DEFENSE LOGISTICS AGENCY

THE NATION’S COMBAT LOGISTICS SUPPORT AGENCY

Office of Equal Employment Opportunity and Diversity

FY2022 Program Status Report

EEOC Management Directive 715 (MD-715)

Warfighter Always
1

Table of Contents

Part A – Agency Identifying Information............................................................................................... 3

Part B - Total Employment...................................................................................................................... 3

Part C.1 - Head of Agency and Head of Agency Designee .................................................................... 3

Part C.2 - Agency Official(s) Responsible for Oversight of EEO Program(s).................................... 3

Part D.1 – List of Subordinate Components Covered in this Report .................................................. 4

Part D.2 – Mandatory and Optional Documents for this Report......................................................... 4

Part E – Executive Summary................................................................................................................... 6

Part E.1 - Executive Summary: Mission............................................................................................... 6

Part E.2 - Executive Summary: Essential Element A – F..................................................................... 6

Part E.3 - Executive Summary: Workforce Analysis......................................................................... 12

Part E.4 - Executive Summary: Accomplishments............................................................................. 15

Part E.5 - Executive Summary: Planned Activities............................................................................ 16

Part F – Certification of Establishment of Continuing EEO Programs............................................ 18

Part G - Agency Self-Assessment Checklist.......................................................................................... 19

Essential Element A: Demonstrated Commitment from Agency Leadership .................................... 19

Essential Element B: Integration of EEO into the Agency’s Strategic Mission................................. 21

Essential Element C: Management and Program Accountability....................................................... 25

Essential Element D: Proactive Prevention ........................................................................................ 29

Essential Element E: Efficiency.......................................................................................................... 30

Essential Element F: Responsiveness and Legal Compliance............................................................ 34

Part H.1 - Agency EEO Plan to Attain the Essential Elements of a Model EEO Program............. 36

Part H.2 - Agency EEO Plan to Attain the Essential Elements of a Model EEO Program............. 39

Part H.3 - Agency EEO Plan to Attain the Essential Elements of a Model EEO Program............. 41

Part H.4 - Agency EEO Plan to Attain the Essential Elements of a Model EEO Program............. 43

Part J - Special Program Plan for the Recruitment, Hiring, Advancement, and Retention of 

Persons with Disabilities......................................................................................................................... 46

Section I: Efforts to Reach Regulatory Goals..................................................................................... 46

Section II: Model Disability Program................................................................................................. 47

Section III: Plan to Recruit and Hire Individuals with Disabilities.................................................... 48

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities................ 54

Section V: Plan to Improve Retention of Persons with Disabilities................................................... 64

Section VI: EEO Complaint and Findings Data ................................................................................. 70

Section VII: Identification and Removal of Barriers.......................................................................... 71
2

Appendix 1 – Glossary............................................................................................................................ 78

Appendix 2 – Organizational Chart...................................................................................................... 79

Appendix 3 – Policy Statements............................................................................................................. 80

Policy Statement on Equal Employment Opportunity........................................................................ 80
3 

Part A – Agency Identifying Information

Agency Second Level 

Component Address City State Zip 

Code

Agency 

Code 

(4 digits)

FIPS 

Code

(9 digits)

Department of 

Defense (DoD)

Defense Logistics 

Agency (DLA)

8725 John J. Kingman 

Road, Suite 1127

Fort 

Belvoir VA 22060 DD07 511001059

Part B - Total Employment

Total Employment Permanent Workforce Temporary Workforce Total Workforce

Number of Employees: 23,784 240 24,024

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

Agency Leadership Name Title

Head of Agency Michelle C. Skubic Vice Admiral, USN, Director

Head of Agency Designee Bradley B. Bunn Senior Executive Service, Vice Director

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

EEO Program Staff Name Title 

Occupationa

l Series 

(4 digits)

Pay Plan 

and 

Grade

Phone Number

(xxx-xxx-xxxx) Email Address

Principal EEO 

Director/Official Janice Samuel EEO Director 0260 GS-15 (571) 767-1140 Janice.Samuel@dla.mil

EEO Deputy Director Dr. Angela 

Curtis EEO Deputy Director 0260 GS-14 (571) 767-9905 Angela.Curtis@dla.mil

Diversity & Inclusion 

Officer

Oscar MarionaAcosta

Diversity and 

Inclusion (DO-D), 

Staff Director

0260 GS-14 (571) 767-0740 Oscar MarionaAcosta@dla.mil

Principal MD-715 

Preparer Eric Spanbauer Acting EEO Program Analyst 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil

Affirmative 

Employment Program 

(AEP) Manager

Eric Spanbauer EEO Specialist 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil

Disability Program 

Manager (DPM) Monique Ray Disability Program Manager 0260 GS-13 (571) 767-1103 Monique.Ray@dla.mil

Reasonable 

Accommodation (RA) 

Program Manager

Monique Ray Disability Program 

Manager 0260 GS-13 (571) 767-1103 Monique.Ray@dla.mil

American Indian 

Employment Program 

Manager

Eric Spanbauer EEO Specialist 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil

Asian Employment 

Program Manager Eric Spanbauer EEO Specialist 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil

Black Emphasis 

Program Manager Eric Spanbauer EEO Specialist 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil

Federal Women's 

Program Manager Eric Spanbauer EEO Specialist 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil

Hispanic Emphasis 

Program Manager Eric Spanbauer EEO Specialist 0260 GS-13 (703) 659-9945 Eric.Spanbauer@dla.mil
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EEO Program Staff Name Title 

Occupationa

l Series 

(4 digits)

Pay Plan 

and 

Grade

Phone Number

(xxx-xxx-xxxx) Email Address

Compliance Officer Kimberly Lewis

Complaints and 

Compliance Division 

(DO-C), Staff Director

0260 GS-14 (571) 767-9905 Kimberly.Lewis@dla.mil

Complaints Program 

Manager Gabriela Reitan EEO Specialist 0260 GS-13 (571) 767-6135 Gabriela.Reitan@dla.mil

Alternative Dispute 

Resolution (ADR) 

Program Manager

Eura Cherry Associate General 

Counsel 0905 GS-15 (571) 767-8905 Eura.Cherry@dla.mil

Anti-Harassment 

Program Manager Marlene Doty Labor RelationsSpecialist 0201 GS-14 (571) 767-0732 Marlene.Doty@dla.mil

Special Placement 

Program Coordinator 

(SPPC), Defense 

Human Resources 

Services - Columbus 

and New Cumberland 

Casandra Green Human Resources 

Specialist 0201 GS-13 (614) 692-9568 Casandra.Green@dla.mil

Steven Carney Human Resources 

Specialist 0201 GS-13 (717) 770-5882 Steven.Carney@dla.mil

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

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

Subordinate Components 

(Third Level) City State Country 

(Optional)

Agency Code 

(4 digits)

FIPS

Codes

(9 digits)

DLA Disposition Services Battle Creek MI USA DD07 260310025

DLA Distribution New Cumberland PA USA DD07 421943133

DLA Troop Support Philadelphia PA USA DD07 426540101

DLA Land and Maritime Columbus OH USA DD07 398940049

DLA Aviation Richmond VA USA DD07 512060760

DLA Energy Fort Belvoir VA USA DD07 511001059

DLA Headquarters (HQs) Fort Belvoir VA USA DD07 511001069

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

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

Did the agency submit the following mandatory documents? Please respond

Yes or No Comments

Organizational Chart Yes

EEO Policy Statement Yes New Director signed new

statements in January 2022

Strategic Plan Yes Includes the “DLA People and 

Culture Plan 2021-2026”

Anti-Harassment Policy and Procedures Yes DLAI 1438.06 (updated 6/30/22)

Reasonable Accommodation Procedures Yes DLAI 1440.01 (updated 11/28/22)

Personal Assistance Services Procedures Yes Draft Appendix to DLA Standard 

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

Did the agency submit the following optional documents? Please respond 

Yes or No Comments

Federal Equal Opportunity Recruitment Program (FEORP) Report No

A Call Memo from OPM was 

never released for FY22. FEORP 

criteria still being revised based 

on E.O 14035. FY21 FEORP 

report was submitted April 2022.

Disabled Veterans Affirmative Action Program (DVAAP) Report Yes

Operational Plan for Increasing Employment of Individuals with 

Disabilities under Executive Order 13548 Yes DLA’s Affirmative Action Plan

Diversity, Equity, Inclusion and Accessibility Plan under Executive 

Order 14035 Yes

A new charter was drafted in 

FY22 on the glide path to 

establish a committee in FY23.

Diversity Policy Statement Yes See Appendix 3.

Human Capital Strategic Plan Yes “DLA People and Culture Plan 

2021-2026.”

EEO Strategic Plan Yes

Results from most recent Federal Employee Viewpoint Survey 

(FEVS) or Annual Employee Survey. Yes FEVS was conducted in 2021. 

Did the agency submit the following mandatory documents? Please respond

Yes or No Comments

(SOP) 1440.01-01; and DLA EEO 

webpage.

Alternative Dispute Resolution (ADR) Procedures Yes DLAI 5308.01
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Part E – Executive Summary

Part E.1 - Executive Summary: Mission

As the nation’s combat logistics support agency, the Defense Logistics Agency manages the end-to-end 

global defense supply chain – from raw materials to end user disposition – for the five military services, 

11 combatant commands, other federal, state, and local agencies and partner and allied nations. 

DLA’s mission is to “deliver readiness and lethality to the Warfighter Always and support our nation 

through quality, proactive global logistics.” To accomplish this mission, DLA has a staff of about 

25,000 employees divided into multiple supply chains that contract for material and services across the 

military classes of supply, to include: subsistence (food/water), clothing and textiles, bulk petroleum and 

other energy products, construction material and equipment, personal demand items, medical material 

and equipment, and repair parts for land, sea, and air systems.

DLA Quick Facts

As a logistics integrator and acquisition/service provider, the agency supports: 

• A worldwide warehouse and distribution services network; 

• Logistics and staff planning support to DoD’s combatant commands; 

• Operations that reutilize or dispose of excess materiel and environmental waste from the military 

services.

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

Summary of our Annual Self-Assessment

Each year the DLA Enterprise (Headquarters) Office of Equal Opportunity and Diversity (DO) assesses the 

agency’s EEO program with a series of questions designed to identify any deficiencies. Our Major 

Subordinate Command (MSC) EEO offices also assess their local EEO Programs and submit results to DO. 

In overall, DO completed a self-assessment on an enterprise level and reviewed subordinate units (MSCs). 

Currently there are no Non-Appropriated Funded (NAF) employees remaining in DLA after they were 

transferred to the Department of Army in December 2020.

Essential Element A: Demonstrated Commitment from Agency Leadership

Communication on the EEO Program 

The DLA Director receives regular briefings such as: EEO workforce demographics, EEO complaints, 

cases of sexual harassment, Reasonable Accommodations (RA) monthly/quarterly reports, COVID-19 

issues such as religious exemptions and pandemic safety policy plans and, signs enterprise-wide policy 

statements such as the Equal Employment Opportunity, the Prevention of Sexual Harassment and Sexual 

Assault Prevention and Response, Reasonable Accommodations and Diversity and Inclusion that are 

distributed to the DLA workforce. In FY22, DO continued to provide DLA’s workforce with the EEO 

office’s full contact information through posters on bulletin boards. SharedPoint Online (intranet) and 

www.DLA.mil. 

During FY22, DO conducted a makeover on the EEO public website at https://www.dla.mil/EEO/, 

including Section 508 accessibility in all DLA websites. The revised DLA EEO public website lists 
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many services and items offered by DLA EEO offices. Additional updates to the DLA EEO public 

website included adding pages for the Affirmative Action Plan and the Elijah J. Cumming Act 

information and its postings, FY22 No Fear Act report, updated EEO Policy Statement in January 2022, 

DLA Instruction (DLAI) 1438.06 for Workplace Harassment Prevention and Response Policy, DLAI 

1440.01 for Procedures for Requesting Reasonable Accommodations for Individuals with Disabilities, 

and DLAI 1440.02 for Equal Employment Opportunity Complaints Program; and added the list of DLA 

Reasonable Accommodation Program Managers (Disability Program Coordinators) on its internal 

website. 

The EEO Director meets regularly with Senior Leadership to provide EEO/RA statistical data and to 

discuss trends and recommend solutions. The EEO director conducts site visits to MSC EEO offices to 

ensure program effectiveness. 

Disability Program

DO remains on the glide path for deploying Entellitrak Reasonable Accommodations (ETK-RA). The 

ETK-RA is a new platform that we will utilize to process, track and store and report on reasonable 

accommodation requests Enterprise-wide. This new platform will automate processing of DLA RA 

requests. The system is projected to go live in April 2023, barring any unforeseen security 

issues/concerns. 

A full-time Disability Program Manager (DPM) was hired in FY21. The Reasonable Accommodations 

(RA) (DLAI 1440.01) was updated in FY22 to be in line with current Agency guidance on Full time 

telework and Remote work, which removed layers in the approval process. The DLA SOP 1440.01-01, 

RA Procedures for Individuals with Disabilities, was approved in FY22 by EEOC and it will be further 

updated in FY23 to reflect the changes in DLA’s process and to incorporate the new ETK-RA request 

system once it goes live; updates will also include updated PAS guidance. DLA EEO training is on 

track to release the newly updated RA and No FEAR Act training for employees and 

Supervisors/Managers through the Learning Management System (LMS) in FY23. This training will 

include opening remarks by the Vice Director of the Agency and the EEO Director to enforce DLA’s 

Policy on Diversity and Inclusion and the Disability Program. 

DO is also creating a dashboard for reasonable accommodations (RA). It will take the data from the 

new ETK-RA system and create a dashboard with D-Staff, J-Codes and MSCs specific statistical 

information. The DLA Leadership will be able to see the metrics for RA requests by location, 

accommodation type, cost, timeframes, fiscal year, decision and much more. This tool is designed to 

assist the leadership with tracking RAs within their organizations and reporting on the data. The 

dashboard is on track to roll out sometime between FY23 4th Quarter or FY24 1st Quarter.

EEO Training Program 

DLA EEO personnel regularly provide virtual and in-person EEO training to educate managers and 

employees on the importance and impact of their respective roles in the EEO process. All EEO offices 

contact information are readily available on our internal SharePoint and internal and external EEO 

website. In FY22, the Prevention of Sexual Harassment (POSH) training was conducted virtually and

provided specialized Harassment/Sensitivity training to the police officers in person. All EEO contact 

information is posted on the public and SharePoint sites. 

DLA EEO opened an EEO Academy for all EEO specialist to provide additional EEO training to help 

with employee skill gaps. 
8 

Essential Element B: Integration of EEO into the Agency’s Strategic Mission

Diversity, Equity, Inclusion and Accessibility (DEIA) Charter & Initiatives

In FY22, IAW E.O. 14035, DO is currently revising the DEIA charter to establish a new committee 

designed to review perceived or actual barriers associated with hiring, personnel actions, upward 

mobility, retention, and other factors associated with retaining a well-trained and capable workforce that 

can meet the demanding requirements of the agency. The committee will analyze anomalies found in 

civilian workplace policies, procedures, and practices, focusing on the root causes that have the potential 

to negatively impact a particular group or groups of employees based on their gender, ethnicity, race, 

sexual orientation, religion, age, or disability and devise a plan to eliminate those root causes. Once 

identified, the committee will identify triggers, conduct analyses, and recommend action plans to 

overcome the barrier(s) that ensures consistent workforce parity throughout the Enterprise. The revised 

charter is in alignment with the DLA’s Strategic Plan (2021-2026) and is expected to be approved by the 

DLA leadership with a new committee way forward in FY23 3rd Quarter. One GS-14 Staff Director will 

oversee the AEP and DEIA Program, one GS-13 and one GS-13 to establish a DEIA program and 

increasing Special Emphasis Program (SEP) initiatives in conjunction with the DEIA committee. 

DLA Strategic Plan

The plan highlights three critical capabilities that are fundamental to our successful transformation: (1) 

People and Culture: supporting our people, (2) Fiscal Stewardship: investing in outcomes, and (3) 

Digital-Business Transformation: embracing the future. The critical capabilities intersect and support 

the five Lines of Effort (LOE) with specific underlying objectives, initiatives, and metrics which is 

fundamental to the success of DLA’s Strategic Plan for People and Culture. This capability aligns with 

DLA’s proven human capital strategies with our mission, LOE’s, and objectives. 

Our ability to attract, develop, and retain a diverse, skilled, and agile workforce is vital to our continued 

mission success. To achieve a shared vision with the agency’s strategic plan, all DLA organizations, 

employees, and leaders must work together to fortify the culture, reward high performance, build 

connections, and prioritize safety of the workforce. 

External Entity Partnerships

DLA maintains ongoing partnerships with DoD agencies (e.g. Diversity Management Operations Center 

(DMOC) and the Office for Diversity, Equity, and Inclusion (ODEI) under the Under Secretary of 

Defense for Personnel & Readiness); our external Federal agencies (e.g. the Office of Employment 

Policy (ODEP) under the Department of Labor, the Diversity and Inclusion division under the U.S. 

Office of Personnel Management (OPM)); Affinity groups (e.g. Blacks in Government (BIG), Federal 

Asian Pacific-Islander American Council (FAPAC), League of United Latino American Council 

(LULAC); and Advocacy groups (e.g. National Industries of the Blind (NIB), Gallaudet University, 

AbilityOne), to name a few. DLA’s collaboration with all our partners is paramount as our agency

rapidly innovates at speed and scale to solve problems. DO will continue to adapt our strategies as 

needed to reflect the rapidly changing, competitive environment in which the EEO operates. 

Essential EEO Staffing

During FY22, three additional billets were authorized for the EEO Office. One GS-14 Staff Director to 

oversee the AEP and DEIA Program, and two GS-13 to establish a Diversity, Equity, Inclusion and 

Accessibility (DEIA) and increasing Special Emphasis Program (SEP) initiatives way forward. Both the 

GS-13 positions have been authorized to hire and currently working with HR to fill the billets. 
9 

Anti-Harassment Program

The HR’s Labor and Employee Relations office has continued to refine the agency’s anti-harassment 

program and is tracking the total times management conducts inquiries on harassment cases not 

associated to EEO basis. The following information is representative of the number of non-EEO cases 

with investigations worked by the agency during: FY20 = 5; FY21 = 21; and FY22 = 26. 

The Policy Statement on Workplace Harassment memorandum was signed by the DLA Director on 

March 4, 2021. The Anti-Harassment Program Manager under the DLA Human Resources successfully 

updated the DLAI 1438.06 “Workplace Harassment Prevention and Response Policy” in coordination 

with the EEOC compliance office which found it to be compliant with a letter of approval on May 10, 

2022. The DLAI 1438.06 was updated on June 30, 2022 and uploaded to DLA’s intranet webpage 

available to all employees. 

For all other complaints of harassment cases with an EEO basis, the EEO office facilitates performance 

of management inquiries during the pre-complaint process. 

Essential Element C: Management and Program Accountability

Agency Management Reviews (AMR)

DO conducted Agency Management Reviews (AMR) offsite visits at two selected MSC EEO Offices at 

Troop Support and Distribution in FY22. A list of the deficiencies and corrections are maintained in the 

Agencies repository. 

Data Management

DO coordinates with HR on a regular basis to ensure data consistency and to seek clarifications received 

through DCPDS. Improvements were noted to the Applicant Flow Vacancy (AFV) Level Detail by 

Customer (formerly the Applicant Flow Data (AFD) Detail Report) provided by the USA Staffing at 

OPM during the FY22 3rd quarter way forward. The DLA Human Resources (J1) also manages the 

Annual Report on Agency Applicant Flow (ARAAF) report for DLA annually to the EEOC.

The Special Emphasis Programs Manager (SEPM)/Affirmative Employment Program Manager (AEPM) 

has gained access to a new system called ADVANA which is the DoD’s enterprise-wide, multi-domain 

data, analytics, and artificial intelligence (AI) platform that provides market-leading tools to perform 

data exploration, analysis, model development, data visualization. The SEPM/AEPM continues to work 

with the ADVANA staff to identify data deficiencies and improve the delivery of data elements 

pertaining to supervisory and non-supervisory positions, including specific categories by Executive, 

Managerial and Supervisory positions for optimized reports, which will enable the identification of 

triggers and support barrier analysis efforts way forward. DO will then continue to investigate identified 

triggers once the Enterprise Diversity, Equity, Inclusion and Accessibility (DEIA) committee becomes 

established in FY23. 

Career Development Data (CDD)

DLA HR Reports and DLA Training consolidated the Tuition Assistance Program (TAP) and some 

other career development programs, such as the two MSC-level mentoring programs into the CDD 

report needed to track promotions, number of applicants, qualified candidates, and selections during 

FY22. The capturing of data has improved which will assist DO to optimize the ongoing evaluation and 
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the effectiveness of CDD and to determine whether triggers can be identified and if barrier analyses

should be conducted. 

Essential Element D: Proactive Prevention

For trigger identifications and barrier analysis efforts in FY22, DO continues to use external new data 

sources: 

• Workforce demographics, including ADVANA.

• MSC-level Special Emphasis Program (SEP) Plans.

• RA program data (EEO-RAM).

• Employee Climate Survey results (Denison).

• Exit Survey data tables.

Essential Element E: Efficiency

Per the FY22 462 report submitted to EEOC, a total of 224 pre-complaints were initiated in FY22. This 

was 24 more pre-complaints initiated than in FY21. In addition to the 224 pre-complaints initiated in 

FY22, 30 were carried over from the previous year, bringing the total of pre-complaints on the books of 

DLA during FY22 to 254. A total of 5 pre-complaints were settled. This is 15 less than in FY21. For 

FY22, there were 217 pre-complaints completed or closed. Of the 217, 5 (2.30%) were settled, and 88 

(40.55%) were withdrawn from processing or were not followed with a formal complaint.

A total of 118 of the informal cases transitioned into the formal complaint stage. At the beginning of 

FY22, there were 208 formal complaints on hand, with an additional 127 formal complaints filed and 

two remanded for processing for a total of 337 formal complaints. 

272

34

117

39

1

313

26

156

34

2

301

30

155

30

1

200

20

170

40

3

224

5

127

24

0

0

50

100

150

200

250

300

350

Pre-Complaints Initiated Pre-Complaints Settled Formal Complaints Filed Formal Complaints

Settled

Findings of

Discrimination

DLA EEO Complaint Trends Overview

FY18 FY19 FY20 FY21 FY22
11 

A total of 187 formal complaints were closed during FY22. Of the 187, 12 (6.4%) were withdrawn, 23 

(12.8%) were settled, and 151 (80.7%) were closed via final action either by final Agency decision 

based on the merit, or final Agency order with a U.S. Equal Employment Opportunity (EEOC) 

Administrative Judge (AJ). 

Progress on Part H.2 - EEO Counseling 

In FY22, 9.9% (23 of 228) EEO informal cases were counseled timely. DO and its' subordinate 

organizations continue to closely track counseling cases from start to close dates. Both HQ and MSC's 

closely monitor counseling timelines by regularly reviewing iComplaint reports. DO also continues to 

conduct training for EEO counselors via an EEO Academy to address any skill gaps.

Progress on Part H.3 – Untimely Final Agency Decisions (FADs) 

During FY22, there were a total of 95 EEO complaints awaiting FADs. Of the 95, a total of 85 FADs 

were issued. Of the 85, 16 (18.82%) were timely in that they were issued within 60 calendar days, and 

69 (81.18%) were untimely in that they were issued beyond 60 calendar days. Of the 69 untimely cases, 

65 were over 60 days; and 4 were mixed cases over 45 days.

In FY22, DLA hired a former FAD writer as a retired annuitant to assist with the backlog of FADs. 

During FY22, the EEO Specialist/FAD Writer (trainee) hired during FY21 departed the agency. DLA 

hired another EEO Specialist/FAD Writer during 4th quarter FY22 to contribute with mission execution. 

DLA has made significant improvements in this area and is headed in a positive direction by issuing 

twice as many Final Agency Decisions (FADs) as FY21 (41). To reduce the backlog the Director of 

Compliance put a team together with one team tackling the untimely old FAD’s while the other team 

tackled the timely FADs required within 60 calendar days. It should be noted the FAD teams consisted 

of three FAD writers to include the Staff Director.

Progress on Part H.4 – Untimely Investigations

During FY22, a total of 90 EEO cases were investigated, 13 were completed by Investigations 

Resolution Division (IRD), and 77 were completed by contract EEO investigators. In overall, 87 were 

completed in 180 days or less, and three were completed in over 180 days. EEO staff at DLA 

headquarters monitors performance of EEO investigator companies that are under the EEO investigator 

contract awarded in FY21.

Essential Element F: Responsiveness and Legal Compliance

In FY22, DLA responded to all RA requests and had a timely completion rate of 89%. It took an 

average of 20 days to grant requests and 26 days to provide the accommodations. 

DLA collaborates with the Office for Diversity, Equity, and Inclusion (ODEI) under the Office of the 

Under Secretary of Defense for Personnel & Readiness. ODEI meets with DoD Component Disability 

Program Managers, including Special Emphasis Program Managers on a monthly basis to discuss 

updates, drafting new policies, sharing best practices, and answering data calls. For example, DO 

participated at ODEI briefings on EEOC Joint Compliance Initiatives, including the Reasonable 

Accommodation Procedures Compliance Initiative and the Priorities for FY22 such as: Barrier Analysis, 

Special Hiring Authorities and Disability Employment Data; and reported their yearly comprehensive 

analysis to improve the data collection of civilian personnel demographics for all reporting requirements
12 

related to hirings, promotions, separations, reasonable accommodations, complaints, organizational 

climates, etc. 

DLA continues to upload to its website the FY quarterly and Annual Notification and Federal Employee 

Antidiscrimination and Retaliation (NoFEAR) Act to DoD. DLA will submit its consolidated report of 

all DLA MSC offices. 

Part E.3 - Executive Summary: Workforce Analysis

Summary of Workforce Data Table Analysis 

Trigger Analysis

During FY22, the DLA workforce decreased by 1.69% to 24,024 employees. While the overall 

workforce decreased, some opportunities improved, DLA saw a slight increase of 0.96% in new hires, 

hiring 2,452 new employees or a 10.21% rate in FY22 compared to 9.25% in FY21. However, People 

of Color (POC) new hires were 11.74% less than the White new hires of 55.87% while all Female new 

hires were 25.12% less than 62.56% Male new hires by the end of FY22. 

Workforce Demographics Analysis

At the beginning of FY22, DLA had under-representation compared to the National Civilian Labor 

Force (NCLF) in these groups: 

• Women Overall: By the end of the year, the number of employees in the overall female group 

increased by 0.10% to 36.40%, which is 11.81% lower than the 48.21% NCLF. 

• Hispanic women increased by 0.09% to 2.43% which is lower than the 6.16% NCLF. 

• White women decreased by 0.08% to 19.42% which is lower than the 31.82% NCLF. 

• Asian women increased by 0.12% to 1.80%, which is lower than the 2.18% NCLF. 

• Multi-Race women increased by 0.02% to 0.32%, which is lower than the 1.05% NCLF.

• Only Black women, Hawaiian Natives/Pacific Islander women and American 

Indian/Alaskan Native women were above their respective NCLF percentages.

Nationwide COVID-19 impacted the workforce and employees left the workforce due to issues with 

childcare, retirement, virtual classrooms at home, and financial setbacks, etc. It is believed these 

factors may have attributed to the trends on females in the DLA workforce. 

• Hispanic men increased by 0.07% to 4.13%, which is below the 6.82% NCLF. 

• Multi-Race men increased by 0.07% to 0.58%, which is below the 1.05% NCLF. 

• Only the Men Overall, White men, Black men, Asian men, Hawaiian Natives/Pacific 

Islander men and American Indian/Alaskan Natives men were above their respective NCLF 

percentages.
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Hiring and Separations 

Hirings: Of these 14 under-represented groups, nine out of 14 hires were well above the Civilian Labor 

Force (CLF) rate except for five triggers observed on Women Overall, Hispanic men & women, White 

Women and Multi-Race men below the CLF rate. Separations: A total of nine out of 14 permanent 

groups of separations were higher than the rate of their respective workforce showing the triggers 

observed on Women Overall, White women, Black men & women, Asian men, Hawaiian women, 

American Indian men & women, and multi-Racial women. A total of 76.2% of DLA’s separations were 

voluntary. 

Women Overall 37.44% of hires < 48.21% NCLF

36.42% of separations > 36.40% in the percentage of hires.

Hispanic Men 3.06% of hires < 6.82% NCLF

3.65% of separations < 4.13% in the percentage of hires.

Hispanic Women 2.16% of hires < 6.16% NCLF

2.21% of separations < 2.43% in the percentage of hires.

White Women 19.41% of hires < 19.42% NCLF

19.98% of separations > 19.50% in the percentage of hires.

Black Men 15.78% of hires > 5.70% NCLF

15.63% of separations > 14.31% in the percentage of hires.

Black Women 11.83 % of hires > 6.61% NCLF

11.72% of separations > 11.70% in the percentage of hires.

Asian Men 3.87% of hires > 2.19% NCLF

3.06% of separations > 2.96% in the percentage of hires.

6.82% 6.16%

35.65%

31.82%

5.70% 6.61%

2.19% 2.18%

0.08% 0.08% 0.31% 0.31% 1.05% 1.05%

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

20%

22%

24%

26%

28%

30%

32%

34%

36%

38%

40%

42%

Hispanic

Males

4.13%

Hispanic

Females

2.43%

White

Males

40.06%

White

Females

19.42%

Black

Males

14.31%

Black

Females

11.70%

Asian

Males

2.96%

Asian

Females

1.80%

NH/PI

Males

0.59%

NH/PI

Females

0.27%

AI/AN

Males

0.97%

AI/AN

Females

0.46%

2+ Males

0.58%

2+

Females

0.32%

FY2022 DLA Workforce compared to NCLF

FY2022 NCLF (2014-2018) American Community Survey)
14 

Asian Women 2.53% of hires > 2.18% NCLF

1.44% of separations < 1.80% in the percentage of hires.

Native Hawaiian or 

Pacific Islander Men

(0.90% of hires > 0.08% NCLF)

0.26% of separations < 0.59% in the percentage of hires.

Native Hawaiian or 

Pacific Islander Women

0.37% of hires > 0.08% NCLF

0.81% of separations > 0.27% in the percentage of hires.

American Indian or 

Alaska Native Men

1.26% of hires > 0.31% NCLF

1.03% of separations > 0.97% in the percentage of hires.

American Indian or 

Alaska Native Women

0.69% of hires > 0.31% NCLF

0.48% of separations > 0.46% in the percentage of hires.

Multi-racial Men 1.22% of hires > 1.05% NCLF

0.44% of separations < 0.58% in the percentage of hires.

Multi-Racial Women 0.45% of hires < 1.05% NCLF

0.33% of separations > 0.32% in the percentage of hires.

Career Development

DLA does offer many career development opportunities, including rotational assignments within DLA 

for GS-11 to GS-14 employees. DLA also offers the Executive Development Program (EDP), which 

allows managers to nominate high potential, highly motivated permanent civilians in grades GS-13 

through GS-15 for various programs under EDP. The DLA Executive Board then approves the 

nominees. In other training programs for all grades, HR reviews and approves or disapproves employee 

applications. In FY22, a total of 1,102 training applicants in GS-7 to GS-15 grades were accepted up 

from 987 in FY21. A total of 415, or 38.20% People of Color, and 477, or 43.28% Women Overall, in 

the same grades category applied and attended. A total of 113, or 11.94% People with Disabilities, and 

23, or 2.06% with Targeted Disabilities, in the same grades category applied and attended. 

Ongoing Barrier Analysis 

In FY22, DO began drafting a Diversity, Equity, Inclusion, and Accessibility (DEIA) Charter which will 

establish a new DEIA Committee. A primary line of effort for the committees will be to analyze 

anomalies and investigate the identified triggers found in civilian workplace policies, procedures, and 

practices impacting equal opportunities by gender, ethnicity, or disability and devise plans to conduct 

barrier analyses and eliminate such barriers in the workforce. DLA Energy has already developed a 

DEIA committee and continues to conduct barrier analysis for their MSC. 

The new DEIA Charter initiative will yield new efforts and it is expected to be approved by the DLA 

leadership with and establish a new committee in FY23 2nd Quarter. In FY21 and FY22, DLA Major 

Subordinate Commands (MSC) continued to identify multiple triggers across the workforce 

demographics and will conduct their barrier analyses after the DEIA committee develops a strategic 

plan. From there, DO will organize subcommittees dedicated to identifying triggers and conducting 

barrier analyses to ensure objectives are achieved and aligned with the agency’s DEIA strategic lines of 

effort. 
15

Part E.4 - Executive Summary: Accomplishments

Objectives from the FY21 MD-715 Report

1) Conduct Special Emphasis Programs (SEP) and barrier analysis on the top triggers and recommend 

corrective action plans for identified barriers. We will comprehensively review our policies, 

procedures, and practices to identify and recommend solutions to barriers.

2) Promote a diverse and inclusive work environment to make progress in achieving a DLA workforce 

consistent with the DoD standard parity rate of 48.0% females in line with the Civilian Labor Force 

(CLF) participation rate at 48.21%. 

3) DO will continue to work with HR to implement procedures of the anti-harassment program to 

ensure tracking of all complaints of harassment without an EEO basis and the total time spent 

conducting its management inquiries. 

4) Use a Tiger Team and hire additional resources to address overdue Final Agency Decisions (FADs). 

5) Training will be provided to the Agency’s servicing EEO Offices to ensure enterprise-wide 

understanding of the Standard Operating Procedures (SOP), to include the process and requirements 

for requesting data. Intent of goal is to streamline the process and ensure that Agency EEO 

specialists understand how to request documents, thus contributing to improved timely completion 

and tracking of Major Subordinate Commands (MSCs) EEO Investigations.

6) Ensure all DLA policy documents are accessible to all employees, consistent with the Rehabilitation 

Act.

FY22 Accomplishments

• The Secretary of Defense presented DLA with the Best Mid-size Component Disability Award for 2022 

for the sixth year in a row. DLA is the only DoD Component to receive this award six years in a row and 

DLA has won a total of 20 awards above all other DoD components since its inception in 1995.

Major Subordinate Commands (MSCs) conducted multiple Special Emphasis Program (SEPs) 

observances throughout the year, including nine DoD-endorsed activities such as: Martin Luther King Jr. 

Day, Black History Month, Women’s History Month, Asian Pacific Heritage Month, Juneteenth Day, 

Women’s Equality Day, Hispanic Heritage Month, National Disability Employment Awareness Month, 

and American Indian/Alaskan Native Heritage Month.

DLA was postured to hire 12 WRP participants with DoD funding for FY22; however, only eleven were 

hired due to the ongoing COVID-19 pandemic until telework restrictions on temporary hires were 

eventually removed. By the end of FY22, seven completed their internships while the remaining four 

crossed over to FY23 with new DoD funding. Two out of nine participants were converted to permanent 

positions. Two WRP participants were named as one of the WRP Participant of the Year and one DLA 

employee named as one of the WRP Recruiter of the Year recognized at a virtual DoD WRP ceremony 

in July 2022. A total of 14 DLA employees volunteered to become recruiters to college students with 

disabilities at different schools who were found to be eligible for this program.

DLA recruited at a virtual event sponsored by the Federal Asian Pacific Islander American Council 

(FAPAC) in conjunction with the Montgomery County College in Rockville, MD with six recruiters 

from the DLA Recruitment Cadre in September 2022.
16

The FAD writer hired during FY21 departed the Agency 2nd quarter FY2022. A new FAD writer was 

hired 4th quarter FY22 and is currently in training. In addition, a retired annuitant who was a former 

FAD writer was hired in FY22 specifically to assist with backlogged FADs.

FY22 saw an improvement in timely investigations. Comparing the FY21 462 report with 32 (29.6%) of 

108 untimely investigations. Whereas, in FY22, 3 out of the 90 were late.

FY22 saw a significant improvement in timely investigations, 97% were timely in FY22 (87/90) 

compared to 70% timely in FY21 (76/108).

DO received reliable data reports from the HR’s anti-harassment program. The new DO-D Staff 

Director co-authored the DLAI 1438.06 “DLAI 1438.06 Workplace Harassment Prevention and 

Response” approved by the EEOC in May 2022 and made available to DLA employees in July 2022.

DO coordinated the nominations for Affinity, DoD and EEO awards throughout the Enterprise which 

resulted with six winners for the League of United Latin American Citizen (LULAC) Excellence in 

Service (1); the Blacks in Government Military Meritorious Service Award (1); DoD/DLA Outstanding 

Employee with a Disability (1); and three EEO Achievement Awards by Employee, by 

Supervisor/Manager and by Organization (3), which brought the positive light this honor brings upon 

DLA.

The Disability Program Manager (DPM) updated the reasonable accommodation procedures and SOPs

and conducted training for supervisors, managers and meets quarterly with Disability Program 

Coordinators to educate and support their efforts. 

Part E.5 - Executive Summary: Planned Activities

Summary of New Objectives for FY23

1) Conduct Special Emphasis Programs (SEPs) and barrier analysis on the top triggers and recommend 

corrective plans of action for identified barriers. We will comprehensively review our policies, 

procedures, and practices to identify and recommend solutions to barriers by end of FY23. A new DO-D 

Staff Director was hired in August 2022 to ensure program effectiveness.

2) Complete the Diversity, Equality, Inclusion and Accessibility (DEIA) new charter to replace the old 

charter as of January 2017, to establish a DEIA Committee, and meet compliance in accordance with 

DoD’s DEIA Strategic Plan for Fiscal Years 2022-2023. Coordinate the appointments of committee 

members to form a viable committee which will perform targeted analysis of certain underrepresented 

groups within DLA. Continue to promote senior leader commitment to EEO and DEIA which fosters a 

culture where all our personnel can thrive by, empowering the workforce, creating an inclusive and 

equitable environment, where status quo can be challenged and where innovation flourishes.

3) Develop a Plan of Action and Milestones (POAM) regarding Recruitment, Retention, and Workforce 

Development to increase and sustain Women and Hispanic participation rates in high-level positions. 

DO plans to hire two additional staff to expand and maintain the POAM initiatives.

4) Establish and maintain relationships with colleges/universities, affinity groups and disability advocacy 

entities for recruitment of individuals with disabilities into entry-level employment and student 

internships such as the WRP and Memorandum of Understanding (MOU) partnerships. A MOU 
17

template was revised and DO has developed a SOP for MOU procedures now awaiting legal approval to 

ensure conformity and effective partnerships with schools throughout the Enterprise. This will expand 

DEIA objectives within our agency way forward. 

5) Improve tracking of Major Subordinate Command (MSC) EEO Counseling and Investigations by 

monthly reporting.

6) DO will continue to work with HR to implement and update procedures that will ensure timely responses 

to data requests during the investigation stage.

7) Ensure all DLA policy documents and websites are accessible to all employees, consistent with the 

Rehabilitation Act. 

8) The DO Affirmative Employment Program Manager and Program Analyst will continue to upgrade 

advanced workforce calculation spreadsheets, improve, and accelerate outputs for key statistical reports 

to improve identification of triggers and barrier analysis. DO plans to hire two additional staff to expand 

the DEIA initiatives.

9) The DLA SOP 1440.01-01, RA Procedures for Individuals with Disabilities was approved in FY22 by 

EEOC and will be updated further in FY23 to reflect the changes in DLA’s process based on the RA 

request system and removal of layers in the approval process. 

10) The Compliance team will continue to clear the FAD backlog.

11) DO will update EEO policy to meet compliance and correct identified deficiencies identified by EEOC 

OFO. 
Part F – Certification of Establishment of Continuing EEO Programs

I, Janice Samuel, Director of Equal Employment Opportunity, GS-0260-15 am the 

Principal EEO Director/Official for the Defense Logistics Agency and that:

The agency has conducted an annual self-assessment of Section 717 and 

Section 501 programs against the essential elements as prescribed by the 

Equal Employment Opportunity, (EEO) Management Directive 715 (MD715). If an essential element was not fully compliant with the standards of 

EEO MD-715, a further evaluation was conducted and as appropriate, EEO 

Plans for Attaining the Essential Elements of a Model EEO Program, are 

included with this Federal Agency Annual EEO Program Status Report.

The agency has also analyzed its work force profiles and conducted barrier 

analyses aimed at detecting whether any management or personnel policy, 

procedure or practice is operating to disadvantage any group based on race, 

national origin, gender, or disability. EEO Plans to Eliminate Identified 

Barriers, as appropriate, are included with this Federal Agency Annual EEO 

Program Status Report.

I certify that proper documentation of this assessment is in place and is being 

maintained for EEOC review upon request.

SAMUEL.JANICE Digitally signed by SAMUEL.JANICE.H.1046995186

.H.1046995186 Date: 2023.04.24 08:40:05

-04'00'

Signature of Principal EEO Director/Official Date

Certifies that this Federal Agency Annual EEO Program Status Report is in compliance with the 

EEOC MD-715.

Digitally signed by 

BUNN.BRADLEY.B.1229635146

Date: 2023.04.22 18:33:47 April 20, 2023 -04'00'

Signature of Agency Head or Agency Head Designee Date

18
19 

Part G - Agency Self-Assessment Checklist

The Part G Self-Assessment Checklist is a series of questions designed to provide federal agencies with 

an effective means for conducting the annual self-assessment required in Part F of MD-715. This selfassessment permits EEO Directors to recognize, and to highlight for their senior staff, deficiencies in 

their EEO program that the agency must address to comply with MD-715's requirements. Nothing in 

Part G prevents agencies from establishing additional practices that exceed the requirements set forth in 

this checklist.

All agencies will be required to submit Part G to EEOC. Although agencies need not submit 

documentation to support their Part G responses, they must maintain such documentation on file and 

make the findings available to EEOC upon request. 

The Part G checklist is organized to track the MD-715 essential elements. As a result, a single 

substantive matter may appear in several different sections, but in different contexts. For example, 

questions about establishing an anti-harassment policy fall within Element C (Management and Program 

Accountability), while questions about providing training under the anti-harassment policy are found in 

Element A (Demonstrated Commitment from Agency Leadership). 

For each MD-715 essential element, the Part G checklist provides a series of "compliance indicators.” 

Each compliance indicator, in turn, contains a series of “yes/no” questions, called “measures.” To the 

right of the measures, there are two columns, one for the agency to answer the measure with "Yes," 

"No,” or "NA;" and the second column for the agency to provide “comments,” if necessary. Agencies 

should briefly explain any “N/A” answer in the comments. For example, many of the sub-component 

agencies are not responsible for issuing Final Agency Decisions (FADs) in the EEO complaint process, 

so in order to answer questions about FAD timeliness with "NA" and explain in the comments column 

that the parent agency drafts all FADs.

A "No" response to any measure in Part G is a program deficiency. For each such "No" response, an 

agency will be required in Part H to identify a plan for correcting the identified deficiency. If one or 

more sub-components answer “No” to a particular question, the agency-wide/parent agency’s report 

should also include that “No” response. 

Essential Element A: Demonstrated Commitment from Agency Leadership

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

and a discrimination-free workplace.

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

Measure Compliance Indicator Measure

Measure 

Met?

(Yes/No/NA)

Comments

A.1.a

Does the agency annually issue a signed and dated EEO policy 

statement on agency letterhead that clearly communicates the agency’s 

commitment to EEO for all employees and applicants? If “yes,” please 

provide the annual issuance date in the comment’s column. [See 

MD-715, II(A)]

Yes Last policy issuance

was issued January 13, 

2022 and disseminated.
20 

Measure Compliance Indicator Measure

Measure 

Met?

(Yes/No/NA)

Comments

A.1.b

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

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

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

reprisal) contained in the laws EEOC enforces? [See 29 Code of 

Federal Regulations (CFR) §1614.101(a)] 

Yes

A.2 – The agency has communicated EEO policies and procedures to all employees.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

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

all employees?

N/A

A.2.a.1 Anti-harassment policy? [See MD-715, II(A)] Yes

A.2. a.2 Reasonable accommodation procedures? [See 29 CFR 

§1614.203(d)(3)]

Yes

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

throughout the workplace and on its public website?

N/A

A.2.b.1 

The business contact information for its EEO Counselors, EEO 

Officers, Special Emphasis Program Managers, and EEO Director? 

[See 29 CFR §1614.102(b)(7)]

Yes

A.2.b.2

Written materials concerning the EEO program, laws, policy 

statements, and the operation of the EEO complaint process? [See 

29 CFR §1614.102(b)(5)]

Yes

A.2.b.3

Reasonable accommodation procedures? [See 29 CFR 

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

comment’s column.

Yes www.dla.mil/EEO/Offers

/ReasonableAccommodat

ion/

A.2.c Does the agency inform its employees about the following topics? N/A

A.2.c.1

EEO complaint process? [See 29 CFR §§ 1614.102(a)(12) and 

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

Yes Listed on the public 

website, bulletin 

boards; explained 

during the EEO 

complaint process, 

during EEO training, 

Supervisory training, 

and new employee 

orientation.

A.2.c.2

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

how often.

Yes During the EEO 

complaint process; new 

employee orientation, 

and EEO training.

A.2.c.3

Reasonable accommodation program? [See 29 CFR 

§1614.203(d)(7)(ii)(C)] If “yes,” please provide how often.

Yes The RA for Employees 

class on Learning 

Management System 

(LMS) is required 

every other year, and 

every year for 

supervisors. Also, 

face-to-face training is 

offered in every MSC.
21 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

A.2.c.4

Anti-harassment program? [See EEOC Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by Supervisors 

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

Yes Annually. A total of 26

non-EEO cases were 

processed and 

resolved. (J13)

A.2.c.5

Behaviors that are inappropriate in the workplace and could result in 

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

how often.

Yes Initially at new 

employee orientations 

and monthly during 

EEO/RA training 

sessions for employees 

and supervisors.

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

A.3.a Does the agency provide recognition to employees, supervisors, 

managers, and units demonstrating superior accomplishment in equal 

employment opportunity? [See 29 CFR §1614.102(a) (9)] If “yes,” 

provide one or two examples in the comments section.

Yes DLA gives three 

awards every year to a 

DLA employee, a DLA 

supervisor, and a MSC 

or D-Staff/J-Code who 

showed “an exemplary 

commitment to equal 

employment 

opportunity.”

A.3.b Does the agency utilize the Federal Employee Viewpoint Survey or 

other climate assessment tools to monitor the perception of EEO 

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

Yes

Essential Element B: Integration of EEO into the Agency’s Strategic Mission

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

from discrimination and support the agency’s strategic mission. 

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

appropriate authority and resources to effectively carry out a successful EEO program.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.1.a

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

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

29 CFR §1614.102(b)(4)]

No The EEO Director 

reports to the Vice 

Director for day to day.

B.1.a.1

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

Director report to the same agency head designee as the mission-related 

programmatic offices? If “yes,” please provide the title of the agency 

head designee in the comments.

Yes EEO Director reports 

to the DLA Vice 

Director. 

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

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

Yes
22 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.1.b

Does the EEO Director have a regular and effective means of advising 

the agency head and other senior management officials of the 

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

program? [See 29 CFR §1614.102(c)(1); MD-715 Instructions, Sec. I] 

Yes Includes periodic

updates, bi-weekly 

meetings with Vice 

Director’s Staff 

Meetings and off-site 

visits.

B.1.c

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

of the agency, and other senior management officials, the "State of the 

agency" briefing covering the six essential elements of the model EEO 

program and the status of the barrier analysis process? [See MD-715 

Instructions, Sec. I)] If “yes,” please provide the date of the briefing in 

the comment’s column.

Yes EEO Director provides 

monthly briefing to 

Senior Leadership.

B.1.d

Does the EEO Director regularly participate in senior-level staff 

meetings concerning personnel, budget, technology, and other 

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

Yes On a bi-weekly and 

quarterly basis.

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.2.a

Is the EEO Director responsible for the implementation of a continuing 

affirmative employment program to promote EEO and to identify and 

eliminate discriminatory policies, procedures, and practices? [See 

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

Yes

B.2.b Is the EEO Director responsible for overseeing the completion of EEO 

counseling? [See 29 CFR §1614.102(c)(4)]

Yes

B.2.c

Is the EEO Director responsible for overseeing the fair and thorough 

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

question may not be applicable for certain subordinate level 

components.]

Yes

B.2.d

Is the EEO Director responsible for overseeing the timely issuance of 

final agency decisions? [See 29 CFR §1614.102(c)(5)] [This question 

may not be applicable for certain subordinate level components.]

Yes

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

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

Yes

B.2.f

Is the EEO Director responsible for periodically evaluating the entire 

EEO program and providing recommendations for improvement to the 

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

Yes

B.2.g

If the agency has subordinate level components, does the EEO Director 

provide effective guidance and coordination for the components? [See 

29 CFR §§ 1614.102(c)(2) and (c)(3)]

Yes
23 

B.3 - The EEO Director and other EEO professional staff are involved in, and consulted on, 

management/personnel actions.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.3.a

Do EEO program officials participate in agency meetings regarding 

workforce changes that might impact EEO issues, including strategic 

planning, recruitment strategies, vacancy projections, succession 

planning, and selections for training/career development opportunities? 

[See MD-715, II(B)]

Yes Alignment Group (AG) 

and Executive Board 

(EB) Senior 

Governance meetings. 

B.3.b

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

inclusion principles? [See MD-715, II(B)] If “yes,” please identify the 

EEO principles in the strategic plan in the comment’s column.

Yes People and Culture 

Plan are the critical 

elements of the 

strategic plan, which 

two objectives aligns

DLA’s “...ability to 

attract, develop, and 

retain a diverse, 

skilled, and agile 

workforce is vital to 

our continued success.

B.4 - The agency has sufficient budget and staffing to support the success of its EEO program.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.4.a

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

sufficient funding and qualified staffing to successfully implement the 

EEO program, for the following areas:

N/A

B.4.a.1

Conduct a self-assessment of the agency for possible program 

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

Yes Two Agency 

Management Reviews 

were conducted in 

FY22.

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

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

Yes

B.4.a.3

Timely, thoroughly, and fairly process EEO complaints, including 

EEO counseling, investigations, final agency decisions, and legal 

sufficiency reviews? [See 29 CFR §§ 1614.102(c)(5) & 1614.105(b) – 

(f); MD-110, Ch. 1(IV)(D) & 5(IV); MD-715, II(E)]

No See Part H.4

B.4.a.4

Provide all supervisors and employees with training on the EEO 

program, including but not limited to retaliation, harassment, religious 

accommodations, disability accommodations, the EEO complaint 

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

identify the type(s) of training with insufficient funding in the 

comment’s column.

Yes

B.4.a.5

Conduct thorough, accurate, and effective field audits of the EEO 

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

29 CFR §1614.102(c)(2)]

Yes

B.4.a.6

Publish and distribute EEO materials (e.g., harassment policies, EEO 

posters, reasonable accommodations procedures)? [See MD-715, 

II(B)]

Yes
24 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.4.a.7

Maintain accurate data collection and tracking systems for the 

following types of data: complaint tracking, workforce demographics, 

and applicant flow data? [See MD-715, II(E)]. If not, please identify 

the systems with insufficient funding in the comments section.

Yes

B.4.a.8

Effectively administer its special emphasis programs (such as, Federal 

Women’s Program, Hispanic Employment Program, and People with 

Disabilities Program Manager)? [5 USC §7201; 38 USC §4214; 

5 CFR §720.204; 5 CFR §213.3102(t) and (u); 5 CFR §315.709]

Yes

B.4.a.9

Effectively manage its anti-harassment program. [See MD-715 

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

Employer Liability for Unlawful Harassment by Supervisors (1999), 

§V.C.1]

Yes

B.4.a.10 Effectively manage its reasonable accommodation program. [See 

29 CFR §1614.203(d)(4)(ii)]

Yes

B.4.a.11 Ensure timely and complete compliance with EEOC orders? [See 

MD-715, II(E)]

Yes

B.4.b Does the EEO office have a budget that is separate from other offices 

within the agency? [See 29 CFR §1614.102(a)(1)]

Yes

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

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

Yes

B.4.d

Does the agency ensure that all new counselors and investigators, 

including contractors and collateral duty employees, receive the 

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

Yes

B.4.e

Does the agency ensure that all experienced counselors and 

investigators, including contractors and collateral duty employees, 

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

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

Yes

B.5 – The agency recruits, hires, develops, and retains supervisors and managers who have 

effective managerial, communications, and interpersonal skills.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.5.a

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

supervisors received training on their responsibilities under the 

following areas under the agency EEO program:

N/A

B.5.a.1 EEO Complaint Process? [See MD-715(II)(B)] Yes

B.5.a.2 Reasonable Accommodation Procedures? [See 29 CFR 

§1614.102(d)(3)]

Yes

B.5.a.3 Anti-Harassment Policy? [See MD-715(II)(B)] Yes

B.5.a.4

Supervisory, managerial, communication, and interpersonal skills in 

order to supervise most effectively in a workplace with diverse 

employees and avoid disputes arising from ineffective 

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

Yes

B.5.a.5

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

encouraging mutual resolution of disputes and the benefits associated

with utilizing ADR. [See MD-715(II)(E)]

Yes
25 

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

B.6.a Are senior managers involved in the implementation of Special 

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

Yes

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

MD-715 Instructions, Sec. I]

Yes

B.6.c

When barriers are identified, do senior managers assist in developing 

agency EEO action plans (Part I, Part J, or the Executive Summary)? 

[See MD-715 Instructions, Sec. I]

Yes

B.6.d

Do senior managers successfully implement EEO Action Plans and 

incorporate the EEO Action Plan Objectives into agency strategic 

plans? [29 CFR §1614.102(a)(5)]

Yes

Essential Element C: Management and Program Accountability

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

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

C.1 – The agency conducts regular internal audits of its component and field offices.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.1.a

Does the agency regularly assess its component and field offices for 

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

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

comments section.

Yes 2 AMR Reviews were 

conducted in FY22, 

and 2 reviews are 

scheduled for FY23.

C.1.b

Does the agency regularly assess its component and field offices on 

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

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

audits in the comments section.

Yes Same as above.

C.1.c Do the component and field offices make reasonable efforts to comply 

with the recommendations of the field audit? [See MD-715, II(C)] 

Yes

C.2 – The agency has established procedures to prevent all forms of EEO discrimination.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.2.a

Has the agency established comprehensive anti-harassment policy and 

procedures that comply with EEOC’s enforcement guidance? [See 

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

Liability for Unlawful Harassment by Supervisors (Enforcement 

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

Yes

C.2.a.1

Does the anti-harassment policy require corrective action to prevent or 

eliminate conduct before it rises to the level of unlawful harassment? 

[See EEOC Enforcement Guidance on Vicarious Employer Liability 

for Unlawful Harassment by Supervisors (1999), §V.C.1]

Yes

C.2.a.2

Has the agency established a firewall between the Anti-Harassment 

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

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

Yes
26 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.2.a.3

Does the agency have a separate procedure (outside the EEO complaint 

process) to address harassment allegations? [See Enforcement 

Guidance on Vicarious Employer Liability for Unlawful Harassment 

by Supervisors (Enforcement Guidance), EEOC No. 915.002, § V.C.1 

(June 18, 1999)]

Yes

C.2.a.4

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

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

Yes

C.2.a.5

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

of notification) of all harassment allegations, including those initially 

raised in the EEO complaint process? [See Complainant v. Dept. of 

Veterans Affairs, EEOC Appeal No. 0120123232 (May 21, 2015); 

Complainant v. Dept. of Defense (Defense Commissary Agency), 

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

provide the percentage of timely-processed inquiries in the comment’s

column.

Yes

C.2.a.6

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

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

1614.203(d)(2)]

Yes

C.2.b

Has the agency established disability reasonable accommodation 

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

29 CFR 1614.203(d)(3)]

Yes

C.2.b.1

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

coordinate or assist with processing requests for disability 

accommodations throughout the agency? [See 29 CFR

1614.203(d)(3)(D)]

Yes

C.2.b.2

Has the agency established a firewall between the Reasonable 

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

Yes

C.2.b.3

Does the agency ensure that job applicants can request and receive 

reasonable accommodations during the application and placement 

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

Yes

C.2.b.4

Do the reasonable accommodation procedures clearly state that the 

agency should process the request within a maximum amount of time 

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

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

Yes

C.2.b.5

Does the agency process all accommodation requests within the time 

frame set forth in its reasonable accommodation procedures? [See 

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

Yes A total of 89% RA 

requests were met. 

C.2.c

Has the agency established procedures for processing requests for 

personal assistance services that comply with EEOC’s regulations, 

enforcement guidance, and other applicable executive orders, guidance, 

and standards? [See 29 CFR 1614.203(d)(6)]

Yes

C.2.c.1

Does the agency post its procedures for processing requests for 

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

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

comment’s column.

Yes https://www.dla.mil/EEO/

Offers/PersonalAssistanc

eServices/
27 

C.3 - The agency evaluates managers and supervisors on their efforts to ensure equal employment 

opportunity.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.3.a

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

have an element in their performance appraisal that evaluates their 

commitment to agency EEO policies and principles and their 

participation in the EEO program?

Yes

C.3.b Does the agency require rating officials to evaluate the performance of 

managers and supervisors based on the following activities?

N/A

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

participation in ADR proceedings? [See MD-110, Ch. 3.I]

Yes

C.3.b.2

Ensure full cooperation of employees under his/her supervision with 

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

§1614.102(b)(6)]

Yes

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

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

Yes

C.3.b.4

Ensure that subordinate supervisors have effective managerial, 

communication, and interpersonal skills to supervise in a workplace 

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

Yes

C.3.b.5 Provide religious accommodations when such accommodations do not 

cause an undue hardship? [See 29 CFR §1614.102(a)(7)]

Yes

C.3.b.6 Provide disability accommodations when such accommodations do not 

cause an undue hardship? [See 29 CFR §1614.102(a)(8)]

Yes

C.3.b.7 Support the EEO program in identifying and removing barriers to equal 

opportunity. [See MD-715, II(C)]

Yes

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

harassing conduct. [See Enforcement Guidance, V.C.2]

Yes

C.3.b.9

Comply with settlement agreements and orders issued by the agency, 

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

Board, labor arbitrators, and the Federal Labor Relations Authority? 

[See MD-715, II(C)]

Yes

C.3.c

Does the EEO Director recommend to the agency head improvements 

or corrections, including remedial or disciplinary actions, for managers 

and supervisors who have failed in their EEO responsibilities? [See 29 

CFR §1614.102(c)(2)]

Yes

C.3.d

When the EEO Director recommends remedial or disciplinary actions, 

are the recommendations regularly implemented by the agency? [See 

29 CFR §1614.102(c)(2)]

Yes

C.4 – The agency ensures effective coordination between its EEO programs and HR program.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.4.a

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

whether personnel programs, policies, and procedures conform to 

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

§1614.102(a)(2)]

Yes
28 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.4.b

Has the agency established timetables/schedules to review at regular 

intervals its merit promotion program, employee recognition awards 

program, employee development/training programs, and 

management/personnel policies, procedures, and practices for systemic 

barriers that may be impeding full participation in the program by all 

EEO groups? [See MD-715 Instructions, Sec. I]

Yes

C.4.c

Does the EEO office have timely access to accurate and complete data 

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

etc.) required to prepare the MD-715 workforce data tables? [See 29 

CFR §1614.601(a)]

Yes

C.4.d

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

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

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

Yes

C.4.e Pursuant to Section II(C) of MD-715, does the EEO office collaborate 

with the HR office to:

N/A

C.4.e.1 Implement the Affirmative Action Plan for Individuals with 

Disabilities? [See 29 CFR §1614.203(d); MD-715, II(C)]

Yes

C.4.e.2 Develop and/or conduct outreach and recruiting initiatives? [See MD715, II(C)]

Yes

C.4.e.3 Develop and/or provide training for managers and employees? [See 

MD-715, II(C)]

Yes

C.4.e.4 Identify and remove barriers to equal opportunity in the workplace? 

[See MD-715, II(C)]

Yes

C.4.e.5 Assist in preparing the MD-715 report? [See MD-715, II(C)] Yes

C.5 – Following a finding of discrimination, the agency explores whether it should take a 

disciplinary action. 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.5.a

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

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

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

Yes

C.5.b

When appropriate, does the agency discipline or sanction managers and 

employees for discriminatory conduct? [See 29 CFR §1614.102(a)(6)]

If “yes,” please state the number of disciplined/sanctioned individuals 

during this reporting period in the comments.

Yes DLA disciplined 26

people.

C.5.c

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

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

about the discriminatory conduct? [See MD-715, II(C)]

Yes
29 

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

C.6.a

Does the EEO office provide management/supervisory officials with 

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

complaints, workforce demographics and data summaries, legal 

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

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

the EEO updates in the comment’s column.

Yes DO sends data to the 

MSC EEO Offices 

every month. Most 

EEMs then brief their 

Commanders on a 

Quarterly basis.

C.6.b Are EEO officials readily available to answer managers’ and 

supervisors’ questions or concerns? [See MD-715 Instructions, Sec. I]

Yes

Essential Element D: Proactive Prevention

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

and eliminate barriers to equal employment opportunity. 

D.1 – The agency conducts a reasonable assessment to monitor progress towards achieving equal 

employment opportunity throughout the year.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

D.1.a Does the agency have a process for identifying triggers in the 

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

Yes

D.1.b

Does the agency regularly use the following sources of information for 

trigger identification: workforce data; complaint/grievance data; exit 

surveys; employee climate surveys; focus groups; affinity groups; 

union; program evaluations; special emphasis programs; reasonable 

accommodation program; anti-harassment program; and/or external 

special interest groups? [See MD-715 Instructions, Sec. I]

Yes

D.1.c

Does the agency conduct exit interviews or surveys that include 

questions on how the agency could improve the recruitment, hiring, 

inclusion, retention, and advancement of individuals with disabilities? 

[See 29 CFR 1614.203(d)(1)(iii)(C)]

Yes

D.2 – The agency identifies areas where barriers may exclude EEO groups (reasonable basis to 

act.) 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

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

find possible barriers? [See MD-715, (II)(B)]

Yes

D.2.b

Does the agency regularly examine the impact of 

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

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

Yes

D.2.c

Does the agency consider whether any group of employees or 

applicants might be negatively impacted prior to making human 

resource decisions, such as re-organizations and realignments? [See 29 

CFR §1614.102(a)(3)]

Yes
30 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

D.2.d

Does the agency regularly review the following sources of information 

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

climate surveys, focus groups, affinity groups, union, program 

evaluations, anti-harassment program, special emphasis programs, 

reasonable accommodation program; anti-harassment program; and/or 

external special interest groups? [See MD-715 Instructions, Sec. I] If 

“yes,” please identify the data sources in the comment’s column.

Yes DO used:

workforce data, 

(DCPDS and USA 

Staffing) complaint 

data, (iComplaints) exit 

surveys, 

(SurveyMonkey) 

employee climate 

surveys, (Denison) 

special emphasis 

programs, (SEP Plans) 

RA program data 

(EEO-RAM)

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

D.3.a.

Does the agency effectively tailor action plans to address the identified 

barriers in particular policies, procedures, or practices? [See 29 CFR 

§1614.102(a)(3)]

Yes

D.3.b

If the agency identified one or more barriers during the reporting 

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

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

Yes

D.3.c Does the agency periodically review the effectiveness of the plans? 

[See MD-715, II(D)]

Yes

D.4 – The agency has an affirmative action plan for people with disabilities, including those with 

targeted disabilities.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

D.4.a

Does the agency post its affirmative action plan on its public website? 

[See 29 CFR 1614.203(d)(4)] Please provide the internet address in the 

comments.

Yes www.dla.mil/EEO/Bus

iness/Policies/ 

D.4.b

Does the agency take specific steps to ensure qualified people with 

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

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

Yes .

D.4.c

Does the agency ensure that disability-related questions from members 

of the public are answered promptly and correctly? [See 29 CFR 

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

Yes

D.4.d

Has the agency taken specific steps that are reasonably designed to 

increase the number of persons with disabilities or targeted disabilities 

employed at the agency until it meets the goals? [See 29 CFR 

1614.203(d)(7)(ii)]

Yes

Essential Element E: Efficiency

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

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

process.
31 

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

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

§1614.105?

Yes

E.1.b

Does the agency provide written notification of rights and 

responsibilities in the EEO process during the initial counseling 

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

Yes See Part H.2

E.1.c Does the agency issue acknowledgment letters immediately upon 

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

Yes

E.1.d

Does the agency issue acceptance letters/dismissal decisions within a 

reasonable time (e.g., 60 days) after receipt of the written EEO 

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

the average processing time in the comments.

Yes Average of 22.3 days 

to accept or dismiss.

E.1.e

Does the agency ensure all employees fully cooperate with EEO 

counselors and EEO personnel in the EEO process, including granting 

routine access to personnel records related to an investigation, pursuant 

to 29 CFR §1614.102(b)(6)?

Yes

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

§1614.108?

No See Part H.4

E.1.g

If the agency does not timely complete investigations, does the agency 

notify complainants of the date by which the investigation will be 

completed and of their right to request a hearing or file a lawsuit, 

pursuant to 29 CFR §1614.108(g)?

Yes

E.1.h

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

timely issue the final agency decision, pursuant to 29 CFR 

§1614.110(b)?

No See Part H.3

E.1.i

Does the agency timely issue final actions follow in receipt of the 

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

CFR §1614.110(a)?

Yes

E.1.j

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

complaint process, does the agency hold them accountable for poor 

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

please describe how in the comment’s column.

Yes When a contracted 

EEO investigator 

delivers a poor work 

product, the contractor 

is allowed 15 days to 

submit a revised 

document. If poor 

work or delays persist, 

DO will work with 

Contracting to ensure 

the contractor is not 

assigned EEO 

investigations in the 

future.

E.1.k

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

complaint process, does the agency hold them accountable for poor 

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

Yes

E.1.l

Does the agency submit complaint files and other documents in the 

proper format to EEOC through the Federal Sector EEO Portal 

(FedSEP)? [See 29 CFR § 1614.403(g)]

Yes
32 

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

E.2.a

Has the agency established a clear separation between its EEO 

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

1(IV)(D)]

Yes

E.2.b

When seeking legal sufficiency reviews, does the EEO office have 

access to sufficient legal resources separate from the agency 

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

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

review in the comment’s column.

Yes Each of the MSC EEO 

offices and HQs EEO 

has an appointed 

agency attorney who 

conducts legal 

sufficiency reviews. 

These attorneys do not 

participate in the 

agency’s defensive 

function.

E.2.c

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

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

attorney and the agency representative? [See MD-110, Ch. 1(IV)(D)]

Yes

E.2.d

Does the agency ensure that its agency representative does not intrude 

upon EEO counseling, investigations, and final agency decisions? [See 

MD-110, Ch. 1(IV)(D)]

Yes

E.2.e

If applicable, are processing time frames incorporated for the legal 

counsel’s sufficiency review for timely processing of complaints? [See 

EEOC Report, Attaining a Model Agency Program: Efficiency (Dec. 1, 

2004)]

Yes

E.3 - The agency has established and encouraged the widespread use of a fair ADR program.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

E.3.a

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

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

29 CFR §1614.102(b)(2)]

Yes

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

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

Yes

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

appropriate? [See MD-110, Ch. 3(IV)(C)]

Yes

E.3.d

Does the agency ensure a management official with settlement 

authority is accessible during the dispute resolution process? [See 

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

Yes

E.3.e

Does the agency prohibit the responsible management official named 

in the dispute from having settlement authority? [See MD-110, Ch. 

3(I)]

Yes

E.3.f Does the agency annually evaluate the effectiveness of its ADR 

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

Yes
33 

E.4 – The agency has effective and accurate data collection systems in place to evaluate its EEO 

program. 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

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

and analyze the following data?

N/A

E.4.a.1

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

the aggrieved individuals/complainants, and the involved management 

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

Yes

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

employees? [See 29 CFR §1614.601(a)] 

Yes

E.4.a.3 Recruitment activities? [See MD-715, II(E)] Yes

E.4.a.4 External and internal applicant flow data concerning the applicants’ 

race, national origin, sex, and disability status? [See MD-715, II(E)]

Yes

E.4.a.5 The processing of requests for reasonable accommodation? [29 CFR § 

1614.203(d)(4)]

Yes

E.4.a.6

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

EEOC Enforcement Guidance on Vicarious Employer Liability for 

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

Yes

E.4.b Does the agency have a system in place to re-survey the workforce on a 

regular basis? [MD-715 Instructions, Sec. I]

Yes Denison survey, Exit 

survey

E.5 – The agency identifies and disseminates significant trends and best practices in its EEO 

program. 

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

E.5.a

Does the agency monitor trends in its EEO program to determine 

whether the agency is meeting its obligations under the statutes EEOC 

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

comments.

Yes Monthly reporting to 

the EEO Managers; 

Quarterly reporting to 

DLA senior leaders on 

formal complaints, top 

3 issues and bases and 

reasonable 

accommodation 

requests.

E.5.b

Does the agency review other agencies’ best practices and adopt them, 

where appropriate, to improve the effectiveness of its EEO program? 

[See MD-715, II(E)] If “yes,” provide an example in the comments.

Yes DLA adopted the US 

Army’s letter of 

congratulations to 

winners of the WRP 

award; Revised DoD 

WRP Resources for 

hiring WRP interns and 

MOUs for MIPR 

processes.

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

federal agencies of similar size? [See MD-715, II(E)]

Yes
34 

Essential Element F: Responsiveness and Legal Compliance

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

guidance, and other written instructions. 

F.1 – The agency has processes in place to ensure timely and full compliance with EEOC Orders 

and settlement agreements.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

F.1.a

Does the agency have a system of management controls to ensure that 

its officials timely comply with EEOC orders/directives and final 

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

Yes

F.1.b

Does the agency have a system of management controls to ensure the 

timely, accurate, and complete compliance with resolutions/settlement 

agreements? [See MD-715, II(F)]

Yes

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

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

Yes

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

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

Yes

F.1.e

When EEOC issues an order requiring compliance by the agency, does 

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

product and/or delays during performance review? [See MD-110, Ch. 

9(IX)(H)]

Yes

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

orders, and other written instructions.

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

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

[See 29 CFR §1614.502; MD-715, II(E)]

Yes

F.2.a.1

When a complainant requests a hearing, does the agency timely 

forward the investigative file to the appropriate EEOC hearing office? 

[See 29 CFR §1614.108(g)]

Yes

F.2.a.2

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

appeal by the agency, does the agency ensure timely compliance with 

the orders of relief? [See 29 CFR §1614.501]

Yes

F.2.a.3

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

the investigative file to EEOC’s Office of Federal Operations? [See 29 

CFR §1614.403(e)]

Yes

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

EEOC with the required documentation for completing compliance?

Yes
35 

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

Measure Compliance Indicator Measure Measure Met?

(Yes/No/NA) Comments

F.3.a

Does the agency timely submit to EEOC an accurate and complete 

NoFEAR Act report? [Public Law 107-174 (May 15, 2002), §203(a)]

Yes DLA submits the 

NoFEAR Act report to 

DoD, who submits a 

report of all DoD 

Agencies.

F.3.b Does the agency timely post on its public webpage its quarterly 

NoFEAR Act data? [See 29 CFR §1614.703(d)]

Yes
36 

Part H.1 - Agency EEO Plan to Attain the Essential Elements of a Model EEO 

Program

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

EEO program. 

Statement of Model Program Essential Element Deficiency

Type of Program Deficiency Brief Description of Program Deficiency

D.2.b

Compliance Indicator: The agency identifies areas where barriers may exclude EEO groups 

(reasonable basis to act.)

Measure: Does the agency regularly examine the impact of management/personnel policies, 

procedures, and practices by race, national origin, sex, and disability? [See 29 CFR 

§1614.102(a)(3)]

Deficiency: DO did not review the remaining relevant policy documents in FY21. 

Objective(s) and Dates for EEO Plan

Date Initiated

(mm/dd/yyyy) Objective Target Date(mm/dd/yyyy)

Modified Date

(mm/dd/yyyy)

Date 

Completed

(mm/dd/yyyy)

03/30/2018 Review all relevant DLA policies, procedures, and 

practices for barriers to equal opportunity. 09/30/2020 09/30/2022 

03/30/2018

DO will accomplish this action by reviewing one 

relevant DLAI, DLA Manual (DLAM), DLA SOP, or 

DLA Job Aid for barriers every month.

09/30/2019 09/01/2019

Responsible Official(s)

Title Name

Performance 

Standards Address the 

Plan?

(Yes or No)

DO Deputy Director Dr. Angela Curtis Yes

AEP Manager Eric Spanbauer Yes

DPM Monique Ray Yes

Special Emphasis Program Manager Eric Spanbauer Yes

Planned Activities toward Completion of Objective

Target Date

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

04/30/2018

Create a list of relevant DLAIs, DLAMs, DLA SOPs, 

and Job Aids. DO will review those action items in 

order of importance.

Yes 06/01/2019
37 

Target Date

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

05/31/2018 Review first policy document. Yes 08/13/2019

06/30/2018 Review second policy document. Yes 08/28/2019

07/31/2018 Review third policy document. Yes 09/11/2019

08/31/2018 Review fourth policy document. Yes 09/20/2019

09/30/2018 Review fifth policy document. Yes 10/01/2019

10/31/2018 Review progress and update list of policy documents for 

review in FY19. Yes 09/30/2022

2019

Expand guidance to ensure all software/hardware 

products are Section 508 accessible; Promote disability 

employment achievements and nominate for the 

SECDEF award.

Yes 09/30/2019

2020

Planning to update RA procedures as mandated by 

EEOC; Establish an effective Alternative Resolution to 

increase participation; Plan to establish User Support 

systems to manage Section 508 challenges; Promote 

disability employment achievements and nominate for 

the SECDEF award.

Yes 09/30/2020

2021

Planned User Support systems available to provide 

configurations, troubleshooting and Assistive 

Technology support throughout the Enterprise; and 

Promote disability employment achievements and 

nominate for the SECDEF award.

Yes 09/30/2021

2022

Hire new FAD writers to reduce high backlogs;

Complete DLAI 1440.01; Provide DEIA awareness and 

complete charter & guidance; Section 508 IT teams to 

train personnel to increase Section 508 knowledge 

accessibility through the DLA enterprise; and Promote 

disability employment achievements; and nominate for 

the SECDEF award.

Yes 09/30/2022

2023

Establish a live DEIA committee and plan to complete a 

DEIA strategic plan; and Promote disability employment 

achievements and nominate for the SECDEF award.

Yes 09/30/2023

Report of Accomplishments

Fiscal Year Accomplishments

FY18

During FY18, DO reviewed the following policy documents:

DLAI 1025.01 - DLA Rotation Program

DLAI 1404.01 - DLA Merit Promotion Program

DLAI 1425.02 - DLA Enterprise Leader Development Program (ELDP)

DLAI 1430.04 - Executive Development Program

DLAI 1430.25 - Civilian Workforce Development and Training

DLAI 1438.06 - Workplace Harassment Prevention and Response Policy

DLA won the SECDEF Best Mid-sized Component on the Achievement of Individuals with Disabilities in 

October 2018.
38

Fiscal Year Accomplishments

FY19

DO-D updated the list of policy documents to review in FY19 and planned Section 508 activities; The DLA 

Section 508 Office provided guidance to implement contract solicitation language with Section 508 

requirements to DLA Acquisition in Solicitation Review Tool for all Contractors and Sellers (Statements of 

Work and Statements of Objectives); and DLA won the SECDEF Best Mid-sized Component on the 

Achievement of Individuals with Disabilities in October 2019.

FY20

Working on items that have been identified in the technical assistance visit.

Drafting new RA procedures for EEOC’s Review.

DLA achieved a 50% Alternative Resolution participation rate during the pre-complaint stage.

Through DLA’s commitment, met the goal in the hiring, and retaining Persons with Disabilities and 

Persons with Targeted Disabilities; User Support systems were readily made available to provide 

configurations, troubleshooting and Assistive Technology support throughout the Enterprise; and DLA won 

the SECDEF Best Mid-sized Component on the Achievement of Individuals with Disabilities in October 

2020.

FY21

Continue to evaluate new releases of Assistive Technology software and provide to DLA users as 

appropriate; Implemented Section 508 procedures for MSCs; and increased Section 508 training on 

technology standards, DLA won two awards: DLA won the SECDEF Best Mid-sized Component on the 

Achievement of Individuals with Disabilities and the SECDEF award for Accessible Communication and 

Technology in October 2021

FY22

Two new FAD writers were hired in FY22; Updated DLAI 1440.01; and Reduced FAD back log by 97%;

DEIA Training was conducted for all HR leaders; and the DLA Enterprise IT Accessibility Team uses 

various platforms to increase knowledge of Section 508 accessibility through the DLA enterprise. DLA 

won the SECDEF Best Mid-sized Component on the Achievement of Individuals with Disabilities in 

October 2022.
39 

Part H.2 - Agency EEO Plan to Attain the Essential Elements of a Model EEO 

Program

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

EEO program. 

Statement of Model Program Essential Element Deficiency

Type of Program Deficiency Brief Description of Program Deficiency

E.1.b 

Compliance Indicator: The agency maintains an efficient, fair, and impartial complaint 

resolution process.

Measure: Does the agency provide written notification of rights and responsibilities in the 

EEO process during the initial counseling session, pursuant to 29 CFR §1614.105(b)(1)?

Deficiency: Untimely EEO Counseling beyond 30 days.

Objective(s) and Dates for EEO Plan

Date Initiated

(mm/dd/yyyy) Objective Target Date(mm/dd/yyyy)

Modified Date

(mm/dd/yyyy)

Date 

Completed

(mm/dd/yyyy)

10/01/2022 Timely complete EEO Counselings within 30 days, or 

90 days with ADR 09/30/2023 

Responsible Official(s)

Title Name

Performance 

Standards Address the 

Plan?

(Yes or No)

DLA EEO Director Janice Samuel Yes

DLA EEO Deputy Director Kimberly Lewis Yes

DO-C Staff Director Vacant Yes

EEO Manager, DLA Headquarters Operations 

(DO-S) Beverly Johnson Yes

EEO Manager, DLA Aviation Deborah Winston Yes

EEO Manager, DLA Disposition Services Arnita Furgason Yes

EEO Manager, DLA Distribution Zachary Currier Yes

EEO Manager, DLA Energy Adam Morrison Yes

EEO Manager, DLA Land and Maritime Penny Copp Yes

EEO Manager, DLA Troop Support Carlos Deño, Jr. Yes
40

Planned Activities toward Completion of Objective

Target Date

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

10/01/2023

Headquarters EEO to track EEO Counseling timelines 

from date of initial filing to closure and share the data 

with EEMs monthly.

Yes

10/01/2023 MSC EEO Offices will monitor counseling timeliness. Yes

10/01/2023

Continue to train EEO professionals through the EEO 

Academy in order to address skill gaps related to EEO 

counseling.

Yes

Report of Accomplishments

Fiscal Year Accomplishments

FY2022

For FY2022, DLA saw 191 (90%) of its 213 informal complaints counseled timely for both 

FY2021 and FY2022. 

This remains steady from FY2021, in which 205 (90%) of DLA’s 228 informal complaints 

were counseled timely. 

The DLA EEO Academy for EEO professionals was instituted in order to address skill 

gaps with the Agency’s EEO community. Topics covered during FY22 were “EEO 

Counseling Plans”, “ROI Legal Sufficiency”, and “EEO Compliance Reports”. 
41 

Part H.3 - Agency EEO Plan to Attain the Essential Elements of a Model EEO 

Program

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

EEO program. 

Statement of Model Program Essential Element Deficiency

Type of Program Deficiency Brief Description of Program Deficiency

E.1.h

Compliance Indicator: The agency maintains an efficient, fair, and impartial complaint 

resolution process.

Measure: When the complainant does not request a hearing, does the agency timely issue 

the final agency decision, pursuant to 29 CFR §1614.110(b)?

Deficiency: DLA issues Merit final agency decisions (FADs) beyond 60 days.

Objective(s) and Dates for EEO Plan

Date Initiated

(mm/dd/yyyy) Objective Target Date(mm/dd/yyyy)

Modified Date

(mm/dd/yyyy)

Date 

Completed

(mm/dd/yyyy)

01/30/2018 Eliminate backlog of merit FADs. 10/01/2020 12/31/2022

Responsible Official(s)

Title Name

Performance 

Standards Address the 

Plan?

(Yes or No)

DLA EEO Director Janice Samuel Yes

DLA EEO Deputy Director Dr. Angela Curtis Yes

DO-C Staff Director Kimberly Lewis Yes

EEO Manager, DLA Headquarters Operations 

(DO-S) Beverly Johnson Yes

DLA Complaints Manager Gabriela Reitan Yes

EEO Specialist Cynthia Sexton Yes

EEO Specialist Tabatha Holloway Yes

EEO Specialist Joseph Sommerville, III Yes

Planned Activities toward Completion of Objective

Target Date

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

7/30/2019 Form a “Tiger” team to clear the backlog of merit FADs. Yes 1/7/2022 8/1/2019
42

Target Date

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

10/15/2019 “Tiger” team to review unassigned merit FADs to 

prioritize FADs based on the type of FAD. Yes 1/7/2022 09/2/2022

12/31/2020 “Tiger” team to be issued merit FAD assignments to 

clear some of the backlog. Yes 1/13/2020 Jan 2022

01/04/2021 A new FAD Team will reconvene January 4, 2021, with 

the goal for the team to complete 4 FADs per month. No 1/31/2022

03/31/2021 DLA will submit a hiring action vice a FAD writer who 

retired on December 31, 2020. No February 2022

03/31/2021 DLA will submit a hiring action vice a new FAD writer. No July 2021

Report of Accomplishments

Fiscal Year Accomplishments

FY21

The Tiger Team was disestablished due to staff shortages: (1) A new FAD writer was hired 

in July 2021 who is in training. The plan for FY22 was to hire a retired annuitant who is an 

experienced FAD writer; (2) In a seven-month period (January to July 2021) the FAD team 

issued an average of four merit FADs per month; (3) Forty-one (41) merit FADs were 

issued in FY21, with seven (17%) of the decisions issued timely within 60 days. 

FY22

The FAD Writer hired during FY21 departed the Agency during the FY22 2nd quarter. A 

new EEO Specialist/FAD Writer (trainee) was hired during the FY22 4th quarter. In 

addition, DLA hired an experienced FAD Writer as a retired annuitant to focus solely on 

helping the Agency to clear out back-logged FADs and improve overall performance on 

issuing timely FADS. 

DLA executed an EEO Directors Leadership Summit during the FY22 3rd quarter in an 

effort to take a top-down approach informing Agency EEO leadership in areas that may 

assist with submission of sound/sufficient reports of investigations (ROIs) which are used 

to prepare the FADs. An out-product of the Summit was the enterprise-wide execution of a 

DLA EEO Academy, which is managed by one of the DLA EEO MSCs. The Academy is 

open to all DLA EEO professionals and covers topics relevant to informal and formal EEO 

complaint processing. The Academy’s first course was held during FY22 4th quarter.

As of September 29, 2022, there were a total of 14 FADs pending. Of the 14 FADs, 6 are 

being worked by FAD writers, or being reviewed by the DLA Office of General Counsel. 

FY22 saw an improvement in the issuance of timely FADS. In FY22, a total of 16 

(18.82%) of the 85 merit FADs were issued timely. This is an improvement from FY21, 

which saw 7 (17.07%) of its 41 merit FADS issued timely, and 7% issued timely in FY20. 
43 

Part H.4 - Agency EEO Plan to Attain the Essential Elements of a Model EEO 

Program 

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

EEO program.

Statement of Model Program Essential Element Deficiency

Type of Program Deficiency Brief Description of Program Deficiency

E.1.f

Compliance Indicator: The agency maintains an efficient, fair, and impartial complaint 

resolution process.

Measure: Does the agency timely complete investigations, pursuant to 29 CFR §1614.108?

Deficiency: DLA did not complete investigations within the applicable timeframes. A total 

of 40% (34/84) of the completed investigations in FY17 were untimely.

Objective(s) and Dates for EEO Plan

Date Initiated

(mm/dd/yyyy) Objective Target Date(mm/dd/yyyy)

Modified Date

(mm/dd/yyyy)

Date Completed

(mm/dd/yyyy)

11/30/2018 Reduce pre-investigation processing time to 10 

business days. 09/30/2020 06/30/2022 

11/30/2018 Reduce post-investigation processing time to 10 

business days. 09/30/2020 06/30/2022

01/30/2018 Reach 90% timely investigations. 09/30/2019 06/30/2022

Responsible Official(s)

Title Name

Performance 

Standards Address the 

Plan?

(Yes or No)

DLA EEO Director (DO) Janice Samuel Yes

DLA EEO Deputy Director Dr. Angela Curtis Yes

Staff Director, Complaints and Compliance Division (DO-C) Kimberly Lewis Yes

EEO Manager, DLA Headquarters Operations (DO-S) Beverly Johnson Yes

EEO Manager, DLA Aviation Deborah Winston Yes

EEO Manager, DLA Disposition Allen Hight Yes

EEO Manager, DLA Distribution Zachary Currier Yes

EEO Manager, DLA Energy Dominica Gay, Acting Yes

EEO Manager, DLA Land and Maritime Penny Copp Yes

EEM, DLA Troop Support Carlos Deño, Jr. Yes
44

Planned Activities toward Completion of Objective

Target Date

(mm/dd/yyyy) Planned Activities

Sufficient 

Funding & 

Staffing?

(Yes or No)

Modified 

Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

3/30/2020

Draft a Standard Operating Procedures (SOP) between 

EEO and Human Resources on how to request data for 

EEO investigations.

Yes 09/29/2020

3/30/2020 Human Recourses/EEO to provide training to EEO 

Specialists on requesting data. Yes 11/19/2020

9/30/2020

Headquarters EEO to track investigation timelines from 

date of filing to accept formal complaints, request to 

investigate to the release of the ROI, and share the data 

with EEMs monthly.

Yes 6/30/2022

Reported 

monthly and 

quarterly in 

FY22. Efforts 

will continue 

into FY23

9/30/2020 Meet with the contracting office to explore and generate 

new investigator contracts. Yes 9/20/2021.

Report of Accomplishments

Fiscal Year Accomplishments

FY2018 No accomplishments in FY18. Untimely investigations increased in FY18 to 39 untimely of 85 

investigations, which 46% were untimely.

FY2019

Updated the planned activities and responsible offices to be more effective in FY19. Reviewed FY19 

planned activities. Performance elements were addressed in the Agency’s Management Reviews (AMR) of 

Land & Maritime and Aviation EEO offices. Six of the seven EEO offices began using contract 

investigators as opposed to IRD. Untimely investigations slightly increased in FY19 from 46% in FY18 to 

47%.

FY2020

DLA EEO and Diversity and DLA Human Resources Offices partnered to create Standard Operating 

Procedures (SOP) that addressed agency internal procedures for requesting EEO data. The SOP was 

finalized September 29, 2020. The SOP specifically addressed the process to request evidentiary data. 

This was done as part of the Agency’s goal to streamline the process and ensure that Agency EEO 

specialists understand how to request documents, thus contributing to improved timely completion of EEO 

Investigations. 

During FY21, training will be provided to the Agency’s servicing EEO Offices to ensure enterprise-wide 

understanding of the SOP, to include the process and requirements for requesting data. 

EEO Managers of each of the Agency’s servicing EEO Offices were provided quarterly information 

concerning the timeliness of the EEO Investigations. Due to leadership changes with four of the EEO 

Offices during FY20, this information transitioned to being disseminated quarterly. Now, that all EEO 

Manager positions are incumbered, reporting of this information will transition back to monthly. 

A Tiger Team was formed to address the EEO investigator contract. The Performance Work Statement 

(PWS) is being revamped, and a solicitation package is being assembled for submission to the DLA 

Contracting Office in FY2021. EEO investigations were completed for 116 cases. Of the 116, 44 (38%) 

were untimely, and 72 (62%) were timely. 

In FY21, DO-C will review the EEO Investigations data monthly in order to ensure continuous 

improvement of timely completed investigations. 
45

Fiscal Year Accomplishments

FY21

On November 19, 2020, training on the process and requirements for requesting EEO evidentiary data was 

provided to the seven (7) EEO offices. Complaint data was reviewed monthly. Completion of timely EEO 

investigations improved. Of the 108 completed investigations, 76 (70%) were timely and 32 (30%) were 

untimely. At the end of FY21, new investigator contracts were awarded.

FY22

DLA has made significant improvements in this area. We will continue to monitor progress on untimely 

investigations and FAD’s. We understand early intervention is the best practice therefore, we have 

partnered with HR and General Counsel to present systemic issues to supervisor and managers quarterly. A 

total of 97% investigations were completed on time above the 90% target goal. 
46 

Part J - Special Program Plan for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities

To capture agencies’ affirmative action plan for Persons with Disabilities (PWD) and Persons with 

Targeted Disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 require 

agencies to describe how their plan will improve the recruitment, hiring, advancement, and retention of 

applicants and employees with disabilities. All agencies, regardless of size, must complete this Part of 

the MD-715 report. 

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 C.F.R. § 1614.203(d)(7)) require agencies to establish specific numerical goals 

for increasing the participation of persons with reportable and targeted disabilities in the federal 

government. 

Using the goal of 12% as the benchmark, does your agency have a trigger involving PWD by 

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

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

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

15.83% is greater than the 12.00% benchmark. 

16.53% is greater than the 12.00% benchmark.

Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by 

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

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

Cluster GS-11 to SES (PWTD)................................................. No

4.57% is greater than the 2.00% benchmark. 

3.61% is greater than the 2.00% benchmark. 

Describe how the agency has communicated the numerical goals to the hiring managers and/or 

recruiters.

DLA has consistently communicated through Disability self-identification video, selfidentification articles and demographic charts. DLA also promotes National Disability Awareness 

Month presentations and seminars, which state our commitment to increase the representation of 

PWTDs to 2% and PWDs to 12% of our workforce. DLA also collaborates with the Office of 

Diversity Equity and Inclusion (ODEI) within OSD and the DLA HR Recruitment Cadre. 
47 

Section II: Model Disability Program

Pursuant to 29 C.F.R. §1614.203(d)(1), agencies must ensure sufficient staff, training, and resources to 

recruit and hire persons with disabilities and persons with targeted disabilities, administer the reasonable 

accommodation program and special emphasis program, and oversee any other disability hiring and 

advancement program the agency has in place. 

A. Plan to Provide Sufficient & Competent Staffing for the Disability Program

Has the agency designated sufficient qualified personnel to implement its disability program 

during the reporting period? If “no,” describe the agency’s plan to improve the staffing for the 

upcoming year. 

Yes. 

Identify all staff responsible for implementing the agency’s disability employment program by 

the office, staff employment status, and responsible official. 

Disability Program Task

# of FTE Staff by 

Employment Status Responsible Official

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

Processing applications from PWD 

and PWTD by Selective Placement 

Coordinators (SPPCs)

0 0 90 Casandra Green, SPPC; Casandra.Green@dla.mil 

Steven Carney, SPPC; Steven.Carney@dla.mil 

SPPCs answering questions from the 

public about hiring authorities that 

take disability into account

0 0 2 Casandra Green, SPPC; Casandra.Green@dla.mil 

Steven Carney, SPPC; Steven.Carney@dla.mil 

Processing reasonable 

accommodation requests from 

applicants and employees

8 0 3 Monique Ray, DLA Disability Program Manager 

(DPM); Monique.Ray@dla.mil 

Section 508 Compliance

6 4 8 Richard Harmon, Branch Chief, Enterprise IT 

Accessibility, J62LC Richard.Harmon@dla.mil

Architectural Barriers Act 

Compliance 0 0 7 Tamberly Averett, Installation Management Division Chief, Tamberly.Averett@dla.mil

Special Emphasis Program for PWDs 

and PWTDs 9 0 0 Eric Spanbauer, DLA Special Emphasis Program Manager (SEPM); Eric.Spanbauer@dla.mil

Has the agency provided disability program staff with sufficient training to carry out their 

responsibilities during the reporting period? If “yes,” describe the training that disability 

program staff have received. If “no,” describe the training planned for the upcoming year. 

Yes. DLA has a full-time Disability Program Manager (DPM) who works with seven Disability 

Program Coordinators (DPCs) at the Major Subordinate Commands (MSCs) EEO offices. 
48 

B. Plan to Ensure Sufficient Funding for the Disability Program

Has the agency provided sufficient funding and other resources to successfully implement the disability 

program during the reporting period? If “no,” describe the agency’s plan to ensure all aspects of the 

disability program have sufficient funding and other resources. 

Yes. The DPM and all DPCs have attended a Disability Program Manager training course, and 

regularly attend workshops and webinars hosted by the National Employment Law Institute 

(NELI), the Job Accommodation Network (JAN), and the Employer Assistance and Resource 

Network (EARN). They also participate in the Federal Exchange on Employment and Disability 

(FEED), hosted by the EEOC, the Office of Personnel Management, and the Department of Labor. 

All DPCs regularly receives updates and advisories from the Computer/Electronic 

Accommodations Program (CAP) and the Workforce Recruitment Program (WRP) for College 

Students with Disabilities with DoD funding at no charge to DLA. 

DO hosts a roundtable every other month to discuss Reasonable Accommodation (RAs) 

Procedures, Special Emphasis Programs (SEP), and Affirmative Employment Program (AEP) 

matters, conduct on-the-spot training, and share best practices, trends, and solutions. 

The DPM hosts a quarterly meeting to discuss RA issues. 

Section III: Plan to Recruit and Hire Individuals with Disabilities

Pursuant to 29 C.F.R. § 1614.203(d)(1)(i) and (ii), agencies must establish a plan to increase the 

recruitment and hiring of individuals with disabilities. The questions below are designed to identify 

outcomes of the agency’s recruitment program plan for Persons with Disabilities (PWD) and Persons 

with Targeted Disabilities (PWTD). 

A. Plan to Identify Job Applicants with Disabilities

Describe the programs and resources the agency uses to identify job applicants with disabilities, 

including individuals with targeted disabilities.

Job applicants may use Schedule A hiring authority to apply for vacancy announcements. If hired 

with the Schedule A hiring authority, selectees are required to complete a SF-256 form to identify 

their disability. On another avenue, supervisors and managers identify and select qualified 

candidates through the Workforce Recruitment Program (WRP) for College Students with 

Disabilities database are hired through the Schedule A hiring authority. 
49 

Pursuant to 29 C.F.R. § 1614.203(a)(3), describe the agency’s use of hiring authorities that take 

disability into account (e.g., Schedule A) to recruit PWD and PWTD for positions in the 

permanent workforce.

DLA uses all available and appropriate hiring authorities to recruit and hire PWD and PWTD. 

Individuals eligible for employment under the hiring authorities pursuant to 29 CFR 

1614.203(a)(3), such as Schedule A, Veterans Recruitment Appointment, and 30% or More 

Disabled Veteran Authority, can be considered for employment opportunities by applying to 

positions on USAJOBs. 

When individuals apply for a position under a hiring authority that takes disability into account 

(e.g., Schedule A), explain how the agency (1) determines if the individual is eligible for 

appointment under such authority and (2) forwards the individual's application to the relevant 

hiring officials with an explanation of how and when the individual may be appointed. 

Individuals requesting consideration through Schedule A hiring authority are required to provide a 

letter from a physician or other care provider certifying their eligibility for Schedule A hiring 

authority. Individuals who request consideration as a 30% or more disabled veteran are required 

to provide DD Form 214, Military Discharge and a letter from the Department of Veteran's Affairs 

or branch of the armed forces certifying an overall service-connected disability. Individuals must 

meet eligibility requirements for the appointment authority and minimum qualifications for the 

vacancy.

HR refers qualified applicants to the selecting official in veteran’s preference order and then if 

they identify as being eligible for Schedule A hiring authority, for 30% or more disabled veteran’s 

authority or both, HR refers qualified applicants to the selecting official in veteran’s preference 

order and then if they identify as being eligible for Schedule A hiring authority, for 30% or more 

disabled veteran’s authority, or both. 

Has the agency provided training to all hiring managers on the use of hiring authorities that take 

disability into account (e.g., Schedule A)? If “yes,” describe the type(s) of training and 

frequency. If “no,” describe the agency’s plan to provide this training. 

Yes. All new supervisors are trained on Schedule A hiring authority during the HR Management 

class, which is refreshed every three years.

B. Plan to Establish Contacts with Disability Employment Organizations 

Describe the agency’s efforts to establish and maintain contacts with organizations that assist Persons 

with Disabilities (PWD) and including Persons with Targeted Disabilities (PWTD), in securing and 

maintaining employment.
50 

Organizations that assist PWDs and PWTDs with securing employment where DLA currently maintains 

contact with:

• Department of Labor for the WRP

• State Rehabilitation Service

• Veteran Employment Centers 

• Gallaudet University

• National Institute of the Blind

• National Technical Institution of the Deaf 

• Disabled American Veterans

• Social Security Administration

• Wounded Warrior Project 

• Philadelphia Veterans Contact and 

Advocacy Program 

• Job Accommodation Network (JAN) 

• Computer/Electronic Accommodations 

Program (CAP) 

• Job Fairs that target PWD and PWTD 

populations, such as the Careers and the 

Disabled Expo. 

• Local college and university campus 

disability programs to inform them of job 

opportunities with DLA and to raise 

awareness of the different hiring authorities 

and programs. 

C. Progression Towards Goals (Recruitment and Hiring) 

Using the goals of 12% for Persons with Disabilities (PWDs) and 2% for Persons with Targeted 

Disabilities (PWTDs) as the benchmarks, do triggers exist for PWD and/or PWTD among the 

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

New Hires for Permanent Workforce (PWD) ........................... Yes

New Hires for Permanent Workforce (PWTD) ........................ No

11.95% is less than the 12.00% benchmark.

2.32% is greater than the 2.00% benchmark.

Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

among the new hires for any of the mission-critical occupations (MCO)? If “yes,” please 

describe the triggers below.

New Hires for MCO (PWD) .....................................................Yes

New Hires for MCO (PWTD)...................................................No

Triggers exist for PWDs in the following MCOs: (Percent of new hires in that MCO.) 

MCOs with enough hires (≥8) for the trigger to be significant are marked in red. 

0080 = 0.36% of 3 hires < 0.83% Security Administration

0089 = 0.12% of 1 hires < 0.95% Emergency Management

0201 = 0.95% of 8 hires < 8.52% Human Resources

0260 = 0.59% of 5 hires < 1.42% Equal Employment Opportunity

0301 = 1.78% of 15 hires < 8.28% Administration and Program

0343 = 1.30% of 11 hires < 12.19% Program Management Analyst

0346 = 0.36% of 3 hires < 2.37% Logistics Management
51 

0510 = 0.12% of 1 hires < 2.49% Accounting

0801 = 0.12% of 1 hires < 1.42% General Engineering

0905 = 0.36% of 3 hires < 2.72% Attorney

1101 = 0.12% of 1 hires < 0.59% General Business & Industry

1102 = 2.37% of 20 hires < 28.05% Contracting

1104 = 0.36% of 3 hires < 2.72% Property Disposal

2001 = 0.59% of 5 hires < 7.22% General Supply

2003 = 0.47% of 4 hires < 2.01% Supply Program Management

2030 = 0.24% of 2 hires < 0.83% Distribution Facilities & Storage Management

2210 = 1.89% of 16 hires < 12.78% Information Technology Management

Note: the other 13 Top MCOs not listed here had no FY22 new hires.

Triggers exist for PWTDs in the following MCOs: (Percent of new hires in that MCO.) 

MCOs with enough hires (≥8) for the trigger to be significant are marked in red. 

0260 = 0.36% of 3 hires < 1.42% Equal Employment Opportunity

0301 = 0.36% of 3 hires < 8.28% Administration and Program

0343 = 0.47% of 4 hires < 12.19% Program Management Analyst

0346 = 0.12% of 1 hires < 2.37% Logistics Management

0801 = 0.12% of 1 hires < 1.42% General Engineering

0905 = 0.12% of 1 hires < 2.72% Attorney

1102 = 0.71% of 6 hires < 28.05% Contracting

1104 = 0.24% of 2 hires < 2.72% Property Disposal

2003 = 0.24% of 2 hires < 2.01% Supply Program Management

2210 = 0.36% of 3 hires < 12.78% Information Technology Management

Note: the other 20 Top MCOs not listed here had no FY22 new hires.

Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

among the qualified internal applicants for any of the mission-critical occupations (MCO)? If 

“yes,” please describe the triggers below.

Qualified Applicants for MCO (PWD) .....................................Yes

Qualified Applicants for MCO (PWTD) ..................................Yes

Triggers exist for PWDs in the following MCOs: (Percent of new hires in that MCO.)

MCOs with enough hires (≥8) for the trigger to be significant are marked in red.

0080 = 0.94% of 18 hires < 1.17% Security Administration

0201 = 15.30% of 294 hires > 14.16% Human Resources

0260 = 1.04% of 20 hires > 0.72% Equal Employment Opportunity

0301 = 12.02% of 231 hires > 11.65% Administration and Program

0343 = 13.58% of 261 hires < 13.81% Program Management Analyst

0346 = 2.13% of 41 hires < 2.16% Logistics Management

0501 = 0.16% of 3 hires < 0.32% Financial Administration & Program

0801 = 0.10% of 2 hires > 0.07% General Engineering
52 

1035 = 0.10% of 2 hires = 0.10% General Attorney

1101 = 0.42% of 8 hires = 0.42% General Business & Industry

1102 = 6.66% of 128 hires > 5.83% Contracting

1104 = 10.61% of 204 hires > 9.55% Property Disposal

2001 = 21.75% of 418 hires < 24.02% General Supply

2003 = 8.79% of 169 hires < 9.10% Supply Program Management

2030 = 6.40% of 123 hires < 6.93% Distribution Facilities & Storage Management

Note: the other 15 Top MCOs not listed here had no FY21 internal hires.

Triggers exist for PWTDs in the following MCOs: (Percent of new hires in that MCO.)

MCOs with enough hires (≥8) for the trigger to be significant are marked in red.

0080 = 1.56% of 5 hires > 1.47% Security Administration

0201 = 5.92% of 19 hires > 5.49% Human Resources

0260 = 1.25% of 4 hires > 0.57% Equal Employment Opportunity

0301 = 15.58% of 50 hires > 14.55% Administration and Program

0343 = 17.45% of 56 hires < 18.39% Program Management Analyst

0346 = 0.62% of 2 hires < 1.60% Logistics Management

0501 = 0.00% of 0 hires < 0.12% Financial Administration & Program

0801 = 0.62% of 2 hires > 0.13% General Engineering

1035 = 0.00% of 0 hires < 0.03% General Attorney

1101 = 0.31% of 1 hires < 0.42% General Business & Industry

1102 = 7.48% of 24 hires > 6.26% Contracting

1104 = 9.35% of 30 hires < 9.76% Property Disposal

2001 = 24.61% of 79 hires < 24.99% General Supply

2003 = 9.66% of 31 hires > 8.99% Supply Program Management

2030 = 5.61% of 18 hires < 7.24% Distribution Facilities & Storage Management

Note: the other 15 Top MCOs not listed here for had no FY22 internal hires.

Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD 

among employees promoted to any of the mission-critical occupations (MCO)? If “yes,” please 

describe the triggers below. 

Promotions for MCO (PWD) ....................................................Yes

Promotions for MCO (PWTD) .................................................Yes

Triggers exist for PWDs in the following MCOs: (Percent of promotions in that MCO.) MCOs with enough hires (≥8) 

for the trigger to be significant are marked in red.

0080 = 0.19% of 24 hires < 2.47% Security Administration

0089 = 0.08% of 10 hires < 1.41% Emergency Management

0201 = 0.09% of 12 hires < 0.80% Human Resources
53 

0260 = 0.11% of 14 hires < 0.54% Equal Employment Opportunity

0301 = 1.80% of 232 hires < 20.58% Administration and Program

0343 = 2.14% of 276 hires < 21.41% Program Management Analyst

0346 = 0.28% of 36 hire < 3.33% Logistics Management

0391 = 0.02% of 2 hires < 0.09% Financial Administration & Program

0501 = 0.29% of 38 hires < 3.65% Accounting

0505 = 0.03% of 4 hires < 0.23% Financial Management

0510 = 0.35% of 45 hires < 3.54% Accounting

0511 = 0.10% of 13 hires > 0.02% Auditing

0690 = 0.01% of 1 hire < 0.15% Property Disposal

0801 = 0.02% of 3 hires < 1.14% General Engineering

0810 = 0.00% of 0 hire < 0.02% Civil Engineering

0905 = 0.12% of 15 hires < 3.14% General Attorney

1035 = 0.00% of 0 hire < 0.12% Public Affairs

1101 = 0.12% of 16 hires < 1.38% General Business & Industry

1102 = 0.57% of 73 hires < 7.47% Contracting

2001 = 0.52% of 67 hires < 4.47% General Supply

2003 = 0.22% of 28 hires < 2.93% Supply Program Management

2030 = 0.00% of 0 hire < 0.07% Distribution Facilities & Storage Management

2210 = 1.35% of 174 hires < 12.66% Information Technology Management

Note: the other seven Top MCOs not listed here had no FY22 Promotions.

Triggers exist for PWTDs in the following MCOs: (Percent of promotions in that MCO.) MCOs with enough hires (≥8) 

for the trigger to be significant are marked in red.

0080 = 0.09% of 12 hires < 2.66% Security Administration

0089 = 0.04% of 5 hires < 1.49% Emergency Management

0201 = 0.06% of 8 hires < 0.89% Human Resources

0260 = 0.06% of 8 hires < 0.65% Equal Employment Opportunity

0301 = 0.90% of 116 hires < 22.37% Administration and Program

0343 = 1.10% of 142 hires < 23.55% Program Management Analyst

0346 = 0.15% of 19 hires < 3.61% Logistics Management

0391 = 0.02% of 2 hires < 0.10% Financial Administration & Program

0501 = 0.13% of 17 hires < 3.94% Accounting

0505 = 0.02% of 3 hires < 0.26% Financial Management

0510 = 0.13% of 17 hires < 3.89% Accounting

0511 = 0.00% of 0 hires < 0.12% Auditing

0690 = 0.01% of 1 hire < 0.15% Property Disposal

0801 = 0.01% of 1 hire < 1.16% General Engineering

0810 = 0.00% of 0 hires < 0.02% Civil Engineering

0905 = 0.09% of 11 hire < 3.26% General Attorney

1035 = 0.00% of 0 hire < 0.12% Public Affairs

1101 = 0.07% of 9 hire < 1.50% General Business & Industry

1102 = 0.33% of 42 hire < 8.04% Contracting

2001 = 0.27% of 35 hire < 4.99% General Supply

2003 = 0.10% of 13 hire < 3.14% Supply Program Management

2030 = 0.00% of 0 hires < 0.07% Distribution Facilities & Storage 

Management
54 

2210 = 0.67% of 87 hire < 14.01% Information Technology Management

Note: the other seven Top MCOs not listed here had no FY22 Promotions.

Section IV: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities

Pursuant to 29 C.F.R §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement 

opportunities for employees with disabilities. Such activities might include specialized training and 

mentoring programs, career development opportunities, awards programs, promotions, and similar 

programs that address advancement. In this section, agencies should identify, and provide data on 

programs designed to ensure advancement opportunities for employees with disabilities. 

A. Advancement Program Plan 

Describe the agency’s plan to ensure Persons with Disabilities (PWDs), including Persons with Targeted 

Disabilities (PWTDs), have sufficient opportunities for advancement. 

Plans for additional programs in FY23: 

• DO continues to recommend and monitor improvements to track and advertise mentoring 

programs temporarily delayed by the COVID-19 pandemic. 

• DLA will continue to maximize the use of hiring authorities and flexibilities for individuals 

with disabilities. 

• DLA will continue to conduct outreach programs to educate and attract employees with 

disabilities to apply for positions within the agency. 

• DLA will continue to provide effective Reasonable Accommodations (RA) ensuring all 

qualified employees and applicants with disabilities are afforded benefits and privileges of 

employment equal to employees and applicants without disabilities. 

• The DLA Career Mapping Program continues to develop the DLA Career Guide, the DLA 

Career Pyramid, DLA Career Paths and DLA Career Checklists for specific job series, which 

will be available to all employees to assist them with advancement of their careers. The Career

Mapping Program will continue to publish new career field specific tools, which will assist with 

planning employee’s career development and progression. 

• Due to the COVID-19 pandemic, Special Emphasis Program Committee groups for PWDs were 

curtailed throughout FY2022. DO has not completed the Diversity, Equity, Inclusion and 

Accessibility (DEIA) charter and is on the glide path to a full committee implementation with 

stakeholder representatives from each D-Staff/J-Codes after the groundwork for virtual 

meetings becomes accessible to all stakeholders by FY2023 1st quarter. 
55 

• DLA will continue to fortify its Strategic Plan for DEIA, People and Culture and Sustainability, 

which includes all Disabled employees within the Agency. DLA’s ability to attract, develop, 

and retain a diverse, skilled, and agile workforce is vital to our continued success as the nation’s 

combat logistics support agency. The DLA People and Culture Plan aligns DLA’s mission, 

goals, and objectives with proven human capital strategies. DLA organizations enterprise wide 

owns this plan and work together to achieve a shared vision. 

• Continuous learning has been a long-standing strategy to ensure the DLA workforce has the 

skills needed to meet the Agency's ever-changing requirements. Rotational assignments focus 

on experiential development designed to expand an individual's functional, cross-functional, and 

leadership abilities through on the job learning. Rotational assignments are a key means of 

obtaining depth and breadth of knowledge, fostering greater information sharing and 

understanding of DLA's mission, collaboration, networking, gaining corporate perspective, as 

well as professional enhancement.

• Several of the DLA organizations use the Pathways to Career Excellence (PaCE) program, 

which is a two-year entry level program that includes successfully completing performancebased measures for advancement and promotion. Another two WRP participants were 

successfully induced into PaCE after having met or exceeded, satisfactory requirements in 

FY22.

B. Career Development Opportunities

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

DLA Enterprise Tuition Assistance Program: Provides financial support for continued education 

courses at the undergraduate or graduate level. Permanent, full-time civilian employees are 

eligible after their initial two-year probationary/trial period in Federal civilian service.

DLA Enterprise Leader Development Program: An Agency-wide leadership development 

program designed to build and enhance the leadership skills of DLA employees at all levels. The 

competencies include supervisory certification, coaching, mentoring, the use of leadership 

development guides, multi-source feedbacks, and behavior-based interviewing techniques. 

Defense Civilian Emerging Leader Program: A DoD cohort and competency-based leadership 

development program for entry level and emerging leaders. Permanent full-time, civilians in 

grades 7 through 12 are eligible, including Federal Wage System employees. 

DLA Enterprise Rotation Program (Cross-Organizational): Cross-organizational rotational 

assignments within DLA. (Intra-organizational rotations are also available) Rotational 

assignments were listed seeking GS-11 to GS-14 employee participation. 

Logistics for the 21st Century: A 5 1⁄2-day course designed by the Institute for Defense and 

Business to provide early-career, high-potential logisticians with a comprehensive and tailored 

educational experience. GS-11 through GS-13 early-career civilian logisticians is eligible.
56 

DoD Defense Pricing and Contracting Acquisition Exchange Program: A unique developmental 

6- to 9-month experience through rotational assignments for high caliber individuals in acquisition 

related career fields. Permanent civilian acquisition employees in grades GS 11 and above are 

eligible.

OSD Sustainment Fellowship Program: A 12-month hands-on leadership and management 

program to enhance the career development of mid-level logistics professionals. Civilian logistics 

employees in grades GS-13 and GS-14 are eligible.

In-House Coaching Program Pilot for FY19: Through in-house coaching, improve leadership 

capability across the agency. Employees who have completed ELDP Level 3 and managers are 

eligible.

DLA Executive Development Program: A program that allows managers to nominate high 

potential, highly motivated individuals to attend up to two training programs, for approval by 

DLA’s executive board. Permanent civilians in grades GS-13 through GS-15 with at least 18-

months of continuous service with DLA are eligible. 

In the table below, please provide the data for career development opportunities that require 

competition and/or supervisory recommendation/approval to participate. 

Career Development 

Opportunities

Total Participants PWD PWTD

Applicants 

(#)

Selectees 

(#)

Applicants 

(%) 

Selectees 

(%) 

Applicants 

(%) 

Selectees 

(%) 

Internship Programs 581 519 11.95% 10.67% 2.50% 2.24%

Fellowship Programs 1 1 0.00% 0.00% 0.00% 0.00%

Mentoring Programs --- --- --- --- --- ---

Coaching Programs --- --- --- --- --- ---

Training Programs 306 258 18.60% 15.69% 1.94% 1.63%

Detail Programs --- --- --- --- --- ---

Tuition Assistance Program 131 119 10.08% 9.16% 1.68% 1.53%

Other Career Development 

Programs 160 126 18.25% 14.38% 3.17% 2.50%

Total 1,179 1,023 58.89% 49.89% 9.30% 7.90%
57 

Do triggers exist for PWDs among the applicants and/or selectees for any of the career 

development programs? (The appropriate benchmarks are the relevant applicant pool for the 

applicants and the applicant pool for selectees.) If “yes,” describe the trigger(s) in the text box. 

Applicants (PWD) .....................................................................Yes

Selections (PWD)......................................................................Yes

A total of 11.95% of the 581 applicants to the Internship Programs (PaCER) were PWDs and 10.67% 

of the selectees were PWDs, which is below the permanent 15.51% PWD workforce benchmark. 

A total of 18.60% of the 306 applicants to the Training Programs were PWDs and 15.69% of the 

selectees were PWDs, which is above the permanent 15.51% PWD workforce benchmark. 

A total of 10.08% of the 131 applicants to the Tuition Assistance Program were PWDs and 9.16% of 

the selectees were PWDs, which is below the permanent 15.51% PWD workforce benchmark. 

A total of 18.25% of the 160 applicants to the Other Career Development Programs were PWDs and 

14.38% of the selectees were PWDs, which is below the permanent 15.51% PWD workforce 

benchmark. 

Do triggers exist for PWTDs among the applicants and/or selectees for any of the career 

development programs identified? (The appropriate benchmarks are the relevant applicant pool 

for applicants and the applicant pool for selectees.) If “yes,” describe the trigger(s) in the text 

box. 

Applicants (PWTD) ..................................................................Yes

Selections (PWTD) ...................................................................Yes

A total of 2.50% of the 581 applicants to the Internship Programs (PaCER) were PWTDs and 2.24% of 

the selectees were PWTDs, which is below the permanent 3.74% PWD workforce benchmark. 

A total of 1.94% of the 306 applicants to the Training Programs were PWTDs and 1.63% of the 

selectees were PWDs, which is below the permanent 3.74% PWD workforce benchmark. 

A total of 1.68% of the 131 applicants to the Tuition Assistance Program were PWTDs and 1.53% of 

the selectees were PWTDs, which is below the permanent 3.74% PWD workforce benchmark.

A total of 3.17% of the 160 applicants to the Other Career Development Programs were PWDs and 

2.50% of the selectees were PWDs, which is below the permanent 3.74% PWD workforce benchmark. 
58 

C. Awards

Using the inclusion rate as the benchmark, does your agency have a trigger involving PWDs 

and/or PWTDs for any level of the time-off awards, bonuses, or other incentives? If “yes,” 

please describe the trigger(s) in the text box. 

Awards, Bonuses, & Incentives (PWD)...........................Yes 

Awards, Bonuses, & Incentives (PWTD) .................................Yes

Time-Off Awards

1 - 10 Hours: PWDs = 14.37% < 15.41% PWTDs = 3.52% < 3.73%

11 - 20 Hours: PWDs = 15.47% < 15.41% PWTDs = 3.93% > 3.73%

21 - 30 Hours: PWDs = 18.04% > 15.41% PWTDs = 4.89% > 3.73%

31 - 40 Hours: PWDs = 16.11% > 15.41% PWTDs = 2.01% < 3.73%

41 or More Hours: PWDs = 0.00% < 15.41% PWTDs = 0.00% < 3.73%

Cash Awards

$500 and Under: PWDs = 14.40% < 15.41% PWTDs = 3.65% < 3.73%

$501 - $999: PWDs = 16.14% > 15.41% PWTDs = 4.15% > 3.73%

$1,000 - $1,999: PWDs = 15.19% < 15.41% PWTDs = 4.05% > 3.73%

$2,000 - $2,999: PWDs = 15.45% < 15.41% PWTDs = 3.46% < 3.73%

$3,000 - $3,999: PWDs = 15.21% < 15.41% PWTDs = 3.23% < 3.73%

$4,000 - $4,999: PWDs = 13.94% < 15.41% PWTDs = 2.93% < 3.73%

$5,000 or More: PWDs = 13.43% < 15.41% PWTDs = 2.24% < 3.73%

Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD 

and/or PWTD for quality step increases or performance-based pay increases? If “yes,” please 

describe the trigger(s) in the text box. 

Pay Increases (PWD) ................................................................Yes

Pay Increases (PWTD) ..............................................................Yes

Quality Step Increases (QSI) Awards

$500 and Under: PWDs = 16.33% > 15.41% PWTDs = 3.44% < 3.73%

Performance Based Pay Increase (PBPI) Awards: 

$2,000 - $2,999: PWDs = 9.09% > 15.41% PWTDs = 0.00% < 3.73%
59 

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

recognized disproportionately less than employees without disabilities? (The appropriate 

benchmark is the inclusion rate.) If “yes,” describe the employee recognition program and 

relevant data in the text box. 

Other Types of Recognition (PWD) .........................................No

Other Types of Recognition (PWTD) .......................................No

DO and HR are not aware of other employee recognition programs. 

D. Promotions 

1. Does your agency have a trigger involving PWDs among the qualified internal applicants and/or 

selectees for promotions to the senior grade levels? (The appropriate benchmarks are the 

relevant applicant pool for qualified internal applicants and the qualified applicant pool for 

selectees.) For non-GS pay plans, please use the approximate senior grade levels. If “yes,” 

describe the trigger(s) in the text box. 

SES

i. Qualified Internal Applicants (PWD) .................................No

ii. Internal Selections (PWD) ..................................................No

Grade GS-15 

i. Qualified Internal Applicants (PWD) .................................Yes

ii. Internal Selections (PWD) ..................................................Yes

Grade GS-14 

i. Qualified Internal Applicants (PWD) .................................Yes

ii. Internal Selections (PWD) ..................................................Yes

Grade GS-13 

i. Qualified Internal Applicants (PWD) .................................Yes

ii. Internal Selections (PWD) .................................................Yes

Applied Qualified Selected
60 

No 

Disability PWDs No Disability PWDs No Disability PWDs

SES 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

GS-15 11.63% 0.86% 12.98% 0.40% 0.42% 0.72%

GS-14 34.05% 3.05% 39.88% 1.74% 1.70% 3.50%

GS-13 54.32% 4.90% 47.14% 2.29% 3.24% 4.34%

Note: SES had no triggers because there were no SES promotions during FY22. In 

overall, 8.81% PWDs applied, 4.43% were qualified and 8.56% were selected, versus 

91.19% PWODs applied, 95.57% qualified and 91.44% were selected. 

2. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or 

selectees for promotions to the senior grade levels? (The appropriate benchmarks are the 

relevant applicant pool for qualified internal applicants and the qualified applicant pool for 

selectees.) For non-GS pay plans, please use the approximate senior grade levels. If “yes,” 

describe the trigger(s) in the text box. 

SES

i. Qualified Internal Applicants (PWTD) ...............................Yes

ii. Internal Selections (PWTD) ................................................Yes

Grade GS-15 

i. Qualified Internal Applicants (PWTD) ...............................Yes

ii. Internal Selections (PWTD) ................................................Yes

Grade GS-14 

i. Qualified Internal Applicants (PWTD) ...............................Yes

ii. Internal Selections (PWTD) ................................................Yes

Grade GS-13 

i. Qualified Internal Applicants (PWTD) ...............................Yes

ii. Internal Selections (PWTD) ................................................Yes

Applied Qualified Selected

No 

Disability PWTDs No Disability PWTDs No Disability PWTDs

SES 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

GS-15 11.47% 0.51% 12.76% 0.39% 7.63% 0.28%

GS-14 34.12% 1.50% 39.99% 1.67% 30.79% 0.56%

GS-13 54.42% 2.43% 47.25% 2.20% 61.58% 2.82%
61 

Note: SES had no triggers because there were no SES promotions during FY22. In 

overall, 4.4% PWTDs applied, 4.26% were qualified and 3.67% were selected, versus 

95.56% PWODs applied, 95.74% qualified and 96.33% were selected.

3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWDs among the new hires to the senior grade levels? For non-GS pay plans, please use the 

approximate senior grade levels. If “yes,” describe the trigger(s) in the text box. 

New Hires to SES (PWD) .........................................................No

New Hires to GS-15 (PWD) .....................................................Yes

New Hires to GS-14 (PWD) .....................................................Yes

New Hires to GS-13 (PWD) .....................................................Yes

0.00% of 0 SES new hires were PWD, vs 0.00% of qualified PWD applicants (note: there were no SES 

openings in FY22).

1.96% of 20 new hires to GS-15 were PWD, vs 0.94% of qualified PWD applicants.

2.45 % of 48 new hires to GS-14 were PWD, vs 1.44% of qualified PWD applicants. 

9.31% of 132 new hires to GS-13 were PWD, vs 3.62% of qualified PWD applicants. 

DLA is now receiving Applicant Flow Vacancy (AFV) Level Detail Report, and triggers were identified. DLA 

will continue to leverage the data and further investigate the triggers to identify potential barriers in the hiring 

process. The USA Staffing Office at OPM changed the former Applicant Flow Data (AFD) Detail Report and 

re-named it as the AFV during the FY22 3rd quarter. OPM created the schema, which includes a new ability to 

identify application details broken down by supervisory vacancies, gender, ethnicity, race, and additional 

disability indicators. DO will look for ways to further leverage the AFV data to better identify triggers to 

conducting barrier analyses.
62 

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWDs among the new hires to the senior grade levels? For non-GS pay plans, please use the 

approximate senior grade levels. If “yes,” describe the trigger(s) in the text box. 

New Hires to SES (PWD) .........................................................No

New Hires to GS-15 (PWD) .....................................................Yes

New Hires to GS-14 (PWD) .....................................................Yes

New Hires to GS-13 (PWD) .....................................................Yes

0.00% of 0 SES new hires were PWTD, vs 0.00% of qualified PWTD applicants (note: there were 

no SES openings in FY22).

0.49% of 20 new hires to GS-15 were PWTDs, vs 1.44% of qualified PWTD applicants. 

0.49% of 48 new hires to GS-14 were PWTDs, vs 0.62% of qualified PWTD applicants.

2.94% of 132 new hires to GS-13 were PWTDs, vs 0.56% of qualified PWTD applicants. 

5. Does your agency have a trigger involving PWD among the qualified internal applicants and/or 

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant 

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If 

“yes,” describe the trigger(s) in the text box. 

Executives

i. Qualified Internal Applicants (PWD) .................................No 

ii. Internal Selections (PWD) ..................................................No

Managers

i. Qualified Internal Applicants (PWD) .................................No

ii. Internal Selections (PWD) ..................................................No

Supervisors 

i. Qualified Internal Applicants (PWD) .................................No

ii. Internal Selections (PWD) ..................................................No
63 

DLA is now receiving AFV, and triggers were identified. DLA will continue to leverage the data and 

further investigate the triggers to identify potential barriers in the hiring process. The USA Staffing 

Office at OPM changed the former Applicant Flow Data (AFD) Detail Report and re-named it as the 

Applicant Flow Vacancy (AFV) Level Detail Report during the FY22 3rd quarter. OPM created the 

schema, which includes a new ability to identify application details broken down by supervisory 

vacancies, gender, ethnicity, race, and additional disability indicators. DO will look for ways to further 

leverage the AFV data to better identify triggers to conducting barrier analyses.

6. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or 

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant 

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If 

“yes,” describe the trigger(s) in the text box. 

Executives

i. Qualified Internal Applicants (PWTD) ...............................No

ii. Internal Selections (PWTD) ................................................No

Managers

i. Qualified Internal Applicants (PWTD) ...............................No

ii. Internal Selections (PWTD) ................................................No

Supervisors 

i. Qualified Internal Applicants (PWTD) ...............................No

ii. Internal Selections (PWTD) ................................................No

DO will work with HR to formulate a data plan to include Executives, Managers and Supervisors 

on a permanent basis. 

7. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWD among the selectees for new hires to supervisory positions? If “yes,” describe the 

trigger(s) in the text box. 

New Hires for Executives (PWD).............................................No

New Hires for Managers (PWD) ..............................................No

New Hires for Supervisors (PWD) ...........................................No
64 

DO will work with HR to formulate a data plan to include Executives, Managers and Supervisors 

on a permanent basis. DO will further investigate when the Enterprise Diversity, Equity, Inclusion 

and Accessibility (DEIA) committee becomes established in FY23.

8. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving 

PWTD among the selectees for new hires to supervisory positions? If “yes,” describe the 

trigger(s) in the text box. 

New Hires for Executives (PWTD) ..........................................No

New Hires for Managers (PWTD) ............................................No

New Hires for Supervisors (PWTD) ........................................No

DO will work with HR to formulate a data plan to include Executives, Managers and Supervisors 

on a permanent basis. DO will further investigate when the Enterprise Diversity, Equity, Inclusion 

and Accessibility (DEIA) committee becomes established in FY23.

Section V: Plan to Improve Retention of Persons with Disabilities

To be a model employer for Persons with Disabilities (PWD) and Persons with Targeted Disabilities 

(PWTD), agencies must have policies and programs in place to retain employees with disabilities. In 

this section, agencies should: (1) analyze workforce separation data to identify barriers retaining 

employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and 

(3) provide information on the reasonable accommodation program and workplace personal assistance 

services.

A. Voluntary and Involuntary Separations 

In this reporting period, did the agency convert all eligible Schedule A employees with a 

disability into the competitive service after two years of satisfactory service (5 C.F.R. § 

213.3102(u)(6)(i))? If “no,” please explain why the agency did not convert all eligible Schedule 

A employees.

No. Sixteen of 20 employees with Schedule A appointments identified as eligible for conversion 

were converted to career or career conditional appointments. The remaining four (4) employees 

were not converted due to an oversight. The actions are anticipated for the remaining force to be 

processed by the pay period projected in FY23. 
65 

Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and 

involuntary separations exceed that of persons without disabilities? If “yes,” describe the trigger 

below. 

Voluntary Separations (PWD) .................................................No

Involuntary Separations (PWD) ...............................................No

Out of the total workforce separations, 95.98% were permanent and 4.02% were temporary. 

Voluntary permanent separations under the 12% benchmark: 11.79% PWDs vs 58.03% PWODs. 

Involuntary permanent separations under the 12% benchmark: 10.09% PWDs vs 54.13% PWODs. 

Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary and 

involuntary separations exceed that of persons without targeted disabilities? If “yes,” describe 

the trigger below. 

Voluntary Separations (PWTD) ................................................No

Involuntary Separations (PWTD) .............................................No

Voluntary permanent separations under the 2% benchmark: 0.92% PWTDs vs 33.947% PWODs. 

Involuntary permanent separations under the 2% benchmark: 1.83% PWTDs vs 54.13% PWODs. 

If a trigger exists involving the separation rate of PWD and/or PWTD, please explain why they 

left the agency using exit interview results and other data sources. 

None.

B. Accessibility of Technology and Facilities

Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform applicants and 

employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), 

concerning the accessibility of agency technology, and the Architectural Barriers Act of 1968 (42 U.S.C. 

§ 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to 

inform individuals where to file complaints if other agencies are responsible for a violation. 
66 

Please provide the internet address on the agency’s public website for its notice explaining 

employees’ and applicants’ rights under Section 508 of the Rehabilitation Act, including a 

description of how to file a complaint. 

The outward facing/external DLA web page, www.dla.mil, has a link at the bottom of the page has 

a link that reads “Section 508.” This link takes visitors to the DLA Section 508 page: 

http://www.dla.mil/508.aspx. This page has resources and instructions individuals who are having 

difficulty accessing any part of the DLA website to complete the hyperlinked DoD Section 508 

Issues, Complaints and Concerns Form at https://dodcio.defense.gov/DoDSection508/Section508-Form/ which starts the current complaint process. 

Please provide the internet address on the agency’s public website for its notice explaining 

employees and applicant’s rights under the Architectural Barriers Act, including a description of 

how to file a complaint.

http://www.dla.mil/EEO/ABA/

Describe any programs, policies, or practices that the agency has undertaken, or plans on 

undertaking over the next fiscal year, designed to improve accessibility of agency facilities 

and/or technology. 

During FY2022, the DLA Enterprise IT Accessibility (J62LC) strengthened its accessibility initiatives 

in the areas of User Support, Procurement of Accessible IT, Application and Content Development, and 

Training. 

User Support

The DLA Enterprise IT Accessibility Team maintains a contract for AT support services. This contract 

provides configuration, troubleshooting and support of AT across the DLA Enterprise so that users with 

disabilities can execute their work and support the warfighter. This contract also provides the 

specialized AT knowledge that is needed to support DLA’s Reasonable Accommodation (RA) 

program. Engineers under this contract provide state-of-the-art IT recommendations to support one or 

multiple disabilities; they also provide input into DLA’s IT policy and infrastructure decisions to 

address the needs of users with disabilities in future infrastructure decisions. 

The DLA Enterprise IT Accessibility Team maintains enterprise licensing for AT software. This more 

efficient, centralized process has greatly reduced lengthy and unproductive wait times experienced by 

AT users by decreasing the time needed to obtain the software from weeks to hours and the time 

needed for installations from days to minutes. 

The DLA Enterprise IT Accessibility Team continues to support and engage with Employees with 

Disabilities by:

• Providing Tier 2 ServiceNow support; 

• Hosting a dedicated support group so that their concerns are routed to a specialized team that 

can address their issues and promptly resolve them; and

• Implementing a dedicated team mailbox providing direct support to users of AT tools, IT 

developers, and content creators.
67 

Over the next fiscal year, we plan to:

• Continue to evaluate new releases of Assistive Technology software and provide to DLA users 

as appropriate. 

Procurement of Accessible IT

DLA J7 has implemented procedures to ensure incorporation of Section 508 contract language into 

official contracting documents. 

• Since January 2022, DLA Acquisition, J72 has pulled a report every other month from Federal 

Procurement Data System – Next Generation (FPDS-NG) of all IT related contracts. From this 

report, randomly selected contracts were reviewed to ensure the following: 

o Section 508 requirements were incorporated in Performance Work Statement (PWS), 

Statement of Objective (SOO), or Statement of Work (SOW) in solicitations for ICT 

products and services, and Procurement notes H11 & L29 were incorporated in 

solicitations and awards when procuring ICT products and services. 

• Additionally, DLA J7 reviews DLA's ICT contracts in GSA's Solicitation Review Tool (SRT) 

for compliance. 

The DLA Enterprise IT Accessibility Team continues to advocate for buying and developing accessible 

IT by providing training, communications, and resources to build awareness of what is required and 

who is responsible. Helpful resources are published on the J62LC intranet site, 

https://dlamil.dps.mil/sites/J62L/SitePages/J62LC.aspx Additionally, DLA HQ Contracting Office has 

a better understanding of the legal requirements for IT accessibility, and they are updating their job aids 

to ensure management of IT accessibility throughout the procurement phases (pre-award, award, and 

post-award). 

Application and Content Development

The DLA Enterprise IT Accessibility Team continues to work with the Learning Management System 

(LMS) program to provide application compliance recommendations, accessibility implementation 

guidance and application testing with multiple Assistive Technology (AT) software tools. The DLA 

Enterprise IT Accessibility Team maintains a partnership with the J1 LMS multimedia team to 

functionally test courses, as well as provide course design guidance and spot checking of enterprisewide mandatory courses prior to their deployment. This engagement continues to reduce the number of 

courses that require alternate engagement actions for AT users. 

In coordination and collaboration with the DLA Enterprise IT Accessibility Team, the DLA Enterprise 

Test Office provides Section 508 compliance testing support for the portfolio community on an asneeded basis. The Enterprise Test Office performs manual testing with JAWS, ZoomText, and Dragon 

Naturally Speaking as well as keyboard-only testing. They also engage with the J62 portfolio 

community, stressing the importance of including Section 508 requirements in all ICT development and 

in procurement actions. 

The DLA Enterprise IT Accessibility Team uses automated software solutions to assist DLA personnel 

in testing and validating website compliance. 

In 2021, the Enterprise IT Accessibility Team completed a pilot of the automated scanning tool, axe 

Monitor, with 17 J62 applications. The team has initiated an Enterprise deployment. The project 

employs two tools, axe Monitor and axe Expert, to assess accessibility compliance.
68 

• axe Monitor: Scanning application which dynamically scans, monitors, and reports on 

accessibility defects of websites and web applications. 

o It provides a mechanical check against the Web Content Accessibility Guidelines (WCAG) 

2.0 AA standard. 

o It provides trend data on improvements or regressions and assists with root cause analysis. 

• axe Expert: Browser extension that provides fast, in-browser accessibility defect results during 

coding, allowing immediate remediation. 

DLA's public website, www.dla.mil, has been undergoing redesign with accessibility as a requirement 

for content, going page by page through the site starting in October 2021. Even though the required 

annual page reviews in prior years included criteria dedicated to Section 508 accessibility, the 

opportunity to have a temporary dedicated team examine content revealed more improperly formatted 

content than expected. Only a few sections remain before redesign is completed and all pages would 

have been reviewed for accessibility.

The redesign team addresses the following specific areas when adapting content, but also looks out for 

any other related accessibility issues:

DLA's public website, www.dla.mil, has been undergoing redesign with accessibility as a requirement 

for content, going page by page through the site starting in October 2021. Even though the required 

annual page reviews in prior years included criteria dedicated to Section 508 accessibility, the 

opportunity to have a temporary dedicated team examine content revealed more improperly formatted 

content than expected. Only a few sections remain before redesign is completed and all pages would 

have been reviewed for accessibility.

The redesign team addresses the following specific areas when adapting content, but also looks out for 

any other related accessibility issues:

• Use of and logical progression of headers on pages to subdivide content, from H1-H4. 

• Ensuring tables are not being used for layout purposes, table data is organized properly and 

logically, and row/column headers are used. 

• Images have alt text. 

• Images of text are replaced with actual text, or a text equivalent is provided. 

• Color is not the sole indicator of emphasis or action within text. 

• Favoring open-captioned videos when given the choice of video content to embed Major 

accomplishments include: 

o Redesigned hundreds of previously inaccessible tables to formats that are both more 

accessible, easier to read and navigate. 

o Developed code to clean up system-generated images associated with our news and 

biographies that weren't displaying alt text. 

o Created text-based equivalents of dozens of promotional brochures. 

The largest challenge will be when the sitewide redesign is complete and individual content managers 

begin creating and editing new content. Risks are mitigated by specifically citing what made previous 

content inaccessible, providing updated standards that further enforce accessibility, and continuing to 

provide training resources to support accessible best practices. 
69 

Training: 

The DLA Enterprise IT Accessibility Team uses various platforms to increase knowledge of 

accessibility through the DLA enterprise, to include the following: 

• Four real-time interactive accessibility webinars. 

• Providing 300 (up from 150) licenses to developers giving access to Deque University, an online accessibility learning platform; 

• Provide training courses in DLA’s Learning Management System (LMS) 

o 18 self-paced accessibility training courses; 

o Nine recorded interactive accessibility webinars; 

• Maintaining an intranet site with best practice accessibility information; 

• Publishing best-practice articles on the DLA intranet site on various accessibility topics; and 

• Maintaining 14 issue-focused knowledge-based articles (KBAs) and more when the need arises.

C. Reasonable Accommodation Program 

Pursuant to 29 C.F.R. § 1614.203(d)(3), agencies must adopt, post on their public website, and make 

available to all job applicants and employees, reasonable accommodation procedures. 

Please provide the average time frame for processing initial requests for reasonable 

accommodations during the reporting period. (Please do not include previously approved 

requests with repetitive accommodations, such as interpreting services.) 

In FY22, a total of 743 (389 in FY21, 589 in FY20) of RA requests were made and 89% (96% in 

FY21, 91% in FY20) of those completed were timely and 1 (1 in FY21, 8 in FY20) remained open to 

the following FY. 

On average during FY22, the Reasonable Accommodation (RA) process took 20 workdays (12 in 

FY21, 20 in FY20) to approve or deny a request for an RA, and 26 workdays (27 in FY21, 34 in 

FY20) from the initial request to provide the RA. 

Describe the effectiveness of the policies, procedures, or practices to implement the agency’s 

reasonable accommodation program. Some examples of an effective program include timely 

processing requests, timely providing approved accommodations, conducting training for 

managers and supervisors, and monitoring accommodation requests for trends. 

DLA has Instructions and detailed procedures for the Reasonable Accommodation Process that 

outline the process and the roles and responsibilities for all stakeholders within the process. 

During FY22, DLA processed 89% (96% in FY21, 88% in FY20) of RA requests within 45 

workdays, just below the 90% goal. This decrease in timeliness was in part due to the increase in the 

types of requests that were submitted during this timeframe (remote work, fulltime telework, 

telework for three or more days a week and reassignment). 

DLA provides interim accommodations while requestors are waiting for their final RA decision. 

This allows employees to continue to work while waiting on the RA process. 
70 

DLA employees are required to attend an on-line RA training course designed to provide awareness 

of matters affecting persons with disabilities in the workplace and DLA’s reasonable accommodation 

application process. All employees are required to renew this training every two years and 

supervisors/managers are required to take it annually. 

DLA will continue to hold the quarterly Enterprise-wide Disability Program, Special Emphasis 

Program & Affirmative Employment Program Roundtable meeting that is a forum for on-the-spot 

training, sharing best practices and trends, discussing accommodation issues, and implementing 

solutions.

D. Personal Assistance Services (PAS) Allowing Employees to Participate in the Workplace 

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required 

to provide PAS to employees who need them because of a targeted disability, unless doing so would 

impose an undue hardship on the agency. 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. 

Some examples of an effective program include timely processing requests for PAS, timely providing 

approved services, conducting training for managers and supervisors, and monitoring PAS requests for 

trends. 

PAS information is available at https://www.dla.mil/EEO/Offers/PersonalAssistanceServices/ about 

“Requesting a Personal Assistance Services” which explains the rights and procedures of the PAS 

process. The new DPM is working to update the DLA SOP 1440.01-01, RA for Individuals with 

Disabilities, which will include the PAS information.

One request was received in the past, but after further clarification and vetting with the Office of 

General Counsel, it was determined that the employee did not qualify, and the individual was 

provided a reasonable accommodation instead. To date the EEO offices have not yet received any 

PAS requests, but they are ready to provide PAS once requested. 

Section VI: EEO Complaint and Findings Data 

A. EEO Complaint data involving Harassment 

1. During the last fiscal year, did a higher percentage of Persons with Disabilities (PWD) file a 

formal EEO complaint alleging harassment, as compared to the government-wide average?

No. The percentages were lower than the Government-wide average for formal complaints of 

harassment cases at 21.98%.

DLA average for FY22: 462 PART IV, Part 2 

Mental: 8 of 127 formal complaints = 6.29% 

Physical: 7 of 127 formal complaints = 5.51%
71 

2. During the last fiscal year, did any complaints alleging harassment based on disability status 

result in a finding of discrimination or a settlement agreement?

In FY22, a total of 7 settlement agreements were entered. There were no findings of discrimination 

alleging harassment based on disability. 

3. If the agency had one or more findings of discrimination alleging harassment based on disability 

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

None. 

B. EEO Complaint Data involving Reasonable Accommodation 

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging 

failure to provide a reasonable accommodation, as compared to the government-wide average?

No. The percentages were lower than the Government-wide average - Failure to Accommodate at 

14.03%.

DLA average for FY22: 462 PART IV, Part 2 

Mental: 1 of 127 formal complaints = 0.78% 

Physical: 6 of 127 formal complaints = 4.72% 

2. During the last fiscal year, did any complaints alleging failure to provide reasonable 

accommodation result in a finding of discrimination or a settlement agreement?

In FY22, there were zero findings of discrimination, and four settlement agreements were entered. 

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

reasonable accommodation during the last fiscal year, please describe the corrective measures 

taken by the agency. 

FY22: N/A.

Section VII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a 

policy, procedure, or practice may be impeding the employment opportunities of a protected EEO group. 
72 

Has the agency identified any barriers (policies, procedures, and/or practices) that affect 

employment opportunities for Persons with Disabilities (PWDs) and Persons with Targeted 

Disabilities (PWTDs)? Yes

Has the agency established a plan to correct the barrier(s) involving PWDs and/or PWTDs? Yes

Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), 

objective(s), responsible official(s), planned activities, and, where applicable, accomplishments. 

Barrier 1

Trigger 1

1) Glass ceiling for PWTDs above the GS-12 level.

2) 3.78% of the permanent workforce has reported a targeted disability, but 3.13% of 

the employees who voluntarily separated from DLA had reported a targeted 

disability.

Barrier(s)

DLA policy documents are not accessible to all employees. DLAIs (DLA 

Instructions), DLA Regulations (DLARs), DLA Manuals (DLAMs), and DLA SOPs 

(Standard Operating Procedures) do not pass the Adobe Acrobat accessibility checker.

Objective(s) Ensure all DLA policy documents are accessible to all employees, consistent with the 

Rehabilitation act.

Responsible Official(s)

Name and Title

Performance Standards 

Address the Plan?

(Yes or No)

Aleeta Coleman, Director, DLA Transformation (DT) No

HQs D-Staff, J-Codes and MSC Issuing Authorities No

Sabrina DeWalt, Chief Policy Management & Oversight (DT) No

Dennis King, Chief Strategy Plans & Governance Division (DT-SPG) No

Michael Dingle, DLA Issuances Program Manager (DT-PMO) Yes

Dana Norton, Enterprise Organizational Alignment Program Manager (DT-SPG) Yes

Randy Davis, DLA Forms Program Manager (DT-PMO) Yes

Jodi Beard, DLA Agreements Program Manager (DT PMO) Yes

T.A. DeLaney, Director Enterprise Business Standards Office (J67B) No
73 

Name and Title

Performance Standards 

Address the Plan?

(Yes or No)

Kathryn Hammer-Wells, Division Chief (J72) Yes

Anne Burleigh, Business Process Analyst (J72) Yes

Planned Activities Toward Completion of Objective 

Target Date

(mm/dd/yyyy)

Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

12/01/2018

Identify all DLAIs, DLARs, DLAMs, Directive-type 

Memoranda (DTMs) and DLA SOPs which do not meet the 

Website Content Accessibility Guidelines (WCAG) 2.0 

guidelines, consistent with 29 USC §794d (DT)

Yes 11/9/2018

12/01/2018

Identify all DLA General Order memorandums and 

missions and functions which do not meet the WCAG 2.0 

guidelines, consistent with 29 USC §794d. (DT)

Yes 11/9/2018

12/31/2018

Alter DLAI 7750.07, Forms Management Program, to 

address 508 compliance requirements, ensuring all forms 

created/revised meet the WCAG 2.0 guidelines. (DT)

Yes 2/4/2019

02/28/2019

Alter the DLAI, DLAR, DLAM, DTM and DLA SOP 

templates to meet the WCAG 2.0 guidelines, consistent with 

29 USC §794d (DT)

Yes 1/30/2019

02/28/2019

Alter DLA Issuance procedures (DLAI 5025.01, DLAM 

5025.01, DLAI 5025.13) to address 508 compliance 

requirements, ensuring all policy and procedure documents 

signed by DT, D-Staff, J-Codes, or MSC Issuing Authorities 

meet the WCAG 2.0 guidelines. Issuances must state:

1) All policy and procedure documents 

created/revised will be 508 compliant.

2) HQs D-Staff, J-Codes and MSCs will be 

responsible for making their existing policy and 

procedure documents 508 compliant. 

3) DT created a standard issuance with Section 508 

compatible template for use to document policies 

and procedures throughout the agency.

4) DT provided the guidance, tools, and training to the 

OPR policy managers and procedural writers for 

oversight requirements for 508 compliancy. OPR 

must establish decentralized operation to ensure 

their local issuances are complying.

Yes 2/4/2019
74 

Target Date

(mm/dd/yyyy)

Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

DT will monitor and report on progress of compliance 

action plans to leadership on a quarterly basis. (DT)

02/28/2019

Ensure Enterprise Organizational Alignment procedures 

(DLAI 5010.05) address 508 compliance requirements, 

ensuring the General Order memorandums, and missions 

and functions documents signed by the DLA Vice Director 

meet the WCAG 2.0 guidelines. Issuance must state:

Current:

1) General Order memorandums and missions and 

functions are 508 compliant beginning in 2020. 

1) DT is responsible for ensuring that General Order

memorandums and missions and functions 

documents are compliant.

2) HQs D-Staff, J-Codes and MSCs and MSCs must 

provide compliant memorandums and missions and 

functions. 

Historical (year 2020 and after):

1) Historical (non-current) General Order 

memorandums signed by the DLA DV and the 

missions and functions dated 2020 and after must 

be 508 compliant.

2) HQs D-Staff, J-Codes and MSCs must provide DT

compliance memorandums and missions and 

functions. 

Yes 2/4/2019

02/28/2019

Alter DLAI 4000.19, Agreements Program, to address 508 

compliance requirements, ensuring all documents signed by 

the agency’s senior designee meet the WCAG 2.0 

guidelines. Issuance must state:

1) All agreements created or revised will be 508 

compliant.

2) HQs J and D codes and MSCs will be responsible 

for making supporting documentation 508 

compliant.

Organizational Support Agreements Managers will ensure 

their organization agreements and supporting documentation 

meet WCAG 2.0 guidelines. (DT)

Yes 01/09/2019

06/30/2019

Ensure the General Order memorandums and missions and 

functions signed by the DLA Vice Director meet the WCAG 

2.0 guidelines. (DT)

Yes 6/21/2019

06/30/2019 Address 508 compliance requirements in planned revision 

of DLAI 5105.02, Annual Operating Plan, to ensure HQs DYes 6/12/2019
75 

Target Date

(mm/dd/yyyy)

Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

Staff, J-Codes and MSC’s Dynamic Operating Plans meet 

the WCAG 2.0 guidelines. (DT)

06/01/2019

Alter Defense Logistics Management System documents to 

meet the WCAG 2.0 guidelines, consistent with 29 USC 

§794d. (J67B)

Yes 9/5/2019

6/30/2019

HQs D-Staff, J-Codes and MSCs provide compliance action 

plans to DT for:

1) Policy and procedures. 

2) General Order memorandums and Missions and 

Functions. 

Historical (non-current) General Order memorandums and 

missions and functions dating back to 2020. (DT)

Yes 12/20/2019

12/31/2019

Conduct a forms survey on active MSC-level forms for 

continued use, revision, and re-designating to DLA-level 

forms, or cancellation. (DT)

Yes 1/10/2020

04/30/2020

Supervisors add relevant planned activities to the 

performance standards of their non-supervisory Responsible 

Officials. (All)

Yes 12/31/2022 1/10/2020

4/31/2020 Alter DLA Acquisition Directive template to meet the 

WCAG 2.0 guidelines, consistent with 29 USC §794d (J72) Yes 12/31/2022 6/25/2020

12/31/2020 Conduct a forms survey on active DLA-level forms for 

continued use, revision, or cancellation. (DT) Yes 12/31/2023 

06/30/2021

HQs D-Staff, J-Codes and MSCs must provide all altered 

policy and procedure documents to DT using the 3-year 

Issuance life cycle from 2019-2021. (All)

Yes 12/31/2023 

09/30/2021

Using the normal 3-year Issuance life cycle, replace all 

inaccessible policy and procedure documents with 

documents that meet the WCAG 2.0 guidelines. (DT)

Yes 12/31/2023 

09/30/2021

Replace currently inaccessible General Orders 

memorandums and mission and function documents dating 

back to 2020 with altered documents that meet the WCAG 

2.0 guidelines. (DT)

Yes 12/31/2023 

09/30/2021 Replace historically inaccessible General Orders 

memorandums and missions and functions dating back to 

Yes 12/31/2023
76 

Target Date

(mm/dd/yyyy)

Planned Activities

Sufficient 

Staffing & 

Funding

(Yes or No)

Modified Date

(mm/dd/yyyy)

Completion 

Date

(mm/dd/yyyy)

2020 with altered documents that meet the WCAG 2.0 

guidelines. (DT)

Report of Accomplishments

Fiscal Year Accomplishments

FY18 The barrier and its root causes were identified. The templates that the MSCs, J-codes, and D-codes are 

using to draft policies do not meet the WCAG 2.0 guidelines. No administrative control existed to ensure 

that the final document meets WCAG 2.0 guidelines.

FY19 The D&I committee met repeatedly to discuss the barrier and how DLA should remove any aspects of 

policy and procedural barriers. 

Most of the planned activities for FY19 were accomplished, as documented above.

FY20 Almost all the planned activities in Part VII were completed; User Support systems were readily made 

available to provide configurations, troubleshooting and Assistive Technology support throughout the 

Enterprise. 

FY21 Continue to evaluate new releases of Assistive Technology software and provide to DLA users as 

appropriate; Implemented Section 508 procedures for MSCs; and increased Section 508 training on 

technology standards; and DLA won the SECDEF award for Accessible Communication and Technology 

in October 2021.

FY22 Worked with 508 Program Management team to continue to evaluate accessibility on all posted documents 

on both intra and external websites; The DLA Enterprise IT Accessibility Team uses various platforms to 

increase knowledge of Section 508 accessibility through the DLA enterprise.

FY23 Planned activities on all aspects of accessibility will continue in FY23 and it will be further supported once 

the Diversity, Equity, Inclusion and Accessibility (DEIA) committee becomes established. 

Please explain the factor(s) that prevented the agency from timely completing any of the planned 

activities.

During FY21, DLA completed almost all the planned activities in Part VII of the FY20 report, 

four target dates for the four of the activities were readjusted and had to be re-targeted to FY21 

due to reduced EEO staffing. In FY22, planned activities continued and delays are not anticipated 

for FY23. 
77 

For the planned activities that were completed, please describe the actual impact of those 

activities toward eliminating the barrier(s).

DLA’s upgraded policy templates allow for new policy documents to be accessible. Current 

policy documents will become accessible as they are reviewed during the normal policy review 

cycle.

If the planned activities did not correct the trigger(s) and/or barrier(s), please describe how the 

agency intends to improve the plan for the next fiscal year. 

DLA has made significant progress in making policy documents accessible, so the plan does not 

currently need improvement. DO remains in close collaboration with the DLA Section 508 office 

and continues to monitor newer developments to ensure full compliance. 
78 

Appendix 1 – Glossary

The following definitions apply to this report:

Applicant: A person who applies for employment.

Applicant Flow Data: Formerly Applicant Flow Data: Information reflecting characteristics of the pool of individuals applying for an 

employment opportunity.

Barrier: An Agency policy, principle, practice, or condition that limits or tends to limit employment opportunities for members of a 

gender, race, or ethnic background or for an individual (or individuals) based on disability status.

Blocked Pipeline: A blocked pipeline occurs when people who are in upwardly mobile occupations fail to reach the senior grade levels 

within those occupations.

Disability: For the purpose of statistics, recruitment, and targeted goals, the number of employees in the workforce who have indicated 

having a disability on an Office of Personnel Management Standard Form 256. For all other purposes, the definition contained in 29 CFR 

§ 1630.2 applies.

Civilian Labor Force (CLF): Persons 16 years of age and over, except those in the armed forces, who are employed or are unemployed and 

seeking work. The EEOC recently updated the CLF with a tabulated (2014-2018) American Community Survey as of January 3, 2022. 

Relevant Civilian Labor Force (RCLF): A specific group in the workforce by individual Job Series. 

Employees: Members of our permanent or temporary work force, whether full or part-time and whether in competitive or excepted service 

positions.

Fiscal Year: The period from October 1 of one year to September 30 of the following year.

Glass Ceiling: A glass ceiling exists when a EEO group cannot reach the executive level of leadership in an organization, despite their 

presence in positions that comprise the feeder pool for executive positions.

Glass Wall: When individuals in an EEO group cannot obtain employment in our MCOs.

Goal: Under the Rehabilitation Act, an identifiable objective set by an Agency to address or eliminate barriers to equal employment

opportunity or to address the lingering effects of past discrimination.

Mission Critical Occupations (MCO): Agency occupational series without which the agency cannot fulfill its mission. These occupations 

also tend to be the most heavily populated relative to other occupations within the agency and typically follow a career path to senior 

leadership positions. For barrier analysis in FY18 and FY19, DO is using the 29 series that reach the GS-15 and SES level.

Persons without Disabilities: Defined by EEOC to be the sum of people who reported that they did not have a disability and people who 

reported that they had a disability, but that the disability was not listed on Standard Form 256.

Reasonable Accommodation (RA): Generally, any modification or adjustment to the work environment, or to the manner or circumstances 

under which work is customarily performed, that enables an individual with a disability to perform the essential functions of a position or 

enjoy equal benefits and privileges of employment as afforded to similarly situated individuals without a disability. For a more complete 

definition, see 29 CFR § 1630.2(o). See also: EEOC's Enforcement Guidance on Reasonable Accommodation and Undue Hardship under 

the Americans with Disabilities Act, No. 915.002 (October 17, 2002).

Race or National Origin (RNO): Used to identify an applicant or employee disclosing their definition of color and/or ethnicity.

Targeted Disabilities: Disabilities that the Federal Government, as a matter of policy, has identified for special emphasis in affirmative 

action programs. They are:

1) Developmental disability

2) Traumatic brain injury

3) Deafness

4) Blindness

5) Missing extremities

6) Partial or complete paralysis

7) Partial or complete paralysis

8) Significant mobility impairment

9) Conclusive disorders

10) Intellectual disability

11) Dwarfism

12) Significant disfigurement

Technical Assistance: Training, assistance, or guidance provided by the EEOC, in writing, by telephone, or in person
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Appendix 2 – Organizational Chart
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Appendix 3 – Policy Statements

Policy Statement on Equal Employment Opportunity