                              - 1) Does the agency have a policy requiring exit interviews?                                    - a) If yes, go to Question 2
                                - b) If no, skip to  Involuntary Separations
                              - 2) In practice, does the agency conduct exit interviews?
                              - 3) Does the agency track the exit interview data?
                              - 4) Does the agency regularly analyze the results of the exit interviews?
                              - 5) Has the agency identified any trends?

### Involuntary Separations

                              - 1) Does the agency make efforts to ensure that it conducts involuntary separations in a fair and non-discriminatory manner?
                              - 2) Has the agency identified any trends in involuntary separations related to any of the following?                                    - a) Grade level
                                - b) Occupation
                                - c) Supervisor status
                                - d) Office
                                - e) Region
                              - 3) Has the union, ombudsman, an employee advocacy group, special emphasis group, or any other interested stake holder expressed any concerns about the involuntary separation rate for a particular EEO group?                                    - a) If yes, did the agency address the concerns?
                              - 4) For each EEO group with a trigger involving their involuntary separation rate, did the separations pertain to the following circumstances?                                    - a) Reductions-in-force
                                - b) Disciplinary removal
                                - c) Constructive discharge

### Reductions in Force

                              - 1) Has the agency experienced a reduction-in-force (RIF) during the last three years?                                    - a) If yes, go to Question 2
                                - b) If no, skip to the  Disciplinary Removals  sub-section of the  Separations  section
                              - 2) Did the selection factors used in the RIF have a disproportionate impact on the terminated employees in any of the EEO protected categories?                                    - a) Race
                                - b) Color
                                - c) Religion
                                - d) Sex
                                - e) National Origin
                                - f) Age
                                - g) Disability
                                - h) Genetic Information
                                - i) Reprisal
                              - 3) Use the following tests to determine disproportionate impact of RIF:                                    - a) Four-Fifths Rule: Was the selection rate for reduction in force of a particular EEO group less than 80% of the selection rate for the EEO group with the highest selection rate?
                                - b) Two or More Standard Deviations: A standard deviation is a measure of dispersion used in statistics. Is the difference between two EEO groups' selection rate and its representation in the workforce greater than two standard deviations, and therefore, statistically significant? [1]
                              - 4) Can the agency justify the disproportionate impact of the reduction-in-force by showing that it was based on reasonable factors other than the employees' status in a particular EEO group?
                              - 5) Within 1 to 2 years of the RIF, did the agency announce any vacancies for the positions that were impacted by the RIF?
                              - 6) Are procedures in place to ensure reductions-in-force are conducted in a non-discriminatory manner?
                              - 7) Did the agency use multiple levels of decision making when deciding the selection factors?
                              - 8) Has the union, ombudsman, an employee advocacy group, special emphasis group, or any other interested stake holder expressed any concerns about the impact of the RIF on a particular EEO group?                                    - a) If yes, did the agency address the concerns?

### Disciplinary Removals

                              - 1) What was the workforce distribution of discipline, including removal, during the last fiscal year (grade, occupation, installation, race, sex, national origin, disability, EEO participation, types of discipline, etc.)?
                              - 2) Of the disciplinary actions based on conduct taken in the last fiscal year, was the rate of receipt substantially similar for all parts of the population?                                    - a) If yes, skip to Question 8
                                - b) If no, go to Question 3
                              - 3) Which groups received more or harsher discipline based on conduct than the others, and why?
                              - 4) Is the conduct of those groups subject to a higher level of scrutiny?
                              - 5) Do members of other groups engage in similar misconduct without having disciplinary actions proposed or taken against them?
                              - 6) Were there offices or subcomponents with higher rates of disciplinary removals based on conduct?
                              - 7) Are certain groups recommended for conduct-based discipline more frequently than others are, regardless of whether such discipline is implemented?                                    - a) If so, are these recommendations for conduct-based discipline based on predetermined objective criteria, or are they highly subjective?
                              - 8) Of the disciplinary actions based on performance taken in the last fiscal year, was the rate of such actions substantially similar for all parts of the population?                                    - a) If yes, skip to Question 17
                                - b) If no, go to Question 9
                              - 9) Which groups received more or harsher discipline based on performance than the others, and why?
                              - 10) Is the performance of those groups subject to a higher level of scrutiny?
                              - 11) Do members of those groups receive opportunities to improve their performance at the same rate as members of other groups?
                              - 12) Were there offices or subcomponents with higher rates of disciplinary removals based on performance?
                              - 13) Are performance appraisals conducted in similar manners for all employees?
                              - 14) Are performance appraisals based on predetermined objective criteria, or are they highly subjective?
                              - 15) Are certain groups recommended for performance-based discipline more frequently than others are, regardless of whether such discipline is implemented?                                    - i) If so, are these recommendations for performance-based discipline based on predetermined objective criteria, or are they highly subjective?
                              - 16) Do performance appraisal narratives or discipline recommendation narratives reveal stereotyping or otherwise negative views of certain EEO groups?
                              - 17) Who determines that disciplinary actions are warranted?
                              - 18) Is there a standardized method, such as a table of offenses, used for determining when disciplinary action is warranted and/or what type of disciplinary action is warranted?                                    - a) If yes, go to Question 19
                                - b) If no, skip to Question 21
                              - 19) Does the agency periodically review such standardized methods for determining the implementation and severity of disciplinary actions to ensure equal treatment regardless of race, religion, sex, national origin, disability, and EEO participation?
                              - 20) Is the EEO office consulted when developing or modifying the standardized methods for determining the implementation and severity of discipline?
                              - 21) Are there a substantial number of EEO complaints where discipline, including removal, is identified as the issue?                                    - a) If so, is there an identifiable trend (i.e., particular group, supervisor, or installation)?                                      - i) If so, what can be done to address this trend (objective criteria, better communication of process and expectations)?
                              - 22) Has the union, the ombudsman, an employee advocacy group, special emphasis group, or any other interested stakeholder expressed concern regarding the rate of discipline for a particular group?                                    - a) If so, did the agency address the concerns?

### Constructive Discharge

                              - 1) Have EEO complainants alleged constructive discharge as the issue of the complaint during the last three years?                                    - a) If no, please skip to Question 2
                                - b) If yes, was discrimination found in any of those complaints based on the following criteria                                      - i) An objective, reasonable person in the complainant's position would have found the working conditions intolerable;
                                  - ii) Conduct that constituted discrimination created the intolerable working conditions; and
                                  - iii) The complainant's involuntary resignation resulted from the intolerable working conditions?
                              - 2) Has the union, the ombudsman, an employee advocacy group, special emphasis group, or any other interested stakeholder expressed concern about constructive discharge involving a particular group?                                    - a) If so, what were the specific concerns raised and what is the agency's response?

### Voluntary Separations

                              - 1) When an employee voluntarily leaves the agency, does the agency ask the employee's reason for leaving?                                    - a) If no, skip to Question 4
                                - b) If yes, go to Question 2
                              - 2) Did the former employees cite any of the following reasons as to why they left the agency?                                    - i) Lack of training and development opportunities
                                - ii) Lack of career advancement opportunities
                                - iii) Discrimination by a supervisor
                                - iv) Hostile work environment
                                - v) Poor management practices (not discrimination or harassment)
                                - vi) Failure to provide an accommodation (religious or disability-related)
                                - vii) Overworked
                              - 3) Are some reasons for leaving the agency cited more often by members of particular EEO groups?
                              - 4) Has the union, ombudsman, an employee advocacy group, special emphasis group, or any other interested stake holder expressed any concerns about the voluntary separation rate for a particular EEO group?                                    - a) If so, did the agency address the concerns?

### Employee Viewpoints and Voluntary Separations

                              - 1) Do you have FEVS data or data from a similar climate survey for your agency?                                    - a) If no, you are done with this section
                                - b) If yes, go to Question 2
                              - 2) Do your employees respond negatively to the following statements at a rate higher than the government-wide average?                                    - a) "Policies and programs promote diversity in the workplace." [FEVS Q34]
                                - b) "Prohibited Personnel Practices (for example, illegally discriminating for or against any employee/applicant, obstructing a person's right to compete for employment, knowingly violating veterans' preference requirements) are not tolerated." [FEVS Q38]
                              - 3) If you have FEVS data broken down by demographic group, do any demographic groups respond substantially more negatively than others do to the following questions?                                    - a) "I am given a real opportunity to improve my skills in my organization." [FEVS Q1]
                                - b) "I have sufficient resources (for example, people, materials, budget) to get my job done." [FEVS Q9]
                                - c) "My workload is reasonable." [FEVS Q10]
                                - d) "Policies and programs promote diversity in the workplace." [FEVS Q34]
                                - e) "Prohibited Personnel Practices (for example, illegally discriminating for or against any employee/applicant, obstructing a person's right to compete for employment, knowingly violating veterans' preference requirements) are not tolerated." [FEVS Q38]
                                - f) "I recommend my organization as a good place to work." [FEVS Q40]
                                - g) "My supervisor/team leader provides me with opportunities to demonstrate my leadership skills." [FEVS Q43]
                                - h) "Supervisors/team leaders in my work unit support employee development." [FEVS Q47]
                                - i) "My supervisor/team leader treats me with respect." [FEVS Q49]
                                - j) "How satisfied are you with your opportunity to get a better job in your organization?" [FEVS Q67]
                                - k) "How satisfied are you with the training you receive for your present job?" [FEVS Q68]

## Contact Information

If you have any questions or comments, please contact Lori Grant (lori.grant@eeoc.gov) or Karen Brummond (karen.brummond@eeoc.gov).

Equal Employment Opportunity Commission Office of Federal Operations 131 M Street NW Washington, D.C. 20507 www.eeoc.gov

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[1] In many cases related to selection, a *hypergeometric test* is appropriate.