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DHS U.S. Coast Guard FY 2022

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 No

*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 No

Grade Level Cluster(GS or Alternate Pay 

Planb)

Total Reportable Disability Targeted Disability

# # % # %

Numarical Goal -- 12% 2%

Grades GS-1 to GS-10 1703 604 35.47 86 5.05

Grades GS-11 to SES 5882 1926 32.74 204 3.47

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.

Hiring goals are communicated from DHS to the Coast Guard’s Recruitment Team. The hiring goals are provided to Coast Guard’s 

Strategic Workforce Planning and Human Resources Analysis Office for monitoring and monthly tracking towards the hiring goals.

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
DHS U.S. Coast Guard FY 2022

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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 Yes

The agency hired an attorney in August 2021 who manages its Disability Program. This individual serves as CG’s Disability 

Program Manager and works with other collateral-duty personnel in this role in implementing the disability program.

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)

Architectural Barriers Act Compliance 1 0 0 LCDR Nicholas Herndon

Facilities Engineer

Nicholas.D.Herndon@uscg.mil

Answering questions from the public about 

hiring authorities that take disability into 

account

0 0 2 Linda Aase, HR 

Specialist, Office of 

Civilian Workforce 

Management (AF only)

Linda.R.Aase@uscg.mil

Victoria.Council@cgexchange.org

Processing reasonable accommodation requests 

from applicants and employees

1 0 1 Caroline Mapp, Persons 

with Disabilities Program 

Manager, Civil Rights 

Directorate (AF)

CivilRightsRA@uscg.mil

Kristi.Mowry@cgexchange.org

Processing applications from PWD and PWTD 0 0 2 Joint collateral 

responsibilities depending 

on the methods the 

applications are received. 

(AF only)

Victoria Council (NAF 

only)

Victoria.Council@cgexchange.org

Special Emphasis Program for PWD and 

PWTD

1 0 0 Caroline Mapp

Person with Disabilities 

Program Manager

Civil RightsRA@uscg.mil

Section 508 Compliance 1 1 0 Dr. Eleanor Thompson

Branch Chief

Section.508@uscg.mil

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

The Disability Program Manager completed the Disability Program Manager Course at DEOMI during this reporting period.

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
DHS U.S. Coast Guard FY 2022

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The CG provided sufficient funding and other resources that aided in successfully implementing its disability program. The CG 

partnered with and used the Department of Transportation, Computer Accommodations Program, and the Disability Resource 

Center to provide reasonable accommodations and personal assistance services.

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

Deficiency

C.2.b.5. Does the agency process all initial accommodation requests, excluding ongoing interpretative services, within 

the time frame set forth in its reasonable accommodation procedures? [see MD-715, II(C)] If “no”, please provide the 

percentage of timely-processed requests, excluding ongoing interpretative services, in the comments column.
DHS U.S. Coast Guard FY 2022

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Objective

Provide guidance and resources necessary to ensure that the agency can process accommodation 

requests within the time frame set forth in its reasonable accommodation procedures, which is 

within 15 business days; share analyses with leadership, working groups and field staff to promote 

timeliness.

Target Date Sep 30, 2020

Completion Date

Planned Activities

Target Date Completion Date Planned Activity

Sep 30, 2019 September 30, 2019 Analyze late accommodation approvals to see if there is a common factor 

that can be addressed.

Sep 30, 2019 September 26, 2019 Guidance regarding service animals provided.

Oct 22, 2019 October 22, 2019 Meet with civil rights Regional Directors to discuss how to address late 

accommodations.

Jan 7, 2020 January 27, 2020 Quarterly review of accommodation requests.

Jan 31, 2020 January 30, 2020 Develop a Reasonable Accommodation Promotion Plan to educate the 

workforce and management officials about reasonable accommodation 

procedures and timeframe.

Jan 31, 2020 Review the current Reasonable Accommodation Promotion Plan to 

educate the workforce and management officials about reasonable 

accommodation procedures and timeframe.

Apr 7, 2020 April 10, 2020 Quarterly review of accommodation requests.

Apr 30, 2020 April 30, 2020 Civil rights and human resources collaboration on guidance regarding the 

reassignment process.

Aug 7, 2020 August 25, 2020 Quarterly review of accommodation requests.

Aug 30, 2020 January 30, 2020 Obtain approval and implement the Reasonable Accommodation 

Promotion Plan.

Dec 31, 2020 December 17, 2020 Meet with civil rights Regional Directors to discuss how to address late 

accommodations and provide training to CRSPs and managers.

Jan 31, 2021 April 12, 2021 Quarterly review of accommodation requests.

Mar 31, 2021 Meet with Regional Directors to review the progress in enhancing 

timelines of the RA process

Mar 31, 2021 December 17, 2020 Meet with Civil rights and human resources to follow up on procedures 

regarding the reassignment process.

Apr 30, 2021 April 15, 2021 Quarterly review of accommodation requests.

Jun 30, 2021 July 27, 2021 Review status of timeliness.

Nov 30, 2021 February 4, 2022 Meet with Regional Directors to review the progress in enhancing 

timelines of the RA process.

Dec 31, 2021 February 4, 2022 Initiated monthly review of accommodation requests.

Feb 28, 2022 March 17, 2022 Perform analysis and review of RAs.

Mar 31, 2022 July 18, 2022 Make an assessment of the Civil Rights Awareness Training.

Jul 31, 2022 July 31, 2022 Review status of timeliness.

Jul 31, 2022 July 27, 2022 Provide RA training to Managers and Supervisors.

Sep 30, 2023 Review current policy for timeline assessment and any areas for 

processing time improvements to complete all requests within timeframes.

Accomplishments Fiscal Year Accomplishment

2021 Met with directors to discuss timelines concerns. The agency provided six 

training sessions for RA request procedures to all managers and supervisors. The 

training was virtual via Teams. The agency hired two new Attorneys’ Advisors 

to work with the disability program. The activities ultimately resulted in a 

decrease of the time average to process of RAs. The new days average is 8.6 

days.

2019 A review of late accommodation approvals found that they usually involved 

reassignment and service animals.
DHS U.S. Coast Guard FY 2022

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Fiscal Year Accomplishment

2022 • Implemented a reasonable accommodation requests (RA) monthly reporting 

requirement to monitor processing timeliness and identify gaps. • Developed and 

implemented use of a reasonable accommodation processing packet job aide for 

processing RA requests. • Conducted multiple training sessions on RAs for 

managers, supervisors, and Civil Rights Service Providers. • Improved the initial 

processing time of RA requests to under 15 days from 30+ days.

2019 Service animal guidance was disseminated to the civil rights staff and posted on 

the civil rights website.

2020 A meeting was held with the civil rights Regional Directors and timeliness 

regarding accommodation approval was addressed.

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

1. Describe the programs and resources the agency uses to identify job applicants with disabilities, including individuals with 

targeted disabilities.

The Selective Placement Program Coordinator in the Office of Civilian Human Resources Workforce Management is the POC for 

Schedule A applicants. The coordinator works closely with the Office of Civilian Human Resources Operations and shares 

applicants’ resumes who have applied to the JOA on USAJOBS as an opportunity to apply Schedule A to eligible applicants.

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

Individuals requesting consideration as Schedule A persons with disabilities applicants are encouraged to apply for all USCG job 

openings that are posted. The vacancy announcements clearly communicate to all applicants how to apply using the Schedule A 

authority or any other non-competitive authority such as 30% or more disabled veteran. Coast Guard hiring managers are 

encouraged to use the 30% or more disabled veterans and the Schedule A hiring authorities. Hiring managers may contact the CG 

Selective Placement Program Manager or the Veterans Program Manager to discuss hiring authorities and to develop recruitment 

strategies to hire persons with disabilities using the Schedule A and 30% or more disabled veterans hiring authority.

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.

Applicants who self-disclose their disability, provide the appropriate documentation, and are determined qualified for the position 

are referred to the selecting official with other non-competitive eligibles.

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
DHS U.S. Coast Guard FY 2022

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The Learning Management System (LMS) provides annual training to hiring managers/supervisors on the use of hiring authorities 

that include Schedule A hiring.

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 Office of Civilian Human Resources Workforce Management has taken a proactive approach to recruitment. The CG reached 

out to all Vocational Rehabilitation agencies in the DC Metro area and held informational sessions on how to navigate USAJOBS, 

mock interviewing, and how to write a Federal resume. CG held a national webinar for all vocational rehabilitation agencies to 

provide tips in how to navigate USAJOBS, how to successfully apply for JOA’s and how to write Federal resumes. More than 20 

agencies participated in the webinar, and it was recorded for those who could not attend. FY22 included four (4) informational 

PWD sessions and five (5) recruitment events for PWD.

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 No

b. New Hires for Permanent Workforce (PWTD) Answer No

New Hires Total

Reportable Disability Targeted Disability

Permanent 

Workforce

Temporary 

Workforce

Permanent 

Workforce

Temporary 

Workforce

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

7318 4.43 0.00 1.91 0.00

6969 4.41 0.00 1.91 0.00

150 27.33 0.00 3.33 0.00

% 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 No

b. New Hires for MCO (PWTD) Answer No

New Hires to Mission-Critical Occupations

Total

Reportable Disability Targetable Disability

New Hires New Hires

(#) (%) (%)

Numerical Goal -- 12% 2%

1102 CONTRACTING 37 29.73 2.70

2210 INFORMATION TECHNOLOGY 

MANAGEMENT

113 26.55 3.54
DHS U.S. Coast Guard FY 2022

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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 N/A

b. Qualified Applicants for MCO (PWTD) Answer N/A

Relevant applicant pool data was not available for comparison to qualified internal applicants.

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 No

b. Promotions for MCO (PWTD) Answer Yes

The qualified applicant pool (QAP) rate for promotion for the Information Technology (IT) MCO for PWTD was 4.00% compared 

with their selection rate of 0%. PWTD promotions for the IT MCO was lower than their participation rate among the QAP.

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.

The CG Civilian Career Management Team (CCMT) advertises professional and leadership development opportunities, detail 

opportunities, and provides career mapping information. CG employees are able to view and apply to detail opportunities online 

through the CCMT website.

B. CAREER DEVELOPMENT OPPORTUNITES

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

The CG provides a variety of career and leadership development opportunities for its employees. These include an open enrollment 

for the mentoring program, leadership training programs and other career training programs. The CG tracks selectees and available 

program seats but does not track individual applicants for programs except for the mentoring program, where enrollment is open to 

every person who applies on an open basis. All information in the mentoring program is self-submitted and unverified. There are no 

applicants or selectees as used in the below table. The mentoring program is creating a disability focused online community to 

connect and empower both members with PWD and PWTD, as well as their peers and supervisors.

2. In the table below, please provide the data for career development opportunities that require competition and/or 

supervisory recommendation/ approval to participate.
DHS U.S. Coast Guard FY 2022

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Career Development 

Opportunities

Total Participants PWD PWTD

Applicants (#) Selectees (#)

 Applicants 

(%) Selectees (%)

 Applicants 

(%) Selectees (%)

Internship Programs NA NA NA NA NA NA

Fellowship Programs NA NA NA NA NA NA

Mentoring Programs NA NA NA NA NA NA

Training Programs NA NA NA NA NA NA

Coaching Programs NA NA NA NA NA NA

Detail Programs NA NA NA NA NA NA

Other Career Development 

Programs

NA NA NA NA NA NA

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

Participation in the CG’s career development program does not qualify a participant for a promotion to a senior grade level upon 

completion.

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

Participation in the CG’s career development program does not qualify a participant for a promotion to a senior grade level upon 

completion.

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

For time-off awards 1-10 hours, PWD and PWTD inclusion rate was 9.44% and 9.63% respectively. Persons with no disabilities 

rate was 10.46%. Therefore, a trigger exists for PWD and PWTD. Also, time-off awards for 11-20 hours for PWD rate was 2.10% 

compared with persons with no disabilities rate of 2.45%. A trigger exists for PWD for this award category. Except for the cash 

award category for $1,000 - $1,999 for PWTD, PWD and PWTD inclusion rate for all other cash awards was lower than persons 

with no disabilities. For cash awards $501 - $599 PWD and PWTD inclusion rate was 17.51% and 16.15% respectively compared 

with person with no disabilities rate of 17.69%; cash awards $1,000 -$1,999 inclusion rate for PWD was 6.20% compared with 

persons with no disability rate of 7.09%; cash awards $2,000 to $2,999 inclusion rate for PWD was 11.44% and 11.80% for PWTD 

compared with persons with no disabilities rate of 13.39%; cash awards $3,000 - $3,999 inclusion rate for PWD and PWTD was 
DHS U.S. Coast Guard FY 2022

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22.12% and 20.81% respectively compared with persons with no disability rate of 25.85%; cash awards $4,000 - $4,999 inclusion 

rate for PWD and PWTD was 11.61% and 11.49% respectively compared with persons with no disability rate of 13.55%; and cash 

award $5,000 and over inclusion rate for PWD and PWTD was 8.24% and 8.39% respectively compared with persons with no 

disability rate of 9.71%. A trigger exists for all cash awards categories.

Time-Off Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Time-Off Awards 1 - 10 hours: 

Awards Given

0 0.00 0.00 0.00 0.00

Time-Off Awards 1 - 10 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 1 - 10 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 11 - 20 hours: 

Awards Given

0 0.00 0.00 0.00 0.00

Time-Off Awards 11 - 20 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 11 - 20 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 21 - 30 hours: 

Awards Given

0 0.00 0.00 0.00 0.00

Time-Off Awards 21 - 30 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 21 - 30 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 31 - 40 hours: 

Awards Given

0 0.00 0.00 0.00 0.00

Time-Off Awards 31 - 40 Hours: 

Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 31 - 40 Hours: 

Average Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 41 or more 

Hours: Awards Given

0 0.00 0.00 0.00 0.00

Time-Off Awards 41 or more 

Hours: Total Hours

0 0.00 0.00 0.00 0.00

Time-Off Awards 41 or more 

Hours: Average Hours

0 0.00 0.00 0.00 0.00

Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $501 - $999: Awards 

Given

0 0.00 0.00 0.00 0.00

Cash Awards: $501 - $999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $501 - $999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $1000 - $1999: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $1000 - $1999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $1000 - $1999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $2000 - $2999: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $2000 - $2999: Total 

Amount

0 0.00 0.00 0.00 0.00
DHS U.S. Coast Guard FY 2022

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Cash Awards Total (#)

Reportable 

Disability %

Without Reportable 

Disability %

Targeted Disability 

%

Without Targeted 

Disability %

Cash Awards: $2000 - $2999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $3000 - $3999: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $3000 - $3999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $3000 - $3999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $4000 - $4999: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $4000 - $4999: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $4000 - $4999: 

Average Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $5000 or more: 

Awards Given

0 0.00 0.00 0.00 0.00

Cash Awards: $5000 or more: Total 

Amount

0 0.00 0.00 0.00 0.00

Cash Awards: $5000 or more: 

Average Amount

0 0.00 0.00 0.00 0.00

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 No

The inclusion rate for PWD quality step increases (QSI) was 2.58% compared with persons with no disabilities rate of 2.97%. PWD 

inclusion rate for QSIs was lower than persons with no disability. A trigger exists.

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 Coast Guard did not have any other types of employee recognition programs.

D. PROMOTIONS

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
DHS U.S. Coast Guard FY 2022

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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 N/A

ii. Internal Selections (PWD) Answer No

c. Grade GS-14

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

ii. Internal Selections (PWD) Answer No

d. Grade GS-13

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

ii. Internal Selections (PWD) Answer No

a. (i) Relevant applicant data was not available for comparison. (ii) Qualified applicant pool data was not available for comparison. 

b. (i) Relevant applicant data was not available for comparison. c. (i) Relevant applicant data was not available for comparison. d. 

(i) Relevant applicant data was not available for comparison.

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 N/A

ii. Internal Selections (PWTD) Answer N/A

b. Grade GS-15

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

ii. Internal Selections (PWTD) Answer No

c. Grade GS-14

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

ii. Internal Selections (PWTD) Answer Yes

d. Grade GS-13

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

ii. Internal Selections (PWTD) Answer Yes

a. SES - (i) Relevant applicant pool data was not available for comparison. (ii) Qualified applicant pool data was not available for 

comparison. b. GS-15 - (i) Relevant applicant pool data was not available for comparison. c. GS-14 - (i) Relevant applicant pool 

data was not available for comparison. (ii) PWTD qualified applicant pool rate was 3.00% compared with their selection rate of 

1.47%. A trigger exists. d. GS-13 - (i) Relevant applicant pool data was not available for comparison. (ii) PWTD qualified applicant 
DHS U.S. Coast Guard FY 2022

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pool rate was 2.59% compared with their selection rate of 1.15%. A trigger exists.

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 No

c. New Hires to GS-14 (PWD) Answer No

d. New Hires to GS-13 (PWD) Answer No

a. SES - Qualified applicant pool data was not available for comparison.

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 No

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

a. SES – Qualified applicant pool data was not available for comparison. b. GS-15 - The new hires qualified applicant pool rate for 

PWTD was 1.55% compared to their 0% selection rate. A trigger exists. d. GS-13 - The new hires qualified applicant pool rate for 

PWTD was 2.20% compared to their 2.08% selection rate. A trigger exists.

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 No

b. Managers

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

ii. Internal Selections (PWD) Answer No

c. Supervisors

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

ii. Internal Selections (PWD) Answer No
DHS U.S. Coast Guard FY 2022

Page 14

a. Executives - (i) Relevant applicant pool data was not available for comparison. b. Managers - (i) Relevant applicant pool data was 

not available for comparison. c. Supervisors - (i) Relevant applicant pool data was not available for comparison.

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 No

b. Managers

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

ii. Internal Selections (PWTD) Answer Yes

c. Supervisors

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

ii. Internal Selections (PWTD) Answer No

a. Executives - (i) Relevant applicant pool data was not available for comparison. b. Managers - (i) Relevant applicant pool data was 

not available for comparison. (ii) - The qualified applicant pool rate for PWTD was 2.97% compared to their 0.00% selection rate. 

A trigger exists. c. Supervisors - (i) Relevant applicant pool data was not available for comparison.

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 No

b. New Hires for Managers (PWD) Answer No

c. New Hires for Supervisors (PWD) Answer No

a. The new hires qualified applicant pool rate for PWD was 21.67% for promotions to executive positions, compared to their 

selection rate of 0.00%. PWD were not among new hire selections for promotions to executive positions, although they were among 

qualified applicants.

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 Yes

b. New Hires for Managers (PWTD) Answer Yes

c. New Hires for Supervisors (PWTD) Answer No

a. Executives - The new hires qualified applicant pool rate for PWTD was 1.39% compared to their 0% selection rate. A trigger 

exists. b. Managers - The new hires qualified applicant pool rate for PWTD was 2.02% compared to their 1.43 % selection rate. A 
DHS U.S. Coast Guard FY 2022

Page 15

trigger exists.

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

The CG converted 10 (25%) of 40 eligible Schedule A employees after two years of service. This is an increase since the last 

reporting period and continues to be a focused effort for improvement to convert eligible Schedule A employees from excepted 

service to career service.

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.

a.Voluntary Separations (PWD) Answer Yes

b.Involuntary Separations (PWD) Answer Yes

The voluntary and involuntary separation inclusion rate for PWD was 8.75% and 3.03%. The voluntary and involuntary separation 

rate for employees without disabilities was 6.31% and 2.39% respectively. PWD voluntarily and involuntarily separated at rates 

higher than persons without disabilities. Triggers exist for PWD among voluntary and involuntary separations.

Seperations Total # Reportable Disabilities %

Without Reportable 

Disabilities %

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 18 0.24 0.17

Permanent Workforce: Resignation 248 3.34 2.38

Permanent Workforce: Retirement 403 5.32 3.92

Permanent Workforce: Other Separations 216 2.76 2.14

Permanent Workforce: Total Separations 885 11.65 8.62

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

The voluntary and involuntary separation inclusion rate for PWTD was 10.25% and 1.55%. The voluntary and involuntary 

separation rate for employees without disabilities was 6.31% and 2.39% respectively. PWTD voluntarily separated at a rate higher 

than persons without disabilities. A trigger exists for PWTD among voluntary separations.
DHS U.S. Coast Guard FY 2022

Page 16

Seperations Total # Targeted Disabilities %

Without Targeted Disabilities 

%

Permanent Workforce: Reduction in Force 0 0.00 0.00

Permanent Workforce: Removal 18 0.00 0.20

Permanent Workforce: Resignation 248 3.07 2.67

Permanent Workforce: Retirement 403 7.06 4.27

Permanent Workforce: Other Separations 216 1.53 2.37

Permanent Workforce: Total Separations 885 11.66 9.51

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.

Office of Workforce Relations is gathering preliminary information in Exit Surveys through root cause analysis to examine trends.

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.

The internet address is as follows: https://www.uscg.mil/access/access/

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 internet address is as follows: https://www.uscg.mil/access/access/

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.

In FY23, the CG plans to review the reasonable accommodation policy and forms to incorporate recent changes outlined in the 

Pregnant Workers Fairness Act (PWFA) and the Providing Urgent Maternal Protections (PUMP) For Nursing Mothers Act. The CG 

continues to explore a reasonable accommodations database with robust features that offer interactive secure communications with 

privacy protection for information or documents.

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 timeframe for processing initial requests for reasonable accommodations for all USCG regions was approximately 10 

days (9.93).

2.
DHS U.S. Coast Guard FY 2022

Page 17

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.

Enforcing the practice of reducing the amount of time each region processes reasonable accommodation requests has resulted in a 

faster processing time from 30 days or more to under 15 days. This practice includes ensuring that each region reports monthly to 

HQ on the number or reasonable accommodation requests received, time frames from the receipt of the request to temporary 

accommodation (if provided) to denial or approval of the request, and any other tolling of the time (search for reassignment, 

medical documentation pending receipt). Additionally, the Disability Program Manager monitors processing times quarterly and 

notifies CG regions if their processing of reasonable accommodation requests are too slow or if they are right on track, while also 

reaching out to each regional director to provide any additional assistance or training if they are exceeding the 15-day processing 

time.

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.

Training has been conducted twice for managers, supervisors and staff at DEOMI by the Disability Program Manager on PAS to 

help them understand the requirements and how to provide assistance to their employees who are in need of such assistance.

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 No

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 of discrimination in FY22 alleging Harassment based on disability status.

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 Yes

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?
DHS U.S. Coast Guard FY 2022

Page 18

Answer No

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 of discrimination for failure to accommodate during FY22.

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
DHS U.S. Coast Guard FY 2022

Page 19

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?

EEO Complaint(s)

Workforce Data Table - B1

The percentage of formal complaints alleging harassment based on disability in FY17 was 17.2%. 

This percentage was lower than the government-wide average of 18.1% in FY17. In FY18, the 

percentage of PWD filing a formal EEO complaint alleging harassment decreased to 15.1%. This 

percentage was lower than the government-wide average of 19.7% in FY18. During FY19, the 

percentage of these type of complaints increased to 24.5%. The government-wide average is not 

available for FY19.

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

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Lack of sufficient training 

and education among 

employees and management 

how to properly handle PWD

Lack of sufficient training and education among employees and 

management has resulted in a misunderstanding of how to properly 

handle PWD. This creates conflict which may result in the filing of 

formal complaints.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

01/01/2018 03/31/2018 Yes Educate all employees and management on how to 

properly address issues that may arise with PWD.

Responsible Official(s)

Title Name Standards Address The Plan?

Persons with Disabilities Program 

Manager

Michael Brenyo Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

02/28/2018 Create and receive approval for a training module that 

can be integrated into the Civil Rights Awareness training 

that address harassment in the workplace related to 

disability and how to appropriately address issues.

Yes 02/21/2018

03/31/2018 Integrate training module and provide training to all 

employees.

Yes 02/21/2018
DHS U.S. Coast Guard FY 2022

Page 20

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

07/31/2018 Review complaint activity to see if the number of PWD 

alleging harassment have decreased, review and revise 

training as required.

Yes 09/30/2018 09/30/2018

02/28/2018 Reaffirm commitment to training and information 

sharing. Schedule regular training for Agency employees.

Yes 02/28/2019

07/31/2019 Review complaint activity to see if the number of PWD 

alleging harassment have decreased, review and revise 

training as required.

Yes 07/31/2019

03/01/2019 Conduct mid-year review of harassment based 

complaints. Address concerns or issues as required.

Yes 03/01/2019

08/01/2019 Conduct near end-of-year review of harassment based 

complaints and continue to address issues as they become 

apparent.

Yes 08/01/2019

03/01/2020 Conduct mid-year review of harassment based 

complaints. Address concerns or issues as required.

Yes 09/22/2020

08/01/2020 Conduct near end-of-year review of harassment based 

complaints and continue to address issues as they become 

apparent.

Yes 09/22/2020

08/30/2020 Complete a written analysis of reviews conducted thus far 

and provide outcomes and recommendations.

Yes 09/23/2021

Report of Accomplishments

Fiscal Year Accomplishment

2020 Reviewed complaint activity, performed training, updated procedures and policies.

2019 PWDPM provided training to 15 human resources personnel regarding accommodation process and procedure.

2019 Inter-departmental working group established to address issues that overlap civil rights, human resources, and 

the legal department.

2018 Began training workforce on new RA and PAS procedures as of 09/18/2018. PWDPM trained 28 employees 

and approximately 50 civil rights staff members. Civil rights staff conducts regular training with workforce.

2019 Reviewed complaint activity.

2018 Completed training slides for new CRA module.

2018 Reviewed complaint activity.

2019 Civil Rights Manual updated with new RA and PAS procedures.
DHS U.S. Coast Guard FY 2022

Page 21

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?

EEO Complaint(s)

Workforce Data Table - B1

The percentage of formal complaints alleging failure to provide reasonable accommodation in FY17 

was 12.1%. This percentage was lower than the government-wide average of 12.5% in FY17. In 

FY18, the percentage of PWD filing a formal EEO complaint alleging failure to provide a 

reasonable accommodation increased to 18.9%. This percentage was higher when compared to the 

government-wide average of 13.5% in FY18. The percentage of these type of complaints for FY19 

was 18.4%. During FY20, these complaints decreased to 12.20%, far below the federal average.

Y

Y

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

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Lack of sufficient training 

and education among 

employees and management

Lack of sufficient training and education among employees and 

management has resulted in a misunderstanding of how to properly 

handle reasonable accommodations. This creates conflict which may 

result in the filing of formal complaints.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

01/01/2018 02/28/2018 Yes 09/30/2020 Educate all employees and management on how to 

properly address situations that may arise out of 

reasonable accommodation requests.

Responsible Official(s)

Title Name Standards Address The Plan?

Persons with Disabilities Program 

Manager

Michael Brenyo Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

02/28/2018 Create and receive approval for a training module that 

can be integrated into the Civil Rights Awareness training 

that address accommodations in the workplace and how 

to appropriately handle them.

Yes 02/21/2018

03/31/2018 Integrate training module and provide training to all 

employees.

Yes 02/21/2018
DHS U.S. Coast Guard FY 2022

Page 22

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

07/31/2018 Review complaint activity to see if the number of PWD 

alleging failure to accommodate have decreased, review 

and revise training as required.

Yes 09/30/0018 09/30/2018

02/28/2018 Reaffirm commitment to training and information 

sharing. Schedule regular training for Agency employees.

Yes 02/28/2019

07/31/2019 Review complaint activity to see if the number of PWD 

alleging failure to accommodate have decreased, review 

and revise training as required.

Yes 07/31/2019

03/01/2019 Conduct mid-year review of accommodation based 

complaints. Address concerns or issues as required.

Yes 03/01/2019

08/01/2019 Conduct near end-of-year review of accommodation 

based complaints and continue to address issues as they 

become apparent.

Yes 08/01/2019

03/01/2020 Conduct mid-year review of harassment based 

complaints. Address concerns or issues as required.

Yes 09/22/2020

08/01/2020 Conduct near end-of-year review of harassment based 

complaints and continue to address issues as they become 

apparent.

Yes 09/22/2020

Report of Accomplishments

Fiscal Year Accomplishment

2018 Began training workforce on new RA and PAS procedures as of 09/18/2018. PWDPM trained 28 employees 

and approximately 50 civil rights staff members. Civil rights staff conducts regular training with workforce.

2018 Reviewed complaint activity.

2019 Civil Rights Manual updated with new RA and PAS procedures.

2019 Reviewed complaint activity.

2019 PWDPM provided training to 15 human resources personnel regarding accommodation process and procedure.

2020 Reviewed complaint activity, performed training, updated procedures and policies.

2018 Completed training slides for new CRA module.

2019 Inter-departmental working group established to address issues that overlap civil rights, human resources, and 

the legal department.

2021 The goal was met as the current average is below the Federal average.
DHS U.S. Coast Guard FY 2022

Page 23

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 - B9

The previous time-off awards inclusion rate for PWD and PWTD for 1 – 30 hours was 20.96% and 

19.00% respectively. The rate for employees with no disability was 34.42%. PWD and PWTD timeoff awards for 1 – 30 hours inclusion rate was lower than the rate of employees with no disability. 

Also, the cash awards inclusion rate for PWD and PWTD for $1000 - $5000 and more was 70.47% 

and 68.85% respectively. The rate for employees with no disability was 81.45%. PWD cash awards 

for $1000 - $5000 and more inclusion rate was lower than the rate of employees with no disability. 

PWTD cash awards for $1000 - $2999 and $4000 - $5000+ inclusion rate was lower than the rate of 

employees with no disability. The CG’s FY22 data showed triggers continue to exist across 

multiple awards categories. (See Part J; Section IV – C (2))

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

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

Conduct further analysis to 

determine if there is a barrier.

To be determined.

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

02/28/2020 03/31/2020 No 08/30/2024 Increase the inclusion rate of time-off and cash awards 

for persons with disabilities and persons with targeted 

disabilities to meet or exceed the rate of persons 

without disabilities.

Responsible Official(s)

Title Name Standards Address The Plan?

Chief, Office of Workforce Relations Ryan Smith No

Chief, Equity, Policy, and Complaints 

Division

TBD Yes

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

04/01/2022 Review awards policy and procedures, and application of 

such.

Yes 04/01/2022

08/30/2024 Prepare report of analysis results. Yes
DHS U.S. Coast Guard FY 2022

Page 24

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

08/30/2024 Collect, review, and analyze relative data to identify 

recurring themes and trends.

No

08/30/2024 Develop and implement action items to communicate 

equity in awards and identified issues.

No

Report of Accomplishments

Fiscal Year Accomplishment

2022 •	The Civil Rights Directorate submitted a budget request for a contractor, conducted market research, and 

drafted a statement of work in an effort to procure a vendor to conduct a barrier analysis.

•	The Office of Workforce Relations began the process of updating CG’s awards instruction and will include 

language to help address this issue.
DHS U.S. Coast Guard FY 2022

Page 25

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

The previous voluntary and involuntary separation inclusion rate for PWD was 5.42% and 2.65%. 

The voluntary and involuntary separation rate for employees without disabilities was 5.01% and 

2.20% respectively. PWD voluntarily and involuntarily separated at rates higher than persons 

without disabilities. Triggers exist for PWD among voluntary and involuntary separations. The 

voluntary and involuntary separation inclusion rate for PWTD was 5.92% and 1.25%. The 

voluntary and involuntary separation rate for employees without disabilities was 5.01% and 2.20% 

respectively. PWTD voluntarily separated at a rate higher than persons without disabilities. A 

trigger exists for PWTD among voluntary separations. The CG’s FY22 data showed triggers 

continue to exist. (See Part J – Section V; A (2-3))

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

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

TBD TBD

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

07/30/2021 02/28/2022 No 12/30/2023 Decrease the voluntary and involuntary separation 

inclusion rate for PWD and voluntary separation 

inclusion rate for PWTD to below the rate of those 

without disabilities.

Responsible Official(s)

Title Name Standards Address The Plan?

Civil Rights Directorate Chief, Equity, 

Policy, and Complaints Division

TBD Yes

Chief, Office of Workforce Relations Ryan Smith No

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/01/2022 Implement CG Exit Survey. Yes 09/01/2022

05/13/2022 Review and analyze exit survey data. Yes 12/30/2023

12/30/2022 Develop and implement Remote Work Policy. Yes 10/27/2022
DHS U.S. Coast Guard FY 2022

Page 26

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

01/30/2023 Issue Remote Work Program guidance and program 

requirements to civilian workforce.

Yes 11/02/2022

12/30/2023 Establish CG Engagement Steering Committee to 

emphasize participation in FEVS, Exit Survey, and other 

CG Surveys and role of employee engagement in 

improving workforce morale, recruitment and retention.

Yes

12/30/2023 Develop 2023 CG Employee Engagement Action plan 

with goal to increase participation in employee feedback 

platforms in order to improve targeted action planning.

Yes

Report of Accomplishments

Fiscal Year Accomplishment

2022 •	The Civil Rights Directorate submitted a budget request for a contractor, conducted market research, and 

drafted a statement of work in an effort to procure a vendor to conduct a barrier analysis.

•	The Coast Guard issued Remote Work Policy October 27, 2022. In addition, an ANCHR (Advisory Notice 

from Civilian Human Resources) was issued on November 2, 2022, to all civilian employees announcing the 

Remote Work Program requirements and eligibility.

•	Coast Guard implemented the CG Exit Survey to collect improved data on separating civilian employees. 

Data collection is underway.
DHS U.S. Coast Guard FY 2022

Page 27

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?

Other

Workforce Data Table - B1

All Schedule A employees are not converted to permanent positions after two years of satisfactory 

performance.

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 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

TBD TBD

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

06/30/2020 06/30/2020 Yes 08/30/2024 Convert Schedule A employees to permanent positions 

after two years of satisfactory performance.

Responsible Official(s)

Title Name Standards Address The Plan?

Civil Rights Directorate Chief, Equity, 

Policy, and Complaints Division

TBD Yes

Chief, Office of Civilian Human 

Resources Operations

Diane Beatrez No
DHS U.S. Coast Guard FY 2022

Page 28

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

09/30/2020 The Selective Placement Program Coordinator (SPPC) 

will continue sending a list of Schedule A employees 

eligible for conversion to the Office of Civilian Human 

Resources Operations at the end of each quarter. The 

DEIA liaison in the Office of Civilian Human Resources 

Operations will reach out to hiring managers and HR 

specialists and send them list of those Schedule A eligible 

employees on a quarterly basis.

Yes 08/28/2020

01/30/2022 Responsible POC’s will monitor quarterly. Yes

10/01/2022 Send reminders to management team about pending 

Schedule A conversions.

Yes

Report of Accomplishments

Fiscal Year Accomplishment

2020 The CG converted six (6) of 19 Schedule A employees with a disability in FY 2020. The Selective Placement 

Program Coordinator (SPPC) provides a list of Schedule A employees eligible for conversion to the Office of 

Civilian Human Resources Operations, CG-123 for subsequent dissemination to management. The SPPC will 

continue to provide a list at the end of each quarter.

2022 •	The Civil Rights Directorate submitted a budget request for a contractor, conducted market research, and 

drafted a statement of work in an effort to procure a vendor to conduct a barrier analysis.

•	The CG converted 10 eligible Schedule A employees to permanent positions.

2021 Established a process where a list of eligible Schedule A candidates for conversion is sent to the Office of 

Civilian Human Resources Operations. 

Converted nine eligible Schedule A employees to permanent positions.
DHS U.S. Coast Guard FY 2022

Page 29

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 - B9

Prior quality step increase (QSI) inclusion rate for PWTD was 0.93%. The QSI rate for employees 

with no disability was 2.95%. PWTD QSI inclusion rate was lower than the rate of employees with 

no disabilities. The CG’s FY22 data showed a trigger exist for PWD. (See Part J – Section IV; C 

(2))

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

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

TBD TBD

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

06/30/2020 06/30/2021 Yes 09/30/2024 Increase the inclusion rate for QSIs for PWTD to meet 

or exceed the rate of those without disabilities.

Responsible Official(s)

Title Name Standards Address The Plan?

Civil Rights Directorate Chief, Equity, 

Policy, and Complaints Division

TBD Yes

Chief, Office of Workforce Relations Ryan Smith No

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

05/31/2022 Review policy and procedures, and application of such. Yes 05/31/2022

05/31/2022 Conduct trend analysis of QSI distribution data. Yes 05/31/2022

09/30/2024 Update policy to include language for equitable 

distribution of QSI’s.

Yes
DHS U.S. Coast Guard FY 2022

Page 30

Report of Accomplishments

Fiscal Year Accomplishment

2022 •	The Civil Rights Directorate submitted a budget request for a contractor, conducted market research, and 

drafted a statement of work in an effort to procure a vendor to conduct a barrier analysis.

•	The Office of Workforce Relations began the process of updating CG’s awards instruction and will include 

language to help address this issue.

•	Conducted trend analysis of QSI distribution data.
DHS U.S. Coast Guard FY 2022

Page 31

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 - B8

Previous PWTD participation rate among internal applicants for promotions to SES positions was 

3.57%. The qualified internal applicants’ rate for PWTD was 0.00 % compared to the internal 

selection rate of 0.00%. Although PWTD were among internal applicants for promotions to SES 

positions, they were not among qualified internal applicants and internal selectees. The new hires 

qualified applicant pool rate for PWD was 8.93% for promotions to SES positions, compared to 

their selection rate of 0.00%. PWD were not among new hires selectees for promotions to SES 

positions, although they were among qualified applicants. The new hires qualified applicant pool 

rate for PWTD was 3.77% for promotions to SES positions, compared to their selection rate of 

0.00%. PWTD were not among new hires selectees for promotions to SES positions, although they 

were among qualified applicants. The qualified internal applicants’ rate for PWTD was 2.12 % 

compared to their internal selection rate of 0.00%. PWTD were not among internal selections for 

promotions to executive positions, although they were among qualified applicants. The new hires 

qualified applicant pool rate for PWTD was 3.27% for promotions to executive positions, compared 

to their selection rate of 0.00%. PWTD were not among internal selections for promotions to 

executive positions, although they were among qualified applicants. Data for FY22 showed triggers 

continue to exist. Data for FY22 showed triggers continue to exist. (See Part J – Section IV (D))

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

Source of the Trigger:

Specific Workforce Data 

Table:

Barrier Analysis Process 

Completed?:

Barrier(s) Identified?:

Barrier Name Description of Policy, Procedure, or Practice

TBD TBD

Objective(s) and Dates for EEO Plan

Date 

Initiated

Target Date Sufficient 

Funding / 

Staffing?

Date 

Modified

Date 

Completed

Objective Description

10/01/2020 09/30/2022 Yes 08/30/2024 Increase the internal selections and new hires rate of 

persons with disabilities and persons with targeted 

disabilities for promotions to management and senior 

level positions to meet or exceed the respective 

groups’ participation qualified applicants' rate.

Responsible Official(s)

Title Name Standards Address The Plan?

Civil Rights Directorate Chief, Equity, 

Policy, and Complaints Division

TBD Yes

Deputy Assistant Commandant for 

Human Resources

Dr. D.M. Navarro No
DHS U.S. Coast Guard FY 2022

Page 32

Planned Activities Toward Completion of Objective

Target Date Planned Activities Sufficient

Staffing &

Funding?

Modified

Date

Completion

Date

04/30/2022 CG-1 will send an email to all selecting officials to 

consider PWD, PWTD applicants when SES vacancies 

occur to enhance promotion.

Yes 06/10/2022 10/31/2022

09/30/2022 Conduct outreach to Disability organizations to post 

JOAs to increase the number of qualified applicants.

Yes 08/30/2024

Report of Accomplishments

Fiscal Year Accomplishment

2022 •	The Civil Rights Directorate submitted a budget request for a contractor, conducted market research, and 

drafted a statement of work in an effort to procure a vendor to conduct a barrier analysis.

•	CG-1D sent an email to all Flag Officers and SESs to encourage recruiting and applications for a diverse 

candidate pool.

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

Barrier #1: FY20 - Some of the complaint reviews were conducted later in order to collect the data in a more effective manner. 

Barrier #2: FY20 - Some of the complaint reviews were performed later than anticipated in order to collect the data in a more 

effective manner.

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

barrier(s).

Barrier #1 and Barrier #2: By more fully educating employees and managers on their obligations and responsibilities related to the 

RA and PAS process, it helps to eliminate possible areas of conflict which may develop. It ensures a more collaborative and 

solution based approach to requests. A review of complaint activity has helped identify possible areas of improvement. The updated 

civil rights manual should help address some difficulty related to the accommodation process. One of the inter-departmental 

working group’s goals is to address accommodation related issues before they become more serious. Barrier#1: FY20 - Regular 

reviews of complaint activity helped ensure the CG could remedy any issues that may develop. Updated training and procedures 

helped address issues relating to disability related complaints. Barrier #2: FY20 - By monitoring reasonable accommodation 

complaint activity, we were positioned to better remedy any issues that may have developed. The training and updated procedures 

helped address issues related to the accommodation process.

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.

Barrier #1: It is possible that as more individuals become aware of their rights and options regarding harassment based on disability, 

the number of complaints as a percentage may rise in the short term. USCG will continue to provide training and information to 

employees and managers to further educate them on the RA and PAS process. FY20 - The number of harassment complaints are 

trending downward, but they are not below the federal average. Further training and guidance may aid in supporting this downward 

trend. Barrier #2: There is still a trigger because it exceeds the government-wide average. USCG will continue to provide training 

and information to employees and managers to further educate them on the RA and PAS process. Feedback from the employees/

managers and the complaints themselves will be analyzed to develop possible ways through which the trigger can be improved. 

FY20 - The CG successfully obtained a percentage that is below the federal average. This trigger is corrected.