Farm Credit Administration

Office of Inspector General

Inspection Report 

FCA’s Implementation Efforts for 

the 2017-2018 Fairness and 

Inclusiveness Assessment

I-20-01 

July 29, 2020
1501 Farm Credit Drive, McLean, VA 22102 703-883-4030 www.fca.gov/about/inspector-general

July 29, 2020

The Honorable Glen R. Smith, Board Chairman 

The Honorable Jeffery S. Hall, Board Member

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102-5090

 

Dear Chairman Smith and Board Member Hall:

The Office of Inspector General (OIG) completed an inspection of the Farm Credit Administration’s (FCA

or Agency) implementation efforts for the 2017-2018 Fairness and Inclusiveness Assessment

(assessment). The objective of the inspection was to analyze FCA’s implementation of diversity and 

inclusion efforts, and we limited our scope to the assessment. We did not review FCA’s agencywide 

diversity, inclusion, and equal employment opportunity program.

In July 2017, FCA’s Office of Equal Employment Opportunity and Inclusion hired a contractor to conduct 

an assessment to identify strengths and challenges of FCA’s diversity and inclusion efforts. In August 

2018, the contractor issued the final report that included 15 recommendations and 50 actions with 

steps the Agency can take to implement each recommendation. 

The OIG found that the Agency had taken preliminary steps to assess and implement recommendations 

in the contractor’s assessment. However, we identified areas for improvement in the Agency’s 

implementation and tracking of recommendations in the assessment. We made five recommendations 

to improve diversity and inclusion efforts resulting from the assessment. FCA agreed to the five 

recommendations and provided appropriate corrective actions for each recommendation.

We appreciate that FCA remains committed to encouraging diversity and inclusion in the workplace 

and understands the importance of continuous improvement. We appreciate the courtesies and 

professionalism extended by FCA to our staff during the inspection. If you have any questions about 

this inspection, we would be pleased to meet with you at your convenience. 

Respectfully,

Sonya K. Cerne 

Assistant Inspector General for Audits, Inspections, and Evaluations

cc: Wendy Laguarda, Inspector General

Thais Burlew, Director of the Office of Equal Employment Opportunity and Inclusion
EXECUTIVE SUMMARY 

FCA’s Implementation Efforts for the 2017-2018 Fairness 

and Inclusiveness Assessment

Report No. I-20-01 July 29, 2020

The Farm Credit Administration (FCA or Agency) is an independent federal 

agency responsible for regulating, examining, and supervising the Farm Credit 

System (System) and the Federal Agricultural Mortgage Corporation (Farmer 

Mac). The Agency’s mission is to ensure that System institutions and Farmer 

Mac are safe, sound, and dependable sources of credit and related services for 

all creditworthy and eligible persons in agriculture and rural America. 

FCA’s employees are its most important resource. Diversity and inclusion are 

essential to achieving an environment in which all employees can reach their 

full potential. FCA’s commitment to diversity and inclusion is established in its 

Equal Employment Opportunity and Diversity board policy statement. The 

Agency strives to create, maintain, and continuously improve on an 

organizational culture that fully recognizes, values, and supports employee 

diversity. 

To identify strengths and challenges of FCA’s diversity and inclusion efforts, 

the Office of Equal Employment Opportunity and Inclusion (EEOI) hired a 

contractor to independently conduct an assessment in July 2017. This initiative 

began under FCA’s prior Board Chairman and Chief Executive Officer (CEO). 

The project objective was to assess the inclusiveness of the FCA workplace; 

identify barriers, if any, to equal opportunity and advancement to higher ranks; 

and develop recommendations to remove barriers if any were found.

The contractor’s final report was issued in August 2018. The report was shared 

with employees in October 2018, along with a message from the former Board 

Chairman about recommendations from the assessment and the Agency’s 

focus areas. FCA designated a new Board Chairman and CEO in July 2019. The 

Agency experienced additional key leadership changes between August and 

October 2019, including the Chief Operating Officer and Chief Examiner.

The contractor’s assessment identified strengths in FCA’s diversity and 

inclusion efforts, including:

• Staff are engaged and mission-focused; 

• Employees believe diversity and inclusion are important and they 

share responsibility for it; 

• Employees feel their rating officials respect them and support their 

work/life balance needs; and

• Employees believe their rating officials foster an environment where 

diverse employees can interact effectively in the workplace.

Objective and Scope

The objective of this inspection was to analyze 

FCA’s implementation of diversity and 

inclusion efforts. Our scope was limited to 

FCA’s 2017-2018 Fairness and Inclusiveness 

Assessment. We did not review FCA’s 

agencywide diversity, inclusion, and equal 

employment opportunity program.

Recommendations

1. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

document actions, milestones and 

accountabilities to address 

recommendations in the fairness and 

inclusiveness assessment, including 

justifications for tabling or not 

implementing recommendations and 

actions. 

2. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

document a monitoring plan for updating 

information in the tracking site through 

completion or closure of each 

recommendation and associated action. 

3. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

update all employees on the status and 

current priorities of actions to address 

recommendations in the assessment.

4. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

brief current FCA leadership on the 

assessment results, implementation 

progress, priorities, and monitoring plan.

5. We recommend the Office of Equal 

Employment Opportunity and Inclusion, 

in coordination with the contracting staff, 

review the contract file for the fairness 

and inclusiveness assessment and add all

available documentation necessary to 

fully support award decisions and 

conclusions reached by the evaluation 

team. 
EXECUTIVE SUMMARY 

FCA’s Implementation Efforts for the 2017-2018 Fairness 

and Inclusiveness Assessment

Report No. I-20-01 July 29, 2020

We found FCA had taken certain preliminary steps to assess and implement 

recommendations in the contractor’s assessment. In July and August 2019, 

EEOI convened a workgroup to discuss recommendations in the report and 

areas of responsibility within the Agency. The Agency also began taking action 

to address recommendations in the assessment by conducting field office visits 

with senior officials, distributing an internal communication about Agency 

benefits, and creating videos introducing Agency leadership.

We found areas for improvement in the Agency’s implementation and tracking 

of recommendations in the assessment. The Agency had not developed 

specific action plans, milestones, and accountabilities to address 

recommendations in the contracted assessment. In March 2020, the Agency 

took a positive step and began developing a tracking site to document the 

status, accountable offices and individuals, and quarterly updates for each 

recommendation in the assessment. However, during our review, the site was 

not complete and missing key elements to track progress. We also found that 

the Agency did not follow the internal competitive contracting process for the 

assessment award. 

Improvements in documentation, communication, and accountabilities will 

help ensure the Agency realizes the full benefits of the independent 

assessment and further demonstrates its commitment to fostering diversity 

and inclusion.

Objective and Scope

The objective of this inspection was to analyze 

FCA’s implementation of diversity and 

inclusion efforts. Our scope was limited to 

FCA’s 2017-2018 Fairness and Inclusiveness 

Assessment. We did not review FCA’s 

agencywide diversity, inclusion, and equal 

employment opportunity program.

Recommendations

1. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

document actions, milestones and 

accountabilities to address 

recommendations in the fairness and 

inclusiveness assessment, including 

justifications for tabling or not 

implementing recommendations and 

actions. 

2. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

document a monitoring plan for updating 

information in the tracking site through 

completion or closure of each 

recommendation and associated action. 

3. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

update all employees on the status and 

current priorities of actions to address 

recommendations in the assessment.

4. We recommend the Office of Equal 

Employment Opportunity and Inclusion 

brief current FCA leadership on the 

assessment results, implementation 

progress, priorities, and monitoring plan.

5. We recommend the Office of Equal 

Employment Opportunity and Inclusion, 

in coordination with the contracting staff, 

review the contract file for the fairness

and inclusiveness assessment and add all

available documentation necessary to 

fully support award decisions and 

conclusions reached by the evaluation 

team. 
TABLE OF CONTENTS

Acronyms ....................................................................................................................................... 1

Background.................................................................................................................................... 1

Prior Reviews ........................................................................................................................................................... 3

INSPECTION RESULTS................................................................................................................... 4

Implementation Efforts............................................................................................................................................. 4

Plans, Timelines, and Accountabilities ........................................................................................................... 5

Tracking Site ............................................................................................................................................................ 8

Implementation Challenges................................................................................................................................. 10

Recommendations 1-4 .......................................................................................................................................... 11

Contracting Process................................................................................................................................................ 12

Recommendation 5 ................................................................................................................................................ 14

Management Comments ............................................................................................................ 15

Objective, Scope, and Methodology ......................................................................................... 19

Appendix A- Assessment Recommendations........................................................................... 20
1 

ACRONYMS AND ABBREVIATIONS

Agency or FCA Farm Credit Administration

CEO Chief Executive Officer

CLF Civilian Labor Force

EEOI Office of Equal Employment Opportunity and Inclusion

Farmer Mac Federal Agricultural Mortgage Corporation

HR Human Resources

IDP Individual Development Plan

OAS Office of Agency Services

OCPA Office of Congressional and Public Affairs

OE Office of Examination

OIG Office of Inspector General

OPM Office of Personnel Management

SEP Special Emphasis Program

System Farm Credit System

BACKGROUND

The Farm Credit Administration (FCA or Agency) is an independent federal agency responsible for 

regulating, examining, and supervising the Farm Credit System (System) and the Federal 

Agricultural Mortgage Corporation (Farmer Mac). The Agency’s mission is to ensure that System 

institutions and Farmer Mac are safe, sound, and dependable sources of credit and related services 

for all creditworthy and eligible persons in agriculture and rural America. 

Employees are FCA’s most important resource in achieving its mission. Diversity and inclusion are 

essential to achieving an environment in which all employees can reach their full potential. 

Diversity and inclusion are also essential elements of the Agency’s strategic plan. FCA’s strategic 

plan includes a goal to cultivate an environment that fosters a well-trained, motivated, and diverse 

staff while providing an effective plan for leadership success. 
2 

Diversity and inclusion goals, priorities, and actions are further defined as part of the Agency’s 

diversity and inclusion strategic plan. The plan states: 

• Goal 1 Tone at the Top: We will intensify our diversity and inclusion efforts through the 

active participation of leadership to accomplish the agency’s mission. 

• Goal 2 Workplace Inclusion and Engagement: We will strive to create and foster an 

inclusive environment that encourages employees to feel uniquely valued and experience 

a sense of belonging, engagement, and connection to the agency’s mission.

• Goal 3 Data-Driven Diversity: We will strive to create and engage a diverse, highperformance workforce, using data-driven approaches and optimizing policies, processes, 

and programs to drive inclusion and diversity efforts and accomplish the agency’s mission. 

FCA has reaffirmed its commitment to equal employment opportunity and diversity in Policy 

Statement 62, which states that all FCA employees should be treated with dignity and respect and 

FCA prohibits discrimination in its policies, program practices, and operations. In addition, the 

policy provides that employees, applicants for employment, and members of the public who seek 

to take part in FCA programs, activities, and services will be treated fairly. The FCA Board Chairman, 

who also serves as the Chief Executive Officer (CEO), is ultimately responsible for ensuring that 

FCA meets all equal employment opportunity and diversity requirements and initiatives in 

accordance with laws and regulations, to maintain a workplace that is free from discrimination 

and that values all employees. 

FCA’s Office of Equal Employment Opportunity and Inclusion (EEOI), led by the Director of EEOI,

manages and directs the Agency’s diversity, inclusion, and equal employment opportunity 

program. The EEOI Director reports directly to FCA’s Board Chairman and CEO, underscoring the 

importance and independence of the office. EEOI provides advice and leadership to Agency 

management to carry out its continuing policy and program of nondiscrimination, affirmative 

action, and diversity. EEOI also serves as the chief liaison with the Equal Employment Opportunity 

Commission and the Office of Personnel Management on all equal employment, diversity, and 

inclusion issues.

As an initiative that began under the prior Board Chairman and CEO, EEOI sponsored an 

assessment to identify strengths and challenges of FCA’s diversity and inclusion efforts. The 

Agency hired a contractor in July 2017 to independently conduct the assessment in order to 

safeguard confidentiality. The total contract value was $76,241. The project objective was to assess 

the inclusiveness of the FCA workplace; identify barriers, if any, to equal opportunity and 

advancement to higher ranks; and develop recommendations to remove barriers if any are found. 

The assessment was designed to help management understand employees’ views on:

• Work experiences and work/life balance, 

• Opportunities for career development and advancement, 

• Efforts of rating officials and senior leadership to promote a fair and inclusive work 

environment, and 

• Overall effectiveness of creating a fair and inclusive work environment.
3 

The contractor was responsible for conducting a survey, reviewing FCA documents and data, 

interviewing leadership and external stakeholders,

1 conducting focus groups, and preparing a 

report with recommendations. The survey was designed to provide more in-depth insight on 

equal employment at FCA, beyond what is included in the Federal Employee Viewpoint Survey.

The report noted that FCA had ranked 3 out of 28 small agencies on the 2017 Best Places to Work 

Index based on the Federal Employee Viewpoint Survey. The survey included about 90 questions 

in 8 different areas. Of the 286 employees invited to take the survey, 245 completed the survey

(about 86%). FCA employees responded to the survey in November 2017.

The contractor issued its final report on August 29, 2018. The report identified FCA’s commitment 

to diversity and inclusion and its intent to be a model employer with a workforce that reflects the 

diversity of the Nation. The report included 15 recommendations with 50 actions to enhance the 

Agency’s diversity and inclusion efforts (see Appendix A for a listing of all recommendations and 

associated actions). The final report was shared with all employees in October 2018, along with 

the Agency’s initial plans for implementing recommendations. 

Prior Reviews

In February 2016, the Office of Inspector General (OIG) completed an audit of human capital 

planning at FCA that contained areas related to the inspection objective. The objectives of this 

audit were to assess the adequacy of the Agency’s human capital planning and the effectiveness 

of its implementation. The report made 11 recommendations, with the following five 

recommendations pertaining to FCA’s workplace diversity and inclusion: 

• Consider a veterans’ representative for Agency veteran efforts; 

• Provide training to all personnel involved in the recruiting and hiring process on potential 

biases and barriers to employment; 

• Conduct an assessment of FCA hiring practices to identify potential barriers and areas of 

improvement; 

• Establish a policy that includes the plan for requesting and analyzing applicant flow data 

for FCA job announcements; and

• Conduct a survey, or use other information-gathering tools, to gather additional targeted 

information on workplace diversity and inclusion.

All recommendations in the report were closed by September 2016. 

 

1 External stakeholders included five individuals at historically black colleges and universities with 

AgBusiness concentrations and professionals of color with AgBusiness degrees to assess FCA’s reputation 

within the diverse talent marketplace.
4 

INSPECTION RESULTS

The objective of this inspection was to analyze FCA’s implementation of diversity and inclusion 

efforts. We limited our scope to FCA’s 2017-2018 Fairness and Inclusiveness Assessment 

(assessment). We did not review FCA’s agencywide diversity, inclusion, and equal employment 

opportunity program. 

We found that FCA had taken initial positive steps to communicate the results of the assessment 

and distribute the final report and recommendations to all employees. The report was shared with 

employees in October 2018 along with a message from FCA’s then Board Chairman and CEO

explaining which recommendations the Agency would prioritize from the assessment. The 

contractor’s report also identified strengths at FCA, including:

• Staff are engaged and mission-focused; 

• Employees believe diversity and inclusion are important and they share responsibility for 

it; 

• Employees feel their rating officials respect them and support their work/life balance 

needs; and

• Employees believe their rating officials foster an environment where diverse employees 

can interact effectively in the workplace.

The Agency had taken certain preliminary steps to assess and implement recommendations in the 

contractor’s assessment. Specifically, in July and August 2019, EEOI convened a workgroup to 

discuss recommendations in the report and areas of responsibility within the Agency. During the 

same timeframe, in July 2019, the President designated a new Board Chairman and CEO and the 

Agency experienced additional leadership changes in the following months. The Agency began 

implementing certain actions in response to the assessment, including conducting field office 

visits by senior officials, distributing an internal communication about Agency benefits, and 

creating videos introducing Agency leadership. 

We found areas for improvement in the Agency’s implementation and tracking of 

recommendations in the assessment. Although it took a positive step and began developing a 

tracking site, the Agency had not developed specific action plans, milestones, and accountabilities

to address recommendations in the assessment. In addition, the award for the assessment did not 

follow the Agency’s competitive procurement process, and the contract file was incomplete. 

Improvements in documentation, communication, and accountabilities will help ensure the 

Agency realizes the full benefits of the independent assessment and further demonstrate its 

commitment to fostering diversity and inclusion. 

Implementation Efforts

The Agency could improve its implementation efforts related to the assessment. EEOI led the 

initiative to conduct a fairness and inclusiveness assessment at FCA. In August 2018 the contractor 

issued its final report including 15 recommendations and 50 actions with steps the Agency can 
5 

take to implement each recommendation.

2 The assessment was designed to identify strengths 

and challenges of diversity and inclusion efforts at FCA. The assessment stated:

“Recommendations that result from this study will be used as input to a process 

that will determine FCA’s path of action. At the end of that process, FCA will have 

articulated specific plans, timelines, and accountabilities to help us better achieve 

FCA’s commitment to diversity and inclusion- including our intent to build and 

maintain a workforce that reflects the rich diversity of individual differences evident 

throughout this Nation. These efforts are grounded in FCA’s leadership’s conviction 

that when individual differences are respected, recognized, and valued, diversity 

becomes a powerful force that can contribute to achieving superior results.” 

In October 2018, the contractor’s final assessment report was shared agencywide along with a 

message from FCA’s then Board Chairman and CEO on initial plans for implementation. The 

Agency’s internal communication with employees stated that it would evaluate each 

recommendation in the assessment and immediately focus on the following recommendations:

• Help bridge the generational gaps that can sometimes present a barrier to having a culture 

of inclusion and continuous improvement, 

• Find ways to better inform employees about the work/life programs available to them, 

• Address and identify hiring barriers, 

• Build on the relationships we have established with diverse universities and professional 

groups, 

• Develop more opportunities for leadership and staff to build relationships, 

• Continue coordination between EEOI and Human Resources to better achieve goals, and

• Distinguish between preferences and requirements in job postings. 

Plans, Timelines, and Accountabilities

During our review, we found that the Agency had not put in place specific plans, timelines, and 

accountabilities to address recommendations from the assessment. A working group was formed 

with members of EEOI, the Office of Agency Services (OAS), the Office of Examination (OE), and 

the Office of Congressional and Public Affairs (OCPA) to discuss each recommendation in the 

assessment. The working group met twice, in July and August of 2019, about a year after the final 

report was issued. EEOI prepared notes from the meetings about each recommendation and how 

it would be addressed. The EEOI Director stated that there were several discussions with senior 

officials about the assessment before the working group was established; however, notes from 

the working group meetings were the Agency’s only documented plan to address

recommendations in the assessment. 

The notes included responsible offices and short descriptions of planned actions, tabled items, 

and areas that had already been addressed by the Agency. However, the working group’s notes 

did not provide a comprehensive plan with milestones, documented follow-up, descriptions of 

2 See Appendix A for a listing of report recommendations and associated actions.
6 

the Agency’s evaluation of each recommendation, or a schedule to monitor implementation 

progress. Specifically, the notes were vague and indicated planned actions for 21 of the 50 

associated actions in the report. The following are examples of the working group notes that 

lacked detailed actions: 

Report Recommendation Working group notes

“Conduct job analysis to determine whether 

criteria are requirements or preferences. 

Assess whether each criterion is so nonnegotiable that FCA/OE would be willing to 

bypass a superstar who doesn’t meet that 

criterion. If not, the criterion is a preference...”

“Expand on what OAS already does and 

communicate to staff.”

“Implement Individual Development Plans 

(IDPs) agencywide. Provide detailed guidance 

on IDP implementation, focused on open and 

honest feedback, resources, actions to 

improve performance, and consistent 

implementation across team members.”

“OAS”

“Update SEP goals and charters to include a 

strategic mission enabler; reflect the inclusion 

of activities that advance the FCA mission and 

staff development needs to achieve the 

mission (e.g., SEPs should identify actions and 

activities to close gaps and execute 

recommendations outlined in this report)...”

“Share information”

“Recruit internally and encourage applicants 

to apply for promotions; strive to have a 

diverse slate of candidates that reflect the 

civilian labor force (CLF) and federal civilian 

workforce.”

“OAS working on policy succession planning.

Creating stand-alone Human Capital Plan. 

Communicate to staff there is no retirement 

wave.” 

Of the 50 actions in the assessment report, the Agency noted it would “table” 22 to evaluate at a 

later date. In general, the working group’s notes stated “table,” and did not explain why the 

recommendation was tabled or the date that the Agency would reevaluate the recommendation. 

Two complete recommendations (with 10 associated actions) were tabled, including: 

• Hold all FCA employees accountable for diversity and inclusion,

3 and 

• Identify Historically Black Colleges and Universities, Hispanic Serving Institutions, American 

Indian Higher Education Consortium institutions and diverse professional groups that 

FCA/OE will commit to building long-term relationships with, and develop a plan to 

achieve a high yield of applicants. 

3 FCA includes a performance standard on diversity and inclusion for employees so that they are evaluated 

in this area as part of overall job performance.
7 

The following actions were also tabled without an explanation of the Agency’s justification: 

• Increase transparency in senior leadership decision-making such as communicating the 

ways in which employee input was considered, the “why” behind the decision, and sharing 

weekly meetings notes (as appropriate); communicate priority decisions via face-to-face 

methods in addition to written communications.

• Provide sample follow-up, trigger questions for Board and leadership to ask when 

discussing decisions with Directors and below.

• Develop an “assessing decisions with a diversity and inclusion lens” tool for the Board, 

leaders, managers, and supervisors to apply during decision-making.

• Set expectation that leaders, managers, and supervisors take risks on younger employees 

when delegating tasks, identify and develop emerging leaders, and focus on 

communicating institutional knowledge; hold leadership, managers, and supervisors 

accountable.

• Hold supervisor roundtables, by managerial level, to share diversity and inclusion best 

practices and solve diversity and inclusion challenges.

• Provide coaches for Board and leadership focused on creating and leading diverse and 

inclusive environments.

• Provide coaches for managers struggling to create and manage diverse teams and 

inclusive environments.

• Including recognition for individuals who stepped in to cover people on special 

assignments.

• Ensuring principles of diversity and inclusion are integrated into award and recognition 

(e.g., someone cannot be recognized as a best performer, if he/she has demonstrated antidiversity and inclusion behaviors).

• Conduct diversity dialogues with mix of race, gender, level, etc. staff to discuss past and 

current harms experienced, diversity and inclusion myths and misconceptions, capacity for 

forgiveness, and what amelioration and moving forward looks like.

• Ensure that OE’s decision criteria – formal and informal – are bias-free and are used in a 

consistent manner, to give women and people of color their fair share of high-visibility 

opportunities.

• Try “Five Cups of Coffee” in which a Board member or leader schedules coffee with small 

groups of staff.

For the remaining seven actions in the assessment report, the working group noted no action 

would be taken or that the recommended action was being addressed, with little or no 

explanation. The following table shows the working group notes for these seven items: 

Action Working Group Notes

“Require all surveys and data collection to 

disaggregate results by race and gender 

demographics (at a minimum). To protect 

survey participants anonymity, don’t compute 

or report results for any subgroup with fewer 

than 10 members. Review and develop 

“Already doing”
8 

targeted strategies to close gaps or 

inequities.”

“Create regular touchpoints between OE and 

OAS and EEOI to develop and implement 

OE’s human capital processes. For example, 

include OAS or EEOI staff on panels that 

conduct interviews and make hiring and 

promotion decisions. Involve OAS/EEOI in 

data tracking and review, for example, to 

increase accountability and transparency 

regarding career development and 

advancement opportunities across 

demographic differences.”

“Already doing. Share information. 

Incorporate OAS more into SEP activities.” 

Increase transparency, communication, 

roles/responsibilities, and accountability 

related to the agency’s diversity and inclusion 

goals.

“Already doing. Share information. 

Incorporate OAS more into SEP activities.” 

“Develop a FCA-specific definition of diversity 

and inclusion and include in all key FCA 

documents (e.g., Human Capital Plan, 

Strategic Plan, Diversity and Inclusion Plan), 

FCA website (EEO and Diversity tab), and 

applicable policies.”

“Following OPM EEO Directives”

“Separate EEO and Diversity into separate 

tabs on FCA’s website.”

“Following OPM EEO Directives”

“Create separate sections for EEO and 

diversity and inclusion in all key documents 

and when communicating to staff; add final 

to communications plan (see 

recommendation #1).”

“Following OPM EEO Directives”

“Update language in documents to clarify 

when FCA means specifically race and gender 

diversity.”

“Following OPM EEO Directives”

Tracking Site 

Recent efforts by the Agency are a step in the right direction, but improvements are needed to 

increase the effectiveness of the site to document and track implementation efforts. During our

inspection, the Agency began developing an internal site to track and document the Agency’s 

implementation of recommendations from the assessment. The site, developed in March 2020,

includes fields for:

• Start date,

• Status,
9 

• Completed date,

• Division/individual assigned,

• Quarterly updates, and

• Priority. 

As of May 2020, the site listed a January 2020 start date for implementing recommendations. In 

addition, the status of all recommendations was noted as “in process,” “tabled,” or “not started,” 

with no recommendations noted as complete. The site documented the assigned program office 

for most items; however, the site only listed a responsible individual for eight actions. Quarterly 

updates were documented for ten actions, and seven of these updates were the notes from the 

working group meetings in July and August 2019. The following table shows the status of items 

in the tracking site by program office: 

Program Office Assigned In Process Not Started Other

EEOI 3 7

OAS 2 2

OE 5

OCPA 1

OAS and OE 3

EEOI and OCPA 1

OCPA and OAS 1

EEOI and OAS 4

No Division listed - Not Started 4

No Division listed - Tabled 17

Total 19 10 21

For the 50 actions in the newly developed tracking site, 3 were rated “high” priority, 17 were rated 

“low” priority and the rest were rated “normal” priority. In general, tabled items were deemed low 

priority. However, priorities assigned in the tracking site did not align with what had been 

communicated to employees. For example, the Agency’s only communication with employees

about plans to address the assessment said two of the recommendations it would focus on 

immediately were to bridge generational gaps and distinguish between preferences and 

requirements in job postings. However, neither of these recommendations were identified as high 

priority in the tracking site. The recommendation to establish a generations SEP was assigned a 

low priority and had not been started. The recommendation to distinguish between preferences 

and requirements had three associated actions. Two were deemed normal priority and had not 

been started, and one was tabled and deemed low priority. 

The tracking site provided a centralized location to document progress; however, key elements 

were missing. The site listed recommendations and associated actions, but it did not include 

specific actions the Agency planned to take. For example, the site included the following action

from the final assessment and ranked it as a “high” priority: “Increase Board and senior leadership 

interaction with staff (e.g., Town Halls, reverse mentoring, matrix mentoring, regular trips to field 

locations).” There was no description of specific steps the Agency planned to take to address this 
10

item. The tracking site included a first quarter update which stated that field office visits were 

conducted and that OCPA has been publishing videos introducing FCA leadership. Along with 

planned action steps and missing information about responsible personnel, there were no target 

completion dates to track Agency progress.

Implementation Challenges

Several factors contributed to implementation challenges. First, the Agency waited almost a year 

to establish a working group to address recommendations in the assessment. Although the final 

assessment was completed in August 2018, the working group did not meet until July 2019. The 

EEOI Director stated that there were several discussions with senior officials about the Agency’s 

response to the assessment; however, notes from the two working group meetings were the first 

and only documented steps for addressing recommendations in the assessment. After the 

working group’s last meeting in August 2019, no additional meetings or follow-up were scheduled 

to discuss or document the status of the Agency’s implementation efforts. The tracking site was 

not developed until March 2020, 19 months after the final report was issued and after the start of 

this review. 

A lack of centralized accountability was another factor that contributed to implementation 

challenges. Recommendations in the assessment involved multiple program offices and 

individuals across the Agency, including OAS, OE, OCPA, and most importantly EEOI. With so many 

different offices and individuals involved, the Agency needs a more centralized project manager

role to ensure plans and actions are tracked, communicated, and implemented in a manner 

consistent with the message to employees and FCA diversity goals. 

Finally, another challenge to implementing the assessment recommendations has been significant 

leadership changes experienced by the Agency after the completion of the assessment. Since the 

final report was issued in August 2018, new individuals were appointed to the following key 

leadership positions: 

• Chairman of the Board and CEO in July 2019,

• Chief Operating Officer in August 2019, and 

• Chief Examiner in October 2019. 

Changes in leadership can change focus areas and priorities, further supporting the need to 

document specific plans, follow-up with centralized accountability, and communicate with 

employees. 

Complete documentation provides a record of the Agency’s response to the assessment. Without 

documented plans, milestones, and accountabilities it is difficult to determine the status of 

implementation efforts and when planned actions will be completed. Furthermore, clear action 

steps and milestones ensure the Agency is committed to completing recommendations in the 

assessment. Specific, detailed follow-up and implementation is especially important given FCA’s 

significant investment to identify areas to strengthen diversity and inclusion efforts. A delayed 

response can create the perception that the assessment was not a priority or current focus for the 
11

Agency. Employee input through a survey and focus groups was a key component of the 

assessment. Therefore, it is even more important that employees know their input was fully 

considered and changes were implemented as a result of findings and recommendations in the 

assessment. Delayed action and limited communication may also discourage employees from 

participating in future assessment efforts and providing open and honest feedback. 

Recommendations 1-4

To improve diversity and inclusion efforts resulting from the assessment:

1. We recommend the Office of Equal Employment Opportunity and Inclusion document 

actions, milestones, and accountabilities to address recommendations in the fairness and 

inclusiveness assessment, including justifications for tabling or not implementing 

recommendations and actions. 

2. We recommend the Office of Equal Employment Opportunity and Inclusion document a 

monitoring plan for updating information in the tracking site through completion or 

closure of each recommendation and associated action. 

3. We recommend the Office of Equal Employment Opportunity and Inclusion update all 

employees on the status and current priorities of actions to address recommendations in 

the assessment. 

4. We recommend the Office of Equal Employment Opportunity and Inclusion brief current 

FCA leadership on the assessment results, implementation progress, priorities, and 

monitoring plan.

FCA Response

The Agency agreed with the recommendations (see additional responses in the Management 

Comments section of this report). EEOI stated the tracking site will be implemented with 

documented actions, milestones, and accountable offices. EEOI will document the rationale when 

it decides not to move forward with a recommendation, based on business judgment, and all 

remaining recommendations will be tracked through completion. EEOI stated a monitoring plan

would be developed to specifically address how information will be updated in the tracking site 

for each recommendation and associated action. Estimated completion dates for the tracking site 

and monitoring plan were noted as August 31, 2020.

Within 30 days of implementing the tracking site, EEOI plans to communicate with staff and brief 

the FCA Chairman. EEOI stated that employees will be updated through the Agency’s internal 

newsletter and the Chairman will receive an overview of assessment results, implementation 

progress, priorities, and the monitoring plan.

OIG Response

The OIG finds the planned actions responsive to our recommendations.
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Contracting Process

During our review, we found that the Agency did not follow internal procedures and the contract 

file was missing necessary information. To safeguard confidentiality and utilize diversity specialists, 

FCA hired a contractor to conduct its assessment. The award was classified as competitive and 

totaled $76,241. As a non-appropriated fund agency, FCA is not subject to certain 

governmentwide procurement requirements. FCA’s procurement policy is established through the 

Policies and Procedures Manual 812, Contracting/Procurement Policy and acquisition procedures 

in OAS Directive 4, Contracts Desk Manual. The Contracts Desk Manual describes FCA’s 

competitive procurement process, which includes acquisition planning, source identification, and 

competition. 

Acquisition 

Planning

• Market 

research

• Statement of 

work

• Requisition

Source 

Identification

• Optional 

Federal 

Supply 

Schedules

• Commercial 

sources

Competition

• Request for 

quotes

• Source 

selection

 

Acquisition planning includes working with procurement personnel to develop a comprehensive 

plan and requirements package. The statement of work is part of this package and describes the 

project objective, required services, deliverables, and period of performance. The Contracts Desk 

Manual states that a statement of work and issuance of a formal request for quotes is deemed 

advisable for most situations involving consulting, advisory, and assistance services contracts, to 

ensure that project requirements and Agency expectations are conveyed in a clear, unequivocal 

manner. Evaluations performed for competitive procurements must be documented to support 

the conclusions reached by the evaluating team and show the differences between proposals and 

the judgment that led to the selection decision.

In reviewing the award for FCA’s assessment, we found:

• Requirements were established after a contractor was selected. The EEOI Director notified 

procurement that a vendor was selected to initiate a contract in May 2017. In June 2017, 

procurement provided EEOI with a statement of work, vendor evaluation forms, and price 

comparison research. Pricing research was not included in the contract file and did not 

include the type of assessment services being procured by the Agency. The statement of 

work in the contract file was prepared by procurement and included required services and 

deliverables from the selected vendor’s proposal. The statement of work did not include 

selection factors or the basis for the Agency’s award decision. The requisition for the 
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contractor was dated July 5, 2017, and the award was signed by the Contracting Officer on 

July 6, 2017. 

• Vendor evaluation forms were created and completed after a contractor was selected in 

May 2017. Three evaluation forms were included in the contract file and were dated June 

14, 2017. Evaluation forms were completed by the EEOI Director, not other members of 

the evaluation team. 

• A request for quotes was not issued for the award. EEOI identified vendors and contacted

them directly. Because a request for quotes and requirements package were not issued, 

proposals were based on discussions with EEOI. As an example, correspondence in the 

contract file stated “I like to think of this as a continuation of our earlier conversation- not 

as a final offer or line in the sand. So if there’s anything that can help make this work better 

for you- more information or any changes, please don’t hesitate to reach out.” EEOI 

received four proposals between October 2016 and April 2017. 

• Documentation in the contract file did not fully support procurement decisions. A 

memorandum to file in the contract file stated that the selected contractor’s proposal was

the most comprehensive and included use of a survey, focus groups, and individual 

interviews, along with policy review. Vendor evaluations did not fully explain differences 

between proposals and comparisons that led to the selection decision. The three 

evaluation forms in the contract file rated vendors in four areas related to past experience 

as well as price. Rankings included: outstanding, excellent, average, or unacceptable 

without supporting information. In addition, the vendor with the lowest price was rated 

“unacceptable” for price without an explanation. 

• Although four proposals were received by EEOI, only three were included in the contract 

file. In addition, the EEOI Director provided correspondence showing that the selected 

vendor modified its initial proposal to “get to FCA’s budget.” Documentation related to 

this negotiation, including the original proposal, was not included in the contract file. 

Procurement personnel stated that the award did not follow the normal competitive process 

because there was an urgency to complete the award. The EEOI Director stated instructions were 

followed from procurement officials who are no longer with the Agency and that requirements 

for the contract were not posted by procurement because it was not required and less efficient. 

Although FCA has additional flexibilities as a non-appropriated Agency, a requirements package

and request for quotes ensure awards are fair and the best value for the Agency. This is especially 

important for higher value contracts with multiple vendor options. Not following the competitive 

contracting process and documenting conclusions can bring into question award decisions and 

raise overall concerns with vendor selection, which can create liabilities for the Agency. 

The assessment award period of performance ended in September 2018. However, it is important 

for the contract file to include all records to support Agency decision-making and procurement 

actions. As of May 2020, the contracting specialist and two contracting officers involved in the 
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award for the assessment had left the Agency. Because of procurement personnel turnover and 

EEOI’s role in identifying sources, discussing proposals, and negotiating with vendors, EEOI can

provide documentation to complete the contract file. 

Recommendation 5

To ensure complete records are maintained: 

5. We recommend the Office of Equal Employment Opportunity and Inclusion, in 

coordination with contracting staff, review the contract file for the fairness and 

inclusiveness assessment and add all available documentation necessary to fully support 

award decisions and conclusions reached by the evaluation team. 

FCA Response

The Agency agreed with the recommendation (see additional responses in the Management 

Comments section of this report). EEOI will work with procurement staff to determine what is 

missing from the contract file and provide responsive documentation. EEOI estimated completion 

of the contract file by September 30, 2020. 

OIG Response

The OIG finds the planned actions responsive to our recommendation.
15

MANAGEMENT COMMENTS
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OBJECTIVE, SCOPE, AND METHODOLOGY

The objective of this inspection was to analyze FCA’s implementation of diversity and inclusion 

efforts. We conducted the inspection at FCA’s headquarters in McLean, VA from January-July 2020. 

The scope of this inspection was limited to FCA’s 2017-2018 Fairness and Inclusiveness 

Assessment. 

We took the following steps to accomplish the objective:

• Identified and reviewed applicable regulations, policies, and procedures related to the 

objective. 

• Reviewed prior reviews related to the inspection objective.

• Interviewed the Director of EEOI and personnel from OAS and OE with significant 

responsibilities related to implementation efforts associated with FCA’s fairness and 

inclusiveness assessment. 

• Requested and reviewed plans, timelines, supporting documentation, and tracking 

documentation related to the assessment. 

• Analyzed information in the tracking site, including start dates, status documentation, 

responsible officials, and priorities. 

• Reviewed the contract file for the assessment, including requirements, evaluation, and 

selection documentation.

This inspection was performed in accordance with the Council of the Inspectors General on 

Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. These standards require 

that we plan and perform the inspection to obtain sufficient, competent, and relevant evidence 

that supports a reasonable basis for our findings, conclusions, and recommendations. We 

assessed internal controls and compliance with laws and regulations to the extent necessary to 

satisfy the objective. Because our review was limited, it would not necessarily have disclosed all 

internal control deficiencies that may have existed at the time of our inspection. We assessed the 

information and data collected during the inspection and determined it was sufficiently reliable 

and valid for use in meeting the inspection objective. We assessed the risk of fraud related to our 

inspection objective while evaluating evidence. Overall, we believe the evidence obtained is 

sufficient to provide a reasonable basis for our findings and conclusions based on the inspection 

objective.
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APPENDIX A- ASSESSMENT RECOMMENDATIONS

FCA’s 2017-2018 Fairness and Inclusiveness Assessment included the following recommendations:

1. Develop a communications plan including:

• Continue to celebrate and highlight FCA’s ranking as a best place to work, 

highlighting all programs and resources that support employees and how to access 

and use them.

• Communicate findings and recommendations from all studies, including this one.

• Increase Board and senior leadership interaction with staff (e.g. Town Halls, reverse 

mentoring, matrix mentoring, regular trips to field office locations).

• Increase transparency in senior leadership decision-making such as 

communicating the ways in which employee input was considered, the “why” 

behind the decision, and sharing weekly meeting notes (as appropriate); 

communicate priority decisions via face-to-face methods in addition to written 

communications.

• Provide sample follow-up, trigger questions for Board and leadership to ask when 

discussing decisions with Directors and below.

• Develop an “assessing decisions with a diversity and inclusion lens” tool for the 

Board, leaders, managers, and supervisors to apply during decision-making.

2. Further define diversity and inclusion expectations such as:

• Require all surveys and data collection to disaggregate results by race and gender 

demographics (at a minimum). To protect survey participants’ anonymity, don’t 

compute or report results for any subgroup with fewer than 10 members. Review 

and develop targeted strategies to close gaps or inequities.

• Set expectation that leaders, managers, and supervisors take risks on younger 

employees when delegating tasks, identify and develop emerging leaders, and 

focus on communicating institutional knowledge; hold leadership, managers, and 

supervisors accountable.

• Create a task force to review and develop recommendations to ensure FCA’s 

performance management system, performance goals, technology, resources, and 

job descriptions support the goal of work/life balance along with mission success. 

This task force should include representatives from leadership and from each 

Special Emphasis Program (SEP), so that leadership and SEPs are working in 

partnership to update performance management at the agency.

3. Build capacity to value diversity and demonstrate inclusive behaviors, such as:

• Hold supervisor roundtables, by managerial level, to share diversity and inclusion

best practices and solve diversity and inclusion challenges.

• Provide coaches for Board and leadership focused on creating and leading diverse 

and inclusive environments.
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• Provide coaches for managers struggling to create and manage diverse teams and 

inclusive environments.

• Train Examiners-in-Charge/managers on having difficult conversations, giving 

feedback, building relationships across difference, unconscious bias, and subtle 

behaviors of exclusion.

• Identify opportunities for cross-training, rotational assignments, and/or collateral 

assignments.

• Establish mentoring for people new to management roles.

4. Establish a Generations Special Emphasis Program to:

• Help bridge the generation gap; create connections

• Support institutional knowledge transfer

• Develop any knowledge, skill, and ability deficiencies that are perceived to be 

hinderances to younger generations getting opportunities.

5. Enhance reward and recognition program, such as:

• Including recognition for individuals who stepped in to cover people on special 

assignments.

• Ensuring principles of diversity and inclusion are integrated into award and 

recognition (e.g. someone cannot be recognized as a best performer, if he/she has 

demonstrated anti-diversity and inclusion behaviors).

6. Acknowledge and address historical challenges with diversity at FCA

• Conduct diversity dialogues with mix of race, gender, level, etc. staff to discuss past 

and current harms experienced, diversity and inclusion myths and misconceptions, 

capacity for forgiveness, and what amelioration and moving forward looks like.

• Develop Frequently Asked Questions about diversity and inclusion, addressing the 

myths and misconceptions and add final to communications plan (see 

recommendation #1)

7. Hold all FCA employees accountable for diversity and inclusion.

• Get an answer to “what will happen when a star performer behaves in a way that 

violates diversity or inclusion principles?” from Board and senior leadership.

• Review, update (as necessary based on answer to question above), and

communicate disciplinary procedures to address individuals who display antidiversity and inclusion behaviors. Invite the EEO Director to review procedures with 

input from SEP managers. Add final to communications plan (see recommendation 

#1).

• Create list of specific diversity and inclusion behaviors and actions (e.g., providing 

instant, open and honest feedback) and conduct a 360 assessment for leaders and 

managers; hold leaders and managers accountable for developing an action plan 

to address any performance gaps.

• Diversity dialogues and facilitation services for the purpose of helping work groups 

have open, even if uncomfortable, conversations about diversity and inclusion.
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• Increase weight of diversity and inclusion metric in performance evaluations; set

clear expectations for this factor that go beyond simply attending SEP events.

8. Clarify and communicate definitions of EEO, Affirmative Action, and diversity and inclusion.

• Develop a FCA-specific definition of diversity and inclusion and include in all key 

FCA documents (e.g., Human Capital Plan, Strategic Plan, Diversity and Inclusion 

Plan), FCA website (EEO and Diversity tab), and applicable policies.

• Separate EEO and Diversity into separate tabs on FCA’s website.

• Create separate sections for EEO and diversity and inclusion in all key documents 

and when communicating to staff; add final to communications plan (see 

recommendation #1)

• Update language in documents to clarify when FCA means specifically race and 

gender diversity.

9. Distinguish between preferences versus requirements.

• Conduct job analysis to determine whether criteria are requirements or 

preferences. Assess whether each criterion is so non-negotiable that FCA/OE would 

be willing to bypass a superstar who doesn’t meet that criterion. If not, the criterion 

is a preference. For example, if an undergraduate degree in accounting or finance 

is currently required, is this requirement supported by job analysis as essential? Are 

any other majors closely-related enough to serve as substitutes? What about 

candidates who have advanced degrees- such as a Master of Business 

Administration- would their undergraduate majors still be important? Clarify, 

codify, and standardize selection criteria.

• Ensure that OE’s decision criteria- formal and informal- are bias free and are used 

in a consistent manner, to give women and people of color their fair share of highvisibility opportunities. 

• Implement Individual Development Plans (IDPs) agencywide. Provide detailed 

guidance on IDP implementation, focused on open and honest feedback, 

resources, actions to improve performance, and consistent implementation across 

team members.

10. Identify Historically Black Colleges and Universities (HBCUs), Hispanic Serving Institutions 

(HSIs), American Indian Higher Education Consortium (AIHECs) institutions and diverse 

professional groups that FCA/OE will commit to building long-term relationships with, and 

develop plan to achieve a high yield of applicants, including: 

• Develop relationships with career counselors, Deans, and professors to build a 

pipeline of entry-level candidates; communicate FCA/OE’s ideal candidate profile 

so that they can begin recruiting on the organization’s behalf.

• Consider selecting a few HBCUs, HSIs, and/or AIHECs with which to develop 

substantial partnerships that include developing FCA/OE specific curriculum 

elements or modules to be included as part of their AgBusiness and AgEconomic 

courses.
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• Outline regularly scheduled meetings and activities to perform on campus with 

students and diverse campus organizations.

• Identify and develop relationships with diverse professional groups that meet 

FCAs/OE requirements and leverage online sources to build a pipeline of midcareer/experienced candidates (e.g. Veteran career fairs, LinkedIn).

• Update recruiting material to highlight finance and credit backgrounds. 

11. Develop opportunities for leadership and staff to build relationships across difference.

• Try “Five Cups of Coffee” in which a Board member or leader schedules coffee with 

small groups of staff.

• Develop informal communication channels for staff to reach out to leaders (e.g., At 

a large financial institution any employee can request a “pull-up” with leadership; 

a pull-up is an informal meeting, usually over coffee in the café. No agenda is 

needed but should be a pointed conversation with a goal in mind).

12. Better position HR, EEOI, and SEPs to achieve diversity and inclusion goals. 

• Create regular touchpoints between OE and HR and EEOI to develop and 

implement OE’s human capital processes. For example, include HR or EEOI staff on 

panels that conduct interviews and make hiring and promotion decisions. Involve 

HR/EEOI in data tracking and review, for example, to increase accountability and 

transparency regarding career development and advancement opportunities 

across demographic differences.

• Increase transparency, communication, roles/responsibilities, and accountability 

related to the agency’s diversity and inclusion goals.

• Update SEP goals and charters to include a strategic mission enabler; reflect the 

inclusion of activities that advance the FCA mission and staff development needs 

to achieve the mission (e.g., SEPs should identify actions and activities to close gaps 

and execute recommendations outlined in this report). Because it is notoriously 

difficult to fit internal networking and development opportunities into busy work 

days, some structure helps these connections happen. With a “Five Cups of Coffee” 

program, Board members and senior leaders could schedule five specific hours, 

over the course of a few months, during which they invite any staff member to join 

them for coffee and casual conversation. Leaders can volunteer for time slots and 

employees can simply sign up and attend. Be sure to include some senior-leader 

field visits in the plans, and/or find creative ways to invite virtual participation. If 

such a program is well-received, offer it on a regular (e.g. annual) basis, rather than 

having it be just a one-off experiment.

13. Use the opportunity of the retirement wave to recruit from diverse pools of candidates for 

open senior positions.

• Substantially increase recruiting efforts; involving diverse leadership and staff in 

on-campus and professional recruiting activities.
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• Recruit internally and encourage applicants to apply for promotions; strive to have 

a diverse slate of candidates that reflect the civilian labor force (CLF) and federal 

civilian workforce.

14. Identify surrogate data analysis techniques to analyze decisions and outcomes across the 

employee life cycle, from recruiting to separation, given FCA’s small numbers. For example:

• Conduct adverse impact analysis (use the 80% rule instead of, or along with, 

statistical significance testing).

• Aggregate data over several years (e.g. analyze promotion rates across 

demographics for the last five years).

• Capture and analyze applicant flow data, to pinpoint where candidates exit the 

process from first recruiting contact to hire.

15. Use SEPs to operate as surrogate cadres of like groups to connect, network, support, and 

share and learn from each other’s experiences; update SEP charters to reflect this goal.

• Currently, FCA’s SEPs are known almost exclusively for cultural celebrations, 

awareness, and one-off events. SEPs can do much more to create value for the 

agency and its employees (see ideas below).
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REPORT FRAUD, WASTE, ABUSE, & 

MISMANAGEMENT: 

Phone: (800) 437-7322 (Toll-Free)

(703) 883-4316

Fax: (703) 883-4059

Email: fca-ig-hotline@rcn.com

Mail: 1501 Farm Credit Drive

McLean, VA 22102-5090

To learn more about reporting wrongdoing to the OIG, please visit our 

website at https://www.fca.gov/about/inspector-general.