Farm Credit Administration

Office of Inspector General

Inspection Report

Farm Credit Administration’s 

Compliance with Executive Order 

13950 on Combating Race and 

Sex Stereotyping

I-21-01

December 18, 2020
1501 Farm Credit Drive, McLean, VA 22102 703-883-4030 www.fca.gov/about/inspector-general

December 18, 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) compliance with Executive Order 13950 on Combating Race and Sex Stereotyping

(Exectuive Order). The Executive Order sets forth specific requirements for contractors, grants, 

agencies, and reporting to the Office of Management and Budget (OMB) and the Office of 

personnel Management. The Executive Order also required agency heads to request from their 

Inspector General a review of agency compliance with the requirements of the Executive Order by 

the end of the calendar year, and not less than annually thereafter. In accordance with this 

requirement, on October 5, 2020, the Board Chairman requested such a review from the OIG, and 

this report is the response to that request.

The objective of this inspection was to review and assess FCA’s compliance with the requirements 

of Executive Order 13950. The OIG review was limited to requirements applicable to FCA under 

the Executive Order. Specifically, we reviewed compliance with section 4, 6, and 7 of the Executive 

Order. FCA does not make grants, so we did not assess compliance with section 5 requirements 

for Federal grants. 

Based on the limited review performed, we found the Agency complied with the requirements of 

the Executive Order. The Agency included required provisions in contracts, incorporated 

requirements of the Executive Order into Agency operations, and submitted a report to OMB with 

Fiscal Year 2020 spending on Federal employee training programs related to diversity or inclusion.

Due to compliance with the selected provisions of the Executive Order, the OIG does not have any 

recommendations in this report.

We appreciate the courtesies and professionalism extended by FCA to our staff during the 

inspection, especially given the tight deadlines that needed to be met. 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
EXECUTIVE SUMMARY 

Compliance with Executive Order 13950

Report No. I-21-01 December 18, 2020

Objective

The objective of this inspection was 

to review and assess the Farm Credit 

Administration’s (FCA or Agency)

compliance with the requirements of 

Executive Order 13950 on Combating 

Race and Sex Stereotyping (Executive 

Order or E.O.).

Background 

FCA is an independent federal agency 

responsible for regulating,

examining, and supervising the Farm 

Credit System (System) and the 

Federal Agricultural Mortgage

Corporation. The Agency’s mission is 

to ensure that System institutions are 

safe, sound, and dependable sources 

of credit and related services for all 

creditworthy and eligible persons in 

agriculture and rural America. 

On September 22, 2020, the

President issued Executive Order 

13950. The Executive Order requires 

agency heads to request from their 

Inspector General a review of agency 

compliance with the requirements of 

the Executive Order. In accordance 

with this requirement, on October 5, 

2020, FCA’s Board Chairman

requested such a review from the 

Office of Inspector General (OIG). This 

report is the OIG’s response to that 

request.

This review was limited to requirements applicable to FCA under 

Executive Order 13950. Specifically, we reviewed compliance with 

sections 4, 6, and 7 of the Executive Order. FCA does not make grants, 

so we did not assess compliance with section 5 requirements for Federal 

grants. 

Based on the limited review performed, we found the Agency complied

with the requirements of the Executive Order. FCA took specific actions 

to address requirements in the Executive Order, including:

• Requesting that the Inspector General conduct a review of the 

Agency’s compliance with the requirements of the Executive 

Order by the end of the calendar year;

• Adding required contract provisions to its standard contract 

clause template;

• Sending a memorandum to senior staff requiring all conditions 

of the Executive Order be incorporated into agency operations;

• Designating FCA’s Director of the Office of Congressional and 

Public Affairs to serve as the Agency’s senior political appointee 

responsible for ensuring compliance with the requirements of 

the Executive Order;

• Notifying employees not to access diversity and inclusion 

training content in the Agency’s electronic learning platform 

until materials could be approved by the Office of Personnel 

Management;

• Developing a process to identify and contact employees who 

accessed certain training; and 

• Submitting a spending report to the Office of Management and 

Budget with diversity and inclusion trainings conducted in fiscal 

year 2020 within required timeframes.

Due to compliance with the selected provisions of the Executive Order, 

the OIG does not have any recommendations in this report.
 

TABLE OF CONTENTS

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

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

Inspection Results ......................................................................................................................... 2

Compliance Requirements...................................................................................................................................... 2

Section 4- Requirements for Government Contractors .......................................................................... 2

Section 5- Requirements for Federal Grants ............................................................................................... 3

Section 6- Requirements for Agencies .......................................................................................................... 3

Section 7- OMB and OPM Review of Agency Training ........................................................................... 4

Objective, Scope, and Methodology ........................................................................................... 5
1 

ACRONYMS

Agency Farm Credit Administration

E.O. Executive Order

Farmer Mac Federal Agricultural Mortgage Corporation

FCA Farm Credit Administration

FY Fiscal Year

OIG Office of Inspector General

OMB Office of Management and Budget

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.

It is important for FCA to adhere to requirements, including Executive Orders, given our role as a 

financial regulator. On September 22, 2020, the President issued Executive Order 13950 on 

Combating Race and Sex Stereotyping (Executive Order or E.O.). The Executive Order states that 

it shall be the policy of the United States not to promote race or sex stereotyping or scapegoating 

in the Federal workforce. The Executive Order also provides that it does not prevent agencies or 

federal contractors from promoting diversity or inclusiveness, provided such efforts are consistent 

with the requirements in the Executive Order. 

The Executive Order sets forth specific requirements for contractors, grants, agencies, and 

reporting to the Office of Management and Budget (OMB) and the Office of Personnel 

Management (OPM). To supplement the Executive Order, OMB and OPM issued additional 

implementation guidance. As of December 2020, the following guidance was issued:

• OMB Memorandum M-20-34, Training in the Federal Government, issued September 4, 

2020;
2 

• OMB Memorandum M-20-37, Ending Employee Trainings that Use Divisive Propaganda to 

Undermine the Principle of Fair and Equal Treatment for All, issued September 28, 2020; 

and

• OPM Memorandum, Mandatory Review of Employee Training Under E.O. 13950 September 

22, 2020, issued October 2, 2020.

The Executive Order requires agency heads to request that their Inspector General review agency 

compliance with the requirements of the Executive Order by the end of the calendar year, and not 

less than annually thereafter. In accordance with this requirement, on October 5, 2020, FCA’s Board 

Chairman requested such a review from the Office of Inspector General. This report is the OIG 

response to that request.

INSPECTION RESULTS

The objective of this inspection was to review and assess Agency compliance with the 

requirements of Executive Order 13950 on Combating Race and Sex Stereotyping (Executive Order 

or E.O.). We limited our scope to the Agency’s progress under the Executive Order from September 

2020 through December 2020.

We found that FCA complied with applicable requirements of the Executive Order. The Agency 

included required provisions in contracts, incorporated requirements of the Executive Order into 

Agency operations, and submitted a report to OMB with fiscal year (FY) 2020 spending on Federal 

employee training programs related to diversity or inclusion. 

Compliance Requirements

Section 4- Requirements for Government Contractors

We determined the Agency complied with section 4 of the Executive Order. The Executive Order 

states that all Government contracting agencies shall include certain provisions in every 

Government contract1 entered into 60 days after the date of the Executive Order.

FCA complied with section 4 of the Executive Order by including required contract provisions in 

contracts awarded after November 21, 2020. On October 27, 2020, FCA added contract provisions 

to its contract clause template to incorporate requirements of the Executive Order into future 

contracting actions. We requested a listing of all contracts awarded or modified from November 

21, 2020 through December 4, 2020. During that time period, FCA awarded two contracts. One 

contract was awarded November 25, 2020. When we reviewed this contract, it did not contain the 

required contract provisions; however, on December 15, 2020, FCA modified the contract to 

include contract provisions in the Executive Order. The other contract was awarded on December 

1, 2020 and contained required contract provisions. 

1 The Executive Order exempts certain contracts in section 4.
3 

Section 5- Requirements for Federal Grants

Section 5 of the Executive Order includes requirements for federal grant programs. FCA does not 

make grants; therefore, the Office of Inspector General (OIG) did not evaluate the Agency’s 

compliance with section 5 of the Executive Order.

Section 6- Requirements for Agencies

We determined the Agency complied with section 6 of the Executive Order. The Executive Order 

required certain steps to be taken regarding diversity and inclusion trainings and incorporating 

the Executive Order requirements into agency operations.

FCA took the following steps to comply with section 6 of the Executive Order:

• FCA took steps to ensure employees did not receive training on divisive concepts outlined 

in the Executive Order. Senior staff and personnel with diversity and inclusion training 

responsibilities were promptly notified about the Executive Order and corresponding 

guidance. The Director of FCA’s Office of Equal Employment Opportunity and Inclusion 

notified Special Emphasis Program (SEP)2 managers about the Executive Order and their 

responsibility to be cognizant of its requirements when developing SEP programming. 

FCA’s Learning and Organizational Change Team was also made aware of requirements in 

the Executive Order. 

• On October 5, 2020, FCA’s Board Chairman sent a memorandum to senior staff requiring 

all conditions of the Executive Order to be incorporated into Agency operations. The 

memorandum included information about compliance in all Agency contracts for diversity 

and inclusion training. The memorandum also directed senior staff to ensure their staff 

were aware of the requirements of the Executive Order and associated guidance and in 

compliance. 

• The Chairman sent a request to FCA’s Inspector General on October 5, 2020 to thoroughly 

assess, by the end of the calendar year, Agency compliance with the requirements of the 

Executive Order. In accordance with the Executive Order, the request included that the 

review be in the form of a report submitted to OMB.

• Lastly, the Chairman selected FCA’s Director of the Office of Congressional and Public 

Affairs to serve as the Agency’s senior political appointee responsible for ensuring 

compliance with the requirements of the Executive Order. A formal notification was sent 

to the appointee on October 5, 2020.

2 FCA SEPs are charged with identifying policies, procedures and practices affecting employees and advising 

management on actions that may increase participation and ensure that all persons are provided 

opportunities to participate in the full range of employment opportunities and achieve their fullest potential.
4 

Section 7- OMB and OPM Review of Agency Training

We determined the Agency complied with section 7 of the Executive Order. The Executive Order 

requires that as of September 22, 2020, all training programs for agency employees relating to 

diversity or inclusion be reviewed by OPM for compliance with the requirements of the Executive 

Order before being used by the Agency. Additionally, within 90 days of the Executive Order, each 

agency must report all spending in FY 2020 on Federal employee training programs related to 

diversity or inclusion to OMB. 

FCA took the following steps to comply with section 7 of the Executive Order: 

• Planned diversity and inclusion training was cancelled to ensure compliance with the 

Executive Order. Specifically, an OIG training event was cancelled pending approval from 

OPM. FCA implemented controls to limit access to diversity and inclusion training available 

through its electronic learning platform. The platform vendor provided a list of available 

diversity and inclusion courses and resources. FCA notified employees with access to the 

electronic learning platform about the Executive Order and instructed them not to access 

diversity and inclusion courses and resources pending a content review by OPM. The 

Agency notified employees that accessed these trainings and planned to conduct biweekly reviews to monitor access. The Agency has not submitted any training programs 

to OPM for review as of the issuance of this report.

• Procurement officials stated the Agency has not pursued debarment of any contractors 

for violations related to the Executive Order. 

• On December 17, 2020 FCA submitted a report to OMB with FY 2020 spending on Federal 

employee training programs related to diversity and inclusion. FCA’s report included nine

trainings, costs, and the number of employees trained. To compile the spending report, 

senior staff received guidance on definitions of “diversity and inclusion” and “training”, 

and individual offices were asked to determine whether such training was conducted 

within their office during FY 2020. 

Due to compliance with the selected provisions of the Executive Order, the OIG does not have any 

recommendations in this report. 

FCA waived the exit conference and elected to not provide any written comments.
5 

OBJECTIVE, SCOPE, AND METHODOLOGY

The objective of this inspection was to review and assess agency compliance with the 

requirements of Executive Order 13950 on Combating Race and Sex Stereotyping. We conducted 

the inspection at FCA’s headquarters in McLean, VA from October 2020 through December 2020. 

The scope of this inspection included the Agency’s progress under the Executive Order from 

September 2020 through December 2020. 

We took the following steps to accomplish the objective:

• Identified and reviewed the Executive Order and applicable guidance. 

• Identified and reviewed applicable internal FCA policies and procedures.

• Interviewed the Director of the Office of Equal Employment Opportunity and Inclusion, 

supervisory learning officer, contracting officer, and senior political appointee responsible 

for compliance with the Executive Order.

• Requested and received documentation related to the Agency’s implementation of 

requirements in the Executive Order. 

• Requested all contracts awarded by the Agency from November 21, 2020 through 

December 4, 2020 and determined whether those contracts included required provisions 

in the Executive Order. Interagency agreements were not included in our sample due to 

requirements in the Executive Order applying to contractors. The sample was selected 

based on the beginning date of the requirement in the Executive Order and a cutoff date 

that allowed for a review within the limited timeframe given for this review. Because our 

sample was judgmental, it cannot be projected to the entire population. 

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

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

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