FISCAL YEAR 2025 

CONGRESSIONAL 

BUDGET 

JUSTIFICATION 

SUBMITTED TO THE CONGRESS OF THE UNITED STATES MARCH 2024

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 
 

 

 

 

Fiscal Year 2025 

Congressional Budget Justification 

U.S. Equal Employment 

Opportunity Commission 

March 11, 2024 

Submitted to the 

Congress of the United States 

OUR MISSION 

Prevent and Remedy Unlawful Employment Discrimination and Advance Equal 

Employment Opportunity for All. 

OUR VISION 

Fair and Inclusive Workplaces with Equal Opportunity for All. 

 

 

 

 

TABLE OF CONTENTS 

I. CHAIR’S REPORT..................................................................................................................1 

A. Fiscal Year (FY) 2025 Budget Highlights........................................................................1 

B. Chair’s Message ..............................................................................................................2 

II. OFFICE OF INSPECTOR GENERAL FUNDING INFORMATION.................................9 

Chart 1: Office of Inspector General ......................................................................................9 

III. BUDGETING AND ACCOUNTING INFORMATION .....................................................11 

A. Appropriation Language ................................................................................................11 

B. Staffing and Funding Profile..........................................................................................12 

C. Analysis of Change........................................................................................................13 

D. Object Class – Agency Summary...................................................................................14 

IV. ENTERPRISE RISK MANAGEMENT PLAN...................................................................15 

V. STRATEGIC PLAN AND PERFORMANCE MEASURES ..............................................17 

A. The Strategic Plan for Fiscal Years 2022 - 2026.............................................................17 

VI. STRATEGIC GOAL I – Combat and prevent employment discrimination through the 

strategic application of the EEOC’s law enforcement authorities......................................19 

A. Introduction...................................................................................................................19 

B. Performance Measures and Results................................................................................21 

C. Program Areas...............................................................................................................29 

1. Private Sector Enforcement.....................................................................................29 

2. Federal Sector Programs.........................................................................................40 

VII. STRATEGIC GOAL II - Prevent employment discrimination and promote inclusive 

workplaces through education and outreach.......................................................................53 

A. Introduction...................................................................................................................53 

B. Performance Measures and Results................................................................................55 

VIII. STRATEGIC GOAL III – Strive for organizational excellence through our people, 

practices, and technology......................................................................................................61 

A. Introduction...................................................................................................................61 

Fiscal Year 2025 Congressional Budget Justification Page i 
 

B. Performance Measures and Results................................................................................62 

C. Outreach........................................................................................................................67 

1. Non-fee-based Outreach .........................................................................................70 

2. Fee-based (Revolving Fund – Education, Technical Assistance and Training) ........71 

D. Program Areas...............................................................................................................74 

1. Highlighted Resource Area .....................................................................................74 

2. Human Resources...................................................................................................74 

3. Public Service.........................................................................................................78 

4. Information Technology - Digital Transformation...................................................79 

5. Finance and Administration ....................................................................................88 

IX. VERIFICATION AND VALIDATION OF DATA.............................................................91 

X. PROGRAM EVALUATIONS..............................................................................................93 

XI. ADMINISTRATION AND SUPPORT................................................................................95 

A. Introduction...................................................................................................................95 

B. Freedom of Information Act Workload..........................................................................95 

C. GINA Study Commission..............................................................................................96 

APPENDIX A: GENERAL STATEMENT OF LAWS..............................................................97 

APPENDIX B: EVALUATION AND EVIDENCE..................................................................103 

APPENDIX C: ENTERPRISE RISK MANAGEMENT ........................................................109 

APPENDIX D: AGENCY RESPONSES TO PL 115-414 GOOD ACCOUNTING 

OBLIGATION IN GOVERNMENT ACT (GAO-IG Act)................................................111 

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I. CHAIR’S REPORT 

A. Fiscal Year (FY) 2025 Budget Highlights 

The U.S. Equal Employment Opportunity Commission (EEOC or Commission) is the leading 

federal law enforcement agency dedicated to preventing and addressing employment 

discrimination on the basis of race, color, religion, sex (including pregnancy, sexual orientation, 

and gender identity), national origin, age, disability, and genetic information. The FY 2025 

Budget requests $488,221,000 for the EEOC, which includes up to $32,500,000 for State, 

Local, and Tribal programs. This request reflects an increase of $33,221,000 from the enacted 

FY 2023 President’s budget level of $455,000,000. 

The EEOC was created by Title VII of the historic Civil Rights Act of 1964, which prohibited 

discrimination in employment on the basis of race, color, religion, sex, and national origin 

throughout the United States. Over the agency’s history, the EEOC’s jurisdiction and workload 

have grown substantially, due to the passage of additional federal employment laws and the 

expansion of the American workforce. Today, the EEOC is responsible for enforcing the 

following laws: 

• Title VII of the Civil Rights Act of 1964 (Title VII), as amended, which prohibits 

employment discrimination based on race, color, religion, sex (including pregnancy, 

sexual orientation, and gender identity), and national origin. 

• The Age Discrimination in Employment Act of 1967 (ADEA), as amended, which 

prohibits employment discrimination against workers who are 40 years of age and older. 

• The Pregnancy Discrimination Act of 1978 (PDA), which amended Title VII to 

clarify that discrimination based on pregnancy, childbirth, or related medical conditions 

constitutes sex discrimination and requires employers to treat workers affected by 

pregnancy, childbirth, or related medical conditions the same as any other employees 

with temporary disabilities with respect to terms and conditions of employment, 

including health benefits. 

• The Equal Pay Act of 1963 (included in the Fair Labor Standards Act) (EPA), as 

amended, which prohibits sex discrimination in the payment of wages to men and 

women performing substantially equal work in the same establishment. 

• Titles I and V of the Americans with Disabilities Act of 1990 (ADA), as amended, 

which prohibit employment discrimination based on disability by private, state, and 

local government employers, and requires those employers to reasonably accommodate 

the known physical or mental limitations of an applicant or employee who is an 

otherwise qualified individual with a disability, unless doing so would impose an undue 

hardship on the operation of the employer’s business. Section 501 and 505 of the 

Rehabilitation Act of 1973 provide the same protections for federal employees and 

applicants for federal employment. 

Fiscal Year 2025 Congressional Budget Justification Page 1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

• Title II of the Genetic Information Nondiscrimination Act of 2008 (GINA), which 

prohibits employment discrimination based on an applicant’s or employee’s genetic 

information (including family medical history). 

• The Pregnant Workers Fairness Act of 2022 (PWFA), which requires employers to 

reasonably accommodate qualified workers’ known limitations related to pregnancy, 

childbirth, or related medical conditions, absent undue hardship. 

Together, these laws protect individuals from employment discrimination (including unlawful 

harassment) based on race, color, religion, sex (including pregnancy, sexual orientation, and 

gender identity), national origin, age, disability, and genetic information. They also make it 

illegal to retaliate against a person for opposing employment discrimination, filing a charge of 

discrimination, or participating in an investigation or lawsuit regarding employment 

discrimination. Finally, provisions in the ADA, the Rehabilitation Act, and GINA strictly limit 

covered entities from obtaining health-related information from applicants and employees and 

require that any genetic or medical information a covered entity has about an applicant or 

employee be kept confidential. The PWFA Requires that a covered entity provide a reasonable 

accommodation to a qualified worker’s know limitation related to pregnancy, childbirth, or 

related medical conditions, absent undue hardship. 

B. Chair’s Message 

I am pleased to present the FY 2025 Congressional Budget Justification for the work of the 

U.S. Equal Employment Opportunity Commission (EEOC or the Commission) to advance 

equal employment opportunity. The FY 2025 Budget request of $488,221,000 includes 

$32,500,000 to support state and local fair employment practice agencies (FEPAs) and tribal 

employment rights offices (TEROs). 

The EEOC was created in direct response to the historic 1963 March on Washington for Jobs 

and Freedom and first opened its doors in 1965 with a simple mission — to prevent and remedy 

discrimination in our nation’s workplaces. Since then, America has made substantial progress 

toward that goal, but much work remains, and history shows that we cannot take that progress 

for granted. Today, the EEOC’s role in promoting equal employment opportunity and 

enforcing the nation’s federal workplace anti-discrimination laws is as necessary as ever. 

Demand for the EEOC’s services continues to increase. The number of new charges filed with 

the agency, which had declined during the initial years of the COVID-19 pandemic, increased 

from just over 61,000 in FY 2021 to more than 73,000 in FY 2022. an almost 20 percent 

increase. In FY 2023, EEOC received 233,704 inquiries, an almost 7 percent increase from FY 

2022, and 81,055 new charges, an increase of over 10 percent compared to FY 2022. In 

response to this demand from America’s workers, as well as expectations from the 

Administration and Congress, the EEOC has worked diligently over recent fiscal years to invest 

the increased resources requested by the Administration and provided by Congress into hiring 

additional staff. As a result, after having a historic low of fewer than 2,000 full-time employees 

at the beginning of FY 2021, the agency ended FY 2023 with more than 2,300 staff on board. 

As a result, the agency has been able to significantly increase the number of charges it resolved 

in each of the two most recent fiscal years. 

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Beyond increased demand from the public, Congress and the Administration have tasked the 

EEOC with additional responsibilities. For instance, the agency has done substantive and 

meaningful work to implement the newly enacted Pregnant Workers Fairness Act, examine and 

address employment discrimination resulting from the use of artificial intelligence and other 

automated systems, and help lead the Administration’s initiative to advance Diversity, Equity, 

Inclusion, and Accessibility (DEIA) in the federal workforce. The EEOC must be able to 

continue to address these and other important issues without having to redirect resources from 

other essential priorities. 

As we celebrate the 60th anniversary of the passage of the Civil Rights Act of 1964 and prepare 

for the 60th anniversary of the EEOC in FY 2025, we continue to work toward an America 

where all people have a fair chance to obtain employment, provide for their families, and 

contribute to our economy. With the demonstrated demand for our services, the ongoing need 

to advance equal opportunity, and the agency’s expanded responsibilities, we believe that now 

is the time to protect the vital progress made over the past four years. This budget would 

accomplish that goal. The Commission is firmly committed to advancing equal employment 

opportunity for America’s workers and looks forward to building on its long legacy of civil 

rights law enforcement to help achieve it. 

FY 2025 Priorities 

The Biden-Harris Administration has called for a whole-of-government approach to addressing 

systemic discrimination and advancing equal opportunity, and the EEOC has a critical role in 

achieving that agenda. As Chair, I am focused on strengthening the capacity and 

responsiveness of the agency and using our resources strategically to ensure the EEOC can 

vigorously enforce the law. With the President’s mark, the EEOC would focus, in particular, 

on the following areas – advancing racial justice and combatting systemic discrimination on all 

protected bases, particularly with respect to vulnerable workers; advancing pay equity; 

addressing the use of artificial intelligence in employment decisions; providing information to 

assist employers that wish to undertake lawful approaches to fostering diversity, equity, 

inclusion, and accessibility (DEIA) in their workplaces, and preventing unlawful retaliation and 

harassment. 

Advancing Racial Justice and Combatting Systemic Discrimination 

As the primary federal agency that enforces laws against employment discrimination, the 

EEOC must continue to play a large role in promoting racial justice and combatting the 

persistent problem of systemic discrimination in employment. Accordingly, with this proposed 

budget, the Commission would provide renewed attention to tackling systemic employment 

discrimination in all forms and on all bases – including but not limited to systemic 

discrimination based on race. Eliminating systemic barriers to equal opportunity in the 

workplace will allow the EEOC to leverage its work to achieve the greatest impact. To this 

end, the EEOC will employ numerous tools, including outreach and education, technical 

assistance, and enforcement, and will use all of them to achieve change on a broad scale. The 

EEOC also will invest in advanced training for dedicated systemic enforcement staff and 

expand the number of positions dedicated to systemic investigations and litigation. Robust, 

strategic systemic enforcement is an important part of the agency’s efforts to leverage its 

limited resources to maximum effect, because it allows the EEOC to address unlawful practices 

Fiscal Year 2025 Congressional Budget Justification Page 3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

on a national, regional or industry level while helping substantial numbers of employees at 

once. In addition, the public attention that systemic cases receive often has a deterrent effect on 

other businesses, extending the impact of a systemic case far beyond a single employer. 

Over the past five fiscal years, nearly a third of all charges filed with the agency have alleged 

some form of racial discrimination. The focus on systemic discrimination while also 

investigating individual charges will help address the long-standing problem of discrimination 

(including harassment and retaliation) based on race more effectively than a focus on individual 

charges alone. 

The EEOC will also continue to play an important role in working with employers who seek 

guidance on how to appropriately eliminate barriers and how to respond to questions about 

fairness in their own practices through technical assistance, outreach and education, and 

guidance. With the Commission’s partners across the federal government, we can help 

employers eliminate systemic discrimination and proactively foster diverse, equitable, 

inclusive, and accessible workplaces that benefit all employees. 

Advancing Pay Equity 

It has been 60 years since passage of the Equal Pay Act and nearly 60 years since passage of 

Title VII of the Civil Rights Act of 1964, which together outlawed pay discrimination in 

employment based on sex, race, color, national origin, or religion. Nevertheless, significant and 

unjustified pay disparities persist. Today, women working full-time make only 82 cents to the 

dollar when compared to white non-Hispanic males, and the gap is even wider for women of 

color, Native American and indigenous women, immigrants, and workers with disabilities. 

Although not all pay disparities result from discrimination, unlawful discrimination in pay and 

promotions, race and gender segregation in jobs and assignments, and harassment that may 

cause workers to leave certain positions or otherwise stall career advancement, contribute to the 

problem. The EEOC will continue to use all the tools at its disposal, including outreach and 

education, enforcement and, where necessary, litigation to address pay discrimination and 

unjustified wage gaps. The Commission also will explore ways to maximize the effectiveness 

of its efforts to combat pay discrimination. In FY 2022, the National Academies of Sciences, 

Engineering, and Medicine issued a report that strongly supported the use of pay data collection 

as a tool to combat pay discrimination and provided recommendations for potential future 

collections. The agency is considering the report’s recommendations as it determines how to 

best focus its resources to address discriminatory compensation practices. 

Diversity, Equity, Inclusion, and Accessibility (DEIA) 

On June 25, 2021, President Biden issued Executive Order 14035, Diversity, Equity, Inclusion, 

and Accessibility in the Federal Workforce, which provides that the Federal Government, as the 

nation’s largest employer, will promote equal opportunity through diversity, equity, inclusion, 

and accessibility (DEIA) in federal workplaces. The Executive Order directs agencies to 

develop and implement a more comprehensive, integrated, and strategic focus on DEIA as key 

components of their strategies to improve organizational performance. 

Since the publication of the Executive Order, the EEOC has embarked on additional key 

initiatives to advance DEIA in its own workplace and across the federal government. The 

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EEOC, alongside the Office of Personnel Management (OPM) and Office of Management and 

Budget (OMB), has helped support and coordinate DEIA activities across the federal 

government to assist agencies in effectively implementing the DEIA Executive Order. The 

agency is also helping to identify and adopt best practices and strategies to promote DEIA in 

the federal workplace and to identify and remove barriers to equal employment opportunity 

consistent with merit system principles and applicable law. For example, in April 2023, the 

EEOC published “Promising Practices for Preventing Harassment in the Federal Sector” in 

furtherance of the Executive Order objectives. 

The EEOC’s own DEIA Strategic Plan lists the agency’s proposed goals and a strategy to 

implement the agency’s DEIA program. The Plan is designed to achieve four overarching 

goals: 

Workforce Diversity. Recruit from a qualified and diverse group of potential applicants drawn 

from all segments of American society to secure and retain a high-performing workforce. 

Employee Equity. Create and sustain equal opportunity for all aspects of the employment life 

cycle. 

Inclusive Practices. Foster a culture that encourages collaboration, flexibility, fairness, and 

inclusion to enable individuals to reach their full potential. 

Accessibility. Develop and maintain facilities, information and communication technology, 

programs, processes, and services so that all EEOC employees can fully and independently use 

them to perform the essential functions of their work. 

The creation, in FY 2022, of the EEOC’s Office for Civil Rights, Diversity, and Inclusion 

(OCRDI) lays the foundation for the agency’s efforts to achieve these goals. The EEOC is 

committed to becoming an organization that attracts, employs, and retains people with differing 

points of view, backgrounds, experiences, perspectives, and ideas and strives to prevent and 

eliminate discrimination internally. The OCRDI demonstrates our commitment to being a 

model equal employment opportunity (EEO) employer as well as a learning organization that 

values the importance of diverse perspectives in driving innovation to advance our mission. 

Addressing Artificial Intelligence and Algorithmic Fairness 

In FY 2021, I launched an agency-wide initiative to ensure that the use of software, including 

artificial intelligence (AI), machine learning, and other emerging technologies used in hiring 

and other employment decisions comply with the federal civil rights laws that the EEOC 

enforces. It is abundantly clear that while AI systems may offer new opportunities for 

employers, they also have the potential to facilitate discrimination. 

Through the initiative, we have examined more closely how existing and developing 

technologies fundamentally change the ways employment decisions are made. As part of the 

initiative, the EEOC: 

• Issued technical assistance to provide guidance on algorithmic fairness and the use of AI 

in employment decisions as it affects persons with disabilities, The Americans with 

Disabilities Act and the Use of Software, Algorithms, and Artificial Intelligence to 

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Assess Job Applicants and Employees, including tips for workers and an accompanying 

video in American Sign Language; 

• Issued technical assistance on certain issues that the use of AI in employment can raise 

under Title VII of the Civil Rights Act of 1964, Selected Issues: Assessing Adverse 

Impact in Software, Algorithms, and Artificial Intelligence Used in Employment 

Selection Procedures Under Title VII; 

• Held a public Commission meeting to hear expert testimony on the role of AI in 

employment decision-making. 

• Held listening sessions with key stakeholders about algorithmic tools and their 

employment ramifications; and, 

• Gathered information about the adoption, design, and impact of hiring and other 

employment-related technologies. 

Moving forward, the agency will continue our efforts to prevent, identify, and remedy 

algorithmic discrimination by providing internal training for enforcement and litigation staff as 

well as awareness and guidance to employers, employees, job applicants, and vendors to ensure 

that these technologies are used fairly and consistently with federal equal employment 

opportunity laws. 

Retaliation 

Retaliation is a persistent and urgent problem in American workplaces. Charges alleging 

retaliation have increased as a percentage of the total number of charges filed with the EEOC 

every year for the last 20 years and represent the largest number of allegations filed with the 

agency. Working with interagency partners and with employers, the EEOC will continue to 

address this urgent problem and help ensure that employers have effective strategies for taking 

immediate action to stop retaliation. The EEOC, the U.S. Department of Labor (DOL), and the 

National Labor Relations Board (NLRB) are working together through a joint interagency 

initiative to raise awareness about retaliation issues when workers exercise their protected labor 

and employment rights. The joint initiative includes collaboration among these civil law 

enforcement agencies to protect workers on issues of unlawful retaliatory conduct, educate the 

public, and engage with employers, business organizations, labor organizations, and civil rights 

groups. 

Strengthening the Agency 

Finally, I have made it a priority to rebuild and strengthen the agency. The Commission has a 

critical role to play in addressing many urgent civil rights issues – including racial justice 

unlawful harassment; the longer-term employment-related impact of the COVID-19 pandemic, 

such as discrimination and accommodations for employees with long COVID; pay equity, and 

the continued implementation of the Supreme Court’s historic decision in Bostock v. Clayton 

County, which affirmed protections against discrimination based on sexual orientation and 

gender identity - to name just a few. It is crucial that the Commission have the resources and 

tools it needs to continue to protect and advance civil rights, both now and far in the future. 

Page 6 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

First and foremost, that requires ensuring that the Commission has sufficient staff necessary to 

address its expanding workload. 

By fiscal year 2020, the EEOC’s full-time staffing had dropped to its lowest level in four 

decades, from more than 3,390 employees in 1980 to fewer than 2,000 employees. During that 

same period, even as the agency’s resources declined, its workload expanded due to the 

increase in the U.S. population and passage of important new legislation that created additional 

civil rights protections, such as the Americans with Disabilities Act of 1990, the ADA 

Amendments Act of 2008, and the Genetic Information Nondiscrimination Act of 2008. 

Fortunately, Congress’ support in the EEOC’s FY 2021 budget made it possible to fill more 

than 450 positions throughout the agency - predominantly front-line staff to help restore our 

ability to fulfill the agency’s vital role in helping prevent and remedy employment 

discrimination. This has been especially important because the EEOC typically loses 

approximately 12 percent of our workforce on an annual basis, and a substantial proportion of 

the EEOC’s workforce is retirement eligible. In FY 2023, the EEOC continued to focus on 

robust workforce planning and hiring to continue to strategically grow our enforcement 

capacity, as we also begin enforcing new civil rights protections in the Pregnant Worker’s 

Fairness Act. The addition of new employees in mission-critical positions over the past three 

fiscal years is a much needed down payment on what I believe should be a long-term 

investment to ensure that the EEOC has resources commensurate with its task. With the 

President’s mark and continued workforce planning, I plan to continue to invest in hiring, 

training, and retention to empower our staff to advance the agency’s mission and vigorously 

enforce the laws entrusted to the EEOC. 

In addition to hiring new staff, the EEOC is working to ensure that its own employment 

practices embody the agency’s values and to support employees by providing the tools and 

other resources employees need to be as effective as possible in their work. The Commission 

continues to embrace the principles of equal employment opportunity in its own workplace, 

recognizing that doing so will enhance the EEOC’s overall effectiveness. In addition to 

providing workplace flexibilities, I have authorized increased training and development to 

support EEOC employees. Working in partnership with internal stakeholders, including the 

EEOC’s union, this process will provide the self-assessments and information to foster 

employee engagement, satisfaction, and productivity, which will facilitate retention of the 

highly qualified and talented staff within the EEOC’s workforce. 

The EEOC was created as a result of America’s bipartisan, national commitment to civil rights 

and equal opportunity for all. As such, the institution serves as tangible proof that the causes of 

justice and equality are greater than hatred, division, and bigotry. That legacy and our work are 

critically important to the American people and to this Administration as we rebuild the 

economy to work for everyone and confront the urgent civil rights issues of our time. 

Sincerely, 

Charlotte A. Burrows 

Chair 

U.S. Equal Employment Opportunity Commission 

Fiscal Year 2025 Congressional Budget Justification Page 7 
 

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II. OFFICE OF INSPECTOR GENERAL FUNDING INFORMATION 

The EEOC is covered by the Inspector General Act of 1978, as amended (U.S.C. App), 

and the table below provides the following information under the Inspector General 

Reform Act of 2008 (Pub. L. No. 110-409): an aggregate request for the Office of 

Inspector General (OIG); amounts required for OIG training; and amounts in support of 

the Council of the Inspectors General on Integrity and Efficiency (CIGIE). 

Category Amount 

Office of Inspector General Initial Request $2,788,660 

Aggregate amount of funds $2,788,6601 

Amount requested in OIG budget for training $62,0002 

Amount requested to support CIGIE $14,1063 

1 This is the total aggregate request for the OIG. 

2 The Inspector General certifies that this amount would satisfy all OIG training requirements for FY 2025. 

3 .0036 percent of $2,788,660 or $14,106 will support the Council of Inspectors General on Integrity and 

Efficiency (CIGIE). 

Chart 1 below shows the Inspector General’s Funding Request by Operating Plan line items. 

Chart 1: Office of Inspector General 

Fiscal Year 2025 Congressional Budget Justification Page 9 
 

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III. BUDGETING AND ACCOUNTING INFORMATION 

A. Appropriation Language 

U.S. Equal Employment Opportunity Commission 

Salaries and Expenses 

For necessary expenses of the Equal Employment Opportunity Commission as authorized 

by Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e), the Age Discrimination in 

Employment Act of 1967 (29 U.S.C. § 621), the Equal Pay Act of 1963 (29 U.S.C. § 206), 

the Americans with Disabilities Act of 1990 (42 U.S.C. § 12101), Section 501 of the 

Rehabilitation Act of 1973 (29 U.S.C. § 705), the Civil Rights Act of 1991 (Public Law 

102-166), the Genetic Information Nondiscrimination Act (GINA) of 2008 (Public Law 

110-233), the ADA Amendments Act of 2008 (Public Law 110-325), the Lilly Ledbetter 

Fair Pay Act of 2009 (Public Law 111-2), and the Pregnant Workers Fairness Act (Public 

Law 117-328), including services as authorized by 5 U.S.C. 3109; hire of passenger motor 

vehicles as authorized by 31 U.S.C. 1343(b); non-monetary awards to private citizens; and 

up to $32,500,000 for payments to State, Local, and Tribal enforcement agencies for 

authorized services to the Commission, $488,221,000, of which $2,788,660 shall be for the 

Office of the Inspector General: Provided, That the Commission is authorized to make 

available for official reception and representation expenses not to exceed $2,250 from 

available funds: Provided further, That the Commission may take no action to implement 

any workforce repositioning, restructuring, or reorganization until such time as the 

Committees on Appropriations of the House of Representatives and the Senate have been 

notified of such proposals, in accordance with the reprogramming requirements of section 

505 of this Act: Provided further, That the Chair is authorized to accept and use any gift or 

donation to carry out the work of the Commission. 

Fiscal Year 2025 Congressional Budget Justification Page 11 
 

 

 

 

 

 

 

 

B. Staffing and Funding Profile 

Table 1 below depicts the EEOC’s total agency staffing and funding profile by Strategic 

Goals and Programs for FYs 2023 through 2025. 

Table 1: Total Agency Staffing and Funding Profile 

FY 2023 to FY 2025 

(Dollars in thousands*) 

Strategic Goal I: Combat and prevent employment discrimination through the strategic 

application of the EEOC’s law enforcement authorities 

Category FY 2023 

(Actual) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Change 

From 

FY 2024 

1. Private Sector Enforcement $348,109 $348,484 $373,286 $24,802 

State, Local, and Tribal $31,500 $31,500 $32,500 $1,000 

2. Federal Sector Enforcement $69,391 $69,016 $76,435 $7,419 

Total Strategic Goal I $449,000 $449,000 $482,221 $33,221 

Strategic Goal II: Prevent employment discrimination and advance equal employment opportunity 

through education and outreach 

Category FY 2023 

(Actual) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Change 

From 

FY 2024 

Outreach (Non-Fee Based) $6,000 $6,000 $6,000 $0 

Total Strategic Goal II $6,000 $6,000 $6,000 $0 

Agency Total 

(includes Strategic Goal III 

Resources listed below) 

$455,000 $455,000 $488,221 $33,221 

Total Full-Time Equivalents** 2,173 2,162 2,162 (0) 

Strategic Goal III: Strive for organizational excellence through our people, practices, and 

technology 

Category FY 2023 

(Actual) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Change 

From 

FY 2024 

Highlighted Resource Areas: 

Information Technology $25,773 28,706 $28,706 $0 

*May not add due to rounding. 

**Includes 14 FTE Reimbursable from Revolving Fund. 

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C. Analysis of Change 

The Analysis of Change, Table 2, below indicates the material changes between the 

EEOC’s request for FY 2024 and request for FY 2025. 

Table 2: Analysis of Change 

FY 2025 

(Dollars in thousands) 

Category FY 2024 

(Request) 

FY 2025 

(Request) 

Net Change 

(+/-) 

Spending Authority (Includes State, Local, and Tribal) $455,000 $488,221 $33,221 

Explanation of Changes: Amount 

Compensation and Benefits 335,529 357,750 22,221 

Total Compensation and Benefits* 335,529 357,750 22,221 

Subtotal Compensation Changes $22,221 

Program Support Changes 

1. EEO Data Collection 7,432 7,432 

2. Addressing Artificial Intelligence and Algorithmic 

Fairness 1,170 1,170 

3. Pregnant Workers Fairness Act 1,398 1,398 

4. Office Rehabilitation and Relocations 1,000 1,000 

Program Support Changes $11,000 

Total Net Change $33,221 

* FY 2025 Compensation and Benefits (C&B) reflects agency estimates as of December 2023. The estimate includes a 

2.0 percent pay increase - $3,865; employee performance awards – $6.719M. 

Fiscal Year 2025 Congressional Budget Justification Page 13 
 

 

 

 

D. Object Class – Agency Summary 

Table 3 below shows the changes in the EEOC’s object class funding over three fiscal 

years. 

Table 3: Object Class Schedule – Agency Summary 

Agency Summary Requirements by Object Class 

FY 2023 to FY 2025 

(Dollars in thousands*) 

OBLIGATIONS BY OBJECT CLASS FY 2023 

(Actual) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Personnel Compensation 

11.1 Full-time permanent (FTP) $228,721 $235,736 251,958 

11.3 Other than FTP 1,046 2,200 2,200 

11.5 Other personnel compensation 8,661 7,000 7,000 

Total Personnel Compensation 238,428 244,936 261,158 

12.1 Civilian personnel benefits 87,192 90,593 96,592 

Total Compensation and Benefits 325,620 335,529 357,750 

21.1 Travel of persons 2,222 2,000 2,000 

22.0 Transportation of things 25 25 25 

23.1 Rental payment to GSA 33,824 34,652 35,067 

23.2 Other rent/communications 4,460 4,500 4,500 

24.0 Printing and reproduction 100 100 100 

25.1 State, local, and tribal contracts 31,500 31,500 32,500 

25.2 Security services (including DHS) 4,480 4,400 4,400 

25.2 Other services from non-federal sources 34,086 28,594 38,179 

25.2 Litigation support 2,840 3,500 3,500 

25.3 Other goods & services from federal sources 7,705 6,000 6,000 

26.0 Supplies and materials 7,138 3,000 3,000 

31.0 Equipment 1,000 1,200 1,200 

Total Other Object Classes 129,380 119,471 130,471 

Agency Total $455,000 $455,000 $488,221 

*May not add due to rounding 

Page 14 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

IV. ENTERPRISE RISK MANAGEMENT PLAN 

During FY 2023, the EEOC continued to improve the agency’s enterprise risk management 

(ERM) framework, which identifies, prioritizes, and manages institutional risk at all levels 

of the agency. In FY 2020, the ERM Handbook was updated to reflect the importance of 

information security, cybersecurity, and physical security in developing the agency’s risk 

registers and profiles. The agency will continue to incorporate ERM into decision-making 

and focus on the integration of risk management and internal controls. As the EEOC’s 

ERM program matures, the Handbook will continue to keep pace with industry standards. 

The agency’s risk management approach supports our ability to identify, analyze, and 

appropriately respond to strategic risks across the full spectrum of the EEOC’s activities. 

Through ERM, we: 

• Provide a structured, disciplined, and consistent approach to assessing risk. 

• Identify strategic risks that threaten the EEOC’s achievement of its long-term 

objectives and goals and manage those risks at the enterprise level through an 

Enterprise Risk Steering Committee that is delineated in its Charter and the ERM 

Policy Handbook. 

• Ensure that risks are managed in a manner that maximizes the value the EEOC 

provides to the nation consistent with defined risk appetite and risk tolerance levels. 

• Align our strategy, processes, people, technology, and information to support agile 

risk management. 

• Provide greater transparency into risk by improving our understanding of 

interactions and relationships between risks in support of improved risk-based 

decision making. 

• Establish clear accountability and ownership of risk. 

Risk management has become central to the EEOC’s mission, vision, and culture. All 

employees are expected to adopt the principles of risk management developed through the 

ERM program as it is progressively expanded to all offices and program areas, and to apply 

the standards, tools, and techniques within their assigned responsibilities. With this 

commitment to ERM, the EEOC can ensure the widest application of equal employment 

practices throughout the nation in the most efficient and cost-effective manner. See 

Appendix C. 

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V. STRATEGIC PLAN AND PERFORMANCE MEASURES 

A. The Strategic Plan for Fiscal Years 2022 - 2026 

1. Introduction 

The U.S. Equal Employment Opportunity Commission Strategic Plan for Fiscal Years 

2022-2026 (“Strategic Plan” or “Plan”) establishes a framework for achieving the EEOC’s 

mission to “Prevent and remedy unlawful employment discrimination and advance equal 

employment opportunity for all,” so that the nation may realize the Commission’s vision of 

“Fair and inclusive workplaces with equal opportunity for all.” 

Through enactment of the Government Performance and Results Act (GPRA) 

Modernization Act of 2010 (GPRAMA), Congress has directed executive departments, 

government corporations, and independent agencies to develop and post a Strategic Plan 

on their public websites every four fiscal years. The implementing guidance in Circular 

No. A-11 from the Office of Management and Budget (OMB) instructs agencies on the 

necessary elements required in an agency’s plan and the requirements to publish a new 

plan with the beginning of each new term of an administration. The Strategic Plan is 

located online at https://www.eeoc.gov/eeoc-strategic-plan-2022-2026. To accomplish our 

mission and achieve the proposed vision, the EEOC is committed to pursuing the 

following three Strategic Goals: 

Strategic Goal I – Combat and prevent employment discrimination through the 

strategic application of the EEOC’s law enforcement authorities. The corresponding 

Strategic Objectives are: 

I.A. The agency has a broad impact on preventing and remedying employment 

discrimination while providing meaningful relief for victims of discrimination; and 

I.B. The agency exercises its enforcement authority fairly, efficiently, and based on the 

circumstances of each charge or complaint. 

The seven performance measures and results for both FY 2022 and FY 2023 are more fully 

described in Section VI.B., starting on Page 21. 

Strategic Goal II – Prevent employment discrimination and advance equal 

employment opportunity through education and outreach. The corresponding Strategic 

Objectives are: 

II.A. Members of the public are aware of employment discrimination laws and EEOC 

enforcement actions and know their rights and responsibilities under these laws; and 

II.B. Employers, federal agencies, unions, and staffing agencies have the information and 

guidance necessary to advance equal employment opportunity, prevent discrimination, and 

effectively resolve EEO (equal employment opportunity) issues. 

The four performance measures and results for both FY 2022 and FY 2023 are more fully 

described in Section VII.B., starting on Page 55. 

Fiscal Year 2025 Congressional Budget Justification Page 17 
 

 

 

 

 

Strategic Goal III – Strive for organizational excellence through our people, practices, 

and technology. The corresponding Strategic Objectives are: 

III.A. The EEOC achieves a culture of accountability, inclusivity, and accessibility; and 

III.B. Resources align with priorities to strengthen intake, outreach, education, 

enforcement, and service to the public to protect and advance civil rights in the workplace. 

The four performance measures and results for both FY 2022 and FY 2023 are more fully 

described in Section VIII.B., starting on Page 62. 

The Plan presents clear and realistic strategies for achieving each Strategic Goal and 

identifies 15 performance measures with annual targets to track the EEOC’s progress 

during FY 2024 as it addresses increasing public demands for the agency’s services. The 

agency’s strategic goals, objectives, and related performance measures are depicted in the 

following Strategic Plan Diagram. 

Page 18 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

VI. STRATEGIC GOAL I – Combat and prevent employment discrimination 

through the strategic application of the EEOC’s law enforcement authorities. 

A. Introduction 

Strategic Goal I, to combat and prevent employment discrimination through the strategic 

application of the EEOC’s law enforcement authorities, reflects the EEOC’s primary 

mission of preventing unlawful employment discrimination and advancing equal 

employment opportunity for all through: 1) the administrative (investigation and 

conciliation) and litigation enforcement mechanisms applicable to private employers, labor 

organizations, employment agencies, and state and local government employers, that 

Congress entrusted to the EEOC; and 2) the adjudicatory and oversight mechanisms for 

federal employers that Congress entrusted to the EEOC. 

There are two Strategic Objectives for Strategic Goal I: 

Strategic Objective I.A: The agency has a broad impact on preventing and remedying 

employment discrimination while providing meaningful relief to victims of discrimination; 

and 

Strategic Objective I.B: The agency exercises its enforcement authority fairly, efficiently, 

and based on the circumstances of each charge or complaint. 

In the past three years, the EEOC has received an annual average of approximately 71,900 

private sector charges of discrimination, more than 7,000 requests for federal sector 

hearings, and 4,200 requests for federal sector appeals. The large number of individual 

charges of discrimination and federal sector requests for hearings and appeals that the 

EEOC receives requires the agency to think strategically about how to allocate its 

resources to ensure the most effective impact possible in its efforts to stop unlawful 

employment discrimination. 

Since at least 1995, the Commission has categorized charges for priority handling based on 

the likelihood of an investigation resulting in a finding of reasonable cause to believe that 

discrimination has occurred. Charge prioritization is a continuous process that occurs 

throughout the life of a charge; in each case, the investigation should be appropriate to the 

charge, considering the EEOC’s resources. In 1996, the Commission adopted a National 

Enforcement Plan (“NEP”) and required District Offices to develop Local Enforcement 

Plans. The NEP worked in tandem with Priority Charge Handling Procedures (PCHP) so 

that the agency investigators and litigators could focus their resources strategically. 

Building on the NEP, in 2000, the Commission developed a Comprehensive Enforcement 

Program that created best practices for internal administrative processing. In December 

2012, the NEP was replaced by the Commission’s Strategic Enforcement Plan for Fiscal 

Years 2013-2016, which established the Commission’s substantive area priorities and 

strategies and integrated the priorities into PCHP. 

Fiscal Year 2025 Congressional Budget Justification Page 19 
 

 

 

 

 

 

The Commission’s Systemic Program 

In 2006, the Commission adopted its Systemic Initiative, now known as its Systemic 

Program. This initiative made the identification, investigation, and litigation of systemic 

discrimination cases (pattern or practice, policy, and/or class cases where the alleged 

discrimination has a broad impact on an industry, profession, company, or geographic 

area) a top priority. The Systemic Initiative also ensured that the EEOC had a coordinated, 

strategic, and effective approach to such cases. The Initiative required the agency to 

effectively use its administrative and litigation tools – including Commissioner Charges, 

directed investigations, and the strategic use of empirical data – to identify and stop 

discriminatory policies and other instances of systemic discrimination. After conducting a 

review of the EEOC’s systemic work over a ten-year period, on July 7, 2016, the 

Commission issued a report on its assessment of that work, “Advancing Opportunity: A 

Review of the Systemic Program of the U.S. Equal Employment Opportunity 

Commission.” The report reviewed the highlights and lessons learned from the agency’s 

successes and challenges following the 2006 Systemic Task Report. 

Establishing Substantive Area Priorities Using the Strategic Enforcement Plan 

In December 2012, the Commission issued a Strategic Enforcement Plan (SEP) for Fiscal 

Years 2013-2016 as a successor to the 1996 NEP. The SEP established substantive area 

priorities and set forth strategies to integrate the EEOC’s private, public, and federal sector 

activities to have a sustained impact in advancing equal employment opportunity. The 

Commission reaffirmed its substantive area priorities with some modifications in the Fiscal 

Years 2017-2021 SEP. On September 18, 2023, the Commission approved the SEP for 

Fiscal Years 2024-2028. 

Table 4, shown on the next page, outlines our budget information for the agency’s 

enforcement programs under Strategic Objective I, reflecting the continued, significant 

increases in the number of inquiries and charges of discrimination the agency receives 

from the public. 

Page 20 Fiscal Year 2025 Congressional Budget Justification 
Table 4: Budget Request Summary for 

Strategic Application of Law Enforcement Authorities 

FY 2023 to FY 2025 

(Dollars in thousands*) 

Category FY 2023 

(Actual) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Private Sector Enforcement $348,109 $348,484 $373,286 

Administrative Charge Resolution 236,516 236,771 254,412 

Mediation 27,054 27,083 29,136 

Litigation 84,539 84,630 89,738 

State, Local, and Tribal 31,500 31,500 32,500 

Federal Sector Enforcement $69,391 $69,016 $76,435 

Hearings 37,472 37,269 41,383 

Appeals 22,666 22,544 25,033 

Mediation 1,323 1,316 1,461 

Oversight 7,930 7,887 8,558 

Total $449,000 $449,000 $482,221 

 

 

 

 

*May not add due to rounding. 

B. Performance Measures and Results 

The EEOC developed seven performance measures, four of which have corresponding submeasures, to track its process in achieving its strategic objectives for Strategic Goal I. 

Performance Measure 1 for Strategic Objective I.A.: By FY 2025, 90 percent of EEOC 

conciliations and litigation resolutions contain targeted, equitable relief and that level is 

maintained through FY 2026. 

Year FY 2022 FY 2023 

Target 86-88% 87-89% 

Results 91.4% 98.1% 

Target Results Target Exceeded Target Exceeded 

The EEOC negotiates resolutions of charges after an investigation has determined that 

there is reasonable cause to believe that unlawful employment discrimination has occurred. 

Because every investigation is dependent on the specific facts of each case, it is neither 

appropriate nor feasible to set a target for the number of reasonable cause determinations 

the agency makes. However, it is appropriate to set a goal for the type of relief that should 

be sought in resolutions of cases once reasonable cause has been found. 

Fiscal Year 2025 Congressional Budget Justification Page 21 
 

 

 

 

 

 

Performance Measure 1 encourages the EEOC to seek relief that goes beyond monetary 

damages for individual victims of discrimination. While it is vital that the EEOC seeks 

meaningful relief for individuals, the Commission’s ultimate goal must be to protect all 

employees and jobseekers from unlawful discrimination. 

The FY 2023 target for Performance Measure 1 was for at least 87 percent - 89 percent of 

the EEOC’s conciliations and litigation resolutions to contain targeted, equitable relief. 

Targeted, equitable relief includes any non-monetary and non-generic relief that explicitly 

address the discriminatory employment practices at issue in the case, and which provides 

remedies to the aggrieved individuals or prevents similar violations in the future. Such 

relief may include, for example, customized training for supervisors and employees, 

development of policies and practices to deter future discrimination, and external 

monitoring of employer actions, as appropriate. 

In FY 2023, the agency had far exceeded the targeted range, reporting 927 administrative 

and legal resolutions with targeted, equitable relief out of 945 resolutions, or 98.1 percent. 

Performance Measure 2 for Strategic Objective I.A. In each year through FY 2026, the 

EEOC continues to favorably resolve at least 90% of enforcement lawsuits. 

Year FY 2022 FY 2023 

Target 90% 90% 

Results 94.8% 90.8% 

Target Results Target Exceeded Target Exceeded 

Performance Measure 2 encourages the EEOC’s litigation program to continue to strive for 

excellence by maintaining its record of successful resolutions. Successful resolutions 

include cases decided by favorable court order and those concluded through a consent 

decree or a settlement agreement. Achieving success for this measure will ensure that the 

EEOC continues to exercise its prosecutorial discretion responsibly, while allowing the 

agency to take on challenging issues and litigate complex cases, including cases of 

systemic discrimination. This measure is significant because achieving success in cases 

raising priority issues under the Strategic Enforcement Plan (SEP) is often challenging and 

resource-intensive, especially in cases involving emerging or developing issues and 

systemic cases. 

The FY 2023 target for Performance Measure 2 was for the agency to favorably resolve 90 

percent of its enforcement lawsuits. As of fiscal year-end 2023, the agency had exceeded 

the target by favorably resolving 89 out of 98, or 90.8 percent, of its enforcement lawsuits. 

Page 22 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

Performance Measure 3 for Strategic Objective I.A. In each year through FY 2026, the 

EEOC increases its capacity to conduct investigations of systemic discrimination through 

training and other resources. 

Sub-Measure 3a.: In each year through FY 2026, the EEOC will provide training to all 

field staff on identifying and investigating systemic discrimination, and at least 90% of 

investigators and trial attorneys will participate in systemic training each year. 

Year FY 2022 FY 2023 

Target Training provided, at least 90% 

participation. 

Training provided, at least 90% 

participation. 

Results 

The agency provided training to all 

Lead Systemic Investigators, 

Systemic Coordinators, and many 

attorneys in the field at its annual 

systemic training conference in 

August 2022. Six Districts 

presented training on identifying 

systemic discrimination in FY 2022 

to all their enforcement staff. It is 

expected that a total of at least 90% 

of investigators and attorneys 

participated in the systemic-related 

trainings. 

Systemic training was provided to 

all enforcement and litigation staff 

in February, April, and May 2023. 

The agency provided training to 

all field staff on identifying and 

investigating systemic AI-related 

discrimination in May 2023, with 

an estimated 90% (at least) of 

investigators and trial attorneys 

attending. Additional training for 

systemic staff was conducted in 

December 2022, February 2023, 

March 2023, May 2023, July 

2023, and during the fourth 

quarter of FY 2023. 

Target Result Target Met Target Exceeded 

Sub-Measure 3b.: By FY 2026, 90% of systemic cause investigations reviewed meet or 

exceed criteria established in the Quality Enforcement Practices Plan (QEP). 

Year FY 2022 FY 2023 

Target 88% 88.5% 

Results 92.7% 92.5% 

Target Result Target Exceeded Target Exceeded 

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Sub-Measure 3c.: By 2026, every District will have at least two dedicated Enforcement 

Unit systemic staff members. 

Year FY 2022 FY 2023 

Target 

At least two dedicated 

Enforcement Unit staff 

Members by FY 2026. 

At least two dedicated 

Enforcement Unit staff 

members by FY 2026. 

Results 

In FY 2022, the agency worked 

toward the target goal of at least 

two dedicated Enforcement Unit 

systemic staff members by FY 

2026. 

In FY 2023, the agency 

continued to work toward the 

FY 2026 goal of at least two 

dedicated Enforcement Unit 

systemic staff members. 

Target Result Target Partially Met* Target Partially Met* 

*Target(s) Partially Met: A rating assigned to target results where: 1) at least half of the activities targeted for completion 

were completed; or 2) EEOC was unable to assess the results because a full year’s worth of data was not yet available. 

Performance Measure 3 emphasizes expanding the EEOC’s capacity to conduct systemic 

investigations, resulting in a coordinated, strategic, and effective approach to systemic 

enforcement. Refocusing efforts on cases that have a broad impact on an industry, 

profession, company, or geographic region will allow the EEOC to increase its impact on 

dismantling discriminatory patterns, practices, or policies. The Commission is committed 

to tackling systemic employment discrimination in all forms and on all bases. Eliminating 

systemic barriers to equal opportunity in the workplace will allow the EEOC to leverage its 

work to achieve the greatest impact. Providing training to the EEOC staff on identification 

and investigation of systemic cases is critical to the success of these efforts. 

The EEOC has numerous tools to combat systemic discrimination and harassment, 

including outreach and education, technical assistance, and enforcement, and uses all of 

them to achieve change on a broad scale. A robust systemic program is an important part 

of these efforts and allows the EEOC to advance equal employment opportunity on a 

national, regional or industry level while helping substantial numbers of employees at the 

same time. 

The FY 2023 targets for Performance Measure 3 through 3c were for at least 90 percent 

participation rate in provided trainings, for 90 percent of systemic investigations to meet or 

exceed the criteria established in the QEP, and for each District to have at least two 

dedicated systemic staff members. 

Throughout the fiscal year, the agency held many systemic trainings, including an inperson systemic training conference. Systemic training was provided to all Office of Field 

Programs and Office of General Counsel staff in February (two sessions), April, and May 

2023. The agency provided training to all field staff on identifying and investigating 

systemic AI-related discrimination in May 2023, with an estimated attendance rate of at 

least 90 percent by investigators and attorneys. Additional training was conducted in 

December 2022, February, March, May, and July 2023 and during the fourth quarter of FY 

2023. The annual systemic training conference is invaluable to provide specialized skills 

training, exchange ideas, and strengthen the working relationships among agency offices, 

Page 24 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

which is essential for this vital program to succeed. In addition, the EEOC held an inperson specialized training for recently promoted lead systemic investigators. By the end 

of the fiscal year, there were five districts with two dedicated Enforcement Unit systemic 

staff members and ten Districts with one dedicated Enforcement Unit systemic staff 

member. Currently, ten Districts, plus the Washington Field Office, each have one 

dedicated Enforcement Unit systemic staff member. 

Performance Measure 4 for Strategic Objective I.A. By FY 2026, the EEOC will make 

significant progress toward enhanced monitoring of conciliation agreements, leading to a 

more robust compliance program. 

Performance Sub-Measure 4a: Each year, the EEOC will report on enhancements to its 

compliance monitoring program for conciliation agreements. 

Year FY 2022 FY 2023 

Target Report Issued. Report Issued. 

Results 

In FY 2022, Systemic conciliation 

agreements were monitored through 

annual submissions of Measures of 

Effectiveness reports 

In FY 2023, the EEOC 

continued to review existing 

compliance monitoring 

procedures and explore potential 

future enhancements. 

Target Result Target Partially Met* Target Partially Met* 

*Target(s) Partially Met: A rating assigned to target results where: 1) at least half of the activities targeted for completion 

were completed; or 2) EEOC was unable to assess the results because a full year’s worth of data was not yet available. 

Performance Measure 4 recognizes that compliance reviews are critical to ensuring full 

satisfaction of the EEOC’s conciliation agreements. When the EEOC finds reasonable 

cause to believe discrimination has occurred, the agency issues a determination and invites 

the parties to engage in informal efforts to resolve the charge, known as conciliation. 

Successful conciliation agreements routinely include relief for the aggrieved individuals, as 

well as targeted, equitable relief that explicitly addresses the discriminatory employment 

practices at issue in the case and is designed to prevent similar violations in the future. 

Effective compliance monitoring is critical to the EEOC’s ability to ensure workplaces are 

free from discrimination after the EEOC makes a finding of discrimination. 

With an emphasis on progress, Performance Measure 4 will lead to enhanced compliance 

monitoring, including streamlined and standardized procedures, improved tracking and 

internal reporting mechanisms, and related training for EEOC field staff. Collaboration, 

evaluation, and system improvements are critical to this performance measure, and 

reporting on enhancements will ensure meaningful progress. 

During FY 2023, the EEOC examined existing technological compliance monitoring 

capabilities and evaluated systemic conciliation monitoring and measures of effectiveness 

for future enhancements to compliance monitoring for all conciliation agreements. These 

feedback measures assist the EEOC in determining whether the relief implemented was 

successful in achieving the desired change in the workplace and bringing employers into 

compliance with the statutes enforced by the Commission. 

Fiscal Year 2025 Congressional Budget Justification Page 25 
 

 

 

 

 

 

 

 

 

The agency’s evaluation and plan for an enhanced compliance program will be completed 

in FY 2024, and a report will be issued by the end of the fiscal year. 

Performance Measure 5 for Strategic Objective I.B.: By FY 2026, 74% of federal 

agencies subject to oversight activities or compliance reviews change their employment 

practices based on EEOC recommendations. 

Year FY 2022 FY 2023 

Target 70% 71% 

Results 78% 80.3% 

Target Result Target Exceeded Target Exceeded 

Performance Measure 5 recognizes that because the federal government is the largest 

employer in the United States, reducing unlawful employment discrimination in the federal 

sector is an integral part of combatting employment discrimination in the nation’s 

workplaces. Moreover, the federal government has tremendous influence over the 

employment practices of private and public employers across the nation and around the 

world. Thus, the promotion of equal employment opportunity in the federal government 

can positively impact all employees and jobseekers. 

Each year, the EEOC conducts program evaluations of a sample of federal agencies, 

focused on an array of issues relevant to the agency. The evaluations are summarized, 

with the EEOC recommending changes in the agency’s employment practices, if needed. 

These recommendations include steps federal agencies can take to correct any 

discriminatory practice identified by the evaluation. Agencies provide the EEOC with 

their Compliance Plans in response to the reports. For the baseline year of FY 2022, the 

EEOC reviewed the Compliance Plans issued in FY 2020 and determined whether they 

were implemented successfully and, if not, what corrective action was appropriate. Based 

on the EEOC's assessment of compliance, a baseline for the number or percent of agencies 

successfully changing practices was established for subsequent years. 

The FY 2023 target for Performance Measure 5 was for 71 percent of the federal agencies 

subject to oversight and compliance reviews to change their employment practices based 

on the EEOC’s recommendations. The percent of agencies substantially implementing the 

EEOC’s recommendations was 80.3 percent. 

Performance Measure 6 for Strategic Objectives II.A. and II.B.: For each year through 

FY 2026, a significant proportion of completed investigations, conciliations, hearings, and 

federal appeals meet or exceed established quality criteria. 

Page 26 Fiscal Year 2025 Congressional Budget Justification 
 

 

Sub-Measure 6a.: By FY 2026, at least 90% of the EEOC’s charge investigations and 

conciliations meet or exceed criteria established in the Quality Enforcement Practices Plan. 

Year FY 2022 FY 2023 

Target 88% 88.5% 

Results 92.7% 93.1% 

Target Result Target Exceeded Target Exceeded 

Sub-Measure 6b.: Each year through FY 2026, at least 90% of the EEOC’s federal sector 

hearings and appeals meet criteria established in the Federal Sector Quality Practices Plan. 

Year FY 2022 FY 2023 

Target 88% 88.5% 

Results 94.6% 94.6% 

Target Result Target Exceeded Target Exceeded 

Performance Measure 6 builds on the EEOC’s previous Strategic Plan with a metric 

focused on quality in both the private and federal sector programs. In September 2015, the 

Commission approved a plan for Quality Enforcement Practices for Effective 

Investigations and Conciliations, known as the QEP. The QEP promotes the rigorous 

implementation of quality investigations and conciliations with progress goals established 

for each year of the Plan. In FY 2016, the EEOC applied the criteria established under the 

QEP to a sample of investigations and conciliations to establish benchmarks for offices to 

use in FY 2017. In FY 2018, the EEOC used those benchmarks to begin projecting future 

targets. The EEOC continues to use the FY 2018 baseline for its target projections through 

FY 2026. The increased goals for quality reviews in this plan will strengthen opportunities 

to constructively resolve cases for workers and employers through investigation and 

conciliation. 

Performance Measure 6 also provides targets for quality work in the federal sector. The 

Federal Sector Quality Practices Plan (FSQP) was approved by the Commission in January 

2017 and includes quality components for hearings and appeals. The FSQP also includes 

quality criteria for the Commission's oversight of federal agencies when reviewing 

affirmative employment and barrier analysis plans, evaluating federal agency complaint 

processes, and offering technical assistance to federal agencies. During FY 2018, the 

agency collected baseline data on the quality criteria set forth in the FSQP, in a manner 

similar to what was done to implement the QEP. Following the collection of baseline data 

based on hearings and appeals file reviews and federal agency compliance reviews, the 

agency established benchmarks for FY 2019 and subsequent years, continuing through FY 

2026. 

The FY 2023 targets for Performance Measure 6 through 6b were for at least 88.5 percent 

of the EEOC’s charge investigations and conciliations and federal sector hearings and 

appeals to meet or exceed criteria established in the QEP and FSQP. 

Fiscal Year 2025 Congressional Budget Justification Page 27 
 

 

 

 

 

 

 

By the end of FY 2023, the agency had conducted thorough reviews of closed charges to 

assess the quality of investigations and charge processing resolutions. Specifically, over 

600 completed investigations (approximately 1 percent of the EEOC’s FY 2022 

resolutions) were reviewed, as part of the agency’s qualified file reviews, sampling closed 

charges from each of the EEOC’s 53 offices. The quality file reviews resulted in an 

overall quality rating of 93.1 percent, exceeding the FY 2023 goal of 88.5 percent, for SubMeasure 6a. 

Also, during FY 2023, the agency’s hearings program evaluated the quality of 

Administrative Judge (AJ) decisions and orders, with a focus on legal analysis, accuracy, 

and writing ability/clarity. Based on these evaluations, the EEOC determined that the goal 

for Sub-Measure 6b was achieved with an average of 96.6 percent of appeals successfully 

meeting the criteria established in the FSQP. When the achievements of these two 

programs were calculated, the combined average goal for both federal sector programs 

exceeded the FSQP requirement of 88.5 percent, resulting in 94.6 percent compliance for 

FY 2023. 

Performance Measure 7 for Strategic Objectives II.A. and II.B.: By FY 2026, EEOC 

will enhance its intake services to potential Charging Parties, Respondents, and 

Representatives. 

Sub-Measure 7a.: By FY 2023, the EEOC will evaluate its intake services, determine 

baseline levels of service, and identify technological solutions and other resources to 

improve those services. 

Year FY 2022 FY 2023 

Target Evaluation completed. Evaluation completed. 

Results 

Completed evaluation involved 

evaluating the agency’s Intake 

Unit functions and staff duties. 

The evaluation of intake functions 

was completed in FY 2023, with 

emphasis on enhancing intake 

services and removing potential 

barriers to submitting inquires, 

filing charges, and the agency’s 

processing of charges. 

Target Result Target Met Target Met 

Sub-Measure 7b.: From FY 2024-2026, the EEOC will make yearly progress in 

improving availability of intake interview appointments. 

Year FY 2022 FY 2023 

Target Yearly progress made. Yearly progress made. 

Results Progress was made. 

In FY 2023, progress was made in 

the areas of evaluation, analysis, 

and identification of improvement 

areas. 

Target Results Target Met Target Met 

Page 28 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

Performance Measure 7 recognizes the importance of intake to the EEOC charge filing 

process. Intake is the first step in the investigative process. Sub-Measures 7a and 7b also 

are in line with the Government Accountability Office’s October 2022 report on the 

EEOC’s enforcement and outreach efforts, which recommended that the agency track 

intake timeframes to help assess service to the public. 

In FY 2023, the targets for Performance Measures 7 through 7b were for the evaluation of 

intake services to be completed with goals set for the following fiscal year. During the 

fiscal year, the EEOC evaluated intake services with regard to Sub-Measure 7a, determined 

baseline levels of service, and identified technological solutions and other resources to 

improve those services. Specifically, the EEOC worked to review and enhance its current 

intake process to more effectively and efficiently fulfill the agency’s mission. This 

involved evaluating improvements related to achieving greater consistency in the agency’s 

intake-related work; soliciting input from internal and external stakeholders; and obtaining 

valuable information that will allow the agency to develop a process that increases 

technological solutions to the overall intake process flow. The EEOC envisions that a new 

and innovative intake process will reduce the length of time for service delivery, remove 

language barriers, and streamline the interview process. 

In addition, several technological solutions were either launched or development was 

started during FY 2023, including the capability to track the length of the intake process in 

the fourth quarter of 2023 and the attorney E-File system. With regard to sub-measure 7b, 

the agency focused on evaluation, analysis, and identification of improvement areas during 

the fiscal year. 

C. Program Areas 

1. Private Sector Enforcement 

Management of the Charge Workload to Enforce the Nation’s Federal Workplace AntiDiscrimination Laws 

The public’s need for the EEOC’s assistance to resolve charges of discrimination continues 

to challenge the agency, even as we invest in staff and systems to strengthen our 

enforcement, deliver excellent service to the public, and promote compliance with federal 

civil rights laws. Because of the high demand for the EEOC’s services and in order to 

implement the agency’s goal to eradicate employment discrimination more effectively, in 

1995 the Commission adopted the use of Priority Charge Handling Procedures (PCHP). 

PCHP, as implemented, categorizes charges for priority handling based on the likelihood 

of an investigation resulting in a finding of reasonable cause to believe discrimination 

occurred. The EEOC uses PCHP to make determinations regarding the level of resources 

to commit to different investigations, emphasizing that the investigation for each case 

should be appropriate to the charge – taking into account the EEOC’s resources. The 

EEOC periodically renews its focus on implementation of PCHP and other strategies to 

achieve and maintain a balanced and sustainable inventory. 

In FY 2023, the agency continued to prioritize ensuring that it had sufficient staff to 

address its expanding workload. During FY 2023, the agency continued rebuilding its 

Fiscal Year 2025 Congressional Budget Justification Page 29 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

staff, which, as noted above, in FY 2020 had reached its lowest level in four decades. The 

EEOC filled 493 positions and ended the year with 2,331 employees. Notably, the 

majority of positions were filled by individuals who were new to the agency and 

predominately front-line staff (investigators, mediators, and attorneys, among other 

positions). As a result of this hiring effort, the EEOC was able to continue to address 

critical service and morale issues by restoring staffing losses in key areas. These hires also 

better positioned the agency to provide quality services to the public and ensure timely and 

appropriate resolution of discrimination charges. 

The number of field staff at the beginning of FY 2023 was 1,376, with 454 available 

investigators. Additional hiring authorizations during FY 2023 resulted in the hiring of a 

total of 380 field staff. With a focus on maintaining staffing levels, the EEOC was able to 

realize significant program accomplishments. For example, in FY 2023, despite an over 

10 percent increase in charge receipts compared with FY 2022, the EEOC ended the fiscal 

year with 51,100 pending charges, a slight decrease from the 51,399 pending charges in 

FY 2022. While changes in charge receipts from year-to-year is unpredictable, adequate 

staffing levels allow us to continue to effectively manage the workload. 

Having additional staff to focus on inventory management enhances service to the public 

and allows staff additional time and resources to devote to developing and resolving 

meritorious charges of discrimination. In FY 2023, the overall private sector merit factor 

rate was 18 percent. In addition, the EEOC secured over $440.5 million in monetary relief 

for individuals during the administrative process, including the successful resolution of 

46.7 percent of conciliations, which represented an over 2-percentage point increase from 

the 44.4 percent rate in FY 2022. The EEOC recovered $45 million for victims of 

discrimination through conciliation and pre-determination settlements in FY 2023, and 

obtained targeted, equitable relief in 98.48 percent of all conciliation agreements. 

In addition to significant hiring, we also continued to focus on additional approaches to 

utilize a multi-pronged effort to ensure that we are managing our inventory efficiently and 

providing quality service to charging parties and respondents, while focusing agency 

resources on charges where the government can have the greatest impact on workplace 

discrimination. We will continue to focus on innovative approaches and to invest in systems 

to better serve the public and advance the agency’s mission of preventing and remedying 

unlawful employment discrimination. Chart 2 on the next page shows actual pending 

inventory at fiscal year end from FY 2021 through FY 2023 and anticipated workloads 

from FYs 2024 through FY 2027. 

Page 30 Fiscal Year 2025 Congressional Budget Justification 
 

 

Chart 2: Private Sector Charges Pending – Ending Inventory 

Private Sector Charges Pending at Year End for 

FY 2021 to FY 2027 

Fiscal Year 2025 Congressional Budget Justification Page 31 
 

 

 

 

Chart 3 below depicts the actual workload for private sector enforcement for FYs 2021 

through 2023 and projected workload through FY 2027. 

Chart 3: Private Sector Enforcement Program Workload Table 

Private Sector Enforcement Program Workload Table 

FY 2021 to FY 2027 

Category FY 2021 

Act. 

FY 2022 

Act. 

FY 2023 

Act. 

FY 2024 

Est. 

FY 2025 

Est. 

FY 2026 

Est. 

FY 2027 

Est. 

Receipts 61,331 73,485 81,055 82,676 84,330 84,330 84,330 

Resolutions 62,187 65,087 81,180 67,275 72,819 75,160 75,160 

Table 5 on the next page details private sector charges received by statute for FYs 2021 

through 2023 and the projected charges through FY 2027, organized by statute. 

Page 32 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 5: Charges Filed by Statute 

Charges Filed by Statute 

FY 2021 to FY 2027 

Category 

FY 

2021 

(Act.) 

FY 

2022 

(Act.) 

FY 

2023 

(Act.) 

FY 

2024 

(Est.) 

FY 

2025 

(Est.) 

FY 

2026 

(Est.) 

FY 

2027 

(Est.) 

Title VII Only 

Charges filed 28,525 39,482 40,313 42,770 43,625 43,625 43,625 

Title VII Only 

Charges resolved 29,471 32,428 42,206 34,248 37,070 38,261 38,261 

Title VII with Concurrents* 

Charges filed 41,764 53,713 56,650 59,107 60,289 60,289 60,289 

Title VII with Concurrents* 

Charges resolved 42,683 45,862 58,325 47,869 51,814 53,480 53,480 

Age Discrimination in Employment Act Only 

Charges filed 4,386 3,414 4,519 4,225 4,310 4,310 4,310 

Age Discrimination in Employment Act Only 

Charges resolved 4,351 3,927 4,399 3,852 4,170 4,304 4,304 

Age Discrimination in Employment Act 

w/Concurrents 

Charges filed 

12,965 11,566 14,144 13,720 13,994 13,994 13,994 

Age Discrimination in Employment Act 

w/Concurrents 

Charges resolved 

13,060 12,133 13,832 12,002 12,991 13,408 13,408 

Equal Pay Act Only 

Charges filed 21 18 50 36 36 36 36 

Equal Pay Act Only 

Charges resolved 26 22 35 26 28 29 29 

Equal Pay Act with Concurrents 

Charges filed 885 815 1,012 975 994 994 994 

Equal Pay Act with Concurrents 

Charges resolved 933 926 1,106 937 1,014 1,047 1,047 

Americans with Disabilities Act Only 

Charges filed 13,030 14,126 17,246 16,742 17,077 17,077 17,077 

Americans with Disabilities Act Only 

Charges resolved 12,868 13,034 15,849 13,303 14,400 14,862 14,862 

Americans with Disabilities Act w/Concurrents 

Charges filed 22,843 25,056 29,160 28,967 29,546 29,546 29,546 

Americans with Disabilities Act w/Concurrents 

Charges resolved 22,783 23,029 27,769 23,408 25,337 26,151 26,151 

Genetic Information Nondiscrimination Act Only 

Charges filed 19 14 50 33 34 34 34 

Genetic Information Nondiscrimination Act Only 

Charges resolved 11 13 52 28 31 32 32 

Genetic Information Nondiscrimination Act 

w/Concurrents 

Charges filed 

242 361 361 387 395 395 395 

Genetic Information Nondiscrimination Act 

w/Concurrents 

Charges resolved 

237 358 416 357 387 399 399 

Total* 

Charges filed 61,331 73,485 81,055 82,676 84,330 84,330 84,330 

Total*

Charges resolved 62,187 65,087 81,180 67,275 72,819 75,160 75,160 

*Totals do not reflect issues/bases filed under more than one statute. 

**Totals for all charges do not equal the sum of all statutes because many charge filings allege issues/bases under more 

than one statute. 

Fiscal Year 2025 Congressional Budget Justification Page 33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Mediation Program 

A key component of the Commission’s enforcement strategy is the continued emphasis on 

the use of alternate dispute resolution (ADR) as an effective tool to resolve charges of 

discrimination early when appropriate. We continue to pursue efforts to secure greater 

participation by employers, using informational materials, and outreach events that 

highlight the benefits of mediation for employers. 

The program continues to receive positive feedback from participants. Based on the 

responses to an annual survey of participants in our mediation program, charging parties 

(employees, job applicants, and retirees) and respondents continue to express their 

confidence in the level of service provided under this process. In FY 2020, the survey was 

placed on hold because of the use of remote mediations. Pursuant to a contract issued in 

FY 2021, independent researchers developed an updated electronic survey that mirrored 

the EEOC’s adaptation to on-line video mediations from previously in-person sessions. 

The survey results were issued and made available to the public in June 2022 on the 

EEOC’s external website through a report entitled “EEOC Mediation Participants’ 

Experience in Online Mediation and Comparison to In-Person Mediation.” In FY 2023, 

building upon the technology enhancements implemented in FY 2022, the EEOC was able 

to timely collect electronic survey responses from its mediators and mediation participants 

concerning their experiences mediating charges via video platforms. The survey results 

indicated overwhelming satisfaction with the EEOC’s mediation program during FY 2023. 

Participants continued to view the EEOC’s voluntary mediation program as highly 

effective, fair, and neutral, and expressed strong satisfaction with the process. The surveys 

continued to show near unanimity regarding participants’ willingness to participate in the 

mediation program in the future. Specifically, 96 percent of participants (98.6 percent of 

employers and 92 percent of charging parties) indicated they would be willing to 

participate in the EEOC’s mediation program again if they were a party to an EEOC 

charge. 

The mediation program continues to enhance the Commission’s efforts to timely resolve 

discrimination charges. In FY 2023, the agency achieved 7,471 successful resolutions out 

of 10,404 charges that were mediated. During FY 2023, mediations were completed in an 

average of 143 days with over $201.2 million in benefits secured. In addition, the EEOC 

staff mediators conducted 193 federal sector mediations in FY 2023. These mediated 

resolutions not only assisted the Commission in reducing the federal sector workload, but 

it also permitted administrative judges to further concentrate their efforts on conducting 

hearings and rendering decisions in the federal complaint process. 

Outreach to employer representatives and other stakeholders highlights the value of ADR 

to resolve charges of discrimination filed with the Commission. The success of the 

mediation program encourages other employers to participate in our mediation program. 

The EEOC field offices conducted a total of 338 ADR employer events. 

Chart 4 below reflects the level of mediations projected for FYs 2024 through 2027. These 

will return to FY 2018 levels in successive years, due largely to the end of the mediation 

pilot program and additional hiring. 

Page 34 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

Chart 4: Private Sector Enforcement Program Mediations 

Private Sector Enforcement Program Mediations 

FY 2021 to FY 2027 

*May not add due to rounding 

State, Local, and Tribal Programs 

The FY 2023 appropriation for State, Local, and Tribal Programs (STLP) activities was 

$31,500,000, the same as the prior fiscal year. The EEOC is requesting an additional one 

million dollars for FY 2025, bringing the total amount to $32,500,000 to maintain the 

EEOC’s relationship with the fair employment practices agencies (FEPAs) and Tribal 

Employment Rights Offices (TEROs). Each year, the agency reimburses our partners for 

the work they perform under the authority of Title VII and the Procedural Regulations (29 

C.F.R. §1601 et seq). Historically, every three (3) years, the EEOC slightly increases the 

reimbursement amounts to help maintain good partnerships, maintain the quality of the 

work, and address inflation concerns. In FY 2025, the 90 FEPA contracts will have 

remained the same for three years and will be due for an increase. The 62 TERO contracts 

will not be due for an increase in FY 2025. SLTP’s requested funding in FY 2025 will 

address the FEPA reimbursement increase, as well as SLTP costs in the areas of training, 

conferences, outreach and engagements, licensing or services, and program support costs. 

The FEPAs help the EEOC resolve charges of employment discrimination and prevent 

duplication of effort, resulting in a more efficient use of resources for both the EEOC and 

the FEPAs. With the requested level of support for FY 2025, we expect FEPAs to resolve 

Fiscal Year 2025 Congressional Budget Justification Page 35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

at least 35,000 intake matters and charges. These resolutions would be in addition to the 

charges the EEOC resolves directly. 

Our outreach and training efforts include enhancements to encourage full utilization of 

technology and support for the SLTP staff in the EEOC field offices with updated and 

relevant tools and resources. For FY 2025, the SLTP training program will include the 

ability to conduct in-person FEPA and TERO training conferences as well as other handson, in-person, and virtual training sessions to ensure the work is performed by our partners 

at a quality level consistent with the EEOC’s expectations. The in-person sessions will 

allow us to provide more interactive education to less senior FEPA and TERO trainees in 

need of investigative skills development than can be successfully accomplished virtually. 

In addition, our ability to reach Native American/Alaska Native communities pursuant to 

White House priorities and Executive Orders requires significant efforts. In FY 2025, such 

efforts will include traveling to remote areas to educate tribal communities; using several 

media outlets such as tribal radio and social media; conducting outreach to tribal youth 

around the country by working with Tribal Colleges and Universities and other federal 

partners such as the Department of Labor and Department of Education; and a campaign to 

educate non-tribal employers operating on tribal lands. 

We have strengthened our relationship with TEROs and FEPAs and identified areas where 

we can achieve efficiencies for all parties. The primary focus continues to be on 

information sharing, training, and enhanced communication between the EEOC and its 

TERO and FEPA partners. For example, FEPAs participate in the development and 

presentation of outreach and education events, frequently joining with the EEOC field staff 

to provide training on Federal, state, and local employment discrimination laws. Similarly, 

TEROs help the EEOC in addressing issues of employment discrimination on or near tribal 

lands and the efforts on tribal lands will increase. 

Further, the Administration has made a key priority of requiring all federal agencies to 

abide by our nation-to-nation federal government trust relationship with Native American 

tribes. To this end, in FY 2022 the EEOC, pursuant to Executive Order 13175, reported to 

the White House and kept updated in FY 2023, the agency’s consultation policy and action 

plan that were created as a result of our consultation with Tribal Leaders. This engagement 

goes beyond previous agency efforts and enhances the EEOC’s ability to reach tribal 

communities to ensure they know their rights under the laws enforced by the EEOC. This 

new EEOC endeavor involves outreach to Tribal Nations, well beyond the 62 TEROs with 

whom the agency has customarily contracted. This will likely increase the actual number 

of TEROs with whom the EEOC contracts in the future. 

We have also continued to engage with our FEPA partners to implement the strategic goal 

that links the FEPAs’ accomplishments to the EEOC’s Strategic Plan. This includes 

mechanisms such as work-sharing agreements to encourage FEPA support of Strategic 

Enforcement Plan (SEP) priorities. During FY 2018 through FY 2023, we continued to 

provide training and guidance to the staff of our FEPA partners on a range of topics 

including charge processing and technical discussions. Additionally, in FY 2023, the 

EEOC increased the number of joint activities conducted with FEPAs. For the first time, 

the EEOC held a joint in-person FEPA and TERO conference at the beginning of the 

fourth quarter of FY 2023. Some sessions included both the FEPAs and TEROs while 

Page 36 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

other segments of the conference program were delivered on separate tracks to maximize 

our effort to provide training content best suited for the respective needs of our external 

partners. 

Chart 5 below shows the actual FEPA receipts, total resolutions and pending inventory for 

FY 2021 – FY 2023, and projections for FY 2024 - FY 2027. 

Chart 5: FEPA Workload Projections 

FEPA Workload Projections 

FY 2021 to FY 2027 

Category (Act.) 

FY 2021 

(Act.) 

FY 2022 

(Act.) 

FY 2023 

(Est.) 

FY 2024 

(Est.) 

FY 2025 

(Est.) 

FY 2026 

(Est.) 

FY 2027 

Receipts 28,111 34,173 37,837 35,000 35,000 35,000 35,000 

Resolutions 42,906 34,682 39,196 35,000 35,000 35,000 35,000 

Pending Inventory 44,125 53,057 51,698 51,698 51,698 51,698 51,698 

Systemic Program 

Tackling systemic discrimination – where a discriminatory pattern or practice or policy has 

a broad impact – is an integral and critical part of the mission of the EEOC. Systemic 

discrimination creates barriers to opportunity that causes widespread harm to workers, 

workplaces, and our economy. Systemic investigations and lawsuits address significant 

legal issues that have a broad impact on an industry, profession, company, or geographic 

area. 

The EEOC has worked to remove discriminatory obstacles to equal opportunity and to 

institute promising practices in thousands of workplaces. As a direct result of the EEOC’s 

systemic investigations and lawsuits, several thousands of workers have received jobs, 

Fiscal Year 2025 Congressional Budget Justification Page 37 
 

 

 

 

 

 

 

 

 

 

 

 

 

wages, and benefits and many more have benefited from positive changes in workplace 

practices. The EEOC’s success rate for conciliation of systemic matters was 46 percent in 

FY 2023. In those cases that the EEOC was not able to resolve in the conciliation process 

in FY 2023, the EEOC achieved a 100 percent success rate in the systemic lawsuits 

resolved. 

In FY 2023, the EEOC field offices resolved over 377 systemic investigations and 

obtained over $29.7 million in remedies during the administrative process as well as 

targeted equitable relief designed to change employment practices, prevent future 

discrimination, and bring employers into compliance with the law. These resolutions 

included voluntary conciliation agreements in 82 systemic investigations in which the 

Commission had found reasonable cause to believe that discrimination occurred. At the 

litigation phase, the EEOC resolved 14 systemic suits in FY 2023, obtaining just over 

$11.7 million for 806 victims of systemic discrimination and significant equitable relief. 

To continue to reinvigorate and expand the agency’s systemic program, the agency plans to 

fill positions for additional lead systemic investigators across the country in FY 2025 to 

augment the existing pool. These investigators are specially trained to identify and 

investigate systemic discrimination, obtain appropriate monetary relief for many aggrieved 

victims of discrimination, and targeted non-monetary relief to effectively change 

workplaces and prevent future discrimination. The skills needed to perform these tasks are 

specialized and distinct from the skills needed to investigate an individual or small class 

case. More systemic lead investigators will contribute to improving the number and quality 

of our systemic cases. Trial attorney hires will ensure that lead systemic investigators 

receive appropriate guidance and legal advice while investigating potential systemic 

violations. Additional labor economists and other experts will be hired to provide 

analytical support for systemic investigations, as well as consulting and testifying services 

for systemic litigation. Increased resources will be directed to key positions that will 

provide national systemic coordination. 

In FY 2023, the agency held its first in-person systemic training conference in four years. 

This conference brought together lead systemic investigators, systemic coordinators, and a 

select number of attorneys from around the country with our staff of analytic experts in the 

Office of Enterprise Data and Analytics (OEDA) and the Office of General Counsel’s 

(OGC) Research and Analytical Services (RAS). In addition, the EEOC held an in-person 

specialized training for the recently promoted lead systemic investigators. In FY 2024, the 

agency plans to have at least one in-person systemic training conference and one 

specialized systemic training for new lead investigators. The annual systemic training 

conference is invaluable to provide specialized skills training, exchange ideas, and 

strengthen the working relationships among agency offices, which is essential for this vital 

program to succeed. The specialized training will be especially beneficial as the agency 

promotes more investigators to lead systemic positions in FY 2024. 

Page 38 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Litigation 

Since 1972, the Commission’s litigation program has served a vital role in fulfilling the 

agency’s mandate to enforce the federal civil rights employment laws. The Commission 

has long emphasized that the litigation program should focus on cases that have the 

potential to impact multiple workplaces or large groups of applicants or employees, 

emerging issues where the agency’s expertise may be especially critical to achieving a 

successful outcome, and individual cases where broader law enforcement goals can be 

advanced with the successful resolution of the case. In addition, the litigation program 

focuses on population groups and geographic locations where private enforcement of antidiscrimination laws is lacking, and where individuals have minimal access to the legal 

system to protect their rights. In all its litigation, the EEOC seeks to secure targeted 

equitable relief as well as monetary relief for all aggrieved individuals. 

In FY 2023, the EEOC resolved 98 merit lawsuits in the federal district courts for a total 

monetary recovery of just over $22.6 million for 968 individuals, achieving a favorable 

result in 91 percent of all district court resolutions. From FY 2019 – FY 2022, the number 

of suit resolutions outpaced the number of new suit filings, resulting in a declining active 

docket in each of those years. The agency has begun to reverse this course with a 

significant infusion of new investigative and trial attorney staff as it rebuilds capacity after 

reaching a 40-year low point in staffing at the end of FY 2020. Many of the new attorney 

hires were placed in offices where staffing had been depleted by attrition or that 

historically have been understaffed despite significant need, notably in the southern region 

of the United States. In addition, at the end of FY 2022, the agency established a new 

Assistant Regional Attorney (ARA) position in each of its legal units to help facilitate the 

development and conduct of complex litigation, with particular attention on systemic 

discrimination. 

As a result of these recent staffing enhancements and realignments, the agency filed 143 

cases in FY 2023, representing a more than 50 percent increase over FY 2022 filings, and 

the second largest number of merits lawsuit filings by the EEOC in the past twelve years. 

Moreover, the FY 2023 lawsuits filed included 25 systemic cases, which are generally the 

most complex, large-scale, and resource-intensive of the agency’s litigation. These filings 

were almost double the number of systemic filings in each of the past three fiscal years and 

the largest number of systemic filings since FY 2018. With additional resources, the 

agency expects that it will be able to maintain its significant level of enforcement as well 

as to file an even greater number of actions on behalf of America’s workers, in all regions 

of the nation in FY 2025. 

The resources requested will permit us not only to establish an upward trend in suit filings 

to remedy discrimination, but also to better support high-impact cases. This is important 

because a credible likelihood that the Commission will pursue systemic cases in court is a 

strong incentive for compliance and, if leveraged effectively, can help reduce the need for 

employees to file individual charges. The EEOC’s cases will focus on challenges to 

systemic discrimination, including discriminatory barriers to employment, unlawful 

qualification standards, systemic racism, and patterns of sexual, religious, and other forms 

of harassment. In addition, cases will focus on other high priority issues, such as 

protecting the rights of LGBTQI+ individuals, protecting the rights of immigrants and 

Fiscal Year 2025 Congressional Budget Justification Page 39 
 

 

 

 

 

 

 

 

 

 

 

 

 

other vulnerable populations, addressing the continuing civil rights impact of the COVID19 pandemic, and pay/compensation discrimination cases. We also expect to bring cases 

involving artificial intelligence and the use of automated systems in employment, 

particularly in the hiring process. 

With the Commission’s receipt of charges under the newly enacted Pregnant Workers’ 

Fairness Act, the agency anticipates an uptick in its litigation filings involving claims of 

unlawful denial of reasonable accommodation for pregnancy, childbirth, or related medical 

conditions, as well as unlawful retaliation and interference. While the Commission has 

engaged in extensive outreach and training to covered entities to ensure compliance with 

these new PWFA obligations and will continue to pursue voluntary compliance, it is 

expected that litigation will be necessary to achieve compliance in many instances given 

the large number of employees across industries and types of employment who may 

request and be entitled to accommodations. 

Further, the agency expects potential increased litigation and amicus curiae participation as 

lower courts apply new Supreme Court jurisprudence involving the federal EEO statutes. 

For instance, both the Supreme Court’s recent decision in Groff v. DeJoy clarifying the 

undue hardship defense for Title VII religious accommodation and the Court’s anticipated 

decision during the 2023-2024 term in Muldrow v. St. Louis addressing types of 

employment actions subject to Title VII protections, may result in selected Commission 

litigation applying and interpreting Title VII as clarified under the new precedents. 

Moreover, the agency anticipates it will file lawsuits relating to claims of workplace 

discrimination based on national origin or religion in the wake of violence in Israel and 

Gaza. 

At the end of FY 2023, the Office of General Counsel had 160 trial attorneys employed 

nationwide. With this proposed budget, in FY 2025, the agency plans to strategically hire 

much-needed additional trial attorneys in field offices and a limited number of new 

attorneys and in-house analytic experts in headquarters, and to continue backfilling 

attorney vacancies when they occur so that the agency can preserve and increase the 

demonstrated results in its litigation program. These hires will help ensure that each 

district is appropriately staffed and supported, will equip the agency to continue rebuilding 

its docket and litigate high-impact cases, across the nation, and provide increased legal 

support and guidance to the agency’s investigative staff. In addition, as its docket expands, 

the agency expects increases in litigation expenses. Much of the agency’s litigation 

requires depositions, expert witness contracts, and litigation support expenses. As the 

effects of the pandemic recede further and more courts return to in-person proceedings, the 

agency expects an increase in travel expenses. The agency also plans to continue its 

investments in training and litigation technology. Investments in infrastructure will better 

position the agency to advance its civil rights mission. 

2. Federal Sector Programs 

Section 717 of the Civil Rights Act of 1964, as amended; Section 501 of the Rehabilitation 

Act of 1973, as amended; the Age Discrimination in Employment Act of 1967, as 

amended; the Equal Pay Act of 1963; the Genetic Information Nondiscrimination Act of 

2008; Pregnant Workers Fairness Act of 2022 (PWFA ), the Government Employee Rights 

Act (GERA) of 1991; and Executive Order (EO) 11478, as amended by EOs 12106, 

Page 40 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

13087, and 13152; and EOs 13145, 13164, 13548, 13985, and 14035 provide the 

Commission with its mandate that all federal personnel decisions be made free of 

discrimination, and requires federal agencies to establish affirmative programs of equal 

employment opportunity (EEO) for all federal employees and job applicants (42 U.S.C. 

§2000e-16 and 29 U.S.C. §791). Under these laws, and through subsequent statutes and 

amendments, Congress and the President gave the EEOC oversight responsibility over 

EEO programs in the federal government to ensure that equality of opportunity is provided 

to the nearly 2.1 million people across the country and around the world who have 

dedicated their careers to public service. EEOC Management Directive 715 (MD-715) is 

the roadmap that guides federal agencies in identifying and removing barriers to equal 

employment opportunity so that the American people have a model federal work force that 

fully reflects the contributions, skills, and talents of all its employees. Additionally, the 

EEOC Management Directive 110 provides federal agencies with Commission policies, 

procedures, and guidance relating to the processing of employment discrimination 

complaints governed by the Commission’s regulations in 29 C.F.R. Part 1614 

Congress mandated that the EEOC act as the enforcement authority for complaints of 

discrimination brought by applicants and employees in the federal sector. The 

Commission implements this authority through regulations that establish procedures for 

federal employees or job applicants to file complaints of employment discrimination. The 

federal agency accused of discrimination is responsible for informal counseling, and, if a 

complaint is filed and that complaint is accepted, the federal agency is also responsible for 

investigating the claims raised therein. At the conclusion of the investigation, or after 180 

days following the filing of a complaint, the complainant may request a hearing before an 

EEOC Administrative Judge (AJ). Instead of requesting a hearing, the complainant may 

request that the agency issue a final decision on the matter. The federal agency’s final 

decision, or final action after a hearing, may be appealed to the Commission. 

On January 1, 2021, Congress enacted the Elijah E. Cummings Federal Employee 

Antidiscrimination Act of 2020 or the Cummings Act. The Cummings Act amended the 

No FEAR Act that requires that federal agencies post findings of discrimination (including 

retaliation) from any final action of the agency, the EEOC, or a court of jurisdiction, after 

all appeals are exhausted. Agencies must publish each notice for one year. 

Federal Sector Enforcement Activities 

The EEOC enforces statutes that require all federal agencies to establish equal employment 

opportunity programs for all federal employees and job applicants. The EEOC has 

adjudicatory responsibilities in the federal EEO complaints process as well as oversight 

responsibilities to ensure that agencies are compliant with all of the Commission’s 

regulations, decisions, policies, and directives. 

The EEOC strives to make sure that the federal government is the leader in establishing a 

workplace that is inclusive and free from barriers. This environment empowers employees 

to attain outstanding outcomes in their service to the nation. Concurrent with these efforts, 

federal agencies must position themselves to attract, develop and retain a highly qualified 

workforce that can deliver results. Equal opportunity in the federal workplace is key to 

accomplishing this goal. 

Fiscal Year 2025 Congressional Budget Justification Page 41 
 

 

 

 

 

 

 

 

 

 

 

 

Federal Sector Improvements – Hearings 

The overarching goal of the EEOC’s federal sector program is to enforce the nation’s laws 

prohibiting employment discrimination in the federal workplace. One way the 

Commission fulfills this mandate is through its vigorous federal sector hearings program. 

With 24 hearing units located throughout the United States, the program provides federal 

sector complainants with a full, fair, and impartial adjudication of their EEO complaints. 

In FY 2023, through the federal sector hearings program, the EEOC secured more than 

$181.6 million in benefits for federal workers (a 45 percent increase from FY 2022). 

Notably, this relief included over $85 million in settlements of significant federal sector 

class action cases. 

During FY 2023, the Commission received a total of 6,641 hearings requests, which 

reflects a decrease of 2.1percent compared with the number received in FY 2022 (6,785). 

Additionally, in FY 2023, the Commission’s hearings program resolved a total of 8,669 

complaints, with a focus on resolving older cases and utilizing case management strategies 

to balance field inventories through the resolution of older cases and the closure of 

incoming cases. During FY 2023, resolutions resulted in a 96.8 percent reduction of 

pending cases that were between 600 and 999 days old, and a 95.1 percent reduction of 

pending cases that were over 1,000 days old. The focus on aged cases also resulted in a 25 

percent reduction in the average age of the overall pending federal hearings inventory. 

The reduction of pending and aged inventory will have a positive impact on the agency’s 

ability to more timely process the hearings complaints received and better serve 

participants in the hearings process. 

We project, as shown in Table 6 on the next page, a focus on processing enhancements 

implemented and level staffing, ensuring pending inventory levels do not significantly 

increase. 

Page 42 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

Table 6: Hearings Workload Projections 

Hearings Workload Projections 

FY 2021 to FY 2027 

Workload FY 2021* 

(Actual) 

FY 2022* 

(Actual) 

FY 2023 

(Actual) 

FY 2024 

(Estimate) 

FY 2025 

(Estimate) 

FY 2026 

(Estimate) 

FY 2027 

(Estimate) 

Hearings 

Beginning 11,666 10,227 7,657 5,642 5,972 6,802 7,882 

Receipts 7,664 6,785 6,641 7,000 7,500 7,750 8,000 

Consolidations (23) (18) (8) (20) (20) (20) (20) 

Total 

Workload 19,307 16,994 14,290 12,622 13,452 14,532 15,862 

Resolutions 9,082 9,336 8,669 6,650 6,650 6,650 6,650 

Pending 10,225 7,657 5,642 5,972 6,802 7,882 9,212 

*Pending beginning inventory adjusted to reflect case activity spanning FYs. 

These workload projections include the positive impact we anticipate with the full 

implementation of the Federal Case Management System. 

The key feature of the hearings Case Management Plan is the requirement that the EEOC’s 

AJs hold an initial conference at the start of the hearings process. The underlying principle 

is that early proactive intervention by the AJ, especially prior to the start of discovery by 

the parties, will lead to more efficient adjudication of cases and an overall reduction in the 

time and resources spent on a case. The results from the hearings Case Management 

System are positive. The initial conferences facilitate settlement and set the parties’ 

expectations and provide an opportunity to discuss how much discovery is needed. 

Identified benefits include: 1) early education; 2) early mediation; 3) early identification of 

issues/partial dismissals/amendments; 4) fewer motions; and 5) greater time to dedicate to 

the more substantial and complicated cases, and to conduct research on novel issues. We 

will continue to evaluate and quantify the efficiencies gained through this Case 

Management System while also working to identify the most effective practices to increase 

efficiencies across the agency. 

The agency continued its focus on expanding the use of technology to make the federal 

hearings and appeals process faster and more effective. For more than eight years, the 

EEOC has provided agencies with a digital method for submitting complaint-related 

documents. During FY 2015, this digital process was enhanced and integrated into our 

Federal Sector EEO Portal (FedSEP). The EEOC Public Portal also provides complainants 

with the capability of accessing hearings and appeals cases, uploading, and transmitting 

hearings and appeals-related documents, and receiving hearings-related documents issued 

by the agency and the AJ, as well as the appellate decisions issued by the Commission. 

Fiscal Year 2025 Congressional Budget Justification Page 43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

The system also allows complainants to request a hearing or appeal online; and to review 

the status of the hearing or appeal case. In addition to the gains in efficiency and cost 

savings, these technological innovations will make the hearings and appeals process more 

transparent for all parties and help reduce the agency’s reliance on support staff to prepare 

and scan paper documents received by the parties. 

Priorities for the federal sector hearings program included exploring additional tools to 

leverage technology in order to increase both the quality and efficiency of decisions issued 

by its AJs, thereby helping to manage the growing hearings inventory. The EEOC has 

made similar case management efforts with respect to class actions filed against the federal 

government and adjudicated by the hearings program. During FY 2023, approximately 

40,000 federal individual employees were included in several class actions. Such 

investments will further improve service and increase efficiencies for federal employees 

and federal agencies utilizing the federal sector hearings process. 

In FY 2023, the EEOC continued the “AJ Academy,” the first national training program 

for AJs, which was launched in FY 2022. The AJ Academy provides effective and 

consistent legal education, case updates, and case management best practices on a yearly 

basis. 

Further, through coordinated collaboration between the EEOC’s Office of Field Programs 

and Office of Federal Operations, the EEOC continued the Federal LINKUP initiative, 

which launched during FY 2022. LINKUP facilitates consistency and communication 

within the EEOC’s federal sector community. 

Chart 6 on the next page demonstrates the workload and number of AJs assigned to handle 

hearings complaints for FYs 2021 through 2023 and projections for FYs 2024 through 

2027. The increases in resolutions in FYs 2021 and 2022 reflect the continued use of the 

case management procedures highlighted above. The decline in inventory levels has 

allowed for more timely processing of both newly filed and older cases using the enhanced 

procedures. We anticipate this prompting a decline in the pending inventory through FY 

2024, then a modest but manageable increase thereafter. 

Page 44 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

Chart 6: Federal Sector Hearings Workload 

FY 2021 to FY 2027 

Federal Sector Appeals Programs 

One vital function of the EEOC is its comprehensive program designed to advance equity 

in federal government employment, including for people of color, those in the LGBTQI+ 

community, and others who have been historically underserved, marginalized, and 

adversely affected by persistent inequality. With the goal of advancing equal opportunity 

for all, the EEOC is responsible for serving as the neutral arbiter in the federal sector for 

appeals from agency decisions on equal employment opportunity (EEO) complaints, 

collective bargaining agreement grievances alleging discrimination against federal 

agencies, and reviewing decisions by the Merit Systems Protection Board containing 

allegations of discrimination in appealable actions under 29 C.F.R. Part 1614. 

The appellate decisions issued by the Commission develop and promulgate the 

Commission's policy and legal interpretation on emerging and evolving civil rights law 

that impacts not only the federal sector, but also workers and employers throughout the 

nation. Finally, the EEOC’s federal sector appellate decisions serve to educate federal 

sector complainants, federal agencies, and the public sector about the law; guide federal 

agencies in their efforts to become model workplaces; and advance the public interest in 

eradicating discrimination in federal employment. To this end, the EEOC’s appellate 

decisions are disseminated to several commercial publishing services as well as posted on 

the Commission’s website. In addition, the EEOC’s website identifies noteworthy 

decisions on current legal topics. 

Fiscal Year 2025 Congressional Budget Justification Page 45 
 

 

 

 

 

 

 

 

 

 

 

Advancing equity requires a systematic approach to embedding fairness in decisionmaking processes. The Commission ensures that its federal appellate adjudicatory 

functions are fair and efficient, and that the decisions the EEOC issues apply relevant law 

and precedent to the unique facts presented in each individual case. The EEOC's federal 

sector appellate attorneys exercise this adjudicatory responsibility while at the same time 

recognizing their responsibility to effectively manage the appellate inventory to ensure that 

decisions are issued as expeditiously as possible. The table below details the EEOC's 

appellate adjudication results and projections. 

Table 7: Appeals Workload Projections 

FY 2021 to FY 2027 

Workload FY 2021 

(Act.) 

FY 2022 

(Act.) 

FY 2023 

(Act.) 

FY 2024 

(Est.) 

FY 2025 

(Est.) 

FY 2026 

(Est.) 

FY 2027 

(Est.) 

Appeals 

Beginning 3,381 3,416 3,503 4,116 8,628 3,983 4,688 

Receipts 4,207 4,212 4,343 8,618 4,838 4,418 4,418 

Total 

Workload 7,588 7,628 7,846 12,734 13,466 8,401 9,106 

Resolutions 4,172 4,125 3,730 4,106 9,483 3,713 3,780 

Pending 3,416 3,503 4,116 8,628 3,983 4,688 5,326 

Table 7 above identifies the actual workload for FYs 2021, through 2023, and projected 

workload for FY 2024 through FY 2027. The workload reflects a steady increase in 

appellate inventory resulting from a projected increase in appeals received in FY 2023 due 

to a surge in AJ resolutions and other pilot projects, while attorney staffing remains level, 

with a significant projected increase in appeals received in FY 2024 in connection with the 

adjudication of a nation-wide class action with over 25,000 class members. 

In its effort to eliminate discrimination in the federal sector, the EEOC’s federal sector 

appellate program issues appellate decisions; orders make whole relief to victims of 

discrimination; orders that responsible agency officials receive appropriate training; orders 

agencies to consider taking discipline against responsible agency employees; refers, as 

appropriate, appellate decisions to the Office of Special Counsel (OSC) for the 

consideration of discipline under OSC’s prohibited personnel action authority; requires 

agencies to post notices to all employees of decisions finding discrimination at the relevant 

agency facility; and ensures agency compliance with such orders. 

The EEOC’s federal sector appellate program has been engaged in ongoing efforts to 

improve quality by addressing circumstances and interactions essential to creating a highfunctioning, dynamic environment, and seeking broader collaboration with the EEOC’s 

other federal sector components. In this effort, the EEOC’s federal sector appellate 

program identified several areas on which to focus improvement, including handling large 

caseloads with limited resources; improving communication between the EEOC’s federal 

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sector hearings, appellate adjudication, and agency oversight components; streamlining 

process enforcement and accountability outside of the EEOC’s federal sector appellate 

program to complete cases in a timely manner; and acknowledging and recognizing the 

efforts and accomplishments of EEOC staff. 

The EEOC has been successful in managing its appellate inventory in part through 

improvements in technology. The EEOC has reaped the benefits in efficiency and cost 

savings resulting from FedSEP and the Public Portal, the digital infrastructure established 

for the exchange of hearings and appeals related documentation. Further, the EEOC has 

continued to provide technical assistance to agencies and made numerous refinements to 

the Portal used by federal agency EEO professionals and attorneys based on their feedback. 

For complainants, the EEOC continues to encourage and educate complainants on the use 

of the EEOC Public Portal. The EEOC promotes complainants’ use of the Public Portal by 

requiring federal agencies to proffer the Portal as one means of filing requests for hearings 

and appeals; notifying complainants of the existence and efficiency of using the Portal in 

acknowledgment letters; and including the Portal as an optional filing tool in recent 

revisions to its regulations. 

In addition to leveraging technology to improve the processing of appeals, the EEOC is 

using its Case Management System to bring consistency and greater efficiencies to the 

processing of federal sector matters through the early categorization of appeals. 

Promptly identifying emerging and priority issues is vital in advancing Commission goals. 

Cases involving issues of racial justice, intersectionality, systemic discrimination, pay 

equity and unlawful retaliation can be identified and prioritized. 

The EEOC’s federal sector appeals program has begun implementing a plan to establish a 

Case Assessment Group to ensure that we are effectively managing caseloads and 

identifying cases with broader impact. As envisioned, this group would be comprised of 

paralegals working in concert with EEOC federal sector attorneys to engage in a robust 

system of case assessment and categorization soon after appeals are filed. 

In addition, at this initial assessment, cases involving Commission priorities are identified 

and directed to the appropriate groups/teams for processing. Once fully created, the group 

would be able to conduct more extensive assessments soon after appeals are filed by 

identifying cases where the appellate decision could result in a broader and more systemic 

impact, establish precedent-setting legal analysis, and/or further the EEOC’s federal sector 

proactive prevention efforts. 

The EEOC will continue to enhance its security requirements for its key staff and offices. 

Security enhancements consist of the security clearances for certain program officials 

(AJ’s, appellate attorneys, senior staff). These measures will help to ensure full, fair, and 

impartial adjudication of EEO complaints of certain hearings and appeals in which the 

intelligence community (IC) and Department of Defense (DoD) agencies are impacted. 

The EEOC’s appellate program also implemented a process for reviewing and streamlining 

the processing of high priority resolutions, thus providing the federal sector appellate 

program more opportunity to focus on appellate resolutions. Through this process, issues 

Fiscal Year 2025 Congressional Budget Justification Page 47 
 

 

 

 

 

 

 

 

 

are vetted, discussed, and resolved, thus expeditiously streamlining the path for the 

resolution of the case. 

The Federal Sector Quality Practices Plan continues to ensure the delivery of excellent and 

consistent service in the EEOC’s adjudication of federal sector hearings and appeals and 

fulfill the Commission’s oversight responsibilities for ensuring federal agencies’ 

compliance with EEO laws. To manage the federal sector appellate inventory while 

providing excellent customer service to our stakeholders, we have implemented a more 

robust targeted case management plan. Goals are focused on resolving aged inventory 

while concurrently resolving a significant number of new appeals within 180 days. In 

addition, the cases involving Commission priorities have been expeditiously processed to 

establish precedent in new and emerging areas of employment law. For example, cases 

involving priorities set forth in the Strategic Enforcement Plan have been issued involving 

sexual orientation discrimination issues, Equal Pay Act matters, Pregnancy Discrimination 

Act cases, Genetic Information Nondiscrimination Act, and class actions. 

As a result of these efforts, at the end of FY 2023, the EEOC had issued 3,730 appellate 

decisions and made 78 findings of discrimination. During this same period, the EEOC's 

appellate program secured $21.1 million in monetary relief for victims of discrimination in 

the federal sector. In addition, the EEOC's federal appellate program issued 64 decisions 

that addressed one or more of the priority issues identified in the EEOC's Strategic 

Enforcement Plan (SEP). 

Chart 7 below identifies the actual workload inventory and number of attorneys assigned to 

adjudicate appeals of EEO complaints for FYs 2021, 2022 and 2023, and projections for 

FYs 2024 through 2027. 

Chart 7: Federal Sector Appeals Workload 

FY 2021 to FY 2027 

Page 48 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

Appellate cases addressing access to the overall federal sector EEO Complaint process 

represent about 40 percent of the incoming appeals. One strategy the EEOC plans to 

utilize to address this is the development of Federal Sector EEO Shared Services. This 

will include the development of a government-wide Federal Sector EEO Complaint 

Management System. Additionally, the EEOC will continue to explore strategies to slow 

the rate of growth of its inventory by using sound case management principles and process 

improvement techniques without compromising quality. The EEOC will control the 

appellate inventory by focusing on resolving its oldest cases; prioritizing cases with the 

broadest impact; quickly addressing those appeals that seek to preserve access to the EEO 

process; and setting in place procedures to address an expected influx of a large number of 

appeals from the adjudication of a nationwide class action case. The EEOC will continue 

to fulfill its responsibilities under the Strategic Enforcement Plan and the Federal 

Complement Plan (which identifies how the federal sector implements the Strategic 

Enforcement Plan priorities) and the Commission's Strategic Plan. 

Oversight of Federal Agencies’ EEO Programs 

The EEOC has oversight responsibility for ensuring that federal agencies maintain 

continuing affirmative programs to promote equal opportunity and to identify and 

eliminate any barriers to participation. The EEOC’s Management Directive 715 (MD-715) 

serves as the roadmap and tool kit for agencies to achieve the overall goal of making the 

federal government a model EEO workplace. MD-715 requires agencies to assess their 

progress and programs on at least a yearly basis on: (1) agency leadership’s demonstrated 

commitment to EEO; (2) integration of EEO into the agency's strategic mission; (3) 

management and program accountability; (4) proactive prevention of unlawful 

discrimination; (5) complaint processing efficiency; and (6) responsiveness and legal 

compliance with the EEOC’s regulations and orders. 

The EEOC works with agencies to promote model EEO program policies and practices 

that foster an inclusive work culture and prevent employment discrimination by using a 

number of oversight tools. These include technical assistance visits followed by written 

feedback, formal program evaluations, opportunities to pilot new complaint processing 

techniques designed to enhance efficiency, technology advances, issuing Notice of Noncompliance to enhance compliance, researching, and producing analytical reports on topics 

of interest to the federal EEO community, and providing fee-based and no-cost training 

and outreach to the federal community. The EEOC sets new oversight goals each fiscal 

year that are tailored to achieve improvements, address emerging issues, and promote the 

government’s goal of becoming a model EEO employer. 

For FY 2023, the EEOC established several technical assistance goals. The first was to 

ensure that 90 percent of agencies have compliant reasonable accommodation procedures 

by the end of FY 2023. To meet this goal, our staff discussed the status of the procedures 

with the agencies during technical assistance meetings and provided written feedback to 

agencies, upon request. During FY 2023, 182 out of 198 agencies, or 91.9 percent of 

federal agencies that received EEOC feedback had compliant reasonable accommodation 

procedures. The EEOC also established a goal ensuring that 75 percent of federal agencies 

had a compliant anti-harassment policy by the end of FY 2023. By the end of FY 2023, 

the FY 2023 goal was met, as 80.3 percent, or 163 out of 203 federal agencies that received 

Fiscal Year 2025 Congressional Budget Justification Page 49 
 

 

 

 

 

 

 

 

 

 

 

 

 

FSP feedback had compliant anti-harassment policies. Moreover, the EEOC established a 

goal to conduct 55 technical assistance visits with agencies in FY 2023 and issue a 

feedback letter within 180 days of each visit. Throughout FY 2023, the EEOC staff have 

conducted 68 technical assistance visits with agencies and timely issued 97 percent of the 

feedback letters. 

The EEOC continues to conduct research that it shares with agencies to assist them in 

maintaining continuing affirmative employment programs to promote equal opportunity 

and to identify and eliminate any barriers to full and fair workplace participation. In FY 

2023, the EEOC issued the following reports and legal articles and made them available on 

our public website. 

• Annual Report on the Federal Workforce FY 2020. 

• Alternative Dispute Resolution in the Federal Sector. 

• Promising Practices for Preventing Harassment in the Federal Sector. 

• Second Chances Part I - Federal Employment for Workers with Past Arrests or 

Convictions. 

• Second Chances Part II - History of Criminal Conduct and Suitability for Federal 

Employment. 

• Timeliness of Merit Final Agency Decisions in the Federal Sector. 

• The Offer of Resolution Settlement Procedure in the Federal Sector. 

Concurrent with these oversight responsibilities in the federal sector, the Commission 

continues its education efforts to assist all stakeholders by: (1) creating and conducting feebased training through the Revolving Fund; (2) creating and conducting customized EEO 

training for EEO professionals, managers, employees and other stakeholders; (3) forming 

strategic partnerships, and (4) participating in free outreach activities, including 

conferences, summits, meetings and other events where the Commission's presence would 

add value. 

Through the EEO Education Consortium, a 1,000+ member community of practice, the 

EEOC offers learning opportunities, networking events, and a federal mentoring program 

to engage current EEO practitioners and leaders. The Federal Mentorship Program piloted 

in FY 2023 with 86 participants and 42 matched mentor/mentee pairs. The mentoring 

program included six interactive sessions for participants and culminated with a 

Completion Ceremony. Participant comments and feedback underscored the development 

gap filled through this program, which provided a venue for growth and development of 

future EEO leader and current practitioners. 

The EEOC also made significant strides in broadening the Commission’s reach by way of 

no-cost outreach initiatives such as webinars, online information sessions, and social 

media. The EEOC staff delivered 14 no-cost webinars and 12 podcasts to the federal 

community on various current and novel EEO and DEIA issues. 

Alongside the effort to expand its presence on social media platforms for better stakeholder 

engagement, the EEOC actively took part in notable stakeholder conferences, including 

those organized by Asian American Government Executive Network, Blacks in 

Government, Federal Dispute Resolution, Federal Asian Pacific American Council, 

Page 50 Fiscal Year 2025 Congressional Budget Justification 
League of United Latin American Citizens, and the EEOC-hosted EXCEL Conference. 

Through these conferences, the staff delivered training, offered updates, and shared 

educational information with a variety of stakeholders. 

Fiscal Year 2025 Congressional Budget Justification Page 51 
 

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VII. STRATEGIC GOAL II - Prevent employment discrimination and advance 

equal employment opportunities through education and outreach. 

A. Introduction 

Investigations, mediations, conciliations, and litigation are only some of the means that the 

EEOC uses to fulfill its mission and vision. Title VII, expressly requires the agency to 

engage in education and outreach activities, including providing training and technical 

assistance, on the laws enforced by the EEOC. Strategic Goal II, to prevent employment 

discrimination and advance equal employment opportunities through education and 

outreach, reflects the EEOC’s obligation to deter employment discrimination before it 

occurs. Educational and outreach programs, projects, and events are also cost-effective 

law enforcement tools because they promote understanding of the law and voluntary 

compliance. All parties benefit when the workplace is free of discrimination, and everyone 

has access to equal employment opportunity. 

There are two objectives for Strategic Goal II: 

Strategic Objective II.A: Members of the public are aware of employment discrimination 

laws and know their rights and responsibilities under these laws; and 

Strategic Objective II.B: Employers, federal agencies, unions, and staffing agencies have 

the information and guidance necessary to advance equal employment opportunity, prevent 

discrimination, and effectively address EEO issues. 

The EEOC aims its education and outreach program primarily toward individuals in 

communities that historically have been subjected to employment discrimination. The 

Commission also provides outreach and education to particularly vulnerable communities 

that may be unfamiliar with EEO laws, or unwilling or unable to exercise their rights under 

these laws, such as individuals who are new to the workforce, immigrants, or migrant 

workers. Moreover, it is important for the agency to provide technical assistance to 

underserved segments of the employer community, including small, new, and 

disadvantaged businesses. Given their size and limited resources, such businesses are 

often less able to take advantage of the EEOC’s training programs and are less likely to 

have in-house human resources professionals to assist them with compliance. 

The EEOC has a robust education and outreach program that provides both free and feebased opportunities for stakeholders and the public. In FY 2023, the EEOC provided free 

and fee-based training on rights and responsibilities under its statues to 314,199 individuals 

at 3,318 events. 

The EEOC often cooperates with other agencies in the performance of educational and 

outreach activities. The EEOC’s 90 State and local FEPAs and the approximately 62 

TEROs, discussed above, are important partners in this regard, as are the Department of 

Labor’s Office of Federal Contract Compliance Programs and the Department of Justice’s 

Civil Rights Division. 

The EEOC’s efforts to strengthen and focus its education and outreach activities have 

included increasing its use of technology and expanding the EEOC’s social media 

Fiscal Year 2025 Congressional Budget Justification Page 53 
 

 

 

 

 

presence. The EEOC’s website provides critical educational materials, including 

information on the laws the agency enforces, the private sector charge and federal sector 

complaint processes, data, and research. The agency has continued to make progress 

toward making its website more user-friendly and accessible. The EEOC’s Strategic Plan 

emphasizes the need to leverage technology to directly reach the agency’s varied and wideranging audiences – including employees, jobseekers, employers, unions, employment 

agencies, attorneys, judges, civil rights and other organizations, issue advocates, and 

policymakers. In addition, the EEOC continues to enhance its use of social media to 

promote its education and outreach activities and to encourage greater use of the website. 

With a continued focus on providing clear, easy-to-understand materials for a diverse array 

of audiences, the Strategic Plan also provides that the EEOC will review its sub-regulatory 

documents and update or augment them as appropriate with accessible and plain language 

materials. 

Finally, in addition to the private sector outreach discussed above, continued emphasis on 

outreach and education in the federal sector is equally important to the EEOC’s efforts to 

promote broad compliance with federal workplace anti-discrimination laws. In FY 2022, 

the EEOC built upon its robust education and outreach program that focuses on both free 

and fee-based education and training opportunities in the federal sector and leveraged the 

use of technology to strengthen and expand the impact of its federal sector education and 

outreach activities. In total, the EEOC delivered nearly 200 federal sector outreach, 

education, and training events, and provided more than 18,000 federal sector employees 

and EEO professional with information about employment discrimination and their rights 

and responsibilities in the workplace. This Plan leverages these activities and relationships 

to drive the creation of a government-wide network to provide information about leading 

practices in the Federal Sector. 

The EEOC developed four performance measures to track its progress in achieving the 

objectives for Strategic Goal II. 

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B. Performance Measures and Results 

Performance Measure 8 for Strategic Objectives II.A. and II.B.: By FY 2026, the 

EEOC leverages technology, analytics, and innovative outreach strategies to provide 

members of the public greater access to information about their rights and responsibilities. 

Year FY 2022 FY 2023 

Target 

The agency will implement and 

report on at least four projects in 

which it has leveraged technology, 

analytics, and innovative outreach 

strategies to increase access to 

information to vulnerable 

communities consistent with the 

Strategic Enforcement Plan (SEP). 

The agency will implement and 

report on at least four projects in 

which it has leveraged technology, 

analytics, and innovative outreach 

strategies to increase access to 

information to vulnerable 

communities consistent with the 

SEP. 

Results 

The EEOC implemented at least four 

projects in which it leveraged social 

media, videos, and translated 

webpages to increase access to 

information to vulnerable 

communities consistent with the 

Strategic Enforcement Plan, 

specifically it implemented social 

media campaigns on race and color 

discrimination, pregnancy, and 

Youth@Work; posted Spanish 

language videos and an American 

Sign language video; and posted an 

additional 18 translated webpages in 

6 languages, 52 new documents in 

Spanish and 18 press releases in 

Spanish. 

During FY 2023, the EEOC 

implemented at least four projects 

in which it leveraged social media, 

videos, and translated webpages to 

increase access to information to 

vulnerable communities consistent 

with the SEP. Specifically, it 

coordinated updates and revisions 

to the Know Your Rights Poster, 

implemented social media 

campaigns on pregnancy, equal 

pay, and reasonable 

accommodations for individuals 

with disabilities, and added 

additional translated webpages. 

Target Result Target Exceeded Target Exceeded 

Performance Measure 8 focuses on using technology, analytics, and innovative outreach 

strategies to strengthen and expand the impact of the EEOC’s education and outreach 

activities in reaching vulnerable communities consistent with the EEOC’s SEP. This will 

be accomplished by utilizing analytics and metrics to directly measure the impact of each 

effort to reach communities. If the effort is successful, it should be incorporated into the 

EEOC’s efforts moving forward. If the effort does not reach the intended audience – 

balancing the level of effort with the results-then the technology or strategy should be 

modified. By using this process, the EEOC can continue to grow and expand its ability to 

reach vulnerable communities with information critical to expanding equal employment 

opportunity. 

The FY 2023 target for Performance Measure 8 was for the EEOC to implement and report 

on at least four projects in which it has leveraged technology, analytics, and innovative 

outreach strategies to increase access to information to vulnerable communities consistent 

with the SEP. 

During the fiscal year, the agency increased access to information by leading the effort to 

update the agency’s “Know Your Rights” poster, which was originally released in October 

Fiscal Year 2025 Congressional Budget Justification Page 55 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2022. Covered employers are required by federal law to prominently display the poster at 

their work sites. The poster summarizes the laws enforced by the EEOC and explains to 

employers their legal responsibilities under those laws. It also describes workers’ rights 

and explains how to contact the EEOC for assistance if an employee or an applicant wants 

to file a charge of discrimination. A further updated Know Your Rights Poster was posted 

in June 2023 to reflect changes required by the Pregnant Workers Fairness Act (PWFA). 

The EEOC included a QR code to the agency’s “How to File a Charge” page on the poster 

so individuals could more easily access that information particularly vulnerable 

populations who are viewing a physical copy of the poster and may not have easy access to 

a computer. The poster is available in English and was translated into and made available 

in 8 languages – Spanish, Arabic, Chinese (simplified and traditional), Haitian Creole, 

Korean, Russian, Tagalog, and Vietnamese. Previously, the poster had only been available 

in English, Spanish, Arabic, and Chinese. Audio files were posted, for the first time, in 

English and Spanish. 

The agency implemented several social media campaigns, one of which focused on 

reasonable accommodations for individuals with disabilities to coincide with the 50th 

Anniversary of the Rehabilitation Act. Another campaign was aimed at workers who may 

be unaware of their rights to equal pay. Because June 21, 2023, marked the 60th 

Anniversary of the Equal Pay Act, the EEOC initiated a type of social media campaign that 

had never previously been undertaken at the EEOC. 

As part of the Instagram-focused campaign, EEOC leaders, other public officials, charging 

parties, celebrities, and the public were asked to make short videos explaining why equal 

pay is important to them. In the two weeks after the campaign launched, the agency 

reached 23,000 accounts, including 20,000 non-followers, allowing the EEOC to reach 

people who do not generally see the agency’s content. As a result, the agency reported a 

10 percent increase in followers. 

Because the PWFA was enacted on December 29, 2022, creating, and distributing 

information aimed at vulnerable workers who were unaware of the new law or reluctant to 

exercise their rights was an important priority in FY 2023. The EEOC created a number of 

informational products to inform workers and employers about the new law and their rights 

and responsibilities under the PWFA, including infographics, a poster for health care 

providers to post in patient waiting rooms, Know Your Rights videos, and a webinar for 

employers. 

The agency distributed information about the PWFA through a variety of means, including 

social media, print, and online media outlets, and to subscribers of EEOC news, reaching 

millions of people. 

The EEOC posted an additional 162 new pages of content in languages other than English, 

including adding materials in traditional Chinese, bringing the total amount of content to 

over 600 webpages. Consistent with the SEP, providing additional access to information to 

individuals with limited English proficiency will enable the EEOC to reach vulnerable 

workers in their native language. 

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Performance Measure 9 for Strategic Objectives II.A. and IIB: By FY 2026, 

participants in outreach, training, and technical assistance programs indicate either an 

improvement in an employment policy, practice, or procedure (employer representatives), 

or an increased knowledge of the laws the EEOC enforces (individuals) as a result of their 

participation. 

Year FY 2022 FY 2023 

Target 

Begin development of mechanism for 

reporting on agency-wide outreach 

events and feedback. 

Develop mechanism for gathering 

participant feedback. 

Results 

Development initiated and 

implemented through the EEOC 

Training Institute that evaluated prior 

survey measures and issued new FY 

2022 surveys at the EEOC’s 

25th annual Examining Conflicts in 

Employment Laws (EXCEL). 

Through its Outreach Training and 

Engagement Division (OTED), the 

agency developed a mechanism for 

gathering participant feedback using 

surveys from national training 

participants as test populations. 

EEOC’s Training Institute continued 

to implement the feedback from all 

(in-person and virtual) workshops, 

courses, conferences, and Customer 

Specific Training (CSTs) for private 

sector, state, and local government 

employers, federal national courses, 

and federal agency training sessions, 

and the 26th Annual EXCEL 

Conference held on July 31-August 2, 

2023. 

In addition, District offices held 

listening sessions with external 

stakeholders and stakeholder feedback 

provided insight into results achieved. 

Target Result Target Met Target Met 

Under the prior Strategic Plan, the Commission’s outreach and education efforts were in 

part measured by the number of sustained partnerships established and maintained with 

organizations that represented: 1) vulnerable or underserved communities, and 2) small and 

new businesses. The current Plan focuses on the qualitative impact of the outreach 

provided to the EEOC’s partners and the public. While not all participants will make a 

change to a policy or increase their knowledge of the laws the EEOC enforces, this 

measure can provide the agency with information about common gaps in knowledge, as 

well as effective ways to communicate with audiences. By using this information in 

planning and implementing outreach efforts, the agency can have a positive impact on 

preventing discrimination and advancing equal employment opportunity. 

The FY 2023 target for this measure was to develop a mechanism for gathering participant 

feedback to be used for future planning and outreach efforts. During the fiscal year, the 

agency developed a mechanism for gathering participant feedback using a survey of 

national training participants as test populations. Data collection began in January 2023 

and included measures of knowledge before and after training. The current national course 

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average is that 72 percent of learners experienced a measurable increase in knowledge after 

training. 

Performance Measure 10 for Strategic Objectives II.A. and II.B.: By FY 2026, the 

EEOC updates existing guidance and training materials, and creates new, user-friendly 

resource tools to address and prevent workplace discrimination. 

Year FY 2022 FY 2023 

Target 

Begin development of priority 

lists of existing guidance, 

technical assistance, and training 

materials for review and 

development. 

Create cross functional group and begin 

review and update of at least two 

resource or guidance documents on 

priority list. 

Results N/A** 

In FY 2023, the agency updated four 

EEOC technical assistance/resource 

documents; completed four plain 

language training materials and resource 

documents; and initiated two priority 

guidance documents. 

Target Result Target Exceeded 

** N/A – Not applicable for FY 2022 reporting. 

Performance Measure 10 will ensure that the EEOC’s sub-regulatory guidance documents 

and resource materials are updated to use plain language. The target for FY 2023 was to 

establish a cross-functional group and begin review and update of at least two resource or 

guidance documents on priority list. The agency’s enforcement work in the private and 

public sectors, its adjudicatory and oversight work in the federal sector, and its outreach 

and education work all depend on the availability of up-to-date and accessible materials 

explaining the laws the EEOC enforces and how to comply with them. While the 

regulations issued by the Commission set the basic legal framework for the 

implementation of those laws, sub-regulatory materials, including the EEOC’s Compliance 

Manual, provide more tangible assistance to those with rights and responsibilities under 

such laws. These materials may require a vote of the Commission and may include a range 

of guidance material, best practices, Q&A’s, website resources, outreach materials, /and 

fact sheets. 

In FY 2023, the EEOC issued the following new or updated agency technical assistance 

documents: 

 Hearing Disabilities in the Workplace and the Americans with Disabilities Act 

(ADA), issued January 4, 2023; 

 COVID-19 technical assistance materials, updated May 15, 2023; 

 Selected Issues: Assessing Adverse Impact in Software, Algorithms, and Artificial 

Intelligence Used in Employment Selection Procedures Under Title VII, issued 

May 18, 2023; and 

 Visual Disabilities in the Workplace and the ADA, updated July 26, 2023. 

Page 58 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

The EEOC also updated or created the following agency resources and training materials 

to provide more understandable, plain language information for stakeholders about the 

laws enforced by the EEOC and the rights and responsibilities of stakeholders: 

 ASL Video to explain the Hearing Disabilities-related technical assistance 

referenced above, issued April 3, 2023. 

 Know Your Rights poster, issued on Oct. 19, 2022, and then again on July 27, 2023 

(to incorporate the PWFA). 

 Youth@Work Human Trafficking page, launched on July 27, 2023. 

Performance Measure 11 for Strategic Objective II.A: Develop a federal governmentwide network and repository to share EEO resources and leading practices that are 

occurring across the federal government. 

Year FY 2022 FY 2023 

Target 

Develop framework for plan for 

network and repository. 

Complete plan for network and 

repository, including stakeholder 

input. 

Results 

Successfully developed a 

framework for network and 

repository. 

In FY 2023, the EEOC, through 

its Outreach Training and 

Engagement Division (OTED), 

created a DEIA repository outline, 

with content including leading 

practices, position descriptions, 

and training. 

The EEOC Education Consortium 

(EdCon) was developed in part to 

provide educational materials for 

federal sector EEO practitioners. 

The repository outline will be 

housed on the EEOC EdCon site, 

and the entire website will be 

updated, in addition to the 

creation of the repository, to 

centralize all the EEO and EdCon 

specific resources. 

Target Results Target Met Target Met 

Performance Measure 11 builds on the leadership and guidance the EEOC provides to 

federal agencies on all aspects of their EEO programs. As part of this role, the EEOC 

ensures federal agency compliance with federal sector regulations; provides technical 

assistance to federal agencies concerning EEO complaint adjudication; monitors and 

evaluates federal agencies’ affirmative employment programs; produces an annual report 

on federal sector complaint processing, appellate case processing, and compliance; 

produces reports on significant issues and government-wide trends in the federal sector; 

develops and distributes federal sector educational material; and conducts training for 

stakeholders. The EEOC embraces and recognizes the value of proactive prevention. 

Thus, in addition to taking remedial actions when agencies fail to comply with the EEOC’s 

appellate orders, regulations, or directives, the EEOC continues and enhances its practice 

of providing technical assistance to agencies on a routine basis before problems arise. 

Fiscal Year 2025 Congressional Budget Justification Page 59 
 

 

 

 

 

 

 

 

This measure leverages the EEOC’s existing work and partnerships to develop a 

government-wide network and repository for EEO resources and leading practices. The 

goal of the new network and repository is to facilitate better communication across 

agencies and create a means for the sharing of practices that will positively impact equal 

employment opportunity in the federal workplace. 

The FY 2023 target for Performance Measure 11 was to complete a plan for a network and 

repository, including stakeholder input. During FY 2023, the agency through its Outreach 

Training and Engagement Division (OTED) created a DEIA repository outline, with 

content including best practices, position descriptions, and training. The EEOC Education 

Consortium (Edcon) was developed in part to provide educational materials for EEO 

Practitioners. The repository outline will be housed on the EEOC Edcon website, and the 

entire website will be updated, in addition to the creation of the repository, to centralize all 

the EEO and Edcon specific resources. The repository and website update are aimed to 

showcase materials created by EEOC and additional federal agencies with expertise in 

DEIA and with extensive EEO knowledge. The outline has been presented to stakeholders 

for review and feedback. OTED’s Edcon Team has also successfully created a network 

with over 900 members. 

The materials and resources for the repository are currently being collected. The website 

will be continuously updated with new materials and current information. Stakeholders 

including the Edcon Advisory Board, consisting of members from all cabinet agencies, 

have and will continue to be included in the process. OTED will continue to grow the 

Edcon Contact list and their social media platforms. 

Page 60 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

VIII. STRATEGIC GOAL III – Strive for organizational excellence through our 

people, practices, and technology. 

A. Introduction 

Strategic Goal III, achieving organizational excellence, seeks to improve management 

functions with a focus on people, service to the public, information technology, 

infrastructure enhancement, and accountable financial stewardship. These areas are crosscutting and require integration and coordination to promote organizational excellence from 

internal and external perspectives. 

For the EEOC to accomplish Strategic Goals I and II, it must ensure excellence in its 

people and the service it provides to the public, as well as its effective management of 

financial and technological resources. Strategic Goal III is both stewardship-focused and 

operational. In recognition of this, and to ensure the agency is held accountable for 

improving its operations where necessary, the Commission is including Organizational 

Excellence as a goal in its Strategic Plan. 

There are two objectives for Strategic Goal III: 

Strategic Objective III.A.: The EEOC achieves a culture of accountability, inclusivity, and 

accessibility. 

Strategic Objective III.B.: Resources align with priorities to strengthen intake, outreach, 

education, enforcement, and service to the public to protect and advance civil rights in the 

workplace. 

The EEOC developed four performance measures to track its progress in achieving its 

objectives for Strategic Goal III. 

Fiscal Year 2025 Congressional Budget Justification Page 61 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

B. Performance Measures and Results 

Performance Measure 12 for Strategic Goal III.B.: Effectively allocate people and 

resources to accomplish agency mission goals, within budgetary limitations. 

Year FY 2022 FY 2023 

Target 

Staff the agency at its authorized 

Full Time Equivalent (FTE) levels 

and increase the total number of 

employees to effectively enforce 

EEOC laws and achieve the 

Agency’s mission. Enhance efforts 

to recruit, hire, train, develop and 

retain a broadly diverse workforce, 

including veterans, members of 

underrepresented groups, and 

individuals with disabilities, that is 

as effective as possible in serving 

America’s racially, ethnically, and 

culturally diverse population of 

workers. 

Maintain the EEOC’s authorized 

FTE levels through hiring and 

retention and the use of 

nontraditional talent pools and 

ensure the hiring process is 

accessible to underrepresented 

groups. Promote the EEOC as a 

model of diversity, equity, inclusion, 

workplace flexibility, accessibility, 

and excellence. 

Results 

The agency enhanced efforts to 

recruit, hire, train, develop and 

retain a broadly diverse workforce 

in FY 2022. The agency used 

various recruitment strategies, 

including partnering with the U.S. 

Peace Corps to obtain applicants 

to allow individuals to be hired 

under special hiring authorities; 

30% veterans’ preference hiring; 

and other special hiring 

flexibilities, such as Schedule A 

appointments for persons with 

disabilities. 

The agency worked to maintain the 

EEOC’s authorized FTE levels 

throughout FY 2023, while using 

various tools to recruit and retain 

talent, primarily with front-line 

positions: 30% veterans preference 

hiring, Pathways, College Graduate 

Hiring Authority, Attorney Honors 

Program , and other special hiring 

flexibilities, such as Schedule A 

appointments for persons with 

disabilities. 

The agency met its authorized FTE 

level while focusing on filling 

mission-critical front-line positions. 

Target Result Target Partially Met* Target Met 

*Target(s) Partially Met: A rating assigned to target results where: 1) at least half of the activities targeted for completion 

were completed; or 2) EEOC was unable to assess the results because a full year’s worth of data was not yet available. 

Performance Measure 12 focuses on recruiting, developing, and retaining a diverse and 

talented workforce with a goal of reaching and maintaining authorized FTE levels by 2026 

(subject to budget availability) with an emphasis on front-line staff. This performance 

measure takes a holistic approach, using various workforce strategies to return to (and 

maintain) staffing levels comparable to a decade ago, recognizing that the ability to add 

staff is contingent on final fiscal year spending bills. 

Performance Measure 12 focuses on recruiting, developing, and retaining a diverse and 

talented workforce with a goal of reaching and maintaining authorized FTE levels by FY 

2026 (subject to budget availability) with an emphasis on front-line staff. This 

Page 62 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

performance measure takes a holistic approach, using various workforce strategies to 

restore and maintain staffing levels comparable to a decade ago, recognizing that the 

ability to add staff is contingent on final fiscal year spending bills. The FY 2023 target for 

Performance Measure 12 was to staff the agency at authorized FTE levels by the end of the 

fiscal year. At fiscal year-end, the agency was staffed with over 2,300 full-time permanent 

employees, which met the authorized FTE level while focusing on filling mission-critical, 

front-line positions. 

Performance Measure 13 for Strategic Goal III.A and III.B: Feedback surveys and 

other mechanisms provide measures of satisfaction for EEOC stakeholder experiences. 

Target FY 2022 FY 2023 

Target 

Improve eeoc.gov feedback surveys, 

adjusting the measures and targets, as 

necessary. Utilize additional feedback 

surveys and other mechanisms to obtain 

data regarding process changes that were 

adopted in response to the pandemic. 

Expand feedback surveys and 

other mechanisms to obtain 

data and to provide measures 

of satisfaction for additional 

services, such as the charge 

filing experience and digital 

services. Review the results 

at the end of the fiscal year to 

set targets for next year. 

Results 

The agency continued to conduct feedback 

surveys throughout the fiscal year, 

including workgroup sessions and 

electronic survey reviews, to support 

continued access to EEOC services 

provided to the public. 

In Q1 of FY 2022, new e-versions of 

participant surveys were issued as part of an 

independent evaluation conducted in 

coordination with academia and the 

EEOC’s ADR Program. Additionally, the 

Revolving Fund evaluated prior survey 

measures and issued new FY 2022 surveys 

at the EEOC’s 25th annual Examining 

Conflicts in Employment Laws (EXCEL) 

Training Conference held August 23-25, 

2022. The results of the FY 2022 EXCEL 

Training Conference evaluation were 

reviewed and analyzed to provide feedback 

and set goals for next year’s conference. 

The agency continued to 

conduct feedback surveys 

throughout the fiscal year, 

including workgroup sessions 

and electronic survey reviews, 

to support continued access to 

EEOC services provided to 

the public. 

Target Result Target Met Target Met 

Performance Measure 13 focuses on obtaining feedback on services provided to the 

EEOC’s stakeholders. It supports Strategic Objective III.B, to align resources with agency 

priorities by strengthening intake, outreach, education, enforcement, and service to the 

public, by obtaining and evaluating feedback from the targeted audiences the Commission 

serves. This feedback then provides measurement of the agency's delivery of services and 

allows improvements to be targeted to areas identified by stakeholders. The EEOC 

recognizes the importance of examining the effectiveness of the Commission's work, 

Fiscal Year 2025 Congressional Budget Justification Page 63 
 

 

 

 

 

 

 

 

particularly the efficacy of intake, outreach, education, guidance, and technical assistance 

documents, to constantly improve the agency’s ability to serve the public and prevent and 

remedy discrimination. 

The FY 2023 target for Performance Measure 13 was for the agency to expand feedback 

surveys and other mechanisms to obtain data and to provide measures of satisfaction for 

additional services, such as the charge filing experience and digital services. The agency 

will review the results at the end of each fiscal year to set targets for the next year. 

During the FY 2023, the EEOC implemented automated “post-call” service quality surveys 

for callers to the EEOC’s 1-800 number. These surveys provide public service feedback 

that enable the EEOC to engage in targeted, ongoing improvements to public service. In 

addition, in June 2023, the EEOC, utilizing a short form of the survey developed by 

independent researchers during the previous year, returned to conducting its annual internal 

qualitative assessment of mediation participants and 96 percent of all participants reported 

that they would utilize the EEOC’s mediation program in a future charge filed with the 

Commission. 

Additionally, the EEOC Training Institute continued to implement feedback surveys for all 

in-person and virtual workshops, courses, conferences, and Customer Specific Training 

(CSTs) for private sector, state, and local government employers, federal national courses, 

and federal agency training sessions. The Training Institute implemented feedback surveys 

for the 26th Annual EXCEL Conference held in-person July 31 through August 2, 2023. 

The Institute solicited feedback from over 8,500 registrants, the results of which will be 

considered in setting goals for the next fiscal year. 

Page 64 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

Performance Measure 14 for Strategic Goal III.B.: Build and deploy charge/case 

management systems for Litigation and Federal Sector program offices. Complete 

deployment, monitor and improve effectiveness of digital charge/case management system 

for program offices. 

Year FY 2022 FY 2023 

Target 

Complete the deployment 

of the agency’s modernized 

charge/case management 

system (ARC) for the 

private sector and state and 

local programs. 

Complete the further deployment of the 

agency’s modernized charge/case 

management system (ARC). 

Develop baselines and measure the 

effectiveness of the modernized 

charge/case management system. 

Results Deployment completed. 

The agency continued its 

comprehensive revamp of EEOC’s 

digital case management platform 

(ARC). New Litigation and Litigation 

Appeals modules were deployed in 

ARC during FY 2023. In addition, 

prioritizing specific enhancements and 

fixes was a key area of focus necessary 

to complete prior to the development of 

baselines and measuring the 

effectiveness of ARC. 

Target Result Target Met Target Partially Met 

*Target(s) Partially Met: A rating assigned to target results where: 1) at least half of the activities targeted for completion 

were completed; or 2) EEOC was unable to assess the results because a full year’s worth of data was not yet available. 

With the first portion of the Technology Modernization Fund (TMF) award, the agency 

developed modernized charge management services for EEOC private sector enforcement 

staff and its 90 State and Local Government FEPAs. On January 18, 2022, the new 

Agency Records Center (ARC) system went live for 145 EEOC and FEPA offices and 

more than 2,000 users. This deployment was the culmination of 22 months of work, 

during which the EEOC charge management modernization team defined and developed a 

charge management solution to enable private sector charge management processes. 

The second, and final, portion of TMF funding was received in mid-2022, supporting the 

remaining two domains that will be serviced by ARC. In FY 2023, the EEOC developed 

and deployed ARC services to support the agency’s litigation and litigation appeals 

processes. During FY 2024, development of services to support the agency’s federal 

sector hearing and appeals processes is underway. 

As the EEOC completes the modernization of its charge/case management systems, the 

agency will seek to maximize its investment in ARC and to provide improved constituent 

services by re-platforming and modernizing its ARC-linked public-facing portals. The 

first new portal, E-File for Attorneys, was deployed in December 2023. Performance 

Measure 14 seeks to track and assess progress on completing the modernization of and 

fully utilizing the agency’s charge/case management system and related constituent 

services. 

Fiscal Year 2025 Congressional Budget Justification Page 65 
 

 

 

 

 

 

 

 

 

 

 

 

The FY 2023 targets for Performance Measure 14 focused on completing the deployment 

of the agency’s modernized charge/case management system (ARC). In addition, these 

targets included developing baselines and measuring the effectiveness of the modernized 

charge/case management system. As referenced above, ARC litigation case management 

was delivered to agency users in January 2023. ARC Litigation Appeals followed, with 

delivery in the third quarter of 2023. FY 2023 also focused on prioritizing enhancements 

to the private sector; the state, local and tribal program; the systemic program; and 

litigation functions – to improve usability, increase reporting capabilities, and resolve 

known issues. Critical priority private sector and litigation enhancements and fixes needed 

to be completed prior to the agency being able to “develop baselines and measure 

effectiveness.” 

Performance Measure 15 for Strategic Objective III.B: The budget process prioritizes 

funding for the EEOC’s strategic goals. 

Year FY 2022 FY 2023 

Target 

As part of an overall increase in 

budget development transparency, 

produce an annual congressional 

budget justification and operating 

plan that reflects strategic 

enforcement, outreach and 

education, and management 

priorities. Meet all submission 

deadlines. 

As part of an overall increase in 

budget development transparency, 

produce an annual congressional 

budget justification and operating 

plan that reflects strategic 

enforcement, outreach and 

education, and management 

priorities. Meet all submission 

deadlines 

Results 

The EEOC's FY 2023 

Congressional Budget was 

submitted to Congress on March 

28, 2022. 

The EEOC's final FY 2022 

Operating Plan was approved by 

the Chair on March 15, 2022. 

The EEOC's FY 2024 

Performance Budget was 

submitted to OMB on September 

12, 2022. 

The EEOC's FY 2024 

Congressional Budget was 

submitted to Congress on March 

13, 2023. 

The EEOC's final FY 2023 

Operating Plan was approved by 

the Chair on January 10, 2023. 

The EEOC's FY 2025 

Performance Budget was 

submitted to OMB on September 

11, 2023. 

Target Met Targets Met 

By developing a strong and clear message for use in budget documents and other 

publications, the EEOC demonstrates the nexus between its budget requests, allocations 

and operating plans and the achievement of its mission and vision. A universal 

understanding of how the strategic goals and objectives direct the work of the agency is 

necessary for success. The EEOC will achieve this common understanding in various 

ways, including integrating Strategic Plan objectives with performance standards and 

ensuring that budget submissions from each component office explain how the agency's 

resources implement the goals and objectives of the Strategic Plan. 

Page 66 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

The FY 2023 targets for Performance Measure 15 were to meet all deadlines required to 

submit the EEOC’s FY 2024 Congressional Budget Justification and the 2023 Operating 

Plan and prepare the EEOC’s FY 2025 Performance (OMB) Budget that aligns resources 

with the Strategic Plan. These documents were all submitted in a timely manner and 

clearly explained how resources aligned with strategic priorities. The final FY 2023 

Operating Plan was approved by the Chair on January 10, 2023. The agency’s FY 2024 

Congressional Budget Justification was submitted to Congress on March 13, 2023. The 

FY 2025 Performance Budget was submitted to OMB on September 11, 2023. 

C. Outreach 

As the table on the next page shows, we have provided and will continue to provide 

outreach and education to individuals in all 50 states as well as the District of Columbia, 

the Commonwealth of Puerto Rico, the U.S. Virgin Islands, and the U.S. Territories of 

American Samoa, Guam, the Commonwealth of Northern Mariana Islands, and Wake 

Island. With the FY 2025 budget for outreach activities, we will expand our outreach to 

individuals across the United States, including underserved areas. We plan to continue to 

host specific events to address the employment discrimination issues that are particular to 

geographic areas or stakeholder communities. In FY 2023, the EEOC conducted 2,885 

free outreach events reaching approximately 298,000 individuals nationwide with 

information about employment discrimination and their rights and responsibilities in the 

workplace, and we anticipate similar outreach levels in FY 2024. 

Fiscal Year 2025 Congressional Budget Justification Page 67 
 

 

 

Table 8: Annual Outreach Events – Fee and Non-Fee 

FY 2023 Annual Outreach Events 

Fee and Non-Fee 

District Office Total Events Total Attendees 

Atlanta District Office 195 73,485 

Birmingham District Office 88 13,367 

Charlotte District Office 143 20,843 

Chicago District Office 90 4,906 

Dallas District Office 119 11,919 

Headquarters and Other Offices 101 12,521 

Houston District Office 251 22,327 

Indianapolis District Office 100 4,061 

Los Angeles District Office 885 33,050 

Memphis District Office 95 5,725 

Miami District Office 206 8,590 

New York District Office 123 7,598 

Philadelphia District Office 237 48,674 

Phoenix District Office 231 21,293 

San Francisco District Office 99 5,550 

St. Louis District Office 148 7,626 

Washington Field Office 207 12,664 

Total 3,318 314,199 

Through public relations, training, and education, the EEOC enhances public awareness of 

employment discrimination and the importance of preventing such discrimination in 

America’s workplaces. Our outreach is meant to provide knowledge and an understanding 

of workplace conditions that may give rise to violations of the statutes we enforce. 

Page 68 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The EEOC targeted its outreach and education programs to vulnerable communities and 

small and new businesses in FY 2023. The EEOC conducted 684 outreach events for 

vulnerable workers and underserved communities in FY 2023, reaching 74,769 

participants. This included outreach to immigrant and farmworker communities, as well as 

communities where individuals are reluctant to come forward to report employment 

discrimination. The EEOC’s field offices also collaborated with partner organizations to 

extend the agency’s reach and better serve vulnerable workers and underserved 

communities . To enhance the EEOC’s ability to identify and reach vulnerable or 

underserved populations, the EEOC developed a data visualization tool to enable EEOC 

field offices to readily obtain demographic and industry data by District Office. The 

EEOC anticipates that this tool will increasingly be supplemented with additional data that 

will further its usefulness. 

Given their size and limited resources, small businesses are often less able to take 

advantage of commercial training programs and less likely to have in-house human 

resources professionals to assist them with compliance. In FY 2023, the agency conducted 

194 outreach events directed toward small businesses, reaching 39,066 attendees. 

In addition, the EEOC continued to promote its public website containing the online Small 

Business Resource Center, a comprehensive resource providing small businesses with tools 

to understand the federal anti-discrimination laws and to prevent employment 

discrimination in their workplaces. The site features answers to frequently asked 

questions, guidance for making employment decisions in common scenarios, and pointers 

for developing good workplace policies. It has tips for small businesses on various 

potential workplace discrimination issues to help businesses avert problems before they 

arise. It also provides quick access to the names and contact information of the EEOC’s 

Small Business Liaisons in the EEOC’s field offices. These liaisons answer questions 

from small business owners as they institute policies and practices to comply with the law. 

The Small Business Association Office of the National Ombudsman’s Annual Report to 

Congress grades all federal agencies on their responsiveness to small business concerns 

and their compliance with the Small Business Regulatory Enforcement Fairness Act of 

1996. The Ombudsman’s most recent report, the 2021 Annual Report to Congress, was 

published in FY 2024 and gave the EEOC an “A” rating across-the-board, the highest 

possible rating, reflecting the U.S. Small Business Administration’s (SBA) recognition of 

the EEOC’s strong commitment to assist this important sector of the economy. 

Through the agency’s education and outreach activities, the EEOC also played a pivotal 

role in promoting racial justice and confronting systemic barriers in the workplace during 

FY 2023. For example, the EEOC conducted outreach to workers of color through 

listening sessions, panel discussions, trainings, and other meetings to strategize ways to 

combat racial and ethnic harassment and discrimination. The EEOC’s field offices 

facilitated the exchange of information across districts, coordinated community 

engagement efforts with other federal agencies, and collaborated with the White House 

Initiative on Asian Americans, Native Hawaiians, and Pacific Islanders (WHIAANHPI), 

and the White House Office of Public Engagement in response to the rise in hate crimes 

and incidents against Asian American and Pacific Islander communities around the nation. 

Through regional roundtables, technical assistance programs, regular planning calls, 

Fiscal Year 2025 Congressional Budget Justification Page 69 
 

 

 

 

 

 

 

 

 

resource-sharing, virtual convenings, and webinars, the EEOC worked with the 

WHIAANHPI Regional Network to address specific community needs and feedback. A 

total of 95 WHIAANHPI events were conducted reaching 4,241 individuals. The agency 

also conducted 31 Historically Black Colleges and Universities outreach events reaching 

1,626 individuals, 188 outreach sessions involving race and color discrimination reaching 

21,386 attendees, 220 events focused on racial justice reaching 24,188 attendees, and 171 

sessions on national origin discrimination reaching 18,753 attendees. 

The EEOC also conducted outreach and education on the workplace civil rights 

implications of the COVID-19 pandemic, providing workers, employers, and other 

stakeholders with up-to-date information about the interplay of COVID-19 and federal 

EEO laws. During FY 2023, the EEOC held 43 outreach events related to COVID-19, 

reaching 7,145 individuals. 

In FY 2023, the EEOC also focused outreach and education on priorities identified in the 

agency’s Strategic Enforcement Plan (SEP) . 

The EEOC takes seriously its role of enhancing public awareness about emerging issues of 

employment discrimination in America’s workplaces. By facilitating effective 

partnerships and collaborations with internal and external stakeholders, the EEOC works to 

reduce and eliminate employment barriers and achieve sustained benefits for the 

communities we serve. In FY 2023, the agency conducted 1,125 partnership events 

reaching 107,032 attendees. 

Non-fee-based Outreach 

Table 9 below shows funding for Outreach (non-fee-based). Our Budget request for FY 

2025 for Strategic Goal II is $6 million. The proposed request for FY 2025 will support 

our existing outreach activities across the United States. 

Table 9: Budget request Summary through Outreach 

FY 2023 to FY 2025 

(Dollars in thousands) 

Year 

FY 2023 

(Enacted) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Outreach (Non-fee-based) $6,000 $6,000 $6,000 

Total $6,000 $6,000 $6,000 

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Fee-based (Revolving Fund – Education, Technical Assistance and 

Training) 

The EEOC Training Institute (Training Institute) provides fee-based training and technical 

assistance to stakeholders in the private and public sectors. The Institute is funded through 

the EEOC’s Revolving Fund (RF), established by Congress in 1992 to enable the EEOC to 

charge reasonable fees for specialized products and services developed and delivered as 

part of the Commission’s training and technical assistance efforts. The Revolving Fund 

(RF) serves as the mechanism through which the EEOC can collect payments, thus 

offsetting some of the costs devoted to training and technical assistance to external entities 

and allowing the agency to offer more non-fee-based outreach events to those populations 

less able to pay for training. 

The Training Institute provides a wide variety of fee-based training to assist private sector 

employers, and state, local, and federal government agencies in educating their managers 

and employees on the laws enforced by the EEOC and how to prevent and eradicate 

discrimination in the workplace. The Training Institute offers workshops, courses, and 

conferences on a variety of EEO compliance issues including, but not limited to, current 

developments regarding EEOC guidance. Additionally, the Training Institute provides 

Respectful Workplaces employee training, Leading for Respect manager and supervisor 

training, and compliance training related to the 2016 Report of the Co-Chairs of the EEOC 

Select Task Force on the Study of Harassment in the Workplace. 

In FY 2023, the Training Institute conducted virtual workshops and virtual and in-person 

courses and Customer Specific Training (CSTs). Below is a more in-depth explanation of 

each type of program offered by the Training Institute in FY 2023. 

Technical Assistance Program Workshops. In FY 2023, the RF continued the new 

product line introduced in FY 2021 to take advantage of the virtual training environment 

and to provide even more opportunities for employees and employers to receive training, 

education, and information about their respective rights and obligations to prevent and 

eradicate workplace discrimination. The Training Institute continued to offer 1-hour 

(breakfast and lunch briefings), 2-hour, 3-hour (half-day), and 5-hour (full-day) 

workshops. These workshops were extremely successful as they allowed the EEOC field 

offices to partner together, pool their creative ideas and resources, and maximize revenue 

potential. These workshops received excellent evaluations from attendees. In FY 2023, 

the Training Institute conducted 29 national (1, 2, 3, and 5-hour) workshops with 6,617 

attendees. 

Customer Specific Training. The Customer Specific Training (CST) programs provide 

training and education for employees, managers, supervisors, and human resource 

professionals from private sector employers and state, local, and federal government 

agencies on their EEO responsibilities and how to prevent and eradicate workplace 

discrimination. The Training Institute can design customized courses to be delivered at 

employers’ worksites, including virtual delivery during this pandemic period. In FY 2023, 

the Training Institute conducted 173 CST events that reached 10,769 attendees. Of those 

events, 36 events focused on Respectful Workplaces employee training (895 attendees) and 

55 focused on Leading for Respect manager and supervisor training (1,565 attendees). 

Fiscal Year 2025 Congressional Budget Justification Page 71 
 

 

 

 

 

 

 

 

 

 

 

 

National Federal Courses and Federal Agency Training. The Training Institute offers 

federal courses that are designed to meet training requirements for EEO practitioners 

working throughout the federal government. In FY 2023, there were 47 national federal 

courses with approximately 1,624 attendees and 40 federal agency training sessions with 

approximately 1,552 attendees. Of the federal agency training sessions, six focused on 

Respectful Workplaces employee training and Leading for Respect manager and 

supervisor training. 

Table 10 below shows the financial summary of the Revolving Fund. 

Table 10: Summary of Financing for the Revolving Fund 

FY 2021 to FY 2027 

(Dollars in thousands*) 

FY 2021 

Actual 

FY 2022 

Actual 

FY 2023 

Actual 

FY 2024 

Est. 

FY 2025 

Est. 

FY 2026 

Est. 

FY 2027 

Est. 

Total Obligations 3,662 3,602 5,065 5,116 5,269 5,427 5,590 

Offsetting collections 

from: 

Federal Funds 1,705 318 1,857 2,160 2,225 2,250 2,250 

Non-Federal Sources 1,861 2,004 2,800 3,240 3,340 3,350 3,350 

Unobligated balance, 

start of year 2,645 2,549 1,269 861 1,145 1,441 1,614 

Unobligated balance, 

end of year 2,549 1,269 861 1,145 1,441 1,614 1,624 

Net Budget 

Authority** 6,211 4,871 5,926 6,261 6,710 7,041 7,214 

*May not add due to rounding 

** Balanced Budget and Emergency Deficit Control Act (BBEDCA) Section 256(k) (2): Mandatory Sequestration 

for FY 2021, $228,000, FY 2022, $193,538, FY 2023, $266,475 (included in the Net Budget Authority line above.) 

Page 72 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

EXAMINING CONFLICTS IN EMPLOYMENT LAWS CONFERENCE 

In July/August 2023, the agency held its 26th Annual Examining Conflicts in Employment 

Laws (EXCEL) Training Conference for federal sector and private sector EEO 

practitioners. This year was the first time the conference was held in person since the start 

of the COVID-19 pandemic. The EXCEL Training Conference gathered Equal 

Employment Opportunity (EEO), Human Resources (HR), and Alternative Dispute 

Resolution (ADR) practitioners from private, state, local, and federal organizations for four 

days of education, training, and professional development. There were 3 plenary sessions, 

1 specialty track, and over 70 open workshops. Topics included the Pregnant Workers 

Fairness Act, disability accommodations the use of artificial intelligence in the workplace, 

and various other significant matters related to employment law and EEO compliance. 

The conference started with a welcome address by Congresswoman and former EEOC 

Chair Eleanor Holmes Norton and an opening plenary session with Charlotte A. Burrows 

Chair, U.S. Equal Employment Opportunity Commission, Cathy Harris, Acting Chair, U.S. 

Merit Systems Protection Board and Susan Tsui Grundman, Chair, U.S. Federal Labor 

Relations Authority. A record number of 880 participants attended from the federal and 

private sectors. The conference received overwhelmingly positive feedback and gave 

participants the needed EEO knowledge, and skills to enhance their performance, and meet 

the evolving demands of today’s workplace while also generating approximately $625,500 

in net revenue. 

Fiscal Year 2025 Congressional Budget Justification Page 73 
 

 

 

 

 

 

 

 

 

 

 

D. Program Areas 

1. Highlighted Resource Area 

Table 11 below shows our highlighted budgetary resources for Information Technology 

(IT). The agency’s IT resources are allocated between Strategic Goal I, Strategic Goal II, 

and Strategic Goal III to identify the full cost of conducting our front-line programs, 

including all of the elements of our operations supporting those programs. 

Table 11: Highlighted Resource Area 

FY 2023 to FY 2025 

(Dollars in thousands*) 

FY 2023 

(Enacted) 

FY 2024 

(Request) 

FY 2025 

(Request) 

Change From 

FY 2024 

Information Technology $25,773 $28,706 $28,706 $0 

Total $25,773 $28,706 $28,706 $0 

2. Human Resources 

a. Workforce Planning 

The EEOC has undergone several changes to its operations and workforce over the years. 

As a result of the pandemic in FYs 2020, 2021 and 2022, and early FY 2023, the EEOC 

successfully adjusted operations to effectively deliver its mission and results while 

observing pandemic precautions, including conducting its work largely remotely. In order 

to continue to serve the public effectively, the EEOC must conduct workforce planning to 

holistically staff and analyze the impact of changes in the laws and the workplace and 

develop and implement strategies to reshape/reform existing workforce structures, staffing, 

and functions for its offices. 

This workforce planning will provide the EEOC with ongoing analysis and staffing plans 

that allow leadership to identify and use human capital (and technology) strategies best 

suited to support the EEOC’s current and future organizational goals in FY 2023, FY 2024, 

and beyond. By partnering with the Office of Personnel Management (OPM) in FY 2024, 

the EEOC will continue to focus on these workforce planning initiatives. 

b. Training and Retention 

The EEOC is focused on training and developing employees at all levels – non-supervisory 

employees, team leads, supervisors, managers, and executive-level staff. 

The EEOC will continue to provide all employees with a comprehensive training program 

and expand access to learning and development through four primary approaches: 1) 

training activities responsive to their individual and executive development plans 

(IDP/EDP); 2) internally sponsored, instructor-led courses, workshops, and webinars; 3) 

Page 74 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

training programs addressing position-related competency needs; and 4) online courses 

available through the EEOC Learning Management System (LMS). 

We intend to address our future leadership needs in a coordinated and thoughtful manner. 

The Talent Management and Leadership Succession Plan will provide the reasoning and 

blueprint for addressing the anticipated loss of experienced leaders by providing a process 

to identify and prepare well-qualified individuals to lead the agency into the future. Also, 

the EEOC is committed to providing our leadership with the necessary skills to lead the 

agency now and in the future. 

During FY 2024 and FY 2025, we will continue to expand web-based and virtual training. 

Although in-person training participation has increased, virtual training opportunities 

remain very popular – allowing the EEOC to convey relevant information and timely 

updates to our staff in all of our Field and Headquarters locations reaching all of the 

EEOC’s employee population. 

In FY 2025, the EEOC plans to launch additional learning and development platforms to 

our system capabilities to deliver quality training for the workforce, to include a new 

leadership development on-demand platform. Because the agency has hired a significant 

number of new employees, training for newly hired investigators will be central to the 

agency’s ability to conduct effective efficient investigations. 

In the first quarter of FY 2023, the EEOC conducted training for 145 new investigators. 

The New Investigator Training was a two-week intensive introductory level training for 

investigative staff that covered important topics that are critical to the development of new 

investigators. 

Training was also provided to investigators on new or emerging issues including, for 

example, matters related to COVID-19, increased awareness surrounding LGBTQI+ issues 

to ensure robust implementation of the Supreme Court’s landmark decision in Bostock v 

Clayton County, and the EEOC’s alignment with Executive Order 13175 and our 

relationship with Native American Tribes and Tribal Employment Rights Offices (TEROs). 

In addition, in early FY 2023, the EEOC provided beginner training for all State, Local and 

Tribal Programs (SLTP) coordinators new to their positions, as well as intermediate training 

later in the year. The EEOC also held a joint FEPA/TERO training conference at the 

beginning of the fourth quarter, FY 2023. Throughout the fiscal year, the EEOC provided 

FEPAs with training materials and EEOC trainers for several regional FEPA investigator 

trainings that FEPAs hosted. In addition, the EEOC provided virtual training to TEROs on 

the EEOC’s Public Portal and How to Complete the Pre-Charge Inquiry Questionnaire. 

Because the EEOC has hired many new attorneys in FYs 2022 and 2023, we have 

conducted necessary training for these new employees. In early FY 2023, OGC conducted 

in-depth new trial attorney orientation for 50 new trial attorneys and supervisory attorneys 

litigating in the field. The 3-day training was conducted in-person and covered all aspects 

of litigation development and litigation on behalf of the EEOC. OGC also partnered with 

OFP and OEDA to conduct a systemic conference in the third quarter of FY 2023, in 

which 50 trial attorneys and supervisory attorneys from all 15 EEOC districts, and analysts 

Fiscal Year 2025 Congressional Budget Justification Page 75 
 

 

 

 

 

from OGC’s Research and Analytical Services, participated in-person. In late FY 2023, 

OGC conducted an in-person, 2-day e-Discovery training for the agency’s 33 e-Discovery 

lead attorneys in the field legal units. 

We plan to continue to conduct more in-person training and conferences for trial attorneys 

and legal unit leadership from across the country in FYs 2024 and 2025. These meetings 

are vital to engagement and retention of the field legal units, as they share strategies and 

best practices about litigation and performance management. As we hire new staff, we will 

need to provide these types of trainings in FY 2025, including in-person, to position the 

agency for success going forward. 

The EEOC strives to make continuous improvements to our training programs to ensure 

our employees at all levels have the knowledge and skills to effectively perform their 

duties. In FY 2025, the EEOC will continue providing mandated training requirements to 

employees and will partner with the Small Agency Council to provide expanded training 

courses from Shared Service providers’ Training Centers. 

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c. Performance Management 

The EEOC uses OPM’s USA Performance (USAP) as it’s software solution to assist 

federal agencies in implementing their Senior Executive Service (SES) and Non-SES 

performance management programs and systems. USAP enables the EEOC to automate 

our performance appraisal process throughout the entire performance rating cycle. It 

allows us to develop performance plans, track, and monitor employees’ performance, 

provide feedback and ratings, and electronically sign performance plans in one system. 

Streamlining the process allows the EEOC to focus on results and performance 

management to happen in real time. 

Through the USAP the EEOC facilitates interactive and continual communication to 

cultivate a more productive and engaged workforce. The agency is able to increase 

visibility and transparency of the performance management process and implement 

performance management best practices and policy suggested by Government Performance 

and Results Modernization Act, Human Capital Assessment and Accountability 

Framework, Performance Appraisal Assessment Tool, and the Goals-EngagementAccountability-Results initiative. 

d. Recruitment and Retention 

In FY 2025, in support of our Workforce Planning initiative, the EEOC will implement a 

workforce plan and a recruitment and retention plan for the field and headquarters offices 

to improve overall recruitment and retention to ensure we retain increased staffing levels. 

The EEOC will continue to act in accordance with OPM and OMB guidance and executive 

orders to ensure compliance with the federal recruitment requirements by providing tools 

and resources needed to attract and retain talent at all levels. To support our recruitment 

and retention plan to fill and retain positions year-round, the EEOC will use a wide range 

of hiring flexibilities to rebuild and increase agency staffing including encouraging 

Schedule A hiring of persons with disabilities; continued use of non-competitive veterans 

hiring appointments; using internships, fellowships, and early career hiring programs that 

include the Pathways Programs (Internship, Recent Graduates, and Presidential 

Management Fellows), College Graduate, and Law Clerk/Attorney Honors Program for 

entry level positions; encouraging Military Spouses appointments; collaborating with 

AmeriCorps VISTA/Peace Corps for various appointments; and building strategic 

partnerships and alliances with stakeholders such as Historically Black Colleges and 

Universities (HBCUs), Hispanic Serving Institutions (HSIs), Asian American and Pacific 

Islander Serving Institutions (AAPISIs), Tribal Nations, local high schools, and 

colleges/universities. The EEOC will use the governmentwide direct hire authority for 

certain AI-related jobs to include IT specialists, computer scientists and engineers working 

on AI, as well as management and program analysts at the GS-9 through GS-13 levels. 

Simultaneously, as part of the workforce planning strategy, the EEOC will closely monitor 

and analyze recruitments and separations of highly qualified candidates and employees due 

to retirements, transfers to other agencies, and separations for employment outside of the 

Federal Government. By utilizing recruitment, relocation, and retention incentives and 

employee development, the EEOC will strategically address human capital needs and build 

Fiscal Year 2025 Congressional Budget Justification Page 77 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

and maintain a high-performing workforce with essential skills and competencies to ensure 

we retain our talent and staffing numbers. 

In FY 2025 and FY 2026, the EEOC will continue to provide programs, including 

Employee Assistance Programs for our entire workforce to support work-life balance that 

ultimately helps with employee retention to maintain and support the EEOC workforce. 

e. Addressing Internal Workplace Issues 

The EEOC addresses internal workplace issues through several programs. RESOLVE is 

the EEOC’s internal Alternative Dispute Resolution (ADR) program that provides a forum 

for the informal resolution of workplace disputes (including grievances and EEO 

complaints) among the Commission’s staff at headquarters and the 53 field offices. 

Mediation is the most commonly used ADR process within the program. Informal 

resolution can also be used in lieu of, prior to, or after mediation. If several employees are 

involved in a conflict, group facilitation may be used to address office wide concerns. 

Addressing workplace issues early and effectively helps foster amicable working 

relationships, enhances employee morale and productivity, and reduces the financial and 

other resources associated with workplace conflict. Our ADR program will: 1) continue 

outreach to all of the Commission’s staff, 2) serve as a resource for individual employees 

and groups of employees, and 3) continue to conduct seminars to help employees develop 

conflict resolution skills. 

The Office for Civil Rights, Diversity and Inclusion (OCRDI), under the direction of the 

Chair, provides leadership in the development, implementation and evaluation of the 

EEOC internal equal employment opportunity (EEO) and civil rights programs, including 

investigations, compliance, and affirmative employment programs; the EEOC’s diversity, 

equity, inclusion, and accessibility (DEIA) programs; and the agency’s reasonable 

accommodation (medical, religious, and interpreter services, etc.) programs. 

OCRDI also provides leadership and management of agency-wide training and 

development of policies and programs designed to establish, maintain, and enhance 

internal EEO and civil rights, DEIA, non-discrimination practices, and a healthy 

organizational culture across the agency. 

3. Public Service 

Across the agency, we are working to better serve the public by making our services easier 

to access, reducing wait times and providing information in plain language that is readily 

understood. 

Through our Information Intake Group (IIG), the EEOC expanded the agency’s public 

accessibility by phone, e-mail, and video phone service for the deaf and hard of hearing. 

The IIG consists of in-house staff who serve as the first line of contact for many members 

of the public and is accessible via toll-free phone lines and e-mail. 

The overwhelming majority of public contact with the IIG occurs through calls to the 

EEOC’s toll-free 1-800 number. The IIG received 522,132 calls in FY 2023 (an almost 10 

percent increase from FY 2022). Callers to the EEOC’s toll-free phone line are 

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immediately provided the opportunity to utilize the IIG’s extensive Interactive Voice 

Response (“IVR”) system to obtain information quickly, efficiently, and without the need 

to speak to an IIG Contact Representative. The IVR also provides callers to the EEOC’s 

toll-free line with the option to receive information quickly and efficiently via SMS text 

messaging. During FY 2023, the IIG’s IVR provided responsive information via SMS text 

messaging to over 124,000 callers to the EEOC’s 1-800 number without requiring those 

callers to speak to an IIG contact representative. Callers to the EEOC’s toll-free number 

who elected to speak to a person were assisted by IIG contact representatives who use an 

extensive knowledge database to respond, in both English and Spanish, to these calls. 

In addition to calling the EEOC’s toll-free 1-800 telephone line, members of the public 

seeking information from the EEOC may also contact the IIG through the EEOC’s public 

email address, info@eeoc.gov. During FY 2023, the IIG received over 86,000 emails via 

the EEOC’s public email address (an almost 25 percent increase over FY 2022). 

Centralizing this first point of access to the public to a single entity has a significant 

impact on our field offices by enabling them to spend more time on investigating and 

resolving charges of discrimination. Many of these callers seek general information about 

their rights, office locations and phone numbers and other types of information more 

efficiently provided through this centralized service. 

Assessing all contact channels combined, including the toll-free 1-800 line, the ASL Video 

Phone line, and the public email address, IIG Contact Representatives received over 

600,000 transactions in FY 2023. Investments made in the IIG have allowed the EEOC to 

expand its reach and more efficiently serve the public. In FY 2023, our staff of 

approximately 39 IIG Contact Representatives (a fully remote position), together with the 

technological advancements in the IIG’s IVR, handled approximately 79 percent of all 

contacts without the need to forward them to EEOC investigators, or other EEOC Offices. 

IIG Contact Representatives allow investigators to be more productive and efficient and 

enhance the agency’s services our service to the public. 

The EEOC has continued to increase the agency’s accessibility to individuals who are deaf 

and hard of hearing. As technology has progressed, video phones have become the 

preferred method of communication for many individuals whose primary language is 

American Sign Language (ASL). When instituted, the EEOC was one of only three 

federal agencies (along with the Federal Communications Commission and the Small 

Business Administration) offering interactive video calls to the public. The EEOC hired 

staff to answer and respond to calls using ASL through videophones. Callers who are deaf 

or hard of hearing are able to have direct access to the EEOC staff, rather than through 

intermediaries, such as interpreters or video relay service. In FY 2023, approximately 

1,284 ASL Video Phone calls were handled by the IIG (an almost 43 percent increase from 

FY 2022). We will continue to assess the public demand for ASL services to determine if 

additional staffing resources are needed to support this aspect of our service to the public. 

4. Information Technology - Digital Transformation 

The EEOC is committed to digital transformation to increase its efficiency and to provide 

timely and effective service to the public. This encompasses everything the agency does, 

Fiscal Year 2025 Congressional Budget Justification Page 79 
 

 

 

 

 

 

 

 

 

from increasing the efficacy of its administrative processes to better supporting missionrelated activities in enforcement and litigation that are directed at stopping and remedying 

unlawful employment discrimination. These efforts are organized around three strategic IT 

goals: 

• Transform the way the EEOC serves the public by making its charge complaint, 

and appeal processes transparent and providing information to its constituents 

online and on demand. 

• Streamline processes to improve customer service for constituents, including 

individuals, state and local partners, Federal agencies, businesses, and other 

organizations. 

• Improve productivity by providing agency employees secure access to the tools, 

data, and documents they require. 

One of the EEOC’s major digital transformation efforts is the modernization of its legacy 

charge/case management system. In early 2020, the Technology Modernization Fund 

(TMF) Board provided the EEOC with an initial tranche of $2 million to modernize the 

legacy technology and data structure of our 22-year-old Integrated Mission System (IMS). 

From FY 2020 through FY 2022, the EEOC defined and built a modern solution to enable 

the agency’s management processes for charges against private, state, and local employers, 

as well as the related processes for its Fair Employment Practices Agency (FEPA) 

partners. Having met the milestones outlined in the agreement with the TMF, the agency 

received the second, and final, tranche of TMF funding in mid-2022, supporting the 

remaining two domains that will be serviced by ARC: federal sector services and litigation. 

The agency deployed litigation and litigation appeals modules in ARC during FY 2023. 

The final modules, supporting federal sector services, are in process, for anticipated 

deployment of Federal Hearings in FY 2024 and Federal Appeals in early FY 2025. 

Modernizing its legacy charge/case management while also transitioning to new, more 

effective, peripheral digital systems is complex, and the success of both is essential to the 

agency’s mission. These supplementary efforts have included: 

• The EEOC previously launched our Public Portals, providing online services 

for parties to submit inquiries, schedule an interview, formalize charges, 

exchange documents, identify processing preferences, check status, and update 

contact information – without the need to visit an EEOC office or use mail 

services. Similarly, the EEOC deployed electronic services to our public sector 

constituents, bringing the EEOC’s federal sector online services on par with the 

private sector. The companion Federal Sector EEO Portal (FedSEP), which 

provides online services to Federal Agency EEO offices, integrates with the 

public sector side of the EEOC Public Portal for information and document 

exchange. 

We conservatively estimated that the use of private sector online services saves 

over 41,000 hours of investigator time (almost two weeks per investigator) 

annually. Electronic service also results in printing/postal/processing savings 

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for the field offices’ clerical staff, freeing each enforcement office 

administrative assistant from more than seven days of work to perform other 

tasks. In addition to these cost savings and efficiency gains, the EEOC’s Public 

Portals proved to be a critical success factor in the agency’s ability to provide 

continuity of services to the public during the COVID-19 pandemic. 

During FY 2023, the EEOC developed a new Attorney eFile tool which allows 

licensed attorneys to submit charges directly to the EEOC, replacing current 

manual processes. This new service was released in December 2023. The 

EEOC estimates that about a third of the charges it receives come from 

attorneys filing on behalf of their clients. Attorneys submitted these charges by 

mail, fax, and hand-delivery, and the EEOC processed them manually, resulting 

in duplication of work for the agency, attorneys, and represented charging 

parties. With this digital solution, the EEOC expects to free up resources to 

better serve individuals who are unrepresented and want to file charges of 

discrimination. The E-file for Attorneys application will help strengthen the 

capacity of the agency in alignment with its recent strategic plan. 

During FYs 2024 and 2025, the EEOC will continue to modernize its Public 

Portal infrastructure to provide additional security, expand language offerings, 

offer more granular data and new services, and improve interview scheduling – 

made possible by the ARC implementation. 

• In FY 2021, the agency integrated multi-language capabilities into its public 

website eeoc.gov, to further reduce barriers in providing information and 

services to our constituents. As of FY 2023, eeoc.gov provides key information 

in 9 languages, with additional expansion underway. 

• In accordance with another of the EEOC’s Strategic Plan goals – to “[align 

resources] with priorities to strengthen outreach [and] education,” the agency 

conducted market research for cloud-based software-as-a-service Outreach and 

Engagement solutions to support the activities of OFP, OFO, and OGC. 

Assessment of a new solution began in FY 2023, with procurement, 

development, and deployment slated for FYs 2024 and 2025. 

For digital transformation projects to achieve the goals of increased efficiency and 

improved service, the EEOC needed to invest in the infrastructure necessary to support a 

digital workplace. Accomplishments and plans in this area include: 

• The EEOC previously expanded Field Offices and Headquarters network 

capacity to better support operations and prepare for the transition to unified 

communications, including investments to replace outdated network equipment. 

These efforts provided highly available, secure, data communication 

capabilities that are critical to our development of digital workplace. Initial 

bandwidth expansion was completed in FY 2021 via the Federal Enterprise 

Infrastructure Solutions (EIS) contract. EIS reduces the agency’s annual data 

communications costs by nearly 50 percent, which are being re-invested in 

increased bandwidth – enabling agency personnel to communicate with voice, 

Fiscal Year 2025 Congressional Budget Justification Page 81 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

video, and data from all locations. The network investments for the EEOC’s 

Headquarters, Virtual Private Network (VPN), and Microsoft Office 365/Azure 

connections enabled the EEOC to support fulltime remote telework brought on 

by the COVID-19 pandemic. 

During FY 2023, the EEOC continued to modernize our network infrastructure 

by implementing secure enterprise wireless capabilities, facilitating 

communication and collaboration throughout the EEOC office space, and 

removing physical workstation-based connectivity limitations. FY 2024 and 

FY 2025 activities will focus on more fully implementing zero-trust 

architectures, as referenced below. 

• In FY 2022, the agency introduced “auto-pilot” laptop deployments, enabling 

laptops to be reimaged and updated fully remotely, without attachment to the 

agency network. This automation will significantly improve the security and 

version control of our endpoints, especially for fully remote workers. During 

FYs 2024 and 2025, the EEOC will continue to refresh end-user equipment – 

mobile devices, laptops, peripherals, and multi-function devices – and will 

deploy the Windows 11 upgrade. We will also expand endpoint and supply 

chain security through configuration and implementation of new security tools 

and services acquired in late FY 2023. 

To improve remote collaboration and communication capabilities during the COVID-19 

pandemic, the EEOC aggressively deployed Microsoft Teams enterprise-wide. Deploying 

and utilizing Teams so rapidly, including developing written guidance, video presentations 

and remote training, helped transform the way the EEOC communicates – as EEOC 

employees are now able to use the enhanced chat, file, meeting, and videoconferencing 

capabilities in Teams. This effort was expanded to provide Teams voice capabilities 

enterprise-wide, enabling staff to make and receive external calls during full-time remote 

work. 

• The migration from legacy telephone systems to unified communications was 

completed in FY 2021, saving the agency over $1.2 million annually, which is 

being reinvested in other needed IT services. 

• The EEOC continued its migration from on-premises and hosted data centers to 

cloud services. In FYs 2022 and 2023, the agency increased its Azure 

Commercial workload usage and, at the same time, reduced costs by leveraging 

Azure Hybrid Use Benefits, reserving Virtual Machine instances, and 

automating storage repository cleanup. 

• One of the significant challenges associated with the COVID-19 pandemic was 

provisioning laptops to the summer interns that were preparing to join the 

agency. Understanding the importance of their assistance, and the time 

constraints related to their service, in less than one month the EEOC designed 

and provisioned a secure Azure Virtual Desktop (AVD) environment for intern 

use. AVD allows interns to securely connect to EEOC systems and services 

from their personal laptops at their remote locations. Using the EEOC’s Azure 

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cloud infrastructure, AVD services are ramped up or down to more efficiently 

and cost effectively meet these fluctuating needs. Due to the success of this 

effort, the AVD platform has expanded to support the EEOC’s continuity of 

operations, advanced data analytics, and litigation support requirements. 

Fiscal Year 2025 Congressional Budget Justification Page 83 
 

Table 12: Cybersecurity Spending by National Institute of Standards and 

Technology (NIST) Framework 

Cybersecurity Spending by NIST Framework 

(Dollars in Thousands) 

FY 2023 

Actual 

FY 2024 

Request 

FY2025-

President's 

Budget 

IDENTIFY 

 Authorization and Policy 1,102 1,138 1,154 

Non-CDM Information Security Continuous 

Monitoring 1,063 1,063 1,063 

PROTECT 

 Cloud Security 918 952 965 

 Credentialing and Access Management 1,145 1,147 1,150 

 Data Safeguarding 505 505 505 

 Secure Data Transmission 140 140 140 

 Secure Patch Management 1,115 980 980 

 Security Training 20 20 20 

 System Security Testing and Analysis 130 130 130 

 Zero Trust Network Architecture 1,570 1,441 1,441 

DETECT 

 Anti-Phishing and Malware Defense 390 390 390 

 Endpoint Detection and Response 122 122 122 

 Intrusion Prevention 315 318 321 

RESPOND 

 Incident Management and Response 825 836 848 

RECOVER 

 Disaster Recovery 352 352 352 

 Incident Notification 28 28 28 

 

 

 

 

*This table includes cybersecurity FTE costs. 

Securing the EEOC’s digital workplace is a critical part of the agency’s plans, with 

priorities developed and put in place to protect data that is central to the agency's mission 

and the privacy of the people whom the EEOC serves. The EEOC acquired several 

systems and services that will enhance security capabilities to better identify, analyze, and 

resolve internal vulnerabilities. 

In January 2022, OMB released M-22-09, Federal Zero Trust Strategy, requiring agency 

enterprise security architectures to be based on Zero Trust (ZT) principles. During FYs 

2022 and 2023, the EEOC made significant progress in implementing Zero Trust 

Architecture (ZTA) requirements across all five pillars: Network, Data, Identity, Device, 

and Application. This work will expand significantly in FY 2024, as outlined below: 

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• The ZTA Network pillar is one of the core capability models. In FY 2022, the 

EEOC initiated the implementation of network access control (NAC), limiting 

and securing network access to only government-furnished devices. NAC 

deployment was completed in FY 2023, switching from “monitor” to “enforce” 

mode throughout the enterprise. 

• In FY 2023, the EEOC completed a comprehensive evaluation of zero trust 

network capabilities and began the incremental implementation of DOJ’s secure 

access and secure edge solution, Justice Edge Trust Service (JETS), to provide 

zero-trust solutions for Internet Access, Private Access, and Advanced Digital 

Experience and Monitoring. 

• JETS implementation, which will continue into FY 2024, will enable the EEOC 

with network segmentation, zero trust network access, and access control. 

Furthermore, it allows for removing VPN infrastructure and eliminating points 

of exposure. 

• The EEOC currently leverages various technologies and security controls to 

gain contextual details and obtain a greater understanding of performance, 

behavior, and activity baselines across ZTA pillars. This visibility improves 

detection of anomalous behavior and provides the ability to make dynamic 

changes to security policies and enforce real-time access decisions. In FY 

2024, the EEOC will expand focus on ZTA Data pillar capabilities. The JETS 

implementation, outlined above, will address some elements of data in-motion 

activities. FYs 2024 and FY 2025 activities will expand to data at rest – 

reviewing data, inventory, categorizing, and labeling. These activities will 

provide extra visibility into data and how it is accessed and used, allowing the 

EEOC to automate categorization, security responses, and granular audits; 

implement additional data integrity/data spillage techniques; and deploy 

comprehensive logging and information sharing to meet the needs of zero trust. 

• For the ZTA Identity pillar, in order to better meet ZT requirements for all 

agency-provided devices, the EEOC made a strategic decision to move away 

from the prior PIV-based device-login solution to a new password-less MultiFactor Authentication (MFA) strategy - providing a strong, non-impersonable 

authentication process for all agency resource access. In FY 2023 the EEOC 

deployed FIDO2/WebAuthn-compliant devices and services for workstation 

logon, remote desktop (RDP) sessions, network device login, and cloud 

applications access. In addition, in FY 2022, the EEOC established an MOU 

with GSA’s Technology Transformation Services for Login.Gov integration. 

The secure sign-in service integration will provide the public with MFA and 

phishing-resistant authentication methods for EEOC’s public-facing systems. 

In FY 2023, the EEOC completed Login.Gov integration for its public-facing 

system receiving Freedom of Information Act (FOIA) requests, as well as our 

new Attorney eFile service. Integration work will continue with the EEOC’s 

other public portals during FY 2024. 

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• To address requirements for the ZTA Device pillar, in FY 2021, the EEOC 

deployed Hardware Security Module (HSM) dedicated cryptographic 

components into the agency’s infrastructure to provide enterprise Public Key 

Infrastructure (PKI) certificates for workstations, servers, applications, and 

other IT security efforts. In FY 2022, the EEOC successfully enabled, tested, 

and deployed a new agency laptop setup experience using Windows Autopilot 

and Microsoft Intune Endpoint Manager, a cloud-enabled transformative 

platform for unified and secure endpoint management. The new process: 

reduces end users’ device setup time by 75 percent; does not require access to 

the EEOC’s Network for provisioning; and ensures that laptops are up to date 

with automatic patches and updates, reducing security vulnerabilities. FY 2024 

ZTA efforts under this pillar are focused on improving device authentication, 

compliance, and inventory management. 

• For the ZTA Application pillar, the above referenced deployment of the TMFfunded ARC system utilized DevSecOps framework practices to integrate 

security into all phases of the software development lifecycle. This includes the 

use of continuous integration/continuous deployment (CI/CD) pipelines, and 

immutable infrastructure Platform-as-a-Service (PaaS) features. In FY 2022, 

the EEOC coordinated with DHS to conduct a “High Value Asset” (HVA) 

security assessment review of the new ARC system and its cloud-based 

environment. The ARC system is designated as an HVA due to its support of 

EEOC mission essential functions. All findings associated with this DHS 

review were fully mitigated by early FY 2023. In FYs 2024 and 2025, the 

EEOC will continue to focus on ZTA secure access cloud and isolation 

requirements. 

In addition to the above efforts, in FY 2022, the agency implemented a Vulnerability 

Disclosure Program (VDP), and operational continuous monitoring capabilities through the 

Department of Homeland Security’s Continuous Diagnostics and Mitigation (CDM) 

Program. These expanded controls will significantly reduce cybersecurity risk and allow 

the agency to better meet Federal Information Security Modernization Act (FISMA) 

requirements and standards. 

On the privacy front, the EEOC implemented Office 365 Data Loss Prevention (DLP) 

technologies to monitor outgoing external email transmissions for content containing 

sensitive information, such as Social Security numbers. In FY 2021, the agency also 

implemented EEOC Secure Share, a secure file transfer solution that enables the agency 

and external parties to exchange files in a HIPPA and FIPS 140-2 compliant manner. The 

EEOC will continue to deploy and utilize data-at-rest encryption and other data loss 

prevention technologies within SharePoint and Azure to better protect and secure the 

agency’s sensitive data. 

Another key IT focus is Enterprise Analytics and Reporting, as the agency has recognized 

the need to better utilize its data for analytics, such as to support decision making, and 

operational reporting, to support mission results. The EEOC migrated its IMS-based 

analytics to Microsoft Power BI, retiring its aging and unsecure Hyperion environment in 

early FY 2022. In FY 2023, this work turned to developing Power BI-based reporting and 

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analytics services for its new ARC charge/case management system. FYs 2024 and 2025 

will continue to expand analytical capabilities and services. 

Finally, the EEOC will be expanding our IT Accessibility/508 Program during FYs 2024 

and 2025 to better meet federal requirements. This includes providing role-specific 

learning paths and task-based, on-the-job training tools that encourage course completion 

and knowledge retention for EEOC’s custom 508 topics; providing executive Section 508 

presentations specific to EEOC leadership; expanding support for our FY 2023 

implemented Document Accessibility Lab; and increasing the availability of existing 508 

contractor resources and consulting services to meet expanding requirements and needs. 

As outlined above, in FY 2023, the EEOC achieved many of our multi-year digital 

transformation milestones – realizing the related benefits, efficiencies, and cost savings. 

With sufficient funding in FYs 2024 and 2025, the EEOC will continue to use its newly 

acquired technologies to their fullest potential – modernizing its network infrastructure, 

improving digital services, and enhancing information security and privacy through our 

ZTA strategy and plan. 

Funding fully supports the following Presidential Priorities: Federal Mission Resilience 

(supporting the Agency’s initiatives to address current inefficiencies in the intake and 

interview scheduling processes and maintaining information and communications 

technology capabilities required to meet agency goals); Equitable Data Budget Initiatives 

(supporting development to conform to new developments in employment discrimination 

laws and supporting Equitable Data Working Group initiatives); Ensuring Effective 

Diversity, Equity, Inclusion, and Accessibility (DEIA) Implementation (ensuring the 

EEOC systems and services meet accessibility standards); Advancing Equity through the 

Federal Government (providing funding to address Equity Action Plans and improve 

public participation in related initiatives); Improving Customer Experience (CX) 

(providing CX perspectives and support into all areas of the EEOC development lifecycle, 

from conception/vision through implementation/support). 

This is particularly relevant to our portal modernization initiatives, which are being 

designed with a CX focus and priority); Digital Service Teams (implementing digital 

modernization strategies that align technology investments to deliver the public in 

impactful ways. For the EEOC, this includes digital process transformation and 

automation activities); Agency Work Environments (maintaining and expanding services 

to meet hybrid/remote work needs); Prioritizing IT Modernization and Cybersecurity 

(ensuring continued funding and focus on mission system modernization, and the 

security/privacy of the systems and data, including zero trust implementations); and 

Designing and Delivering Integrated Digital Experiences (modernizing new and existing 

websites and digital services to improve the public’s interactions with the agency and 

ensure accessibility). 

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5. Finance and Administration 

Office Rehabilitations and Relocations 

The EEOC continues to collaborate with the General Services Administration (GSA) to 

right-size space to achieve optimum assigned staff and space capacity ratio of a 70 percent 

or more capacity utilization rate of EEOC-occupied space. 

We continue to prioritize, plan, and execute imminent lease expiration, opportune space 

reductions, and other major space management operations in support of the agency’s 

strategic objectives and overall mission. 

The EEOC continues to incorporate space reduction or sustainment measures to comply 

with amended OMB memorandum M-12-12 “Promoting Efficient Spending to Support 

Agency Operations,” Executive Order 13589 requirements to reduce operating costs and 

“Reduce the Footprint (RTF).” Measures we employ include, but are not limited to the 

following: 

• The EEOC will employ measures to ensure that the total square footage of our 

office space does not increase from the FY 2015 RTF baseline. The agency will 

return to GSA or lessor unneeded or underutilized space (rightsizing); and 

identify “off-setting” office space to reduce when we must exceed the RTF 

baseline for one or more of the EEOC’s offices. 

• Adherence to Agency Space Allocation Guidelines, for universal application of 

personnel and office space requirements that include a designated number of 

two-person private offices dependent upon the total square feet of the office. 

• For maximum economic efficiency, the Commission continues to plan space 

requirements for both the short and long terms and “right-size” offices in 

conjunction with lease expiration operations. We also fund security and safety 

improvements and furniture replacement as needed. 

• The EEOC will continue to review all space needs, current and emerging to 

ensure that we maximize our space utilization and update our space allocation 

guidelines to adjust for a post-COVID work environment, as detailed in OMB 

Memorandum M-21-25 “Integrating Planning for A Safe Increased Return of 

Federal Employees and Contractors to Physical Workplaces with Post-Reentry 

Personnel Policies and Work Environment, Appendix II.” Our efforts will 

consider the agency’s mission, current and future workplace needs, and most 

importantly the impact on the communities we serve. To this end, the EEOC is 

working with GSA to seek to repurpose of some existing space to accommodate 

the newly formed Office for Civil Rights, Diversity and Inclusion (OCRDI); 

establish a separate physical security office; and, to establish a hoteling/shared 

space section to accommodate several cubicles and offices for remote workers 

and enhanced workstation sharing. 

Based on the above, the following is a summary of FY 2023 completed space actions and 

FYs 2024-2026 planned space actions: 

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• FY 2023: Completed lease awards, relocation, and Tenant Improvement 

projects: Charlotte, Dallas, Milwaukee, Memphis, and Savannah. 

• FY 2024: Expiring leases and lease awards, anticipated relocations, and office 

wide re-configuration Commission projects: Birmingham, Cincinnati, 

Indianapolis, Nashville, New Orleans, New York, Pittsburg, San Diego, and St. 

Louis. 

• FY 2025: Anticipated expiring lease, relocation, and office wide reconfiguration Commission projects: Detroit, Headquarters, Honolulu, Mobile, 

Raleigh, and Tampa. 

• FY 2026: Anticipated expiring lease, relocation, and office wide reconfiguration Commission projects: Boston and Oklahoma City. 

Financial Management and Data Analysis 

The “Digital Accountability and Transparency Act of 2014” (DATA Act) requires 

agencies to designate an Agency Senior Accountable Officer (SAO) to meet the legislative 

and regulatory requirements. 

The EEOC’s designated SAO is the CFO. The EEOC is taking steps to improve budget, 

performance and financial data as prescribed by the DATA Act. 

Financial and Spending Data Analysis and Compliance 

The EEOC currently uses the Department of Interior’s Oracle Contract Life Cycle 

Management (CLM) System to procure goods and services. The CLM has many system 

and control limitations, does not produce 508-compliant contract documents, and is no 

longer in compliance with basic regulatory requirements, including the DATA Act, clause, 

and form updates, e.g., Standard Form 26 (SF26), Item 13 is not updated to reflect the past 

update from March 2013 of “41 U.S.C. 3304(a)”, the authority for using other than full and 

open competition. Additional help desk support requests for data fix scripts are often 

required to resolve historical data inputs and revisions to prior workarounds for technical 

integration obstacles which were required for processing obligations prior to system 

upgrades. 

The EEOC is taking various complementary approaches and has implemented controls to 

overcome the CLM system limitation and non-compliance challenges to meet the 

legislative and regulatory mandates, and to satisfy the DATA Act requirements. 

Security, Safety, Emergency Preparedness and Continuity of Operations 

In FY 2022, the Commission completed the installation of an Enterprise Physical Access 

Control System (ePACS) in all 53 Field Offices and Headquarters. This brings the EEOC 

into compliance with HSDP-12, FIPS 201, NIST SP 800-116 and DHS/Interagency 

Security Committee standards and guidance. Ongoing support, life cycle replacement, 

office relocation installation, service and maintenance are required. 

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In FY 2019, the Commission embarked on mitigating active shooter vulnerabilities within 

their Field Office’s intake areas for offices located in buildings without physical security 

screening (x-ray and magnetometer) and armed Protective Security Officers. The EEOC, 

working with GSA, collaborated to install ballistic resistant glass transaction windows in 

16 locations without physical security screening and armed Protective Security Officers. 

The final installation was complete in FY 2023. Future office relocations into buildings 

without physical security screening and armed Protective Security Officers will include 

ballistic glass transaction window installations. 

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IX. VERIFICATION AND VALIDATION OF DATA 

The agency’s private sector, federal sector, and litigation programs require accurate 

enforcement data, as well as reliable financial and human resources information, to assess 

the EEOC’s operations and performance results and make sound management decisions. 

The EEOC will continue efforts to ensure the accuracy of program information and 

analysis of the information. 

The EEOC systematically reviews the information collected in the agency’s databases for 

accuracy by using statistical software (e.g., SAS, PowerBI, etc.) and program reviews of a 

sample of records during field office technical assistance visits. Additionally, headquarters 

offices regularly conduct analyses to review the information collected to identify erroneous 

entries requiring correction to collection procedures. 

The modernization of the agency’s legacy IMS application to the new ARC system 

continues to improve the collection and validation of information for the EEOC’s program 

data related to charge intake, investigation, mediation, conciliation, and FEPA functions – 

migrating away from manual activity-based data entry to automated event-driven 

recordation. During these modernization efforts, the EEOC has identified many areas 

where the agency will be able to further improve and automate current processes and 

related data integrity. Because several performance measures require data to assess agency 

achievements, it is significant that the EEOC can now obtain reliable data more quickly. 

The EEOC’s Office of Inspector General (OIG) continues to review the agency’s data 

verification and validation procedures, information systems, and databases and offers 

recommendations for improvement. The agency uses the OIG’s information and 

recommendations to continually improve the EEOC’s systems and data. 

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X. PROGRAM EVALUATIONS 

Program evaluation is an important component of the EEOC’s effort to ensure that its 

programs are operating as intended and achieving results. A program evaluation is a 

thorough examination of program design or operational effectiveness that uses rigorous 

methodologies and statistical and analytical tools. Evaluations also use expertise internal 

and external to the agency and the program under review. 

Independent program evaluations have played an important role in formulating the 

strategic and performance goals for the EEOC’s Strategic Plan. They have helped shape 

some of the program issues and key focus areas for improvement, thereby increasing the 

plan’s value as a management tool to guide the agency’s strategic efforts in attaining 

overall productivity and program efficiency, effectiveness, and accountability. To that 

end, the EEOC has undertaken the following program evaluations to advance its 

performance-based management initiatives under the Government Performance and 

Results Management Act, and to improve the effectiveness of key agency programs. The 

findings and recommendations in these independent assessments of the agency’s programs 

were used to guide development of the EEOC’s strategic direction and goals for the next 

several years. 

Digital Process Transformation and Automation program, KAI Partners for the EEOC 

Office of Inspector General, January 2023. 

OIG evaluation of EEOC’s Management of Private Sector Customer Service, October 

2022. 

Evaluation of the EEOC’s Social Media Program, Hager Sharp, Office of Inspector 

General, July 2021. 

Evaluation of EEOC’s Contracts Administration Activities, Office of Inspector General, 

March 2020. 

EEOC Federal Hearings and Appeals Processes, The Center for Organizational Excellence, 

Inc. and CohnReznick LLP, Office of Inspector General, March 2020. 

Evaluation of the EEOC’s Data Analytics Activities, Elder Research, Office of Inspector 

General, September 2018. 

Consistent with the Commission’s focus on improving the effectiveness of government 

through rigorous evaluation and evidence-based policy initiatives, the EEOC will continue 

to identify appropriate program areas for evaluation during the reporting period of the 

agency’s Strategic Plan. This will ensure that its efforts align with the agency’s budget 

and other programmatic priorities. The EEOC will assess its progress on an ongoing basis 

to reaffirm its commitment to fulfilling the agency’s mission. 

In FY 2023, the agency continued its work to address the recommendations from several 

OIG and GAO evaluation projects. See Appendix D for more detail. 

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XI. ADMINISTRATION AND SUPPORT 

A. Introduction 

We are constantly seeking ways to achieve organizational excellence by improving our 

organizational capacity through sound management of our resources. Maximizing 

effective use of EEOC resources is essential to achieving the agency’s enforcement and 

outreach goals. 

B. Freedom of Information Act Workload 

The data suggest that the number of requests received under the FOIA will stabilize at 

slightly under 14,700 by FY 2027. 

Table 13 below depicts the actual FOIA workload for FYs 2021 - 2023 and projections for 

the number of requests received, processed, and pending for FYs 2024 - 2027. 

Based on actual workload data from the first three quarters of FY 2022, as noted in Table 

13 below, the agency projects the number of FOIA requests to be received each year from 

FYs 2024 - 2027 as approximately 14,704 requests annually. Based on data from the first 

three quarters of FY 2022, the number of FOIA requests processed each year is estimated 

to be approximately 14,655 in FYs 2024 through FY 2027. 

Table 13: Freedom of Information Act (FOIA) 

FY 2021 to FY 2027* 

FY 2021* 

(Actual) 

FY 2022** 

(Actual) 

FY 2023 

(Actual) 

FY 2024 

(Est.) 

FY 2025 

(Est.) 

FY 2026 

(Est.) 

FY 2027 

(Est.) 

Carryover 

Previous 

Year 

2,003 1,275 2,052 2,152 2,201 2,250 2,299 

Receipts 15,320 14,040 14,753*** 14,704 14,704 14,704 14,704 

Total 

Workload 17,323 15,315 16,805 16,856 16,905 16,954 17,003 

Processed 16,048 13,263 14,653  14,655 14,655 14,655 14,655 

Pending 

FOIA** * 1,275 2,052 2,152 2,201 2,250 2,299 2,348 

* Updated numbers are from section V.A. of EEOC’s FY2021 annual FOIA report cleared by DOJ. 

** Updated numbers are from section V.A. of EEOC’s FY2022 annual FOIA report cleared by DOJ. 

*** Received FOIAs for the first three quarters of FY2023 are 3,435, 3,920, and 3,710 totaling 11,065. Taking the average of quarters 

1 through 3 which is 3,688 and adding it to quarters 1 through 3, the projected receipts for FY2023 is 14,753. This quarterly 

information can be found at foia.gov. 

**** Processed FOIAs for the first three quarters of FY2023 are 3,537, 3,688, and 3,765 totaling 10,990. Taking the average of these 

numbers, which is 3,663, and adding it to the total, the projected processed FOIAs for FY2023 is 14,653. This quarterly information 

can be found at foia.gov. 

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C. GINA Study Commission 

Section 8 of Title II of the Genetic Information Nondiscrimination Act (GINA) of 2008 

requires that a commission designated by members of Congress be established on May 21, 

2014, to review the developing science of genetics and to make recommendations to 

Congress regarding whether to provide a disparate impact cause of action under GINA. To 

date, Congress has not designated any members. In order to abide by our statutory 

responsibilities, should such a Commission be established, we anticipate that we would 

need to cover the following costs for the eight-member commission: shared rent and 

security; IT services; per diem, including air fare; postal services; and other miscellaneous 

expenses. 

To be known as the Genetic Nondiscrimination Study Commission, this commission 

would be located in a facility maintained by the EEOC. Although members will not 

receive compensation for the performance of services for the commission, the statute 

requires that members receive travel expenses, including per diem, while away from their 

homes or regular places of business in the course of performing services for the 

commission. The statute authorizes sums to be appropriated to the EEOC as shall be 

necessary to carry out the requirements of Section 8. 

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APPENDIX A: GENERAL STATEMENT OF LAWS 

The U.S. Equal Employment Opportunity Commission (the EEOC or Commission) was 

established under Title VII of the Civil Rights Act of 1964 (78 Stat. 253, 42 U.S.C. 2000e 

et seq.), and became operational on July 2, 1965. The EEOC is a bipartisan Commission 

comprised of five members, who are appointed by the President, with the advice and 

consent of the Senate, for rotating five-year terms. No more than three members may 

come from the same political party. The President designates one Commissioner to serve 

as Chair and another Commissioner to serve as Vice Chair. In addition to the 

Commissioners, the President appoints a General Counsel to a four-year term to support 

the Commission and oversee the agency’s litigation programs. 

The EEOC is charged with preventing and remedying unlawful employment 

discrimination and advancing equal opportunity for all. The EEOC fulfills its mission 

through the implementation of a vigorous law enforcement program that includes 

investigation, conciliation, mediation, and litigation, complemented by an outreach 

program that provides information, guidance, and technical assistance to help prevent 

discrimination. 

Statutes Enforced 

The EEOC enforces Title VII of the Civil Rights Act, which prohibit discrimination on the 

basis of race, color, religion, sex, or national origin by private and state or local employers 

with 15 or more employees; by employment agencies; by labor organizations with 15 or 

more members; by joint labor-management training and apprenticeship programs; and by 

the federal government. The law also requires employers and other covered entities to 

reasonably accommodate an employee’s religious practices unless doing so would pose 

“undue hardship” as interpreted by the Supreme Court in Groff v. DeJoy, 143 S. Ct. 2279 

(2023), meaning that a “burden is substantial in the overall context of the employer’s 

business.” In 1978, Title VII was amended to enact the Pregnancy Discrimination Act 

(PDA), which requires employers to treat pregnancy, childbirth, or a medical condition 

related to pregnancy or childbirth as any other medical condition with respect to terms of 

employment, including health benefits. 

In addition to Title VII, the EEOC enforces the Age Discrimination in Employment Act of 

1967 (ADEA); the Equal Pay Act of 1963 (EPA); Sections 501 and 505 of the 

Rehabilitation Act of 1973; Titles I and V of the Americans with Disabilities Act of 1990 

(ADA); Title II of the Genetic Information Nondiscrimination Act of 2008 (GINA); and 

the Pregnant Workers Fairness Act (PWFA). 

The ADEA protects individuals aged 40 and older from age-based employment 

discrimination. It covers private employers with at least 20 or more employees, state and 

local governments, employment agencies, labor organizations with 25 or more members, 

and the federal government. The ADEA was amended in 1990 by the Older Workers 

Benefit Protection Act to prohibit age discrimination in fringe benefits and to limit waivers 

of ADEA claims. 

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The EPA prohibits sex-based discrimination in the payment of wages to men and women 

performing substantially equal work in the same establishment. The EPA applies to most 

employers. 

Titles I and V of the ADA prohibit employment discrimination against qualified 

individuals on the basis of an employee’s or applicant’s disability. The act covers both 

private sector and state or local government employers with 15 or more employees, 

employment agencies, and labor organizations with 15 or more members, and joint labormanagement training and apprenticeship programs. Sections 501 and 505 of the 

Rehabilitation Act protect qualified individuals from employment discrimination on the 

basis of disability by the federal government, and section 501 requires that federal 

employers undertake affirmative action on behalf of individuals with disabilities. 

The ADA and the Rehabilitation Act both require employers to make reasonable accommodations for individuals with disabilities absent undue hardship (i.e., significant difficulty 

or expense). The laws also regulate when employers may ask for certain medical 

information, require medical testing, and disclose employee medical records, regardless of 

whether the affected individual is a qualified individual with a disability. The ADA 

Amendments Act of 2008 broadened the definition of “disability” under the ADA and the 

Rehabilitation Act. 

Title II of GINA protects individuals against employment discrimination based on genetic 

information, including information about an individual’s genetic tests and the genetic tests 

of an individual’s family members, as well as information about an individual’s family 

medical history. GINA covers employers with 15 or more employees, including state and 

local governments as well as employment agencies; labor organizations; joint labor-management training and apprenticeship programs; and the federal government. GINA also 

strictly limits access to genetic information and requires that covered entities maintain the 

confidentiality of any genetic information that they obtain. 

The PWFA requires employers to make reasonable accommodations for employees or 

applicants with known limitations due to pregnancy, childbirth, or related medical 

conditions, absent undue hardship (i.e., significant difficulty or expense). The PWFA 

covers employers with 15 or more employees, including state and local governments as 

well as employment agencies; labor organizations; joint labor-management training and 

apprenticeship programs; and the federal government. President Biden signed the PWFA 

into law on December 29, 2022; the law went into effect on June 27, 2023. 

All of the EEOC-enforced laws prohibit retaliation. Title VII, ADEA, ADA, the 

Rehabilitation Act, GINA, and the PWFA prohibit retaliation against individuals who have 

reasonably opposed discrimination, or who have filed a charge, served as a witness, or 

otherwise participated in an EEO proceeding. The EPA prohibits retaliation against an 

individual because they have filed a complaint (internal or with an enforcement agency) or 

instituted or testified in a proceeding. 

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Enforcement Methods 

Private Employers, State and Local Government Respondents 

Members of the public may file charges alleging employment discrimination in violation 

of EEOC-enforced laws with an EEOC field office. Charges also may be initiated by the 

EEOC’s Commissioners or, alternatively, “on behalf of” another person by an individual 

or organization, such as a union or civil rights group. After charges are filed, the EEOC’s 

staff members investigate and the EEOC may issue a determination of “reasonable cause” 

or dismiss the charge for a variety of reasons. If the agency determines there is reasonable 

cause to believe unlawful discrimination occurred, it attempts to resolve the charge through 

conciliation. The EEOC also attempts to settle charges through mediation, in lieu of an 

investigation or at any stage of an investigation. Under Title VII, the ADEA, ADA, 

GINA, and the PWFA, filing a charge generally is a prerequisite to filing a lawsuit. Filing 

a charge of discrimination is not a prerequisite to filing a suit under the EPA. 

EEOC-enforced laws authorize the EEOC to file suit in federal district court in order to 

remedy employment discrimination if it is unable to achieve resolution through voluntary 

conciliation. If, however, the charge of discrimination involves allegations under Title VII, 

the ADA, GINA, or the PWFA against a state or local government, the EEOC refers it to 

the Attorney General, who may file suit in federal court. The EEOC may bring its own 

suits alleging violations of the ADEA or EPA by state or local governments. 

Federal Agency Respondents 

The EEOC also oversees a separate administrative process for employment discrimination 

claims against the federal government. The federal government, as an employer, is subject 

to these anti-discrimination requirements through Section 717 of Title VII; Section 15 of 

the ADEA; Section 501 of the Rehabilitation Act; the EPA; Section 201 of GINA; and 

Section 102 of the PWFA. These laws provide the EEOC with oversight responsibility, 

including the authority to maintain procedures used by federal departments and agencies in 

processing internal complaints of employment discrimination. In addition, the EEOC has 

jurisdiction to review final administrative decisions of departments or agencies on their 

discrimination complaints. 

The EEOC may award relief to federal employees, applicants and former employees to 

remedy harm suffered by violations of these laws and may monitor federal agencies’ compliance. It also is responsible for ensuring that federal departments and agencies maintain 

programs of equal employment opportunity, including by posting equal employment 

opportunity data pursuant to the Notification and Federal Employee Antidiscrimination 

and Retaliation Act of 2002 (the “No FEAR Act”) – including the additional 

responsibilities under the Elijah E. Cummings Federal Employee Antidiscrimination Act of 

2020 amendments – to help Congress, federal agencies, and the public assess whether and 

to what extent agencies are meeting their EEO responsibilities. 

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Data Reporting and Record Keeping 

Under section 709(c) of Title VII, the EEOC may require covered entities to keep records 

that are relevant to determining whether the law has been violated and may require 

reporting from this information. Pursuant to this authority, the EEOC requires covered 

private employers, state or local governments, and labor organizations to file periodic 

reports providing data on the makeup of their workforces or memberships by gender and 

racial/ethnic categories. The EEOC uses this data in charge investigations and other 

enforcement activities. It also uses this data to produce reports about the status of workers 

by race, ethnicity, or gender in selected industries. 

Section 709(e) of Title VII forbids the EEOC or any EEOC officer or employee from 

making public any information before a Title VII proceeding is instituted that involves that 

information. EEOC staff who violate this prohibition may be found guilty of a criminal 

misdemeanor and could be fined or imprisoned. The EEOC directly imposes this Title VII 

confidentiality requirement on all of its contractors, including contract workers and 

contractor companies, as a condition of their contracts. With respect to other federal 

agencies with a legitimate law enforcement purpose, the EEOC gives access to information 

collected under Title VII only if the agencies agree, by letter or memorandum of 

understanding, to comply with the confidentiality provisions of Title VII. For the EEOC, 

its agents and contractors, Title VII only permits disclosure of information after suit is filed 

in a particular matter on the issues that were investigated at the administrative level. 

With respect to data-sharing with FEPAs, Title VII states that the EEOC may give FEPAs 

information (including EEO-1 data) about employers in their jurisdiction on the condition 

that it not be made public prior to the institution of a proceeding under state or local law 

involving such information. The EEOC’s current practice is to share with a contracted 

FEPA the EEO-1 data filed by an organization within the FEPA’s jurisdiction. The 

contracts include provisions imposing obligations with respect to confidentiality, privacy, 

and data security. The EEOC may also share data with a non-contracted FEPA only if 

specified internal review protocols are followed and such sharing is deemed appropriate. 

In such instances, non-contracted FEPAs will be required to formally agree to 

confidentiality, privacy, and data security requirements. The general rule is that EEO-1 

data for an employer within the FEPA’s jurisdiction will be shared. However, the policy 

recognizes and allows for additional data to be shared to assist labor market analyses, in 

some instances. Title VII authorizes the EEOC to decline to honor a FEPA’s subsequent 

requests for information if the FEPA violates Title VII’s confidentiality requirements. 

Leadership and Coordination of Federal EEO Efforts 

Under Executive Order 12067, the EEOC provides leadership and coordination to all 

federal departments’ and agencies’ programs enforcing federal statutes, executive orders, 

regulations and policies that require equal employment opportunity. The executive order 

instructs the EEOC to eliminate conflict, competition, duplication, and inconsistency when 

coordinating these programs and to promote efficiency and effectiveness. All federal 

departments and agencies are required to cooperate with and assist the EEOC in 

performing these functions and are required to furnish the EEOC with such reports and 

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information as it may require, including any proposed rules, regulations, policies, 

procedures, or orders concerning equal employment opportunity during their development 

and in final at least 15 working days before issuance. 

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APPENDIX B: EVALUATION AND EVIDENCE 

1. Agency Context 

a. Current Efforts and Future Plans 

The EEOC recognizes the importance of data driven decision-making and the 

transformative role data can have to make the federal government more efficient and to 

better serve the American people. The EEOC is committed to building our capacity to 

provide mission critical evidence and better integrate our information and data policy into 

budget, performance and management decision making. As a basis for this emphasis, the 

agency is guided by: 

• The EEOC’s Strategic Plan and its prioritization across the agency’s long-term 

strategic goals and objectives; 

• The EEOC’s Strategic Enforcement Plan, FYs 2024-2028; 

• Foundations for Evidence-Based Policymaking Act of 2018; 

• OMB Guidance including OMB M-21-27, OMB M-20-12, and OMB M-19-23; 

• Executive Order on Advancing Racial Equity and Support for Underserved 

Communities Through the Federal Government; 

• Executive Order on Diversity, Equity, Inclusion, and Accessibility in the Federal 

Workforce; 

• Presidential Memorandum on Restoring Trust in Government Through Scientific 

Integrity and Evidence-Based Policymaking; 

• Executive Order on Improving the Nation’s Cybersecurity; and 

• Executive Order 14058 on Transforming Federal Customer Experience and Service 

Delivery to Rebuild Trust in Government. 

b. Recent Major Progress 

The EEOC’s Data Governance Board and Chief Data Officer provide executive leadership 

and oversight for the development and implementation of the policies and processes that 

govern the collection, creation, management, use, and disclosure of the EEOC’s data. 

The EEOC continues to make great strides with its Data and Analytics Modernization 

Program. In FY 2023, the program focused on enhancing the transparency of agency 

functions and operations, reducing burden on stakeholders, augmenting agency use of 

modern data analytics to drive data-driven decision making, and promoting greater public 

access to the data. The EEOC’s Data and Analytics Modernization Program 

accomplishments include: 

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• Administered the 2022 EEO-3 (Local Union Report) and the 2022 EEO-5 

(Elementary- Secondary Staff Information Report); 

• Enhanced EEOC Explore, a web-enabled, user-friendly, data query and mapping 

tool, to facilitate and encourage greater access to and use of EEOC data for both 

agency staff and members of the public; 

• Continued to modernize, enhance, and streamline the agency management 

workload reporting process thereby reducing burden on district office staff and 

utilizing the modern analysis and reporting platforms; 

• Implemented improvements to eeoc.gov/data, the agency’s one-stop shop for data 

and analytics that enables access to the EEOC’s publicly available workforce 

demographic data, and easy-to-explore datasets, along with visualizations on 

specific topics; 

• Entered into an Interagency Agreement with the Census Bureau to provide secure 

access to agency data for qualified researchers using its Federal Statistical Research 

Data Center network. 

c. Current Barriers 

The EEOC, having made significant initial strides to modernize its methods of data 

collection, reporting, and access in recent years, will seek to identify resources in FY 2023 

and FY 2024 to continue the agency’s work to implement data-driven decision-making, 

enterprise-wide, and to use data to deliver on the EEOC’s mission and serve both the 

agency and the public. 

2. Evaluation Projects 

In FY 2023, the agency continued its work on the following evaluation projects: 

• Inter-Agency Agreement between the EEOC and the National Academies for a 

Panel to Evaluate the Quality of Compensation Data Collected from U.S. 

Employers by the EEOC through the EEO-1 Form. In FY 2020, the EEOC 

contracted with the National Academies to evaluate the EEOC’s historic, first-time 

collection of pay data from certain private employers and federal contractors 

between July 2019 and February 2020. On July 28, 2022, the National Academies 

issued an approximately 300-page Consensus Study Report, which concluded that 

the data the EEOC collected may be used to prioritize investigations and the 

agency’s allocation of resources to identify potential pay discrimination. 

The report also offers recommendations for improving the collection of pay data in 

the future. Many of the recommendations complement and were incorporated into 

existing efforts as part of the agency’s ongoing modernization of its EEO data 

collections and data analytics that began in FY 2022 and continued in FY 2023. 

The EEOC will use the report from the National Academies to inform the agency’s 

approach should it decide to again undertake pay data collection in the future. 

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• Mediation Survey Modernization Project. EEOC mediation participants continue to 

share their feedback by completing a survey electronically, in English, Spanish, 

Chinese (Simplified), and Haitian Creole. The project’s benefits include fewer 

steps in the process of distributing the survey to participants, faster receipt of 

survey responses, reduced data entry, and elimination of postage. In FY 2023, 

technological enhancements were made to allow for same day availability of survey 

results, data compilation, and analysis. 

Previously, surveys were sent weekly/bi-weekly to the participants, with results 

dependent upon the dates of the transmissions maintained in each office in varying 

Excel formats. The cross-office collaboration and experience acquired in executing 

targeted survey instruments, protocols, and oversight among EEOC program 

offices is an excellent model for other strategic applications involving customer 

canvassing, training/outreach assessments, and targeted programmatic evaluations. 

• The EEOC’s Data and Analytics Modernization Program. The goals of the 

modernization program are to: 1) enhance transparency of agency functions and 

operations; 2) reduce burden on our stakeholders; 3) augment agency use of 

modern data analytics to drive data-driven decision making; and 4) promote greater 

public access to data. In FY 2023, the EEOC’s OEDA led and participated in 

several modernization efforts specific to the evaluation of its data collection and 

reporting. With the transition of the enforcement data collection from the EEOC’s 

IMS to ARC, OEDA worked closely with EEOC’s Office of Information 

Technology (OIT) and OFP to identify reporting errors. Inaccurate data or data 

collection issues were promptly reported to OIT/OFP and collaboratively corrected. 

In FY 2023, OEDA continued to rebuild its regular reporting for enforcement using 

the new ARC data structure and performed regular quality assurance testing on the 

reports. 

Specific initiatives of the EEOC’s Data and Analytics Modernization Program include: 

Provide Secure Access to the EEOC’s Restricted Data for Research and Statistical 

Purposes. 

To protect the EEOC’s restricted-access data released for research purposes, the agency 

through an Interagency Agreement with the Census Bureau is establishing through the 

Federal Statistical Research Data Center, a modern, secure, and privacy-protected 

approach to facilitate access to protected data for external researchers. The agreement 

advances the goals of the bipartisan Foundations for Evidence-Based Policymaking Act, 

which directed federal agencies to enhance evidence-building efforts, make greater use of 

existing data collections, and improve public access to data and will launch in early FY 

2024. 

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EEOC Explore. 

This project enhances the transparency of agency functions and operations by facilitating 

and simplifying access to agency publicly releasable data by creating easily accessible 

public use files, documentation, and a web-enabled, state-of-the-art, user-friendly, data 

query and mapping tool, to facilitate access, and encourage greater use of the EEOC’s 

publicly available data. The initial public launch displays EEO-1 aggregated files for FY 

2014 - FY 2018. Additional years of EEO-1 and other EEO data collection files will be 

added each year as data becomes available for publication. This publicly accessible tool is 

located at www.eeoc.gov/statistics/employment/jobpatterns/eeo1. 

Data Visualizations for the Public. 

The EEOC has created new data visuals to accompany the existing data summary product 

it releases to the public in tabular format. The purpose of these visuals is to display 

enforcement data in a simple, comprehensible, and visually appealing way for all our 

internal and external stakeholders. These products represent the EEOC’s first major new 

type of data product in more than 20 years. These data visualizations illustrate statistics 

for employment discrimination charges and resolutions for the general public as well as 

specialists in anti-discrimination law and are part of the agency’s broader effort to bring 

greater transparency to the EEOC’s operations. The agency is also creating customized 

visualizations for use by internal stakeholders in each district to support enforcement and 

outreach functions of the agency. The public-facing charge data dashboard, covering the 

enforcement and litigation statistics for FY 2012 - FY 2021 has been added to EEOC 

Explore since FY 2022, and is accessible at https://www.eeoc.gov/data/enforcement-andlitigation-statistics-0. 

Creation of a New System for the Federal Sector. 

Executive Order 14035 mandates the EEOC to adopt a data-driven approach for advancing 

policies that enhance diversity, equity, inclusion, and accessibility within its workforce. 

This approach must also safeguard employee privacy and protect sensitive information. 

This aligns with EEOC Strategy Goal III.B.1, which emphasizes utilizing technology to 

transform operations and improve service. 

To strengthen oversight and assist federal agencies, the EEOC aims to establish the 

Government-wide Complaint Management System (GWCMS). This system will 

efficiently gather and analyze data to combat workplace discrimination across the federal 

sector. Additionally, it will replace the complex annual data collection currently required, 

saving resources by avoiding duplication. 

Currently, each federal agency maintains its own EEO activity tracking system, leading to 

disjointed reporting. A centralized system would offer benefits such as real-time 

oversight, the elimination of time-consuming annual collection of data, the reduction of 

duplicative reports, and the enhancement of data-driven decision-making. These 

advantages promote fairness, inclusivity, and efficiency within the federal workplace. 

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In October 2021, the EEOC surveyed federal agencies to determine if they supported the 

creation of a centralized system and held a meeting with leaders of federal agency EEO 

programs to discuss the potential project. The EEO community broadly supported the 

project, with the stipulation that they would be active participants in its development. 

In FY 2023 and FY 2024, the EEOC will initiate the creation of the Federal Integrated 

Business Framework (FIBF) for EEO business standards. Developing these standards is 

essential for streamlining the EEO process. These standards will adhere to reliable sources 

and will be valuable for assessing EEO solutions and services. This is aimed at 

establishing consistent EEO business solutions across the government. The initial 

implementation of the system is scheduled to begin in FY 2025. 

Enterprise Data Warehouse. 

Since FY 2019, the EEOC has built and maintained an enterprise data warehouse (EDW) 

which serves as a central repository for cleaned, versioned analytical data from disparate 

sources. Over the past several years, this FISMA-compliant EDW has served as an 

important agency resource in the development of various data products and tools and as a 

secure means through which remote access to the EEOC’s mission-critical data can be 

provided to other federal government agencies, such as the GAO. 

Data Visualization Tool for EEOC Outreach and Education Coordinators. 

The EEOC has created an interactive data visualization tool for internal stakeholders in the 

EEOC’s Office of Field Programs to support outreach and education activities. Using 

public-use Census Bureau data and the Tableau visual analytics platform, the tool enhances 

data-driven decision making by enabling users to identify counties, EEOC districts, and 

states with relatively high concentrations of vulnerable workers by race and ethnicity, sex, 

age, and disability, and depicts the proximity of Tribal Employment Rights Office to the 

nearest EEOC office. The tool provides other characteristics of vulnerable worker 

populations including median income and foreign languages spoken. Future versions of 

the tool will overlay the Census data with data from the EEO data collections and historical 

charge data to also inform enforcement activities. 

Evaluate the Efficacy of Existing Relevant Federal Data Sets. 

The EEOC is working to identify other federal sources of administrative and survey data 

(e.g., Bureau of Labor Statistics, Census Bureau) that, alone or in combination with 

existing EEOC data, may allow exploration into detecting and developing new tools and 

models for increasing understanding and awareness, identifying solutions, and 

implementing actions targeting the reduction of illegal employment discrimination. 

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APPENDIX C: ENTERPRISE RISK MANAGEMENT 

BACKGROUND 

The EEOC Enterprise Risk Management Policy Handbook established formal Enterprise 

Risk Management (ERM) within the EEOC in accordance with Section II of OMB 

Circular A-123, ERM and Internal Control are components of a robust governance 

framework. ERM as a discipline, deals with identifying, assessing, and managing risks. 

Through adequate risk management, agencies can concentrate efforts on key points of 

failure and reduce or eliminate the potential for disruptive events. OMB Circular No. A123 defines management’s responsibilities for ERM and includes requirements for 

identifying and managing risks. 

The EEOC recognized that many risks within the organization are interrelated and cannot 

be effectively and efficiently managed independently within a given Headquarters or Field 

Office. The interconnected risks facing the EEOC must be managed across the 

organization and, in many instances, in coordination with the agency and its stakeholders. 

Therefore, the EEOC Enterprise Risk Steering Committee (ERSC) was established to 

oversee the development and implementation of processes used to analyze, prioritize, and 

address risks across the EEOC. The ERSC is composed of the following representatives: 

• Chief Risk Officer (CRO) and Committee Chair 

• Director, Office of Field Programs 

• Director, Office of Federal Operations 

• District Director Representative 

• Regional Attorney Representative 

• Field/Area/Local Office Director Representative 

• Chief Information Officer (CIO) 

• Chief Information Security Officer (CISO) 

• Director, Office of Enterprise Data and Analytics 

• Deputy General Counsel 

• Associate Legal Counsel 

• Chief Financial Officer (CFO) 

• Chief Human Capital Officer (CHCO) 

• Director, Office of Communications and Legislative Affairs (OCLA) 

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APPENDIX D: AGENCY RESPONSES TO PL 115-414 GOOD ACCOUNTING 

OBLIGATION IN GOVERNMENT ACT (GAO-IG Act) 

This bill requires each federal agency, in its annual budget justification, to include a report 

on: (1) each public recommendation of the Government Accountability Office (GAO) that 

is classified as "open" or "closed, unimplemented”; (2) each public recommendation for 

corrective action from the agency's office of the inspector general (OIG) for which no final 

action has been taken; and (3) the implementation status of each such recommendation. 

Audit Report Name: Performance Audit of the EEOC Commercial Charge Card Program 

Month and Year Report was Issued: OIG Report Number 2018-007-AOIG 

Date of Report: May 31, 2019 

Recommendation Implementation Status 

Purchase Cards - the Administrative Officer or District Resources Manager should maintain 

documentation of all account closures electronically or in hard copy. 

Travel Cards - The Charge Card Program Manager should maintain documentation of all 

account closures electronically or in hard copy. 

EEOC Order 360.003 for purchase 

cards has been revised to include the 

procedures which indicates that 

Administrative Officer or District 

Resource Managers are to maintain 

account closure documents. Work is 

in progress on internal guidance 

necessary to implement the A/OPC 

monitoring of purchase card closure 

memoranda. 

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Audit Report Name: Evaluation of EEOC Federal Hearings and Appeals Process 

Month and Year Report was Issued: OIG Report Number 2018-01-EOIG 

Date of Report: March 30, 2020 

Recommendation Implementation Status 

OIT developers should meet directly with software users, such as OFO attorneys and 

supervisory attorneys and OFP AJs and Supervisory AJs (SAJ) to determine additional 

requirements. 

Charge-Case Management 

Modernization Governance Charter 

outlines “Roles and Responsibilities” 

for workgroup participation.” 

See 3.1 related to TMF approved 

schedule changes for ARC Federal 

Hearings and Appeals. 

Solicitation of Application 

Requirements – Ongoing 

Federal Hearings FY 2024 

Federal Appeals FY 2025 

Assign a target number of days for intake so that management can determine if changes 

implemented impact the efficiency of the process. 

The Office of Federal Operations 

(OFO) established a target amount of 

goals/measures for intake to scan and 

docket. This allowed for assessment 

of the productivity of the office. 

However, although OFO believes the 

action taken has implemented the 

recommendation, closure remains 

pending. Testing and validation 

required. 

Audit Report Name: Final Report: FY 2021 Annual Report on EEOC’s Compliance with the Payment Integrity Information 

Act of 2019 (PIIA) 

Month and Year Report was Issued: OIG Report Number 2022-002-IOIG 

Date of Report: July 11, 2022 

Recommendation Implementation Status 

Annually conduct an improper payment review in accordance with PIIA and follow the 

guidance outlined in OMB Circular A-136, section II.4.5 [Payment Integrity Information Act 

Reporting]. 

Completed. FY 2022 Period 1 was 

conducted June 30, 2022. FY 2022 

Period 2 conducted October 2022. 

Auditors unable to confirm that 

action taken implemented the 

recommendation. Further testing and 

validation are required. 

Report the OIG’s finding of non-compliance with the FY 2021 PIAA requirements, as 

outlined in OMB Memorandum M-21-19, Section VI.D, “Agency Responsibility When a 

Program is non-Compliant”. 

Completed. OMB Payment Integrity 

has confirmed receipt and updated 

distribution lists. Further testing and 

validation for closure pending by 

auditors. 

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Audit Report Name: Transmittal of Management Letter Report for FY 2020 Financial Statement Audit 

Month and Year Report was Issued: OIG Report Number 2020-002-AOIG 

Date of Report: December 16, 2020 

Recommendation Implementation Status 

Recommend that EEOC management create a control where management reviews, on a 

sample basis, at least quarterly, the approved PP&E disposals/retirements or conformity to the 

EEOC SOP for OIT Excess Property that states, “When equipment is disposed of and SF 120, 

SF 122, or SF 120 copy using GSAXcess, is approved by the EEOC Approving Official(s), 

CSD Backup or Property management who have been found to not adhere to requirements of 

the SOPs for OIT Excess Property and require them to obtain additional training, to include 

certifying they have read the Approval Officials responsibilities, as it relates to the 

aforementioned control. 

Completed. The Office of 

Information Technology (OIT) 

believes that steps were taken to 

remediate the finding FY 2021. OIT 

coordinated to conduct a full review 

of all IT related assets that are still 

reflected within OFF to confirm 

whether the IT asset is physically in 

use or in storage within each office 

and whether continued inventorying 

within OFF is appropriate. The 

“clean-up” process, documented by 

the appropriate Approving Official, 

retires assets that no longer exist, or 

assets that are now inventoried within 

ServiceNow, from the OFF System. 

Closure of the recommendation is 

pending. Further testing and 

validation are required with the 

auditors. 

Audit Report Name: Performance Audit of the EEOC’s Charge Card Program 

Month and Year Report was Issued: OIG Rpt. No. 2020-004-AOIG 

Date of Report: March 24, 2021 

Recommendation Implementation Status 

Recommend that the Office of the Chief Financial Officer of the U.S. Equal Employment 

Opportunity Commission enhance the documentation, monitoring, and enforcement of its 

controls over the closure of charge card (purchase and travel) accounts. 

Repeat Finding. EEOC Order 

360.003 has been revised and issued 

November 2023 to include the 

recommendations, procedures to 

close out purchase card accounts, 

compliance with Section 889 of the 

John S. McCain National Defense 

Authorization Act for FY 2019, 

update micro-purchase threshold and 

quarterly reviews of randomly 

selected purchase cards. OCFO/ASD 

believes that the action taken 

implements the recommendation. 

Closure of the recommendation is 

pending. Testing and validation 

required by auditor. 

Recommend the EEOC ensure that emailed policy memos are promptly updated in the 

appropriate EEOC Directives Transmittal Order. 

The EEOC issued Purchase Card 

Memorandum 2202-01 to Purchase 

Cardholders and Approving Officials 

regarding Purchase Card Rebates. 

The revised EEOC Order 360.003 

will incorporate emailed policy 

memos. EEOC Order issued 

November 2023. Testing and 

validation for closure pending by 

auditors. 

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Recommendation Implementation Status 

Recommend that the Office of the Chief Financial Officer of the U.S. Equal Employment 

Opportunity Commission enhance the documentation and monitoring of controls over the 

validation process of charge card transactions. 

Work in progress. The EEOC 

conducts quarterly reviews. Internal 

Guidance Procedure, “Internal 

Purchase Card Review” created and 

issued to Approving Official/Purchase 

Card on March 8, 2021. 

• For purchase cards, EEOC management should create a control where management reviews, 

on a sample basis, purchase cards transactions to ensure all obligating documents and 

purchase orders are in conformity with EEOC Directives Transmittal Order 360.003, 

Commercial Purchase Charge Card Program Practical User’s Guide. 

Work in progress. EEOC Order 

360.003 revised and issued 

November 2023. Management will 

create a control where management 

reviews, on a sample bases, purchase 

cards transactions to ensure all 

obligating documents and purchase 

orders are in conformity with the 

newly revised EEOC Directives 

Transmittal Order 360.003, and 

Commercial Purchase Charge Card 

Program Practical User Guide. 

• For travel cards, EEOC management should create a control where management reviews, on 

a sample basis, travel card transactions to ensure all travel authorization or vouchers and 

receipts are in conformity with EEOC Directives Transmittal Order 345.001, Travel and 

Transportation Administrative Policies and Procedures Manual. 

Testing and validation required. The 

EEOC documented instructions in the 

Annual Business Process Memo and 

SOPs outlining the requirements for 

travel card closure procedures. SOPs 

have been updated to be consistent 

with CitiManager directives with 

additional controls for secure travel 

application processing, records 

maintenance, and travel card closing 

procedures. Updated monitoring and 

oversight testing procedures for 

validation of travel transactions 

included in the Improper Payment 

Testing guidance which is considered 

by FSSD on a semi-annual basis. 

We recommend EEOC management update its policies and procedures to include all required 

safeguards and internal controls to be compliant with the Government Charge Card Abuse 

Prevention Act of 2012. In addition, the EEOC should create a monitoring control to review 

the policy when changes or updates are made to federal law or Office of Management and 

Budget or General Services Administration guidance. 

EEOC Order 360.003 updated to 

include all required safeguards and 

internal controls for compliance. The 

EEOC attends monthly and quarterly 

A/OPC meeting conducted by GSA 

Center for Charge Card Management 

and reviews OMB Circular A-123 

Appendix B. Testing and validation 

required by auditors for closure. 

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Audit Report Name: Evaluation of the EEOC’s Social Media Program 

Month and Year Report was Issued: OIG Report No. 2020-001-EOIG 

Date of Report: July 26, 2021 

Recommendation Implementation Status 

Simplify the EEOC’s social media architecture by consolidating many of the existing social 

media channels and limiting creation of new channels. 

Work in progress. The Office of 

Communication and Legislative 

Affairs (OCLA) will determine 

criteria for evaluating if a social 

media channel is successful/should 

exist as a separate channel; Identify 

all existing social media channels and 

evaluate whether they should be 

consolidated; Consolidate and clean 

up existing social media channels; 

and ensure official media channels 

are consistently branded across 

platforms. FY 2024 

Implement a consistent content approval process run by OCLA. Work in progress. A social media 

manager was hired 8/28/2022. EEOC 

is in the process of developing criteria 

for content that needs approval and an 

approval process within Agorapulse 

or other social media management 

tool. A draft process proposal is 

undergoing review. FY 2024 

Complete revisions to the social media handbook and provide to all staff managing social 

media channels 

Work in progress. 

Now that a Social Media Manager 

was hired 8/28/2022, OCLA is in the 

process of reviewing social media 

accounts and revising social media 

handbook draft; circulating for review 

and revisions; and distributing final 

updated social media handbook. FY 

2024. 

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Audit Report Name: Final Report: Performance Audit of the EEOC Federal Information Security Modernization Act of 2014 

(FISMA) for FY 2021 

Month and Year Report was Issued: OIG Rpt. No. 2021-004-AOIG 

Date of Report: March 15, 2022 

Recommendation Implementation Status 

Recommend that EEOC plans and prepares to meet the goals of the TIC initiative, consistent 

with OMB M-19-26. The agency should define and customize, as appropriate, a set of 

policies, procedures, and processes to implement TYIC 3.0, including updating its network and 

system boundary policies, in accordance with OMB M-19-26. This includes, as appropriate, 

incorporation of TIC security capabilities catalog, TIC use cases, and TIC overlays. 

Work in progress. EEOC will meet 

the goals of the TIC initiative, 

consistent with OMB M-19-26. The 

agency will define and customize, as 

appropriate, a set of policies, 

procedures, and processes to 

implement TIC 3.0, including 

updating its network and system 

boundary policies, in accordance 

with OMB M-19-26. This includes, 

as appropriate, incorporation of TIC 

security capabilities catalog, TIC use 

cases, and TIC overlays. 4/15/2024 

Recommend that EEOC implement strong authentication mechanisms for privileged and nonprivileged users in accordance with Federal guidance, to meet the required use of PIV or an 

Identify Assurance Level (IAL)3/Authenticator Assurance Level (AAL) 3 credential of the 

agency’s networks, including remote access sessions, in accordance with Federal targets. The 

agency should continue developing their plans for organization-wide use of strong 

authentication mechanisms for non-privileged users and require multifactor authentication to 

network access for all user accounts. 

Work in progress. EEOC will 

implement strong authentication 

mechanisms for privileged and noprivileged users in accordance with 

Federal guidance, to meet the 

required used of PIV or an Identity 

Assurance Level (IAL) 

3/Authenticator Assurance Level 

(AAL) 3 credential of the agency’s 

networks, including remote 

accessions, in accordance with 

Federal Targets. The agency will 

continue developing their plans for 

organization-wide suite of strong 

authentication mechanisms for nonprivileged users and require 

multifactor authentication to network 

access for all user accounts. FY 2024 

– confirmation required by audited 

office. 

Recommend that EEOC review and remediate the medium level severity vulnerabilities 

identified during external penetration testing by: 

Disabling IKE Aggressive Mode. 

Refraining from the use of pre-shared authentication keys. 

Implementing multi-factor authentication for all VPN access. 

Work in progress. EEOC will 

perform identified actions to better 

strengthen security controls. 

Removed from VPN the advertising 

of Internet Key Exchange (IKE) 

Aggressive Mode with Pre-shared 

Key and disable the functionality if 

enabled. Disable TLS 1.2 or 1.3. 

VPN access requires machine 

authentication via decentralized 

public key infrastructure (DPK) 

certificate. Yubikey has been 

successfully integrated into the VPN 

authenticates architecture for 

supplementing user-based multifactor authentication. 

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Audit Report Name: Transmittal and Exist Conference Memorandum: Federal Information Security Modernization Act of 

2014 (FISMA) Fiscal Year 2022 Performance Audit 

Month and Year Report was Issued: OIG Report No. 2022-001-AOIG 

Date of Report: November 3, 2023 

Recommendation Implementation Status 

Recommend that EEOC defines, communicates, and implements an organization wide SCRM 

strategy to guide supply chain analyses, provide communication channels with 

internal/external partners and stakeholders, and assist in building consensus regarding the 

appropriate resources for SCRM. 

Work in progress. OIT will ensure 

practicality of policy by 

implementing and enforcing 

throughout OIT; disseminate agencywide, by departments; test agencywide implementation, and modify 

current processes ensuring supply 

chain analysis, internal and external 

communication channels, auditing, 

and risk assessments components. 

Recommend that EEOC implement strong authentication mechanisms for privileged and onprivileged users in accordance with Federal guidance, to meet the required use of PIV or an 

Identity Assurance Level (IAL) 3/Authenticator Assurance Level (AAL) 3 credential of the 

agency’s networks, including remote access sessions, in accordance with Federal targets. The 

agency should continue developing their plans for organization-wide use of strong 

authentication mechanisms for non-privileged users and require multifactor authentication to 

network access for all user accounts. 

Work in progress. EEOC systems 

require multiple layers of identify 

assurance and authorization. Login & 

password is required for PC access; 

now tokens are also required for VPN

or online access. PIOV cards are 

employed where external systems 

require, and MS operations require 

random verification by MFA. EEOC 

is standardizing on IAL3/AAL3 

tokens, now acquired, and being 

distributed. Achieved union buy-in. 

2023 Q4. Testing and validation 

pending by auditors to determine if 

steps taken implement 

recommendation. 

Recommend that EEOC review and remediate the medium the medium level severity 

vulnerabilities identified during external penetration testing by: 

Disabling IKE Aggressive Mode if supported. 

Refraining from the use of pre-shared authentication keys. 

If using a pre-shared key cannot be avoided, use strong keys. 

Do not allow VPN connections from a non-approval IP address, if possible. 

Completed. This is a repeat finding. 

OIT considers this finding complete. 

OIT remediated this finding by 

disabling the advertising of IKE 

Aggressive Mode. Testing and 

validation pending. 

Recommend that EEOC: 

Determine if listening ports or entire system should be blocked from public access. 

Regularly review network device search engines for new systems belonging to EEOC or those 

that may be masquerading as EEOC systems. 

Perform a forensic analysis on identified system to ensure no malicious access has taken 

place. 

For authorized remote sessions, create a control to address remote access being left open after

the session has concluded. 

Create an auditability feature that checks internally via an agent when a device with remote 

access is listening. 

Create an auditability feature that checks for remote connection software being installed. 

Completed. OIT considers the finding 

complete. OIT disabled the RDP 

services on the identified client 

endpoint withing the day of notice. 

Testing and validation pending. 

Recommend that EEOC review and remediate the level 4 severity vulnerabilities identified 

during internal vulnerability scanning to avoid compromises to agency systems. 

To remediate vulnerabilities and prevent further exploitation, the agency should implement 

risk mitigation procedures such as: performing system updates, operating systems with 

administrative rights, downloading patches, uninstalling unprotected applications, etc. 

Where risk acceptance is required for vulnerabilities based on EEOC’s network operations 

and risk assessments, we recommend that EEOC formally document the risk acceptance along 

with any associated mitigation activities. 

Work in progress. OIT will mitigate 

these findings using technology 

enhancements (i.e., patching, 

scanning) and bolstered validation 

procedures. Continuous Diagnostics 

and Mitigation (CDM) solutions 

continue being deployed to aid in this 

effort. OIT will reevaluate 

implementation of a Governance, 

Risk and Compliance (GRC) solution 

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Recommendation Implementation Status 

to enhance risk management and 

improve risk visibility, monitoring, as 

well as documenting risk decisions to 

include risk acceptance. 2023 Q4 

Recommend that EEOC review and remediate the level 5 severity vulnerabilities identified 

during internal vulnerability scanning to avoid compromises to agency systems. 

To remediate vulnerabilities and prevent further exploitation, the agency should implement 

risk mitigation procedures such as: applying vendor-released security fixes, disabling certain 

user access rights, upgrading to the latest supported version, and removing 

vulnerable/obsolete hardware from its network. 

These vulnerabilities should be added and tracked on POAMS. 

Where risk acceptance is required for vulnerabilities based on EEOC’s network operations 

and risk assessments, we recommend that EEOC formally document the risk acceptance along 

with any associated mitigation activities. 

Work in progress. OIT will mitigate 

these findings using technology 

enhancements (i.e., patching, 

scanning) and bolstered validation 

procedures. Continuous Diagnostics 

and Mitigation (CDM) solutions 

continue being deployed to aid in this 

effort. OIT will reevaluate 

implementation of a Governance, 

Risk and Compliance (GRC) solution 

to enhance risk management and 

improve risk visibility, monitoring, as 

well as documenting risk decisions to 

include risk acceptance. 2023 Q4 

Audit Report Name: Evaluation of EEOC’s Management of Private Sector Customer Service 

Month and Year Report was Issued: OIG Report No. 2021-001-EOIG 

Date of Report: October 18, 2022 

Recommendation Implementation Status 

EEOC should develop a customer service plan to include establishing goals and objectives, 

developing performance metrics that target the goals, and measuring performance against the 

goals. This plan must include goals and metrics for the IIG. 

Work in progress. EEOC’s Deputy 

Chief Operating Officer (DCOO) 

will be the senior official 

responsible for developing a 

customer service plan that includes 

goals, objectives, and performance 

metrics including the IIG. The 

DCOO will form a workgroup that 

includes representatives from 

customer facing offices to examine 

the requirements of a plan and 

produce a draft. When complete the 

draft will be circulated for comment 

to all office directors before it is 

finalized by the Chair. FY 2024 Q1 

EEOC must manage customer expectations by making customer service standards available to 

the public. 

Work in progress; partially 

completed. Upon approval by OCH, 

the customer service plan will be 

published to the Budget and 

Performance page of the EEOC 

website. The IIG added 

approximate wait times to 

Interactive Voice Responses when 

callers choose to speak with a 

Contact Representative, and the IIG 

is considering for FY 2024 adding 

an estimated response time to the 

IIG’s automatic replies to emails. FY 

2024 

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Recommendation Implementation Status 

The IIG must collect customer feedback and use the data to improve customer service efforts. Completed. The IIG and its private 

vendor completed all testing for the 

IIG’s new automated system for 

collecting “post-call” customer 

service surveys. Specifically, callers 

to the EEOC’s 1-800 number are 

now asked to complete a customer 

service survey at the conclusion of 

their call. These surveys are 

expected to provide customer 

service feedback that will enable the 

IIG to engage in targeted, ongoing 

improvements to customer service. 

The customer service survey was 

launched on August 22, 2023, after 

an approximate six months of 

development and testing. Support 

documentation has been requested 

for closure. 

The IIG should explore and implement ways to reduce the call hold time and email response 

time for customers. 

Completed. The IIG completed its 

refresher training to IIG Contact 

Representatives to ensure they are 

proficient with the knowledge base 

they need to respond to callers to the 

1-800 number in the most accurate 

and time-efficient manner possible. 

The IIG is currently engaged in 

ongoing refresher training for all 

Contact Representatives with 

respect to IIG protocols for 

responding to IIG email inquiries 

with the most accurate information 

and in the most time-efficient 

manner. Support documentation has 

been requested for closure. 

The IIG should design and implement a quality assurance program for customer emails. Completed. The IIG completed 

designing, drafting, and 

implementing a new quality 

assurance program for IIG responses 

to customer email inquiries. This 

new quality assurance program for 

responses to email inquiries has 

been added to the IIG’s overall 

written Quality Assurance 

Handbook. Support documentation 

has been requested to support 

closure. 

Fiscal Year 2025 Congressional Budget Justification Page 119 
 

 

 

 

 

 

 

 

Recommendation Implementation Status 

OFP should assess the usefulness of generating 846 inquiries (i.e., return on investment) and 

assess whether automatic close out in the system is more practical. 

Completed. OFP assessed the 

usefulness of generating 846 

Inquiries. OFP, with the agreement 

of the Office of the Chair, 

determined that the IIG should still 

generate 846 Inquiries. Generating 

those inquiries enables the EEOC to 

continue its process of engaging in a 

follow-up with all callers to the IIG 

whom the IIG has determined may 

have a claim that falls within the 

EEOC’s jurisdiction. That followup process, however, is now being 

done within the IIG (not by EEOC 

Field Offices) in order to increase 

the return on investment of 

following up on these 846 inquiries 

and eliminate duplication in field 

offices. 3/3/2023. Support 

documentation has been requested 

for closure. 

OFP should establish guidelines for generating 846 inquiries and other information sharing 

between the IIG and district offices. 

Completed. OFP established 

guidelines for generating 846 

Inquiries by Marcy 3, 2023. OFP 

established guidelines for 

information sharing between the IIG 

and EEOC Field Offices during the 

first half of FY 23. The most recent 

update to the national intake 

contacts list containing all IIG 

designated email addresses and 

Hotline phone numbers was 

distributed on July 18, 2023. 

Support documentation has been 

requested to support closure. 

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Audit Report Name: Final Report Transmittal of the OIG Digital Process Transformation and Automation (DPTA) Evaluation 

Month and Year Report was Issued: OIG Report No. 2021-002-EOIG 

Date of Report: January 20, 2023 

Recommendation Implementation Status 

Engage an independent organizational change management firm/entity to assist EEOC in 

implementing recommendations 2 through 9. 

Work in progress. In lieu of 

acquiring third-party services to assist 

with this effort, the EEOC will 

leverage its Data Governance Board 

(DGB), comprised of senior leaders 

across various programs offices, to 

review the evaluation and oversee 

corrective actions from an 

organizational change management 

perspective. This will start in mid2024 due to other agency priorities. 

EEOC will provide training and 

informational sessions to members of 

the DGD, and their delegated staff, 

when necessary, to ensure that they 

are well-grounded in the principles of 

DPTA. 03/31/2024 

Create a Digital Support Unit (DSU) of dedicated staff. Work in progress. The EEOC will 

create a DSU, an intra-agency 

working group, comprised of senior 

professionals and managers from 

OIT, OEDA, OFO, OFP, and OGC, 

championed by a senior leader, to 

assign and oversee DPTA crossprogram activity. This strategy has 

been successful in the past with the 

development and implementation of 

technology. 03/31/2024 

Define a clear, consistent, and comprehensive vision of digital transformation at EEOC. Work in progress. The EEOC Data 

Governance Board governance 

documents will outline a vision for 

digital transformation at the EEOC. 

03/31/2024. 

Consider formulating a Digital Transformation Strategy, either as a strategic goal in the EEOC 

Strategic Plan for Fiscal Years 2023-2027 or as a standalone document. 

Work in progress. The EEOC DGB 

will outline and monitor related plans 

and initiatives for the EEOC. 

06/30/2024. 

Plan at least three digital pilot projects with appropriate evaluation methods. Work in progress. The DPTA Intraagency Working Group will outline 

and monitor related plans and 

initiatives for the EEOC. 06/30/2024. 

Task OEDA with a goal of building a Data Analytics Plan for EEOC. Work in progress. By the end of 

FY24, OEDA intends to use the data 

points garnered from the Charge Data 

Lifecycle Project, currently in the 

early developmental phase, to build 

more advanced statistical forecasting 

models by taking advantage of 

predictive analytics and advancing to 

prescriptive analytics. 

• Once the information gathering 

is near completion, OEDA will 

work with OCH and OCHCO to 

hire staff to support the effort. 

By the end of FY24, OEDA will form 

a workgroup with the end goal of 

Fiscal Year 2025 Congressional Budget Justification Page 121 
 

 

 

 

 

 

 

 

Recommendation Implementation Status 

drafting a Data Analytics Plan. 

Activities involved will include: 

• Drafting a Charter for a small 

intra-agency workgroup. 

• Determining what tools, 

technologies, and storage 

requirements will be needed. 

• Determining the cost(s) for 

acquiring the tools, tech, and 

storage and the means (inhouse, procurement). 

Incorporating the needs and goals of 

the EEOC DGB. 06/30/2024. 

Develop an EEOC Organizational Communication Strategy and Plan. Work in progress. In conjunction 

with the EEOC DGB, OCLA will 

develop an organizational 

communication strategy and plan to 

guide our internal and external 

messaging and communications with 

stakeholders. OCLA staff will also be 

provided training on DPTA. 

06/30/2024. 

Develop a Target-State Architecture Plan. Work in progress. The Office of 

Information Technology (OIT) will 

develop a current and target-state 

architecture plan for the overall IT 

infrastructure. Some of this work is 

ongoing, but the process will be 

formalized and monitored through the 

EEOC DGB. 06/30/2024. 

Inventory and plan the decommissioning of outdated technologies and online content. Work in progress. The OIT and 

OCLA will present and review plans 

for decommissioning outdated 

technologies and online content with 

the EEOC DGB. Some of this work is 

ongoing, but the process will be 

formalized and monitored through the 

EEOC DGB. 

• OCLA, OIT and OEDA have 

coordinated to format and send new 

datasets to data.gov to bring EEOC 

content up to date. New submissions 

have been sent and are subject to 

data.gov publishing timelines. 

• Cleanup of EEOC YouTube 

content has been completed. Content 

was organized into playlists. 

• Updating content on the Open 

Government page is in progress 

(OCLA, OIT, and OEDA). 

06/30/2024. 

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Audit Report Name: Evaluation Report: EEOC Payment Integrity Information Act of 2019 (PIIA) FY 2022 

Month and Year Report was Issued: OIG Report No. 2023-001-EOIG 

Date of Report: May 22, 2023 

Recommendation Implementation Status 

Recommends EEOC develops agency-wide Improper Payment risk assessment standard 

operating procedures (SOP). This SOP should include risk assessment procedures to be 

performed by each identified significant programs. These procedures should be based on OMB 

A-123 guidance found in Appendix C. For each identified significant program (OCHCO), a 

responsible program point of contact should be established. The responsible party should report 

results of their programs risk assessment to the EEOC responsible office (or office). 

Completed. The Office of the Chief 

Human Capital Officer developed the 

SOP “Improper Payment Risk 

Assessments and Internal Auditing” 

to ensure compliance with OMB A136 PIIA and reporting requirements. 

Support documents provided for 

closure. Testing and validation 

pending. 

Develops a SOP to ensure annual compliance with OMB A-136 PIIA review and reporting 

requirements. 

Work in progress. OEDA will ensure 

that SOP is drafted to key 

stakeholders, including OCHCO, 

OCFO. And DCOO. OEDA will 

implement agency-wide PIIA SOP 

following input, revisions, and 

approval. FY 2024 

Audit Report Name: Audit of the EEOC’s FY 2023, and 2022 Financial Statements 

Month and Year Report was Issued: OIG Report No. 2023-001-AOIG * New Report * 

Date of Report: November 15, 2023 

Recommendation Implementation Status 

Recommends that EEOC adjust the balances for all activity as of September 30, 2023, and 

vigilantly monitor transactions related to software under development, especially those 

associated with the TMF. As such, OIT should notify OCFO at least quarterly of all activity 

related to software under development for proper recording of costs associated with internally 

developed software. 

OCFO will coordinate with OIT to 

develop and implement TMF 

procedures that ensure the accuracy 

and timely recording of such 

transactions per Treasury Manual 

requirements for quarterly and yearend financial reporting. FY 2024 

Recommend EEOC review all State and Local Program undelivered orders at year end and 

accrue an estimated value of these payments that will be made after year-end. As the State and 

Local Program is a reimbursement for the current year activity, the expectation is that a 

significant amount of these transactions will be submitted for reimbursement. EEOC should 

perform a historical review of State and Local Program reimbursements against contracts to 

determine an estimate to apply to all unpaid State and Local Program undelivered orders at 

each year end. Utilizing this historical ratio against current year outstanding undelivered 

orders as an accrual amount should help ensure that EEOC capture its costs for the fiscal year. 

OCFO will review OIT IUS software 

development costs on a quarterly 

basis in SGL 1832, SGL 6610, 

SGL2290, and SGL 6100. 

12/31/2023-9/30/2024 

Fiscal Year 2025 Congressional Budget Justification Page 123 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Audit Report Name: Federal Information Security Modernization Act of 2014 (FISMA) FY 2023 Performance Audit 

Month and Year Report was Issued: OIG Report No. 2023-002-AOIG * New Report * 

Date of Report: November 20, 2023 

Recommendation Implementation Status 

We recommend that EEOC communicates and implements an organization-wide SCRM and 

CSCRM strategy to guide supply chain analyses, provide communication channels with 

internal/external partners and stakeholders, and assist in building consensus regarding the 

appropriate resources for SCRM and C-SCRM. We recommend that EEOC offices of the Chief 

Financial Officer and the Chief Information Officer identify SCRM/C-SCRM as a risk to be 

included in their respective ERM risk registers until the issue is resolved so that commission 

management understand that SCRM/C-SCRM is a commission-wide requirement. 

Work in progress. OIT is in the 

process of developing a corrective 

action plan to address the thirteen 

recommendations. 

We recommend that EEOC continue its full implementation in accordance with their plan. For 

the ZTA Identity pillar, to better meet ZT requirements for all agency-provided devices, the 

EEOC made a strategic decision to move away from the prior PIV-based device-login solution 

to a new password-less Multi-Factor Authentication (MFA) strategy - providing a strong, nonimpersonable authentication process for all agency resource access. 

Work in progress. 

We recommend that EEOC plans and prepares to meet the goals of the TIC initiative, consistent 

with OMB M-19-26. The agency should define and customize, as appropriate, a set of policies, 

procedures, and processes to implement TIC 3.0, including updating its network and system 

boundary policies, in accordance with OMB M-19-26. This includes, as appropriate, 

incorporation of TIC security capabilities catalog, TIC use cases, and TIC overlays. 

Work in progress. 

EEOC should develop an executable plan to meet the requirements of OMB M-21-31 and 

ensure the plan is properly supported. 

Work in progress. 

EEOC’s information security team should, in conjunction with other EEOC offices: a. Identify 

and document all applicable policies and procedures to cybersecurity and information security; 

b. Develop and use an accessible repository, such as SharePoint, for all identified documents, 

regardless of what office they reside in; c. Design a risk-based approach to review and update all 

identified documents in the repository, including who is responsible for reviewing and updating 

each document. d. Document the review/update in each document as well as the responsible 

party within the information security team who ensures that each document has been updated 

per the documented procedure for review. e. Designate a responsible official within the OIT to 

review and update the process as necessary on annual basis. 

Work in progress. 

We recommend that EEOC: Review all devices and systems and ensure default credentials are 

not in use. Implement the use of complex credentials for all systems.

•

• • Review system for 

potential malicious access. • If it is not possible to change passwords to something complex, 

consider isolating the device on a separate network segment and implementing ACLs that limit 

what devices and who may attach to the system. • Determine if the application should be 

publicly available. If not, implement NSG rules within Microsoft Azure or ACLs within 

firewalls to limit or block all external applications to the site. • Ensure it has a policy in place 

that addresses NIST 800-53, Rev 5, IA-5(5). • Ensure procedures are written in such a way to 

accomplish what is written in the policy. • Ensure it has people in assigned a role to follow and 

evaluate default credentials. • Consider how new or existing technologies it has can assist in 

these efforts. 

Work in progress. 

We recommend that EEOC: • Update to a recent BIRT viewer component, well past version 

4.12. • Determine if the application should be publicly available. If not, implement NSG rules 

within Microsoft Azure or ACLs within firewalls to limit or block all external application to the

site. • Remove default and un-needed .rptdesign files that allow for passing a parameter with 

attacker-controlled input. • Ensure BIRT viewer component is proxied through an authenticated 

connection and not via direct calls to the NXG servers. Implement the use of complex 

credentials for all systems. • Ensure it has a policy in place to address NIST 800-53, Rev 5, SI2. • Ensure procedures are written in such a way to accomplish what is written in the policy. •

Ensure it has people in assigned a role to remediate flaws in accordance with its policy and risk 

tolerance. • Consider how new or existing technologies it has can assist in these efforts. 

Work in progress. 

We recommend that EEOC: • Review all devices and systems and ensure default credentials are 

not in use. • Implement the use of complex credentials for all systems. • It is not possible to 

change this password to something complex. Consider isolating the device on a separate 

network segment and implementing ACLs that limit what devices and who may attach to the 

system. • Determine if the management page should be publicly available. If not, implement 

Work in progress. 

Page 124 Fiscal Year 2025 Congressional Budget Justification 
 

 

 

 

 

 

 

Recommendation Implementation Status 

ACLs within firewalls to limit or block all external application to the site. 

• Ensure it has a policy in place to address NIST 800-53, Rev 5, SI-2. • Ensure procedures are 

written in such a way to accomplish what is written in the policy. • Ensure it has people in 

assigned a role to remediate flaws in accordance with its policy and risk tolerance. • Consider 

how new or existing technologies it has can assist in these efforts. 

We recommend that EEOC: • Patch to the most recent version of firmware and confirm that this 

information is not disclosed from the administrative page source code. • Determine if the 

management page should be publicly available. If not, implement ACLs within firewalls to limit 

or block all external application to the site. • Ensure it has a policy in place to address NIST 

800-53, Rev 5, SI-2. • Ensure procedures are written in such a way to accomplish what is 

written in the policy. • Ensure it has people in assigned a role to remediate flaws in accordance 

with its policy and risk tolerance. • Consider how new or existing technologies it has can assist 

in these efforts. 

Work in progress. 

We recommend that EEOC: • Review source code and source code repositories for code 

containing internal IP addresses and URLs. • Remove inappropriately stored information from 

source code. 

Work in progress. 

We recommend that EEOC: • Limit access from specific IP addresses to the Amazon AWS EKS 

API. • Configure AWS Control Tower’s data residency controls to alert on publicly accessible 

Amazon EKS endpoints. • If AWS Control Tower is not in use, create an AWS Config rule to 

detect whether an Amazon EKS endpoint is blocked from public access. 

Work in progress. 

We recommend that EEOC ensures that every sensitive form transmits content over HTTPS. •

Ensure it has a policy in place that addresses and enforces protects the confidentiality and/or the

integrity of transmitted information. • Ensure procedures are written in such a way to 

accomplish what is written in the policy, to include compensating controls. • Ensure it has 

people in assigned a role to enforce the policy and procedures in place to protect the 

confidentiality and/or the integrity of transmitted information. • Consider how new or existing 

technologies it has can assist in these efforts. 

Work in progress. 

Ensure it has a policy in place to address NIST 800-53, Rev 5, SI-2, Flaw Remediation. •

Ensure procedures are written in such a way to accomplish what is written in the policy. 

Work in progress. 

Audit Report Name: Final Report Transmittal for Customer Service Portals Evaluation 

Month and Year Report was Issued: OIG Report No. 2022-001-EOIG * New Report * 

Date of Report: September 12, 2023 

Recommendation Implementation Status 

Institute a governance framework for managing the Agency’s portals. Work in progress. 

Include requirements to use the U.S. Web Design System in the Agency’s Project Plan for 

designing, developing, and implementing the next generation of portals. 

Work in progress. 

Implement mechanisms to ensure that the design and management of the portals are responsive 

to customer needs. 

Work in progress. 

Simplify portal content and customer instructional materials and embed instructional materials 

within the relevant pages of each portal. 

Work in progress, 

Ensure that the design and function of all portals accurately reflect EEOC’s business rules and 

applicable laws. 

Work in progress. 

Make targeted improvements to address accessibility issues on the existing portals. Work in progress. 

Take specific actions to improve users’ ability to collaborate and communicate through the 

portals. 

Work in progress. 

Fiscal Year 2025 Congressional Budget Justification Page 125 
 

 

 

 

 

 

 

 

 

 

 

 

Audit Report Name: GAO: Gender Pay Differences: The Pay Gap for Federal Workers Has Continued to Narrow, but BetterQuality Data on Promotions Are Needed 

Month and Year Report was Issued: GAO-21-67 

Date of Report: December 3, 2020 

Recommendation Implementation Status 

As part of the Equal Employment Opportunity Commission's plans to implement a new data 

system, the Chair of the Equal Employment Opportunity Commission should assess the 

feasibility of developing the agency's capacity to systematically analyze retaliation charge data, 

including the protected activities associated with these charges. 

As part of the development of ARC, 

the EEOC assessed the feasibility of 

developing the capacity to 

systematically analyze retaliation 

data. 

Audit Report Name: GAO: Workplace Sexual Harassment: Experts Suggest Expanding Data Collection to Improve 

Understanding of Prevalence and Costs 

Month and Year Report was Issued: GAO-20-564 

Date of Report: October 16, 2020 

Recommendation Implementation Status 

As part of the Equal Employment Opportunity Commission's plans to implement a new data 

system, the Chair of the Equal Employment Opportunity Commission should assess the 

feasibility of developing the agency's capacity to systematically analyze retaliation charge data, 

including the protected activities associated with these charges. 

Closed – Implemented. In January 

2022, the EEOC deployed a new 

charge management system that will 

allow EEOC staff to systematically 

analyze retaliation charge data, 

including the protected activities 

associated with these charges. For 

example, the new system requires 

staff to enter the underlying basis 

and issue for most retaliation 

allegations and permits them to link 

charges, which allows for further 

tracking, analysis, and reporting on 

retaliation charges. 

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Audit Report Name: GAO: Freedom of Information Act: Agencies Are Implementing Requirements but Additional Actions Are 

Needed 

Month and Year Report was Issued: GAO-18-365 

Date of Report: June 25, 2018 

Recommendation Implementation Status 

The Chair of EEOC should take steps to develop and document a plan that fully addresses best 

practices with regards to reduction of backlogged FOIA requests. 

Chief FOIA Officer developed a 

FOIA backlog reduction plan in FY 

2018. Applying this plan, EEOC 

staff reduced the agency backlog of 

overdue FOIA requests in FYs 2019 

- 2021; the FOIA backlog of 

overdue receipts at the end of FY 

2022 is estimated at under 100 

agency-wide, out of receipts 

numbering over 13,700 per year 

The Chair of EEOC should work with FCC to develop a new memorandum of understanding 

that includes a plan for EEOC to routinely share data with FCC regarding discrimination charges 

filed against broadcasters and cable and satellite television operators. 

Work in Progress. EEOC is working 

with FCC to review the types of 

data collected by each agency, the 

potential for data sharing, and the 

possible improvements in 

enforcement. 

Audit Report Name: GAO: Workforce Diversity: Hispanic Workers Are Underrepresented in the Media, and More Data Are 

Needed for Federal Enforcement Efforts 

Month and Year Report was Issued: GAO-22-104669 

Date of Report: October 5, 2022 

Recommendation Implementation Status 

The Chair of EEOC should work with FCC to develop a new memorandum of understanding 

that includes a plan for EEOC to routinely share data with FCC regarding discrimination charges 

filed against broadcasters and cable and satellite television operators. 

Work in Progress. The EEOC has 

begun the process of reformulating 

its prior agreement with FCC and 

will work in collaboration with FCC 

to review the MOU and explore 

possible improvements in EEO 

enforcement. 

The Chair of EEOC should improve EEOC's approach to routinely identify local unions required 

to file an EEO-3 report to help ensure that they file such reports on the demographics of union 

members. 

Work in Progress. The EEOC is 

actively taking additional steps to 

explore approaches that would allow 

the agency to better determine 

whether all eligible local referral 

unions are complying with reporting 

requirements designed to collect 

demographic data on union 

membership and referrals. 

Fiscal Year 2025 Congressional Budget Justification Page 127 
Page 128 Fiscal Year 2025 Congressional Budget Justification

Audit Report Name: GAO: Equal Employment Opportunity Commission: Oversight of the Length of the Charge Intake Process 

is Needed

Month and Year Report was Issued: GAO-23-106245

Date of Report: October 31, 2022

Recommendation Implementation Status

The Chair of the EEOC should monitor field office-level data on the length of the intake 

process. For example, EEOC could monitor these data by including them in the monthly 

internal management reports it produces. 

Closed - Implemented. The EEOC 

developed enhancements to the 

agency’s charge management system 

to track the time between a potential 

charging party’s initial inquiry and 

the date of the intake interview and 

implemented a daily management 

report that tracks the average length 

of the intake process for each field 

office – covering the number of days 

between the initial inquiry date and 

the intake interview date.

Audit Report Name: GAO: Information Management: Agencies Need to Streamline Electronic Services

Month and Year Report was Issued: GAO-23-105562

Date of Report: December 20, 2022

Recommendation Implementation Status

The Chair of the Equal Employment Opportunity Commission should establish a reasonable 

time frame for accepting remote identity proofing with authentication, digitally accepting access 

and consent forms from individuals who were properly identity proofed and authenticated and 

posting access and consent forms on the agency's privacy program website.

Work in Progress. The EEOC has 

finalized plans to use the agency’s 

FOIA portal vendor to route Privacy 

Act requesters through Login.gov to 

accept online access and consent 

forms from individuals who have 

been identity proofed and 

authenticated. In addition, this 

initiative is in the acquisition phase 

with planned delivery during the 

second quarter of FY 2024.
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