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HHS Food and Drug Administration FY 2021

Affirmative Action 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 affirmative action plan will 

improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities.

Section I: Efforts to Reach Regulatory Goals

EEOC regulations (29 CFR §1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation 

of persons with disabilities and persons with targeted disabilities in the federal government

1. 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.

a. Cluster GS-1 to GS-10 (PWD) Answer No

b. Cluster GS-11 to SES (PWD) Answer Yes

In FY21, the FDA did not have a trigger involving PWDs in the GS-1 to GS-10 cluster as 14.67% of the workforce within these 

grade series identified as having a disability. However, FDA did have a trigger in the GS-11 to Senior Executive Service (SES) 

cluster, where 5.64% of the workforce within these series identified as having a disability. This indicates a possible blocked pipeline 

where PWDs are encountering obstacles in grade levels prior to more senior-level grades. The data indicates that representation of 

PWDs steadily declines starting at the GS-11 (11.72%), followed by GS-12 (7.66%), GS-13 (5.76%), GS-14 (4.52%), GS-15 

(2.67%), and finally SES (0%). Note: the FDA does have other senior level positions of which PWDs represented 3.36% in FY21.

*For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, as set forth in 29 C.F.R. § 1614.203(d)(7). For all 

other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the Washington, DC 

metropolitan region.

2. 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.

a. Cluster GS-1 to GS-10 (PWTD) Answer No

b. Cluster GS-11 to SES (PWTD) Answer Yes

In FY21, the FDA did not have a trigger involving PWTDs in the GS-1 to GS-10 cluster as 4.06% of the workforce within these 

grade series identified as having a targeted disability. However, FDA did have a trigger in the GS-11 to SES cluster, where 1.5% of 

the workforce within these series identified as having a targeted disability. This indicates a possible blocked pipeline where PWTDs 

are encountering obstacles in grade levels prior to more senior-level grades. The data indicates that representation of PWTDs 

steadily declines starting at the GS-13 (1.49%), GS-14 (1.36%), GS-15 (0.65%), and finally SES (0%). Note: the FDA does have 

other senior level positions of which PWDs represented 3.36% in FY21.

Grade Level Cluster(GS or Alternate Pay 

Planb)

Total Reportable Disability Targeted Disability

# # % # %

Numarical Goal -- 12% 2%

Grades GS-1 to GS-10 983 135 13.73 27 2.75

Grades GS-11 to SES 14845 801 5.40 112 0.75

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.
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In FY21, the FDA did not officially communicate the numerical goals to hiring managers and/or recruiters. However, OEEO is committed to coordinating with the Office of Human Capital Management (OHCM) and the Office of Talent Solutions (OTS) a 

marketing and training initiative that communicates the numerical goals. The FDA’s DEIA 2022-2025 Strategic Plan has objectives 

to enhance the collection, analysis, and reporting of demographic data (Objective 4); enhance outreach, recruitment, and retention 

efforts to increase representation of underrepresented groups (Objective 5) “Enhance outreach, recruitment, and retention efforts to 

increase representation of underrepresented groups" which directly speaks to understanding barriers to achieving representation that 

reflects the civilian workforce within each grade level and establishes targeted programs to remove those barriers across various 

stages of the employee lifecycle and to improve accessibility across the Agency (Objective 6). All objectives have working groups 

called Objective Teams to focus on these efforts for 2022-2025. The requirements of the MD-715 have been communicated to the 

Objective Teams for awareness, and incorporation into the assessment of the regulatory goals and data supporting PWDs and 

PWTDs. Objective Teams 4, 5, and 6 will incorporate PWDs and PWTDs into their work and explore specific recommendations as 

suggested by the EEOC. All objective teams will report implementation progress to the Equal Employment Opportunity 

Governance Council (EEOGC) on a quarterly basis and will complete an annual report at the end of each fiscal year to report 

progress. Specifically, the Agency has outlined a measurement approach in Objective 5 to monitor progress to the degree to which 

FDA’s workforce representation matches the Civilian Workforce within each grade level, including representation across PWD, and 

PWTD in line with Schedule A hiring authority. Additionally, to demonstrate leadership commitment, in FY21 every FDA Senior 

Executive is required in accordance with their performance plan’s “Leading People” section to support a minimum of three FDA 

DEIA objectives.”

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

1. 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.

Answer No

As of September 2021, the RAO staff included six FTEs, to include two full time Interpreting Services staff. The office is projected 

to add one additional FTE in FY22 and two additional FTEs during FY23.

2. 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 

(Name, Title, Office 

Full Time Part Time Collateral Duty Email)

Processing applications from PWD and PWTD 4 0 5 Nolan L. Jones, HR 

Specialist (Special 

Placement Programs 

Coordinator), OTS, 

Nolan.Jones@fda.hhs.gov

Jessica Romero, HR 

Specialist (Schedule A 

Program Coordinator), 

OTS, 

Jessica.Romero@fda.hhs.gov

Patricia Lawson, HR 

Specialist (Priority 

Placement Programs 

Coordinator), OTS, 

Patricia.Lawson@fda.hhs.gov
HHS Food and Drug Administration FY 2021

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Disability Program Task

# of FTE Staff By Employment Status Responsible Official 

(Name, Title, Office 

Full Time Part Time Collateral Duty Email)

Processing reasonable accommodation requests 

from applicants and employees

6 0 0 Tiffany Branch, Director, 

OEMS, 

Tiffany.Branch@fda.hhs.gov

Special Emphasis Program for PWD and 

PWTD

0 0 1

Cristina Bartolomei

cristina.bartolomei@fda.hhs.gov

Section 508 Compliance 1 0 0 Rita Harrison, IT 

Specialist (Internet), 

OIMT, 

Rita.Harrison@fda.hhs.gov

Architectural Barriers Act Compliance 1 0 0 Donald Demers, Director, 

OFEMS, 

Donald.Demers@fda.hhs.gov

Answering questions from the public about 

hiring authorities that take disability into 

account

4 0 5 OTS Special Placement 

Program Coordinators 

(from list above), OTS 

Policy Staff (5 

employees), and all OTS 

Staff (HR Specialists) who 

posts job announcements.

3. 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.

Answer Yes

All reasonable accommodation staff members received a minimum of eight hours of reasonable accommodation related training. 

The RAO staff completed the following trainings: - National Employment Law Institute (NELI) ADA Workshop - Gilbert and 

Kaplan: Nuts and Bolts of Disability Law and Reasonable Accommodation To carry out its responsibilities regarding the disability 

program, the OTS Special Placement Program Coordinators will receive training to provide support and assistance to the disability 

program. Depending on OTS FY22 budget, the OTS plans to provide the Special Placement Program Staff training in the areas of 

reasonable accommodation, equal employment opportunity, other on-the-job training or other formal/informal training specific to 

the functional roles and responsibilities assigned to provide support and assistance to the Agency’s disability program.

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.

Answer Yes

Section III: Program Deficiencies In The Disability Program
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Brief Description of Program 

Deficiency

B.4.a.8. to 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]

Objective Hire additional staff in various positions, including Special Emphasis Program Managers, EEO 

Specialists, and a Data Analyst to provide support to the Diversity and Compliance Staff.

Target Date Sep 30, 2022

Completion Date

Planned Activities

Target Date Completion Date Planned Activity

Sep 30, 2022 In FY22, OEEO will recruit for several vacancies to continue to build the 

effective management of Special Emphasis Programs.

Accomplishments

Fiscal Year Accomplishment

2021 In March 2021, the OEEO onboarded a Senior Program Manager for DEIA with 

collateral responsibilities to administer 7 Special Emphasis Programs. As a 

result, the OEEO effectively re-engaged with all FDA ERGs; conducted a 

strategic action planning session with the ERGs to align to FDA-wide DEIA 

objectives; hosted over a dozen Special Emphasis trainings and events, 5 of 

which included remarks from Acting Commissioner Janet Woodcock; and 

developed a user friendly internal website for employees to stay apprised with 

Special Emphasis news, trainings and events. However, the OEEO recognized 

the need for additional staff to ensure continuing and improved SEP operations.

2022 FDA has funded and is actively recruiting staff to support Special Emphasis and 

Disability programs. The Disability Program Manager will handle disability 

program related objectives, initiatives, and actions that arise during the 

application and selection processes and the Special Emphasis Program Managers 

will focus on DEIA implementation, Employee Resource Group (ERG) 

partnership, and MD-715 reporting. These positions will reside in OEEO but will 

work in partnership with HC/TM stakeholders. The FDA now has greater 

alignment and coordination between OEEO, RAO, and OTS, all of which 

support and engage PWDs and PWTDs. The coordinating efforts between these 

offices align the functions of the staff to further support the Agency’s goals and 

objectives toward PWDs and PWTDs. The FDA DEIA Strategic Plan, Objective 

6, outlines improving accessibility across the agency to ensure effectiveness of 

practices utilized to provide accessibility across the Agency for FDA employees 

and prospective employees, including reasonable accommodations, workplace 

accessibility, and accessibility across information and communication 

technologies. The Advisory Committee for Employees with Disabilities (ACED) 

is an advisory board chartered by the Commissioner of the U.S. Food and Drug 

Administration (FDA) to provide advice on policies, issues, and concerns 

impacting employees with disabilities within FDA and those seeking 

employment by the agency. The ACED provides a communication channel 

between FDA employees and management. Although this group has existed 

since 2009 and referenced in previous MD-715 reports, OEEO is now leveraging 

ACED as a strategic partner to accomplish the DEIA Objectives and initiatives. 

OEEO joins the ACED meetings and the annual meeting with the Commissioner. 

The ACED Chair serves as the DEIA Objective Team 6 co-chair. One of 

ACED’s subcommittees is the Succession, Training, Awareness and Retention 

Subcommittee (STAR). The intent of this subcommittee is to enhance, 

recommend, and support training to increase knowledge and awareness of the 

recruitment, retention, and career development of persons with disabilities.
HHS Food and Drug Administration FY 2021

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Brief Description of Program 

Deficiency

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)]

Objective Include examples of disability based harassment in FDA's anti-harassment policy training materials

Target Date Sep 30, 2022

Completion Date May 15, 2022

Planned Activities

Target Date Completion Date Planned Activity

Sep 30, 2022 OEEO will assist OHCM in the development of anti-harassment training 

materials and will include examples of disability-based harassment.

Accomplishments

Fiscal Year Accomplishment

2021 Accomplishments will be included in the FY22 report.

2022 The FDA's Anti-harassment training was updated with examples of disability 

based harassment.

Brief Description of Program 

Deficiency

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 comments column.

Objective Revise, submit, and get approval for the revised SMG for RA to EEOC for review which contains 

the procedures for Personal Assistance Services (PAS).

Target Date Sep 30, 2022

Completion Date

Planned Activities

Target Date Completion Date Planned Activity

Sep 30, 2022 The FDA will revise the “Staff Manual Guide: Policy and Procedures for 

Providing Reasonable Accommodation for Individuals with 

Disabilities” (SMG for RA) which contains the procedures for PAS. The 

Agency will submit to EEOC for review and concurrence ensuring that 

the procedures meet EEOC guidance. When approved by EEOC, the 

SMG for RA including PAS procedures will be posted on the FDA public 

website at: https://www.fda.gov/about-fda/office-operations/reasonableaccommodations.

Accomplishments Fiscal Year Accomplishment

Brief Description of Program 

Deficiency

D.4.a. Does the agency post its affirmative action plan on its public website? [see 29 CFR §1614.203(d)(4)] If yes, 

please provide the internet address in the comments.

Objective

OEEO will work with FDA Office of Digital Transformation to post the FY20 Affirmative Action 

Plan to the public website. The website location will be: https://www.fda.gov/about-fda/jobs-andtraining-fda/equal-employment-fda.

Target Date Sep 30, 2022

Completion Date

Planned Activities Target Date Completion Date Planned Activity

Accomplishments Fiscal Year Accomplishment

Section IV: 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 

PWD and PWTD

A. PLAN TO IDENTIFY JOB APPLICATIONS WITH DISABILITIES
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1. Describe the programs and resources the agency uses to identify job applicants with disabilities, including individuals with 

targeted disabilities.

During 2021, the FDA utilized a variety of recruitment and outreach strategies (e.g., virtual job fairs, job opportunity 

announcements/advertisements including the Pathways Program, etc.) designed to increase the number of qualified applicants with 

disabilities and applicants with targeted disabilities, including disabled veterans. FDA continued to work with targeted groups 

supporting persons with disabilities including The Maryland Division of Rehabilitation Services (DORS), DC Department on 

Disability Services Rehabilitation Services Administration, Gallaudet University, and Walter Reed Wounded Warriors and 

Transitioning Warriors. FDA also began utilizing the Professional Diversity Network platform which includes posting on their job 

board to reach a broad range of diverse candidates which target people with disabilities, military and veterans. In addition, FDA 

actively engaged with Walter Reed Wounded Warriors and Transitioning Warriors to provide informational sessions on a monthly 

basis, connecting with over 50 veterans in FY21. In FY21, the FDA advertised approximately 1,471 job opportunity announcements 

(JOAs), which included language for persons with disabilities and persons with targeted disabilities, including disabled veterans and 

military spouses to apply. During this recruitment period, individuals with disabilities/targeted disabilities including disabled 

veterans had the discretion to apply under various hiring mechanisms, competitively or noncompetitively. The mechanisms included 

delegated examining, direct hire, merit promotion, Veterans Recruitment Appointment, Veterans Employment Opportunity Act of 

1998, Pathways Program, and specific non-competitive hiring authorities, such as Schedule A, 30% or more disabled veterans, or 

military spouses. In addition, to maximize hiring of PWD and PWTD including veterans with a 30% or more disability FDA has 

created a Resume Repository tool that is used to track, store, and share resumes of PWD and PWTD including 30% of more 

disabled veterans who apply to positions at the FDA. All FDA managers and supervisors have access to this repository to view 

available, qualified candidates for their respective positions, and are encouraged to hire these candidates noncompetitively. To 

protect the integrity of the hiring and recruitment process, to include HIPPA laws, EEOC laws, etc., hiring/selecting officials are not 

provided a copy of the applicant’s schedule A letter or the verification/certification by the medical/service provider, DD214 or other 

personally identifiable information.

2. 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

PWD or PWTD may apply to available opportunities within the FDA using a variety of hiring authorities, e.g., Title 5 (Schedule A, 

delegated examining, direct hire, merit promotion, VRA, VEOA, Pathways Program, etc.), Title 21 (21st Century Cures Act) and 

Title 42 (e.g., Special Consultants, Service Fellows, Advisory Committee Members/Consultants, Senior Biomedical Research and 

Biomedical Product Assessment Service), SL/ST and Senior Executive Service (SES). Sufficient outreach efforts are taken to assure 

that a diverse pool of potential candidates (e.g. minorities, women, and individuals with disabilities) are made aware of 

opportunities. When recruiting for vacant positions, the FDA includes the area of consideration – individuals with disabilities, and 

language in its JOAs to encourage PWD or PWTD including disabled veterans to apply. Job announcements include specific 

information on job duties, qualifications, how they will be evaluated, how to apply and required documentation required at time of 

application as well as appropriate reasonable accommodation and EEO statements and other pertinent information sufficient for a 

PWD or PWTD to apply for consideration. PWD or PWTD must meet eligibility and qualification requirements and other 

requirements identified in the job announcement or based on OPM’s Qualifications Standards for the occupational series/positions 

they’re interested in receiving consideration for. Additionally, PWD or PWTD may submit their application to the SPPS and have 

uploaded to the FDA Resume Repository and receive consideration under the schedule A hiring authority. Appointments under the 

Schedule A excepted service hiring authority may be temporary or non-temporary.

3. 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 may apply to the Schedule A hiring authority via USAJOBS or directly to the FDA by contacting the SPPS. Individuals 

are informed of the following via USAJOBS or by the SPPS: § Required Documentation when applying under Schedule A, for 

example, Resume, Transcript or Credential Evaluation Report (CER) if education was obtained outside the United States and is 

being used for education qualifications, their Disability Letter (Schedule A) or Disability Letter (VA). Other acceptable information 

may be provided if the individual is a current Federal employee and seeking to apply for consideration under this hiring authority. § 

The FDA will provide reasonable accommodation to applicants with disabilities who are not able to apply online. If you need a 

reasonable accommodation for any part of the application process, please contact the Applicant Help Desk. Decisions on granting a 
HHS Food and Drug Administration FY 2021

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reasonable accommodation will be made on a case-by-case basis. Depending on the nature/severity of an individual’s disability 

(vision-impaired, hearing-impaired, or missing limbs), individuals may use TTY or a representative on their behalf to inquire about 

the process, time, requirements, etc. Whatever mechanism being used, the SPPS and servicing OTS HR Specialist provide the 

guidance, assistance and support to individuals with disabilities or targeted disabilities including disabled veterans to ensure they 

can properly apply for consideration and to address any issues/concerns they have regarding the application and selection processes. 

Individuals with disabilities/targeted disabilities including 30% or more disabled veterans who apply via positions advertised on 

USAJOBS are treated in the same/similar manner as other candidates who apply to the same position. Individuals with disabilities/

targeted disabilities including 30% of more disabled veterans who apply via the FDA Resume Repository are handled differently. 

Application packages are uploaded to the repository, reviewed for qualifications and matching to 1 or more occupational series/

positions. Individuals may be referred directly to the hiring official. All FDA managers and supervisors have access to this 

repository to view available, qualified candidates for their respective positions, and are encouraged to hire these candidates 

noncompetitively. To protect the integrity of the hiring and recruitment process, to include HIPPA laws, EEOC laws, etc., hiring/

selecting officials are not provided a copy of the applicant’s schedule A letter or the verification/certification by the medical/service 

provider, DD214 or other personally identifiable information. Following receipt of an individual with a disability/targeted disability 

application package, the OTS reviews to ensure the individual meets the minimum qualifications (e.g., education and/or experience, 

certification, licensure, etc.) for the position to be filled. Once the individual is determined to the meet the qualifications for the 

position, the individual is referred to the hiring official for consideration. Interviews are at the discretion of the hiring official. If 

selected for the position, the hiring official or designee conducts reference checks. A tentative office of employment is made. 

During the tentative offer phase, the individual’s schedule A letter is verified with the respective medical or service provider that 

issued the letter. A template (form) letter was designed for this purpose. Upon receipt of the certification from the medical/service 

provider stating the letter is valid and issued by the medical/service provider, the servicing Schedule A Program Coordinator 

notifies the servicing OTS HR Specialist, who in turns, notifies the FDA Center/Program Office. [One significant win-win was the 

implementation of SPPS e-Fax solution in 2021 which allowed direct communication with the medical/service provider to reduce 

the time to receive certification.] Once all other pre-employment clearances are completed and determined the individual may be 

employed, a final offer is made to the individual and a mutual start/enter-on-duty date is agreed. The individual attends New 

Employee Orientation. At the request of the employee and based on their needs, a reasonable accommodation can be provided (e.g., 

interpreter, reader, personal assistant, TTY services, etc.) If the PWD and PWTD candidate is selected for the position, FDA 

encourages the manager to convert the applicant from noncompetitive to career conditional after two years. Note: The contents of 

an individual’s schedule A letter are not provided to the hiring official by a staff member of the OTS.

4. 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.

Answer Yes

In FY21, the SPPS continued to provide training on the various hiring programs, (e.g., Schedule A and 30% or more disabled 

veterans to hiring officials, human capital staff and OTS staff, as needed, or upon request. In October 2021, the FDA’s Advisory 

Committee for Employees with Disabilities (ACED) hosted a special roundtable event and invited the SPPS to attend and present on 

the Schedule A hiring authority and other hiring authorities that may be used for disabled veterans. The FDA plans to record a 

presentation regarding the ABCs of Schedule A and post to its FDA Hiring Managers Toolkit. Hiring officials may view this 

recorded presentation at their discretion to learn about the Schedule A hiring authority and resume repository to assist them in 

filling their vacant positions with qualified individuals.

B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS

Describe the agency’s efforts to establish and maintain contacts with organizations that assist PWD, including PWTD, in 

securing and maintaining employment.

The FDA OTS partners with various sources to include but not limited to the following: § FDA’s Advisory Committee for 

Employees with Disabilities (ACED), which is an advisory board chartered by the Commissioner, FDA to provide advice on 

policies, issues, and concerns impacting employees with disabilities within FDA and those seeking employment by the agency. § 

The ACED is a communication channel between FDA employees and management. The OTS SPPS collaborates with the ACED. § 

Department of Labor’s Workforce Recruitment Program (WRP) which is a recruitment and referral program that connects federal 

and private-sector employers nationwide with highly motivated college students and recent graduates with disabilities who are eager 
HHS Food and Drug Administration FY 2021

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to demonstrate their abilities in the workplace through summer or permanent jobs. The FDA also has various agreements with 

minority serving institutions and organizations, state vocational rehabilitation agencies and the DOL to assist with hiring PWD and 

PWTD for positions within the Agency. There is a Career and Student Profile System to recruit staff for PWD and PWTD for 

internships and career opportunities within the Agency. The OTS SPPS is also identified on OPM’s Special Placement Program 

Coordinator point of contact website. The FDA will continue its efforts to partner and collaborate with various organizations 

nationwide to assist in the recruitment, placement and retention of persons with disabilities or persons with targeted disabilities 

including disabled veterans.

C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING)

1. Using the goals of 12% for PWD and 2% for PWTD 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.

a. New Hires for Permanent Workforce (PWD) Answer Yes

b. New Hires for Permanent Workforce (PWTD) Answer Yes

In FY21, PWDs represented 6.07% of new hires to the FDA permanent workforce, which is below the 12% benchmark; PWTDs 

represented 1.65% of the new hires to the FDA permanent workforce which is below the 2% benchmark.

New Hires Total

Reportable Disability Targeted Disability

Permanent 

Workforce

Temporary 

Workforce

Permanent 

Workforce

Temporary 

Workforce

(#) (%) (%) (%) (%)

% of Total 

Applicants

% of Qualified 

Applicants

% of New Hires

2. 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. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for MCO (PWD) Answer Yes

b. New Hires for MCO (PWTD) Answer Yes

In FY21, OEEO was not able to fully analyze applicant flow data for new hires. The OEEO was able to review high-level applicant 

flow data for all MCOs and determined there are triggers for both PWD and PWTDs in several mission critical occupations. Some 

occupations did not have any applicants who were PWD or PWTD, and others did have qualified applicants who identified as PWD 

or PWTD but either none were selected or the selection rates were low compared to the benchmark.

New Hires to Mission-Critical Occupations

Total

Reportable Disability Targetable Disability

New Hires New Hires

(#) (%) (%)

Numerical Goal -- 12% 2%

3. 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. Select “n/a” if 

the applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Qualified Applicants for MCO (PWD) Answer Yes
HHS Food and Drug Administration FY 2021

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b. Qualified Applicants for MCO (PWTD) Answer Yes

In FY21, OEEO was not able to fully analyze applicant flow data for internal applicants. The OEEO was able to review high-level 

applicant flow data for all MCOs and determined there are triggers for qualified PWD and PWTD internal applicants in several 

mission critical occupations. Some occupations did not have any applicants who were PWD or PWTD, and others did have 

qualified applicants who identified as PWD or PWTD but either none were selected or the selection rates were low compared to the 

benchmark.

4. 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. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. Promotions for MCO (PWD) Answer Yes

b. Promotions for MCO (PWTD) Answer Yes

In FY21, OEEO was not able to fully analyze applicant flow data for promotions. The OEEO was able to review high-level 

applicant flow data for all MCOs and determined there are triggers for qualified PWD and PWTD internal applicants for mission 

critical occupation promotions. Some occupations did not have any applicants who were PWD or PWTD, and others did have 

qualified applicants who identified as PWD or PWTD but either none were selected or the selection rates were low compared to the 

benchmark.

Section V: 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 PWD, including PWTD, have sufficient opportunities for advancement.

FDA plans to provide opportunities and advancement for PWD and PWTD. The OEEO will work with the OTS and the OHCM to 

identify opportunities for training/mentoring, career development, awards, promotions, and similar programs for PWD and PWTD. 

The FDA’s DEIA 2022-2025 Strategic Plan has objectives to enhance equitable treatment of all employees (Objective 2), enhance 

the collection, analysis, and reporting of demographic data (Objective 4); enhance outreach, recruitment, and retention efforts to 

increase representation of underrepresented groups (Objective 5) and to improve accessibility across the Agency (Objective 6). 

FDA has several career development programs at the Center level; however, they do not track if participants are PWD or PWTD. 

Objective Team 4 is working to establish efficient, effective, and operationally feasible mechanisms to collect the workforce data 

(HC/TM lifecycle data) and Objective Team 5 will evaluate that data to support FDA’s plan to ensure PWD and PWTD will receive 

advancement opportunities. The outcome of the work from the DEIA Objective Teams during the implementation period, will 1) 

identify if there are triggers for recruitment and/or selection process for PWD and PWTD for hiring and promotion; 2) perform 

barrier analysis if there are triggers; and 3) establish a detailed plan on how the Agency will ensure that PWD and PWTD receive 

advancement opportunities. OEEO will work with the OTS and the OHCM to identify opportunities for training/mentoring, career 

development, awards, promotions, and similar programs for PWD and PWTD. FDA will also leverage ACED’s STAR to increase 

knowledge and awareness of the recruitment, retention, and career development of persons with disabilities.

B. CAREER DEVELOPMENT OPPORTUNITES

1. Please describe the career development opportunities that the agency provides to its employees.

FDA has several career development programs at the center level however they do not track if participants are PWD or PWTD. The 
HHS Food and Drug Administration FY 2021

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Agency is looking at centralizing all of the career development opportunities within the centers to provide that information on future 

MD 715 reports.

2. 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 (%)

Detail Programs N/A N/A N/A N/A N/A N/A

Internship Programs N/A N/A N/A N/A N/A

Fellowship Programs N/A N/A N/A N/A N/A

Mentoring Programs N/A N/A N/A N/A N/A

Coaching Programs N/A N/A N/A N/A N/A

Training Programs N/A N/A N/A N/A N/A

Other Career Development 

Programs

N/A N/A N/A N/A N/A

3. Do triggers exist for PWD 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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWD) Answer N/A

b. Selections (PWD) Answer N/A

FDA does not have data for PWD or PWTD applicants for fellowship, career development, coaching, training, or detail programs. 

We are looking at capturing this information in future reports.

4. Do triggers exist for PWTD 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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. Applicants (PWTD) Answer N/A

b. Selections (PWTD) Answer N/A

FDA does not have data for PWD or PWTD applicants for fellowship, career development, coaching, training, or detail programs. 

We are looking at capturing this information in future reports.

C. AWARDS

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for any level of 

the time-off awards, bonuses, or other incentives? If “yes”, please describe the trigger(s) in the text box.

a. Awards, Bonuses, & Incentives (PWD) Answer Yes

b. Awards, Bonuses, & Incentives (PWTD) Answer Yes

Time Off: Using the Inclusion Rate, in FY21 both PWD and PWTDs received 1-10 hour time-off awards at a lower rate than non-
HHS Food and Drug Administration FY 2021

Page 11

PWD/PWTDs. PWDs had an inclusion rate of 21.13%, PWTD had an inclusion rate of 20.8% and non-PWD/PWTD has a 24.54% 

inclusion rate. However, PWD and PWTDs received a time-off awards at a higher rate than non-PWD/PWTDs for the following 

time allotments: 10-20 hours, 21-30 hours and 31-40 hours. At 41-80 hours, PWDs received a higher rate of awards whereas 

PWTDs received a lower rate. Cash Awards: PWDs and PWTDs received cash awards at the same or a higher rate than non-PWD/

PWTDs in the following categories: - $501-$999 - $1000-$1999 - $7000-$7999 -$9000-$9999 -$30000-39999 PWDs and PWTDs 

received cash awards at a lower rate than non-PWD/PWTDs in the following categories: -$500 and under -$2000-$2999 -$3000-

$3999 -$4000-$4999 -$5000-$5999 (only PWDs, PWTDs had the same rate as non PWTDs) -$6000-$6999 -$10000-$10999 -

$20000-$20999

Time-Off Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Time-Off Awards 1 - 10 hours: 

Awards Given

3394 18.02 20.83 19.72 17.72

Time-Off Awards 1 - 10 Hours: 

Total Hours

29917 158.80 183.13 162.68 158.12

Time-Off Awards 1 - 10 Hours: 

Average Hours

8 0.84 0.06 5.63 0.00

Time-Off Awards 11 - 20 hours: 

Awards Given

3401 22.97 20.57 23.24 22.92

Time-Off Awards 11 - 20 Hours: 

Total Hours

62506 412.01 379.15 395.07 414.99

Time-Off Awards 11 - 20 Hours: 

Average Hours

18 1.79 0.12 11.97 0.00

Time-Off Awards 21 - 30 hours: 

Awards Given

2558 16.44 15.37 13.38 16.98

Time-Off Awards 21 - 30 Hours: 

Total Hours

68462 440.15 412.41 349.30 456.13

Time-Off Awards 21 - 30 Hours: 

Average Hours

26 2.74 0.18 18.31 0.00

Time-Off Awards 31 - 40 hours: 

Awards Given

3766 22.55 23.03 22.54 22.55

Time-Off Awards 31 - 40 Hours: 

Total Hours

166836 1003.48 1019.07 1021.83 1000.25

Time-Off Awards 31 - 40 Hours: 

Average Hours

44 4.64 0.30 31.69 -0.12

Time-Off Awards 41 or more 

Hours: Awards Given

20 0.21 0.12 0.00 0.25

Time-Off Awards 41 or more 

Hours: Total Hours

1156 10.12 7.30 0.00 11.90

Time-Off Awards 41 or more 

Hours: Average Hours

57 5.06 0.40 0.00 5.95

Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $501 - $999: Awards 

Given

3730 25.92 22.30 26.06 25.90

Cash Awards: $501 - $999: Total 

Amount

2755114 19636.04 16426.23 19266.20 19701.12

Cash Awards: $501 - $999: 

Average Amount

738 79.77 5.07 520.42 2.23

Cash Awards: $1000 - $1999: 

Awards Given

7008 41.73 42.86 40.85 41.88

Cash Awards: $1000 - $1999: Total 

Amount

9915359 57534.25 60780.53 54135.21 58132.34

Cash Awards: $1000 - $1999: 

Average Amount

1414 145.21 9.76 933.10 6.57
HHS Food and Drug Administration FY 2021

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Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $2000 - $2999: 

Awards Given

5105 25.82 32.12 21.13 26.64

Cash Awards: $2000 - $2999: Total 

Amount

12520810 62651.11 78850.90 51989.44 64527.14

Cash Awards: $2000 - $2999: 

Average Amount

2452 255.64 16.90 1732.39 -4.21

Cash Awards: $3000 - $3999: 

Awards Given

2519 12.43 15.98 10.56 12.76

Cash Awards: $3000 - $3999: Total 

Amount

8616643 42222.02 54683.52 35838.03 43345.35

Cash Awards: $3000 - $3999: 

Average Amount

3420 357.74 23.56 2388.73 0.37

Cash Awards: $4000 - $4999: 

Awards Given

754 2.32 4.92 1.41 2.48

Cash Awards: $4000 - $4999: Total 

Amount

3309421 10011.70 21615.33 5841.55 10745.48

Cash Awards: $4000 - $4999: 

Average Amount

4389 455.01 30.23 2920.42 21.19

Cash Awards: $5000 or more: 

Awards Given

502 1.05 3.31 1.41 0.99

Cash Awards: $5000 or more: Total 

Amount

4796522 11331.51 31771.61 8910.56 11757.50

Cash Awards: $5000 or more: 

Average Amount

9554 1133.09 66.05 4454.93 548.57

2. 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.

a. Pay Increases (PWD) Answer Yes

b. Pay Increases (PWTD) Answer Yes

QSIs: PWDs received QSIs at a lower rate (3.37%) than than non-PWDs (4.83%). PWTDs received awards at a higher rate (5.11%). 

Performance-Based Pay Increases: PWDs and PWTDs received performance-based pay increases at a lower rate, PWD (0.30%) and 

PWTD (0%), than non-PWD/PWTDs (0.50%).

Other Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Total Performance Based Pay 

Increases Awarded

0 0.00 0.00 0.00 0.00

3. 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.

a. Other Types of Recognition (PWD) Answer N/A

b. Other Types of Recognition (PWTD) Answer N/A

The only awards that are calculated are the time-off awards, QSIs, Cash Awards and Performance-Based Pay Increases. If there are 

other types of recognition that the Agency is giving to PWD and PWTD is is not currently being tracked. FDA is looking at ways to 

capture other types of recognition given to PWD and PWTD.

D. PROMOTIONS
HHS Food and Drug Administration FY 2021

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1. Does your agency have a trigger involving PWD 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. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWD) Answer N/A

ii. Internal Selections (PWD) Answer N/A

b. Grade GS-15

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer Yes

c. Grade GS-14

i. Qualified Internal Applicants (PWD) Answer Yes

ii. Internal Selections (PWD) Answer Yes

d. Grade GS-13

i. Qualified Internal Applicants (PWD) Answer Yes

ii. Internal Selections (PWD) Answer Yes

According to our available data, in FY21 there were no internal promotions to the SES level. There were triggers for PWD in 

internal selections for the GS-15, which was lower (0%) than the qualified pool of PWDs (3.45%). For the GS-14, qualified internal 

applicants were lower (1.73%) than the relevant applicant pool (5.76%) and internal selections were lower (0%) than the qualified 

applicant pool (1.73%). For the GS-13, qualified internal applicants were lower (2.91%) than the relevant applicant pool (7.66%) 

and internal selections were lower (0%) than the qualified applicant pool (2.91%). This indicates that a glass wall exists for PWDs, 

which is a barrier preventing career advancement for qualified employees with a disability.

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. Select “n/a” if the applicant data is not available for your agency, and 

describe your plan to provide the data in the text box.

a. SES

i. Qualified Internal Applicants (PWTD) Answer Yes

ii. Internal Selections (PWTD) Answer Yes

b. Grade GS-15

i. Qualified Internal Applicants (PWTD) Answer Yes

ii. Internal Selections (PWTD) Answer Yes

c. Grade GS-14

i. Qualified Internal Applicants (PWTD) Answer Yes

ii. Internal Selections (PWTD) Answer Yes
HHS Food and Drug Administration FY 2021

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d. Grade GS-13

i. Qualified Internal Applicants (PWTD) Answer Yes

ii. Internal Selections (PWTD) Answer Yes

According to our available applicant flow data, there were PWTDs that did not apply for internal promotions for any of the senior 

grade levels. This indicates that a glass wall exists, meaning there is a barrier preventing PWTDs either from moving to an 

occupation with a promotional ladder or being promoted in their current occupation.

3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD 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. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWD) Answer N/A

b. New Hires to GS-15 (PWD) Answer Yes

c. New Hires to GS-14 (PWD) Answer Yes

d. New Hires to GS-13 (PWD) Answer Yes

In FY21, there were no applicants that self identified as having a disability for the GS-14 and GS-15 positions. For the GS-13, there 

were applicants with a disability (3.03%) but none were determined to be qualified (0%). No data was available for the SES. This 

indicates a blocked pipeline to senior grades for PWDs. Additional outreach resources need to be made available to ensure PWDs 

are applying to senior grade levels at the FDA.

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD 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. Select “n/a” if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box.

a. New Hires to SES (PWTD) Answer N/A

b. New Hires to GS-15 (PWTD) Answer Yes

c. New Hires to GS-14 (PWTD) Answer Yes

d. New Hires to GS-13 (PWTD) Answer Yes

In FY21, there were no applicants that self identified as having a targeted disability at senior grade levels. No data was available for 

the SES. This indicates a blocked pipeline to senior grades for PWTDs. Additional outreach resources need to be made available to 

ensure PWTDs are applying to senior grade levels at the FDA.

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. Select “n/a” if the applicant data is not 

available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWD) Answer N/A

ii. Internal Selections (PWD) Answer N/A
HHS Food and Drug Administration FY 2021

Page 15

b. Managers

i. Qualified Internal Applicants (PWD) Answer N/A

ii. Internal Selections (PWD) Answer N/A

c. Supervisors

i. Qualified Internal Applicants (PWD) Answer No

ii. Internal Selections (PWD) Answer Yes

In FY21, the FDA only had access to applicant flow data for promotions to supervisory positions in the aggregate, meaning we did 

not have access to disaggregated AFD on promotions to Executives and Managers. With the available data, we were able to identify 

a trigger in the internal selection for PWDs, where the qualified applicant pool was 5% yet 0% of the qualified applicants were 

selected for a supervisory promotion. There seems to be a glass ceiling preventing qualified PWDs from being selected to 

supervisory positions at the FDA. We need to investigate whether the barrier is institutional/structural (policy-related), attitudinal 

(biases or others), and/or physical.

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. Select “n/a” if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box.

a. Executives

i. Qualified Internal Applicants (PWTD) Answer N/A

ii. Internal Selections (PWTD) Answer N/A

b. Managers

i. Qualified Internal Applicants (PWTD) Answer N/A

ii. Internal Selections (PWTD) Answer N/A

c. Supervisors

i. Qualified Internal Applicants (PWTD) Answer Yes

ii. Internal Selections (PWTD) Answer Yes

In FY21, the FDA only had access to applicant flow data for promotions to supervisory positions in the aggregate, meaning we did 

not have access to disaggregated AFD on promotions to Executives and Managers. With the available data, we were able to identify 

a trigger in the internal selection for PWDs, where the qualified applicant pool was 5% yet 0% of the qualified applicants were 

selected for a supervisory promotion. There seems to be a glass ceiling preventing qualified PWDs from being selected to 

supervisory positions at the FDA. We need to investigate whether the barrier is institutional/structural (policy-related), attitudinal 

(biases or others), and/or physical.

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. Select “n/a” if the applicant data is 

not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWD) Answer N/A

b. New Hires for Managers (PWD) Answer N/A

c. New Hires for Supervisors (PWD) Answer Yes
HHS Food and Drug Administration FY 2021

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In FY21, the FDA only had access to applicant flow data for promotions to supervisory positions in the aggregate, meaning we did not have access to disaggregated AFD on promotions to Executives and Managers. With the available data, we were able to identify 

a trigger in the internal selection for PWDs, where the qualified applicant pool was 5% yet 0% of the qualified applicants were 

selected for a supervisory promotion. There seems to be a glass ceiling preventing qualified PWDs from being selected to 

supervisory positions at the FDA. We need to investigate whether the barrier is institutional/structural (policy-related), attitudinal 

(biases or others), and/or physical.

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. Select “n/a” if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box.

a. New Hires for Executives (PWTD) Answer N/A

b. New Hires for Managers (PWTD) Answer N/A

c. New Hires for Supervisors (PWTD) Answer Yes

In FY21, the FDA only had access to applicant flow data for promotions to supervisory positions in the aggregate, meaning we did 

not have access to disaggregated AFD on promotions to Executives and Managers. With the available data, we were able to identify 

a trigger in the internal selection for PWDs, where the qualified applicant pool was 5% yet 0% of the qualified applicants were 

selected for a supervisory promotion. There seems to be a glass ceiling preventing qualified PWDs from being selected to 

supervisory positions at the FDA. We need to investigate whether the barrier is institutional/structural (policy-related), attitudinal 

(biases or others), and/or physical.

Section VI: Plan to Improve Retention of Persons with Disabilities

To be model employer for persons with disabilities, 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 assistance services.

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS

1. 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.

Answer No

In accordance with the EEOC guidance, specifically The ABCs of Schedule A Tips for Hiring Managers on using the Schedule A 

Appointing Authority, agencies are strongly encouraged to make permanent appointments unless there is a compelling reason to do 

otherwise. There is no mandatory requirement to convert. However, when the employee is performing satisfactorily, agencies are 

strongly urged to convert Schedule A appointees at the end of the two-year period for noncompetitive conversion. The intent behind 

Schedule A is to help people with disabilities attain "civil service competitive status." Civil service competitive status is obtained 

through conversion to the competitive service, rather than remaining in the excepted service. The FDA did not convert all eligible 

Schedule A employees with a disability into the competitive service after two years of satisfactory service for varying reasons, e.g., 

EEOC guidance, individuals may have separated prior to conversion date, etc. The FDA will monitor Schedule A appointments to 

determine when an employee is eligible to be converted and ensure the proper personnel action is taken to convert Schedule A 

employees who perform satisfactorily and those who do not perform satisfactorily. The FDA OTS is developing Schedule A 

guidance to align with statutory, regulatory, OPM and EEOC guidance; to provide guidance on converting individuals to a 

permanent position in the competitive status; and what to do when an individual is not performing satisfactorily or having conductrelated issues.

2. 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.
HHS Food and Drug Administration FY 2021

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a.Voluntary Separations (PWD) Answer No

b.Involuntary Separations (PWD) Answer Yes

In FY21, the percentage of PWD among voluntary separations (3.96% Inclusion Rate) did not exceed that of persons without 

disabilities (4.84% Inclusion Rate). However, the percentage of PWD among involuntary separations (0.20% Inclusion Rate) did 

slightly exceed that of persons without disabilities (0.13%). Given the differences in the involuntary separations are ~.07 we do not 

detect a trigger, however, we will continuously monitor this metric to ensure PWDs are not being disparately separated 

involuntarily.

Seperations Total # Reportable Disabilities %

Without Reportable 

Disabilities %

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 20 0.10 0.12

Permanent Workforce: Resignation 247 0.69 1.47

Permanent Workforce: Retirement 340 1.88 1.96

Permanent Workforce: Other Separations 147 0.69 0.86

Permanent Workforce: Total Separations 754 3.37 4.40

3. 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.

a.Voluntary Separations (PWTD) Answer Yes

b.Involuntary Separations (PWTD) Answer No

In FY21, the percentage of PWTD among voluntary separations (5.10% Inclusion Rate) exceeded that of persons without 

disabilities (4.84% Inclusion Rate). The percentage of PWTD among involuntary separations (0% Inclusion Rate) did not exceed 

that of persons without disabilities (0.13%). We do see a trigger in the voluntary separation rates of PWTDs which indicates we 

must look into specific nature of action codes and well as exit interview data to better understand the reasons why PWTDs are 

leaving and why it's a higher rate that non-PWTDs.

Seperations Total # Targeted Disabilities %

Without Targeted Disabilities 

%

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 20 0.00 0.12

Permanent Workforce: Resignation 247 0.65 1.43

Permanent Workforce: Retirement 340 1.96 1.96

Permanent Workforce: Other Separations 147 0.00 0.85

Permanent Workforce: Total Separations 754 2.61 4.35

4. 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.

In FY21 the top 5 reasons for leaving the FDA, as reflected in the nature of action codes, are as follows: 1) Retirement (43%), 2) 

Moving to Private Sector (23.7%), 3) Moving to New Federal agency (18.28%), 4) Other (7.77%) and 5) Expiration of 

Appointment (1.9%). The reasons for PWD and PWTD leaving the FDA were as follows: 1) Retirement (40%), 2) Moving to New 

Federal Agency (27%), 3) Moving to Self Employment (6.7%), 4) Expiration of Appointment (6.7%) and 5) Other (6.7%). The top 

5 reasons for leaving for non-PWD/PWTDs, as reflected in exit interviews, were 1) Leaving for a Career Change (12.8%), 2) 

Leaving to obtain a better salary (11.8%), 3) Leaving for a promotion (10.9%), 4) Leaving to obtain better professional 

development/training opportunities (7.4%), 5) Leaving because of organizational culture/work environment (7%). The top 5 reasons 

for leaving for PWD and PWTDs, as reflected in exit interviews, were 1) Leaving for a Promotion (14.9%), 2) Leaving because of 

dissatisfaction with senior leader/manager (10.6%), 3) Leaving for career change (10.6%), 4) Leaving for another reason (8.5%), 5) 

Leaving to obtain a better salary (8.5%). The main identified difference between PWD and PWTDs is how they cite dissatisfaction 
HHS Food and Drug Administration FY 2021

Page 18

with senior/leader manager as one of the top 5 reasons for leaving, however non-PWD/PWTDs also cite this as a reason but it lands 

as #7 with 6.2% of the response rate vs 10.6% for PWD/PWTDs.

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES

Pursuant to 29 CFR §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.

1. 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.

https://www.fda.gov/about-fda/about-website/internet-accessibility and https://www.fda.gov/media/80908/download

2. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ 

rights under the

Architectural Barriers Act, including a description of how to file a complaint.

The Agency does not currently have an Architectural Barriers Act located on its public website.

3. 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.

The FDA, along with the Department of Health and Human Services, has a commitment to the accessibility and functionality of the 

web site content for all Americans. This commitment takes the form of a constantly evolving service of improving accessibility for 

our community of users. As the technology of the internet evolves, the FDA shares with its users the ongoing improvement of FDA 

websites and its services. For individuals with disabilities who are having problems accessing information on the FDA web site 

using assistive technology, they are encouraged to contact the FDA 508 Coordinator (FDA508Coordinator@fda.hhs.gov). The FDA 

is committed to making content accessible to everyone. For individuals submitting presentations or documents to the FDA, 

guidance for formatting documents properly and assisting FDA efforts in equivalent access and transparency is provided. At this 

time, virtually all FDA information is being made accessible via screen readers and other accessibility tools with the exception of 

some pre-2001 information, dockets, and some technical documents, which may not be available in accessible formats.

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.

1. 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.)

The average time for processing reasonable accommodation requests during FY21 was 30.5 days. The Agency’s established 

timeframe for processing reasonable accommodation requests is 60 days. Review of processing procedures, as well as timeframes, 

was completed during FY21 and revised projected to emulate best practices from other federal agencies best practices starting in 

FY22.

2. 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.

The Agency is currently upgrading tracking procedures and has employed resources to accurately capture requests. System and 
HHS Food and Drug Administration FY 2021

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procedural changes, and one additional staff member, assisted with a 52% decrease in recorded processing days from FY20 (FY21 – 

30.5 days from FY20 – 58.3 days). An adjustment of tracking processes allowed a more accurate view of request statuses, enabling 

subsequent prompt follow-up from the RAO to ensure timely determination and implementation of accommodation requests, as 

applicable. Continuance of Agency maximum telework posture trainings by the RAO were conducted virtually during FY21. RAO 

has developed and implemented presentations for the Agency’s bi-weekly New Employee Orientation. During FY21 around 600 

supervisors and managers were provided with one to two hours of reasonable accommodation training through such venues as 

quarterly Office of Regulatory Affairs (ORA) Supervisory Personnel Practices for new supervisors and supervisory refreshers, in 

addition to FDA University Supervisory 101 and 201. Throughout FY21, the RAO continued to coordinate training offerings with 

FDA Centers/Offices for managers and supervisors on an ad-hoc basis, including executive and senior leadership from two FDA 

Centers. During FY21, the RAO to provide Executive Officers and senior officials of the agency with monthly status/trend reports 

of FDA and Center/Office specific reasonable accommodation requests. The reasonable accommodation workgroup established in 

FY19 completed the review and revision of the FDA reasonable accommodation policies and procedures during FY21. The revised 

policy has been submitted to the EEOC for review and endorsement. In FY22, the FDA submitted the revised “Staff Manual Guide: 

Policy and Procedures for Providing Reasonable Accommodation for Individuals with Disabilities” (SMG for RA) to EEOC for 

review which contains the procedures for PAS, as allowed by EEOC guidance. When approved by EEOC, the updated SMG for RA 

be updated on the FDA public website at: https://www.fda.gov/about-fda/office-operations/reasonable-accommodations.

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE

Pursuant to 29 CFR §1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required to provide personal 

assistance services (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.

FDA’s procedures for Personal Assistance Services (PAS) include processing of requests on a case-by-case basis. During FY21 we 

received one request for PAS which was later withdrawn. Requests for PAS are processed by the Reasonable Accommodation 

Office and may be submitted by the employee, a third party, and/or the supervisor. Information for submitting related requests can 

be found at: https://fda.sharepoint.com/sites/OC-Intranet-OC-OO-OEMS-DCCP/SitePages/Reasonable-Accommodations.aspx In 

FY22, the FDA submitted the revised “Staff Manual Guide: Policy and Procedures for Providing Reasonable Accommodation for 

Individuals with Disabilities” (SMG for RA) to EEOC for review which contains the procedures for Personal Assistance Services 

(PAS) procedure, as allowed by EEOC guidance. When approved by EEOC, the updated SMG for RA be updated on the FDA 

public website at: https://www.fda.

Section VII: EEO Complaint and Findings Data

A. EEO COMPLAINT DATA INVOLVING HARASSMENT

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging harassment, as compared 

to the governmentwide average?

Answer No

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?

Answer Yes

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.

There were no findings. Settlement agreement terms included attorney’s fees and lump sum payments to complainants.
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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?

Answer No

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?

Answer Yes

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.

There were no findings. Settlement agreement terms included attorney’s fees and lump sum payments to complainants.

Section VIII: 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.

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect employment opportunities for 

PWD and/or PWTD?

Answer No

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD?

Answer Yes

3. 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
HHS Food and Drug Administration FY 2021

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STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER:

Provide a brief narrative 

describing the condition at 

issue.

How was the condition 

recognized as a potential 

barrier?

Workforce Data (if so identify the table)

Workforce Data Table - B1

There's a trigger in the total representation of People with Disabilities (PWD) and People with 

Targeted Disabilities (PWTDs) in the permanent workforce.

N

N

STATEMENT OF 

BARRIER GROUPS:

STATEMENT OF 

IDENTIFIED BARRIER:

Provide a succinct statement 

of the agency policy, 

procedure

or practice that has been 

determined to be the barrier 

of the 

undesired condition.

Barrier Group

People with Disabilities

People with Targeted Disabilities

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Low Entry of PWD and 

PWTDs to FDA

We have not yet identified a specific policy, practice, or procedure 

that is directly impacting the low entry of PWD and PWTDs to the 

FDA workforce, however, we have theorized that the lack of a 

policy and practice of communicating our 12% and 2% goals in 

addition to lack of expanded Agency-wide training and education 

about the benefits of hiring PWDs and PWTDs might be 

contributing to this lack of representation. Further analysis needs to 

be done in order to objectively identify the cause or multiple causes.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

09/30/2021 09/30/2025 Yes To ensure the agency meets or exceeds EEOCs 12% 

and 2% regulatory goal for PWD an PWTDs.

Responsible Official(s)

Title Name Standards Address The Plan?

Director, OEEO LaKeisha McClendon Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2022 OEEO and OHCM will establish a consistent method of 

communicating EEOCs 2% and 12% goals and tracking 

for increasing the representation of persons with 

disabilities and persons with targeted disabilities.

Yes
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Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

04/30/2022 The OEEO, via the DEIA Workgroup, will establish a 

series of working teams that will focus on implementing 

objectives outlined in the DEIA Strategic Plan. 

Specifically Objective #5, which focuses on running 

barrier analysis to understand opportunities and 

recommend actions to enhance outreach, recruitment, and 

retention efforts to increase representation of 

underrepresented groups, and Objective #6, which places 

particular focus on improving accessibility across the 

agency by ensuring processes around accessibility 

communications, reasonable accommodation, facilityrelated concerns etc. meet employee needs.

Yes

Report of Accomplishments

Fiscal Year Accomplishment

2021 Accomplishments will be reflected in the FY22 report.

4. Please explain the factor(s) that prevented the agency from timely completing any of the planned activities.

The FDA is reassessing its planned activities to address gaps in the disability program. Past planned activities were not a result of a 

true barrier analysis, thus measuring them is not feasible. The OEEO will address this deficiency by conducting a gap analysis on 

the EEO program. The FDA’s DEIA 2022-2025 Strategic Plan has objectives to enhance the collection, analysis, and reporting of 

demographic data (Objective 4); enhance outreach, recruitment, and retention efforts to increase representation of underrepresented 

groups (Objective 5) and to improve accessibility across the Agency (Objective 6). As part of DEIA implementation, FDA has 

established a cross-agency Barrier Analysis team (Objective Team 5). This team includes Human Capital professionals, DEIA 

subject matter experts (SMEs), and other SMEs from across the Agency. FDA identified that there was a general lack of 

understanding of what barrier analysis is across the Agency. Due to the lack of institutional knowledge, there was a need to provide 

barrier analysis training. The barrier analysis training process began with FDA arranging through the EEOC to provide barrier 

analysis training to the DEIA Objective Team 5 on May 3, 2022. This training was recorded and made available to all the DEIA 

Objective Team co-chair for awareness. The intent of DEIA Objective 5 is to understand barriers to achieving representation that 

reflects the Civilian Workforce within each grade level and establish targeted programs to remove those barriers across various 

stages of the employee lifecycle. The Agency has established a measurement approach in Objective 5 to monitor progress to the 

degree to which FDA’s workforce representation matches the Civilian Workforce within each grade level, including representation 

across PWD, and PWTD in line with Schedule A hiring authority. Objective Team 5 will establish a process consistent with the 

EEOC requirements and will begin conducting barrier analysis, quarterly self-assessments, and in-depth workforce analysis to 

identify barriers throughout the employee lifecycle. The outcome of the work from the DEIA Objective Teams during the 

implementation period, will 1) develop a resource toolkit that will support the identification of triggers; 2) performing barrier 

analysis; 3) develop and implement actions plans to address each barrier; and 4) review the effectiveness of the plans. The Objective 

Team will report back to the EEOGC on a regular basis.

5. For the planned activities that were completed, please describe the actual impact of those activities toward eliminating the 

barrier(s).

N/A

6. 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.
HHS Food and Drug Administration FY 2021

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N/A