NATIONAL AERONAUTICS AND SPACE 

ADMINISTRATION (NASA) 

MODEL EQUAL EMPLOYMENT OPPORTUNITY 

PROGRAM STATUS REPORT: FY 2019 

OFFICE OF DIVERSITY AND EQUAL OPPORTUNITY 

 
Cover photo credit: Apollo 11 Landing Site, May 22, 2012, NASA/Goddard/Arizona State University, 

accessed at: <https://moon.nasa.gov/resources/23/apollo-11-landing-site/>. In FY 2019, NASA celebrated 

the 50th anniversary of the Apollo 11 moon landing. 
 

 

 

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

MODEL EQUAL EMPLOYMENT OPPORTUNITY PROGRAM STATUS REPORT: 

FY 2019 

Table of Contents 

Parts A-D: Agency Information ..........................................................................................3 

Part E: Executive Summary ................................................................................................5 

Section I. Agency Mission and Leadership .................................................................5 

Section II. The Six Essential Elements of a Model EEO Program ...............................5 

Demonstrated Commitment of Agency Leadership...........................................6 

Integration of EEO into the Agency’s Strategic Mission .....................................6 

Management and Program Accountability.........................................................7 

Proactive Prevention of Unlawful Discrimination ..............................................7 

Efficiency .............................................................................................................9 

Responsiveness and Legal Compliance ...............................................................9 

Section III. Workforce Analyses..................................................................................9 

Section IV. FY 2019 Model EEO Agency Plan Accomplishments..............................11 

Section V. FY 2020 Planned Activities ......................................................................12 

Conclusion ................................................................................................................13 

Part F: Certification of Establishment of Continuing EEO Programs ...............................15 

Part G: Agency Self-Assessment Checklist - FY 2019 .......................................................17 

Part H: Essential Element Deficiencies and Planned Activities........................................30 

Part I: Barrier Analysis and Planned Activities.................................................................36 

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

of Persons with Disabilities ..............................................................................................39 

Section I: Efforts to Reach Regulatory Goals ...........................................................39 

Section II: Model Disability Program........................................................................40 

A. Plan to Provide Sufficient & Competent Staffing for the Disability Program 

...........................................................................................................................40 

B. Plan to Ensure Sufficient Funding for the Disability Program ......................41 

Section III: Plan to Recruit and Hire Individuals with Disabilities ............................41 

A. Plan to Identify Job Applicants with Disabilities...........................................41 

i 
 

 

B. Plan to Establish Contacts with Disability Employment Organizations........43 

C. Progression Towards Goals (Recruitment and Hiring) .................................43 

Section IV: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities................................................................................................................44 

A. Advancement Program Plan .........................................................................44 

B. Career Development Opportunities.............................................................45 

C. Awards ..........................................................................................................46 

D. Promotions ...................................................................................................46 

Section V: Plan to Improve Retention of Persons with Disabilities .........................50 

A. Voluntary and Involuntary Separations........................................................50 

B. Accessibility of Technology and Facilities .....................................................51 

C. Reasonable Accommodation Program .........................................................51 

D. Personal Assistance Services Allowing Employees to Participate in the

Workplace.........................................................................................................52 

Section VI: EEO Complaint and Findings Data..........................................................52 

A. EEO Complaint Data Involving Harassment ..................................................52 

B. EEO Complaint Data Involving Reasonable Accommodation (RA) ...............52 

Section VII: Identification and Removal of Barriers.................................................53 

Appendix A: Data Analyses ..............................................................................................56 

Workforce Summary ................................................................................................56 

Occupational Categories, by Race and Ethnicity......................................................58 

Individuals with Disabilities ......................................................................................61 

Federal Employee Viewpoint Survey (FEVS) Results ...............................................62 

Appendix B: Documents Required by EEOC .....................................................................64 

Appendix C: List of Frequently Used Acronyms...............................................................65 

ii 
PARTS A-D: AGENCY INFORMATION 

MD-715

PART A - D 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

For period covering October 1, 2018 to September 30, 2019. 

PART A 

Department 

or Agency 

Identifying 

Information 

Agency National Aeronautics and Space Administration 

Address 300 E Street, SW 

City, State, Zip Code Washington, DC 20546 

CPDF Code NN00 

FIPS code(s) 01, 06, 11, 12, 22, 24, 28, 39, 48, 51 

PART B 

Total 

Employment 

Permanent Workforce 17,459 

Temporary Workforce 92 

TOTAL EMPLOYMENT 17,551 

PART C1 Leadership Name Title 

Head of 

Agency and 

Head of 

Agency 

Designee 

Head of Agency James F. Bridenstine Administrator 

Head of Agency Designee 

PART C2 

Agency 

Official(s) 

Responsible 

for Oversight 

of EEO 

Programs 

EEO Program Staff Name/Title 

Occupational 

Series/Pay 

Plan and 

Grade 

Phone 

Number Email Address 

Principal EEO 

Director/Official 

Stephen T. Shih, Associate 

Administrator, Office of 

Diversity and Equal 

Opportunity (ODEO) 

0260/SES (202) 358-

2167

stephen.t.shih 

@nasa.gov 

Affirmative Employment 

Program Manager 

Janet Sellars, Director, 

Diversity and Data/ 

Analytics Division, ODEO 

0301/SES (202) 358-

0730

janet.e.sellars 

@nasa.gov 

Complaint Processing 

Program Manager 

Richard N. Reback, 

Director, Complaints and 

Programs Division, ODEO 

0260/SES (202) 358-

1597

richard.n.reback 

@nasa.gov 

Diversity & Inclusion 

Officer 

Barbara Spotts, Equal 

Employment Manager 

0260/GS-15 (202) 358-

0946

barbara.l.spotts 

@nasa.gov 

Hispanic Program 

Manager (SEPM) 

Nicole Lassiter, Equal 

Opportunity Specialist 

0260/GS-14 (202) 358-

1932

nicole.e.lassiter 

@nasa.gov 

Women's Program 

Manager (SEPM) 

Nicole Lassiter, Equal 

Opportunity Specialist 

0260/GS-14 (202) 358-

1932

nicole.e.lassiter 

@nasa.gov 

Disability Program 

Manager (SEPM) 

Rebecca Doroshenk, 

Program Analyst 

0260/GS-14 (202) 358-

0038

Rebecca.d.doroshenk 

@nasa.gov 

3 
Selective Placement 

Program Coordinator 

(Individuals 

w/Disabilities) 

Joan Davidson, Human 

Resources Specialist 

0201/GS-14 (202) 358-

1033

joan.b.davidson 

@nasa.gov 

Reasonable 

Accommodation Program 

Manager 

Rebecca Doroshenk, 

Program Analyst 

0260/GS-14 (202) 358-

0038

Rebecca.d.doroshenk 

@nasa.gov 

Anti-Harassment 

Program Manager 

David Chambers, Equal 

Opportunity Compliance 

Manager 

0360/GS-15 (202) 358-

3158

david.r.chambers 

@nasa.gov 

ADR Program Manager Dorenda King, Equal 

Opportunity Manager 

0260/GS-15 (202) 358-

0726

dorenda.r.king 

@nasa.gov 

Compliance Manager Judy Caniban, Equal 

Employment Manager 

0260/GS-15 (202) 358-

0726

judymarie.d.caniban 

@nasa.gov 

Principal MD-715 

Preparer 

Rebecca Kraus, Civil 

Rights Analyst 

0160/GS-15 (202) 358-

2303

rebecca.s.kraus 

@nasa.gov 

Other EEO Staff Vincent Patterson, Equal 

Employment Manager 

0260/GS-15 (202) 358-

0952

vincent.e.patterson 

@nasa.gov 

PART D-1 

List of 

Subordinate 

Components 

Covered in 

This Report 

Subordinate Component and Location 

(City/State) 

CPDF and FIPS codes 

Ames Research Center (ARC), Moffett Field/CA NN21 06001, 06003, 06005, 06013, 06085, 

06087 

Armstrong Flight Research Center (AFRC), 

Edwards/CA

 NN24 06029, 06037 

Glenn Research Center (GRC), Cleveland/OH NN22 39035, 39055, 39143, 39153, 39085, 

39093 

Goddard Space Flight Center (GSFC), Greenbelt/MD NN51 24033, 24031, 24027, 24003, 11001, 

51001 

Headquarters (HQ), Washington/DC NN10 11001, 24033, 24031, 51013, 51059, 

51107 

Johnson Space Center (JSC), Houston/TX NN72 48157, 48167, 48291, 48473, 48071 

Kennedy Space Center (KSC), KSC/FL NN76 12009, 12095 

Langley Research Center (LaRC), Hampton/VA NN23 51115, 51650, 51700 

Marshall Space Flight Center (MSFC), Huntsville/AL NN62 01089 

NASA Shared Services Center (NSSC), Stennis/MS NN10 28045, 28047, 28059 

Stennis Space Center (SSC), Stennis/MS NN64 28045, 28047, 28059 

PART D-2 

Mandatory 

and Optional 

Documents 

for this 

Report 

See Appendix B. 

4 
PART E: EXECUTIVE SUMMARY 

MD-715

PART E

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

National Aeronautics and Space Administration For period covering October 1, 2018 to September 30, 2019. 

EXECUTIVE SUMMARY 

Section I. Agency Mission and Leadership 

As the world leader in human space exploration, space technology, Earth and space science, and 

aeronautics research, the mission of the National Aeronautics and Space Administration (NASA) is to 

“lead an innovative and sustainable program of exploration with commercial and international 

partners to enable human expansion across the solar system and bring new knowledge and 

opportunities back to Earth, support growth of the Nation’s economy in space and aeronautics, 

increase understanding of the universe and our place in it, work with industry to improve America’s 

aerospace technologies, and advance American leadership” (NASA 2018 Strategic Plan). The work 

of NASA benefits Americans and all humanity. NASA inspires the world with exploration of new 

frontiers, discovery of new knowledge, and development of new technology. 

With top-level support from the NASA Administrator and NASA’s leadership team, the NASA Office 

of Diversity and Equal Opportunity (ODEO) and Center equal employment opportunity (EEO) offices 

engaged in significant activities in FY 2019 to advance EEO in the NASA workforce. In 2019, for the 

eighth year in a row, NASA was ranked the best place to work in the Federal Government by the 

Partnership for Public Service. NASA ranked the highest among large agencies in all categories, 

including fairness in leadership and support for diversity. The Agency’s Federal Employee Viewpoint 

Survey (FEVS) results for 2019 also show that NASA ranked highest among large agencies on the 

Engagement Index (83 percent positive responses) and the New Inclusion Quotient (New IQ) Index 

(79 percent positive responses) (see Appendix B, Figures 4 and 5). 

The FEVS is just one measure of NASA’s achievements in EEO and diversity and inclusion (D&I). NASA 

also measures the success of its EEO program against the six Essential Elements of a Model EEO 

Agency, as outlined by the U.S. Equal Employment Opportunity Commission (EEOC) in Management 

Directive 715 (MD-715). FY 2019 accomplishments and EEO successes are identified and discussed 

below. 

Section II. The Six Essential Elements of a Model EEO Program 

NASA carefully examined its current EEO program status and compared it to the Model EEO Program 

Self-Assessment measures (Part G). Of the 157 measures, NASA identified four deficiencies within 

its EEO program reflecting a compliance rate of 97 percent. Utilizing the results of the self5 
assessment, the Agency developed plans to address program deficiencies (Part H) and workforce 

triggers regarding participation rates for certain groups (Parts I and J). 

Demonstrated Commitment of Agency Leadership 

During FY 2019, the NASA Administrator further demonstrated his commitment to EEO and diversity 

with the launch of an enterprise-wide Unity Campaign. The goal of the Campaign is to “power and 

propel” NASA’s workforce and internal organizations to work more effectively to accomplish NASA’s 

missions. The Administrator enabled continued collaboration by charging ODEO to lead this effort 

in partnership with the Mission Support Directorate and the Office of the Chief Human Capital Officer 

(OCHCO). NASA recognizes that organizations thrive when the environment is one of cooperation 

where leadership wholeheartedly values and empowers their diverse workforce. Further, when 

leaders are equipped with skills to build psychological safety, encourage individual well-being, and 

belonging, employees will give discretionary effort beyond what is required. The NASA Unity 

Campaign expounds on the concept of “workplace civility” as introduced through the EEOC Civility 

Training initiative in 2017 to include the concept of “workforce unity” which encompasses an 

organizational culture where everyone is able and willing to transcend beyond self-focused issues 

and fully engage collectively in behaviors that contribute to mission success. These behaviors will 

also aid in connecting the workforce to improve relationships and enhance trust among NASA 

teammates. As NASA embarks on Project Artemis, to land the first woman and the next man on the 

moon, it will be essential for leaders at all levels of the organization to fully understand and embrace 

the latest research in leadership to maximize effectiveness and innovation in every pocket of the 

organizational culture. 

During the reporting period, NASA commissioned the development of a leadership training course 

on incorporating unity as a leadership ideology to aid leaders in creating a more inclusive work 

environment. 

Integration of EEO into the Agency’s Strategic Mission 

NASA is committed to attracting, selecting, developing, empowering, and retaining a highly capable 

and talented workforce. Specifically, Strategic Objective 4.4 of the 2018 NASA Strategic Plan is to: 

“Cultivate a diverse and innovative workforce with the right balance of skills and experience to 

provide an inclusive work environment in which employees that possess varying perspectives, 

education levels, life experiences, and backgrounds can work together and remain fully engaged in 

our mission.” The plan identifies strategies relating to equal employment opportunity, diversity, and 

inclusion for the NASA workforce, including: proactive efforts to prevent discrimination and ensure 

EEO in the workplace; regular assessment of the FEVS New IQ Index; measurement of increases in 

participation rates of employee groups through comparison with the relevant civilian labor force 

(RCLF); targeted outreach and recruitment efforts to increase diversity in the Agency’s internship, 

fellowship, and early career hiring programs; and greater access to career opportunities through 

mentoring and other forms of formal and informal education and awareness (such as networking 

and shadowing) for both managers and employees. 

6 
Management and Program Accountability 

NASA managers and supervisors are accountable for advancing EEO in the workplace through their 

performance evaluations. NASA ODEO reports quarterly on EEO and D&I performance outcomes at 

the Baseline Performance Review (BPR) meeting, which is chaired by the NASA Associate

Administrator and attended by Officials-in-Charge. In addition, the Associate Administrator (AA) for 

Diversity and Equal Opportunity is a full and active member of NASA’s senior leadership team as 

evidenced by regular participation on various decision-making bodies, boards, panels, and councils,

such as: 

• Senior Management Council (SMC). The AA, ODEO, is part of the Agency’s senior decisionmaking body for strategic direction and planning. The SMC is led by the NASA 

Administrator; its purpose is to determine the Agency strategic direction, assess progress 

toward achieving its vision, and serve as a forum for review and discussion of issues 

affecting Agency management. 

• Mission Support Council (MSC). The AA, ODEO, serves on the MSC, which is the Agency's 

senior decision-making body regarding the integrated mission support portfolio. The 

council members are advisors to the Deputy Associate Administrator. The MSC assesses 

and determines mission support requirements to enable the successful accomplishment 

of the Agency's mission. 

• Performance Review Board (PRB). As a member of the PRB, the AA, ODEO, participates in 

annual performance reviews of NASA’s Senior Executive Service (SES) members. 

• Executive Resources Board (ERB). The AA, ODEO, is on the ERB, which provides advice, 

counsel, and recommendations for consideration by the Administrator relating to 

management of executive human resources at NASA, inclusive of personnel policy, 

planning, and development. 

Further, per NASA’s Procedural Requirement (NPR) 3335.1, Merit Promotion and Placement Plan, 

supervisors are responsible for the following: 

• Integrating D&I into strategic recruitment decision-making to enhance organizational 

effectiveness and help achieve mission goals. 

• Participating in the development of recruitment strategies aimed at reaching qualified 

individuals who are underrepresented in the workplace as identified in the Agency’s 

Federal Equal Opportunity Recruitment Program (FEORP) plans and barrier analyses. 

Proactive Prevention of Unlawful Discrimination 

In FY 2019, NASA completed another successful year of its Anti-Harassment Campaign. The

Campaign, launched in FY 2018, emphasizes a broad application of anti-harassment policy and 

procedures going beyond legal compliance and focusing on workforce and mission. Since FY 2018, 

reports of harassment have increased dramatically from 55 in FY 2017, to 95 in FY 2018, and 91 in FY 

2019. NASA views this increase to be the result of the Campaign, as the Campaign has made 

employees more aware of the process and has helped to create an environment in which employees 

7 
feel safe coming forward with their concerns. NASA’s efforts in FY 2019 demonstrated continued 

success in this area, with expeditious processing averaging less than 60 days. The Agency’s focus on 

prevention yielded broad proactive efforts (including corrective action in 35 percent of cases, despite 

no violation of the anti-harassment policy) and success in preventing harassment as evidenced by 

the low number 19 of formal EEO complaints filed in FY 2019 alleging harassment (none of which 

alleged sexual harassment). 

In FY 2019, the AA, ODEO, continued conducting in-person trainings at NASA Centers and ODEO staff 

conducted follow-up training for Center Anti-Harassment Coordinators. In May 2019, NASA

deployed a new on-line “gamified” anti-harassment training for Agency employees and contractors; 

more than 3,000 individuals took the new training. The training received national recognition when 

NASA received the Gamicon Award for the “Best Use of Narrative in Gamification Design.” 

ODEO staff members conducted an array of training for NASA employees which included modules 

on EEO, reasonable accommodation, alternative dispute resolution, and diversity and inclusion. Such 

training included: 

• Cognitive and Unconscious Biases in Decision Making. This course enabled participants to 

identify the role that poor communication and cognitive and unconscious biases play in the 

decision-making process. Course participants were trained on understanding how decisionmaking can be compromised at all levels in an organization through reliance on heuristics 

(mental shortcuts) such as groupthink, optimism bias, confirmation bias, and unconscious 

bias. This course was delivered to employees at NASA Headquarters and Stennis Space 

Center. NASA plans to hold additional course offerings at Glenn Research Center in FY 2020. 

• Diversity Dialogue Facilitator Training Program. The purpose of this course was to build a 

cadre of facilitators to assist the workforce in addressing diversity and inclusion in the 

workplace. The goal of the training program was to develop skills in understanding group 

dynamics, learn techniques to effectively facilitate diversity dialogue, and learn fundamental 

and practical tools to effectively manage highly sensitive topics and the dialogue

process. Seventeen NASA employees completed the training and NASA plans to use this 

cadre of Diversity Dialog Facilitators throughout the enterprise in FY 2020. 

The Agency continued its robust outreach and recruiting presence at national affinity group 

conferences/events that included the following in FY 2019: 

• Black Engineer of the Year Awards Conference. 

• Society of Asian Scientists and Engineers (both national and regional conferences). 

• Society of Black Engineers Conference. 

• Federal Asian Pacific American Council (ODEO AA served as the keynote speaker at the 

conference). 

• Society of American Indian Government Employees Conference. 

• Society of Hispanic Professional Engineers Conference (both national and regional 

conferences). 

• American Indian Science and Engineering Society National Conference. 

8 
• Society for Advancement of Hispanics/Chicanos and Native Americans in Science Conference. 

• Society of Women Engineers Conference. 

Efficiency 

To improve effectiveness and efficiency in NASA Center EEO programs, the Agency sponsored Special 

Emphasis Program (SEP) manager training for 15 staff members at the NASA Stennis Space 

Center. Additionally, the Agency held SEP meetings throughout the year. Current plans include 

hosting an agency-sponsored training session at NASA Glenn Research Center in FY 2020. 

NASA also continues to use Alternative Dispute Resolution (ADR) and the Anti-Harassment Program 

(AHP) to efficiently and effectively address issues in the workplace. In FY 2019, NASA resolved AHP 

cases in an average of 54 days, compared to 67 days for ADR and 685 days through the formal EEO 

process. For ADR, 58 percent of EEO complainants participated at the informal stage, compared to 

53 percent Government-wide, and 50 percent of complainants participated at the formal stage, 

compared to 9 percent Government-wide.1 

Responsiveness and Legal Compliance 

In FY 2019, NASA posted timely No FEAR Act data, met established deadlines for submitting the FY 

2018 MD-715 report, and submitted a timely Annual Statistical Report of Discrimination Complaints 

(EEOC Form 462) to EEOC. NASA also improved the timeliness of its EEO counseling, investigations, 

and issuance of Final Agency Decisions (FADs). In particular, EEO counseling improved from 75 

percent timely in FY 2018 to 89 percent timely in FY 2019, and 100 percent of investigations were 

completed timely (compared to 94 percent in FY 2018). NASA continues to eliminate its backlog and 

improve the timeliness of FADs, significantly reducing its inventory of untimely EEO complaints 

pending adjudication in FY 2019. 

Section III. Workforce Analyses 

In order to attract and retain a diverse workforce, NASA works to ensure equal opportunity in all 

aspects of its human capital management, including recruitment, hiring, promotions, awards, etc. 

Moreover, NASA monitors workforce composition data to determine if discrepancies exist in 

participation of any demographic group.2 The FY 2019 workforce composition data revealed the 

following triggers (see Appendix B, Table 1): 

1

 In May 2017, NASA submitted to EEOC its method for measuring ADR participation, to ensure the Agency is accurately 

capturing the status of ADR. Instead of only measuring closed cases (462, part X and XI), NASA looks at the total number of new 

informal and formal complaints within the reporting period and tracks how many of those were offered and participated in ADR. 

NASA measures participation by determining how many complainants who were offered ADR accepted and participated in ADR. 2

 A “snapshot” of the NASA workforce can reveal “triggers” for various groups at certain grade levels and in leadership positions 

when compared to: their total representation at NASA; the Federal STEM workforce; and the U.S. civilian labor force (see Appendix 

B, Table 1). As defined by EEOC, a trigger is a situation that alerts the Agency to the possible existence of a barrier to EEO. For 

example, low participation (or representation) of a group in certain occupations, or among employees receiving promotions, 

awards, etc., may indicate that there is an Agency policy or practice that limits the full participation of that group. A trigger does 

not by itself demonstrate a barrier to equal opportunity; it indicates an area to be monitored or further analyzed. 

9 
• Hispanics and Women are employed at NASA in lower percentages than their representation

in the National Civilian Labor Force (NCLF).3 Hispanics make up 8 percent of NASA employees

and 10 percent of the NCLF. Women make up 34 percent of NASA employees but are 48

percent of the NCLF. 

• Similar to the workforce composition findings in FY 2018, some groups are underrepresented

in the higher grades and leadership positions:

 NASA Senior Executive Service (SES) members: Asian Americans and Pacific Islanders

(AAPI), Hispanics, and individuals with disabilities (IWD) account for a lower percentage

of the SES compared to their overall representation in the NASA workforce. For example,

Hispanics and AAPI each make up 8 percent of the workforce, yet account for 4 and 5

percent, respectively, of SES employees.

 Senior Level (SL) and Senior Scientific and Professional (ST) employees: Blacks, Hispanics,

Women, and IWD are employed in lower percentages in SL and ST positions than their

overall representation in the workforce. Blacks make up 12 percent of the NASA

workforce, yet are only 2 percent of SL and ST employees. Hispanics are 8 percent of the

NASA workforce, but occupy just under 5 percent of the ST and SL positions. Women

account for 34 percent of NASA employees, yet are only 18 percent of ST and SL

employees. IWD comprise 9.5 percent of NASA employees, but only 6.5 percent of those in 

ST and SL positions.

 GS-14 and GS-15: IWD account for 7 percent of GS-14 and GS-15 employees, Blacks

account for 9 percent, and Women account for 30 percent, although they represent 10

percent, 12 percent, and 34 percent of the NASA workforce, respectively. 

Triggers also exist with regard to specific occupations when compared to the RCLF, particularly for 

AAPI (see Appendix B, Tables 2-3).4

 AAPI account for 12 percent of engineers in the RCLF but only 9 

percent of NASA engineers. AAPI also represent 14 percent of physical science positions in the RCLF,

yet account for 10 percent of NASA physical scientists. Women also represent a smaller percentage 

of physical scientists at NASA (27 percent) than in the RCLF (37 percent). 

NASA data shows AAPI, Blacks, Hispanics, Women, and IWD represent a greater proportion of those 

occupying professional administrative (PA) positions when compared to the RCLF (see Appendix B, 

Table 4). For example, 

• Hispanics account for 10 percent of Program Analysts at NASA, compared to 5 percent

in the RCLF.

3

 The NCLF includes all non-institutionalized civilians age 16 and over who are either employed or unemployed. U.S. Census 

Bureau, “Labor Force: Glossary,” accessed at <https://www.census.gov/topics/employment/labor-force/about/glossary.html>. 

The EEOC requires the use of the NCLF as a benchmark. 4 The RCLF measures individuals in the civilian labor force in occupations equivalent to occupations in the Federal Government. The 

Census Bureau defines the RCLF as “the Civilian Labor Force (CLF) data that are directly comparable (or relevant) to the population being 

considered in the labor force.” U.S. Census Bureau, “Equal Employment Opportunity Tabulation: FAQs,” accessed at 

<https://www.census.gov/topics/employment/equal-employment-opportunity-abulation/about/faq.html#par_textimage_514458183>. 

10 
• AAPI employees are 12 percent of NASA accountants, but only 9 percent of accountants 

in the RCLF. 

• IWD are 22 percent of NASA human resources (HR) specialists, yet occupy only 4 percent 

of comparable positions in the RCLF. 

• Blacks account for approximately 28 percent of NASA employees in HR, accounting, and 

contract specialist positions, more than two times their representation in those fields in 

the RCLF. 

NASA is working toward attaining the goals for the employment of IWD and individuals with targeted 

disabilities (IWTD), as established by EEOC. The goals for IWD are 12 percent of employees in grades 

GS-10 and below and 12 percent of employees in grades GS-11 and above. The goals for IWTD are 2 

percent of employees in each grade category. NASA exceeds the goals for the employment of IWD 

and IWTD in grades GS-10 and below (23.8 percent and 6.4 percent, respectively), and is slightly 

below the goals for GS-11 and above (10.6 percent and 1.8 percent, respectively). These percentages 

have increased slightly since FY 2018. (See Appendix B, Figure 4.) 

As noted in Parts I and J of this report, NASA has not completed its barrier analysis. The Agency plans 

to obtain additional data and conduct further analyses to determine the causes for any differences 

observed in the trends described above, as well as trends in recruitment, hiring, promotion, and 

employee retention. 

Section IV. FY 2019 Model EEO Agency Plan Accomplishments 

For FY 2019, NASA focused on five program deficiencies, identified in Part G: (1) development and 

issuance of an EEO policy statement, (2) issuance of Reasonable Accommodation (RA) procedures, 

(3) improvement of counseling timeliness, (4) improvement of timeliness in investigations, and (5)

improvement of timeliness in FADs (see Parts H-1, H-3, H-4, H-5, and H-6, respectively). As a result,

NASA achieved marked progress in all five areas in FY 2019, closing out three of the five action

plans. NASA finalized and published its updated RA procedures on April 22, 2019. The new

procedures incorporate requirements for the provision of Personal Assistance Services (PAS) for

IWD (Part H-3). In addition, NASA completed 100 percent of its investigations within the

timeframes established by EEOC, compared to 94 percent timely in FY 2018 (Part H-5), and issued

its EEO policy statement in March 2020 (Part H-1).

Work continues on the remaining action plans. NASA has increased counseling timeliness from 75 

percent of cases in FY 2018 to 89 percent in FY 2019 (Part H-4). NASA also continues to make 

progress in timeliness FADs (Part H-6). In FY 2019, 20 percent of FADs were timely, a 20 percent 

improvement over FY 2018. NASA hired a dedicated FAD writer in FY 2019 and instituted a rigorous 

plan to improve its timeliness in completing FADs in FY 2020. In fact, between May and November 

2019, NASA reduced its inventory of untimely EEO complaints pending adjudication by 59 percent 

(from 17 to 7). 

11 
 

 

NASA continues to collect and review data in order to improve its barrier analysis process (see Parts 

I and J). ODEO and human capital (HC) offices continue to build their partnership to address data 

needs, identify system updates to accommodate the new MD-715 tables, obtain more-detailed 

applicant flow data, and share data analyses. In FY 2019, ODEO developed standard data reports for 

each of the major NASA offices, which were used by the Director of the Diversity and Data/Analytics 

Division, ODEO, in briefing NASA officials-in-charge. In addition, ODEO drafted a plan for conducting 

an in-depth barrier analysis related to Women and AAPI in physical science positions. (See Part I.) 

Section V. FY 2020 Planned Activities 

In FY 2020, NASA intends to execute the following activities to address program deficiencies and 

triggers identified in Parts H, I, and J of this report: 

• Objective: Ensure all counseling is completed timely within 30 or 90 calendar days, 

pursuant to 29 CFR §1614.108 (Part H-4). 

 NASA intends to provide staff training in informal complaints processing, counseling

techniques, and writing counselor’s reports, as well as utilizing the Agency’s cadre of

counselors to improve timeliness of EEO counseling.

• Objective: Ensure all FADs are issued within 60 calendar days, pursuant to 29 CFR 

§1614.110(b) (Part H-6).

 NASA will continue working towards meeting timeliness requirements for issuance of

FADs.

• Objective: Strengthen data analytics capabilities for conduct in-depth barrier analyses (Parts I 

and J). 

 ODEO will continue partnering with OCHCO and other stakeholders to leverage

existing tools to collect and analyze workforce trends.

 NASA will conduct a barrier analysis regarding the employment of Women and AAPIs

as physical scientists at NASA, including tracking applicant flow data by sex and race.

 NASA will post information regarding the Architectural Barriers Act complaint process

on the Agency Web site.

 NASA will improve its collection of demographic data pertaining to career

development programs; track Schedule A hiring and conversions; and revise exit

surveys to obtain additional data related to IWD separations (to be completed in FY

2021).

 NASA will conduct barrier analysis regarding differences between the IWD inclusion

rate and hiring and promotion rates of IWD and IWTD in mission critical occupations

(to be completed in FY 2021).

Note that although NASA did not respond “yes” to Part G question B.1.a, “Is the agency head the 

immediate supervisor of the person (‘EEO Director’) who has day-to-day control over the EEO office? 

12 
[29 CFR §1614.102(b)(4)],” there is no action plan for this item as there has been no observable 

impact resulting from AA’s position in the organizational structure. (See Part H-2.) 

Conclusion 

As NASA plans its return to the Moon and on to Mars, NASA’s leadership is proud of its 

accomplishments in leveraging, empowering, and supporting a diverse talent pool to accomplish its 

mission. As the “Best Place to Work in Government,” NASA will continue to implement and create 

initiatives that will further enhance our ability to recruit, hire, develop, and retain top talent by 

cultivating an inclusive culture that fosters unity and belonging. 

13 
14 
 

 

 

 

PART F: CERTIFICATION OF ESTABLISHMENT OF CONTINUING EEO PROGRAMS 

MD-715

PART F

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

CERTIFICATION of ESTABLISHMENT of CONTINUING EQUAL EMPLOYMENT 

OPPORTUNITY PROGRAMS 

I, 

Stephen T. Shih, Associate Administrator for Diversity 

and Equal Opportunity/0260/SES 

am the 

Principal EEO 

Director/Official (Insert name, official title/series/grade above) 

for: National Aeronautics and Space Administration 

(Insert Agency/Component Name) 

The Agency has conducted an annual self-assessment of Section 717 and Section 501 programs 

against the essential elements as prescribed by EEO MD 715. If an essential element was not 

fully compliant with the standards of EEO MD 715, a further evaluation was conducted and, as 

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

included with this Federal Agency Annual EEO Program Status Report. 

The Agency has also analyzed its workforce profiles and conducted barrier analyses aimed at 

detecting whether any management or personnel policy, procedure, or practice is operating to 

disadvantage any group based on race, national origin, gender, or disability. EEO Plans to 

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

Program Status Report. 

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

EEOC review upon request. 

05/08/2020

Signature of Principal EEO Director/Official 

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

compliance with EEO MD 715. 

Date 

Digitally signed by James Bridenstine James Bridenstine Date: 2020.05.04 16:12:00 -04'00' 

Signature of Agency Head or Agency Head Designee Date 

15 
16 
PART G: AGENCY SELF-ASSESSMENT CHECKLIST - FY 2019 

MD-715

PART G

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP 

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

opportunity and a discrimination-free workplace. 

Indicator 

Measures 

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

policy statement.

Measure 

Met? Comments 

A.1.a Does the agency annually issue a signed and dated EEO 

policy statement on agency letterhead that clearly 

communicates the agency’s commitment to EEO for all 

employees and applicants? If yes, provide the annual 

issuance date in the comments column. [MD-715, II(A)] 

Yes 

NASA issued an updated 

EEO policy in March 

2020. 

A.1.b Does the EEO policy statement address all protected bases 

(age, color, disability, sex (including pregnancy, sexual 

orientation and gender identity), genetic information, 

national origin, race, religion, and reprisal) contained in the 

laws EEOC enforces? [29 CFR § 1614.101(a)] 

Yes 

Indicator 

Measures 

A.2 – The agency has communicated EEO policies and

procedures to all employees.

Measure 

Met? Comments 

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

procedures to all employees: 

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

A.2.a.2 – Reasonable accommodation procedures? [29 CFR § 

1614.203(d)(3)] Yes 

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

in the workplace and on its public Web site: 

A.2.b.1 – Business contact information for its EEO Director EEO 

Counselors, EEO Officers, Special Emphasis Program 

Managers? [29 CFR § 1614.102(b)(7)] 

Yes 

A.2.b.2 – Written materials concerning the EEO program, laws, 

policy statements, and the operation of the EEO complaint

process? [29 CFR § 1614.102(b)(5)] 

Yes 

A.2.b.3 – Reasonable accommodation procedures? [29 CFR § 

1614.203(d)(3)(i)] If yes, provide the internet address in 

the comments column. 

https://nodis3.gsfc.nasa 

.gov/displayDir.cfm?t=N 

PR&c=3713&s=1C 

Yes 

A.2.c Does the agency inform its employees about the following: 

A.2.c.1 – EEO complaint process? [29 CFR §§ 1614.102(a)(12) and 

1614.102(b)(5)] If yes, provide how often. Yes At least annually 

A.2.c.2 – ADR process? [MD-110, Ch. 3(II)(C)] If yes, provide how 

often. Yes At least annually 

A.2.c.3 Yes At least annually – Reasonable accommodation program? [29 CFR § 

1614.203(d)(7)(ii)(C)] If yes, provide how often. 

A.2.c.4 – Anti-harassment program? [EEOC Enforcement Guidance 

on Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1] If yes, provide how often. 

Yes At least annually 

17 
A.2.c.5 – Behaviors that are inappropriate in the workplace and 

could result in disciplinary action? [5 CFR § 2635.101(b)] 

If yes, provide how often. 

Yes At least annually 

Indicator

Measures 

A.3 – The agency assesses and ensures EEO principles

are part of its culture.

Measure

Met? Comments 

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

supervisors, managers, and units demonstrating superior 

accomplishment in equal employment opportunity? [29 CFR 

§ 1614.102(a) (9)] If yes, provide one or two examples in

the comments section. 

• Agency Honor Awards

– EEO Medal

• Annual Robert H.

Goddard Awards –

Diversity/EEO award

• Ames EEO/Diversity 

Excellence Award 

Yes 

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

Survey or other climate assessments to monitor the 

perception of EEO principles within the workforce? [5 CFR 

Part 250] 

Yes 

Essential Element B: INTEGRATION OF EEO INTO THE AGENCY’S STRATEGIC MISSION 

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

that is free from discrimination and support the agency’s strategic mission. 

Indicator

Measures 

B.1 - The reporting structure for the EEO program

provides the principal EEO official with appropriate

authority and resources to effectively carry out a

successful EEO program.

Measure

Met? Comments 

B.1.a Is the agency head the immediate supervisor of the person 

(“EEO Director”) who has day-to-day control over the EEO 

office? [29 CFR §1614.102(b)(4)] 

The AA for ODEO 

formally reports to the 

Deputy Associate 

Administrator and has 

access to the 

Administrator. 

See Part H-2 

No 

B.1.a.1 If the EEO Director does not report to the agency head, 

does the EEO Director report to the same agency head 

designee as the mission-related programmatic offices? If 

yes, provide the title of the agency head designee in the 

comments. 

The Mission Directorates

(Aeronautics, Human 

Exploration, Science, 

and Space Technology), 

the Mission Support 

Directorate, and the 

NASA Center Directors 

report to the Associate 

Administrator. 

No 

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

reporting structure for the EEO office? [29 CFR 

§1614.102(b)(4)]

Yes 

B.1.b Does the EEO Director have a regular and effective means of 

advising the agency head and other senior management 

officials of the effectiveness, efficiency and legal compliance 

of agency’s EEO program? [29 CFR §1614.102(c)(1); MD715 Instructions, Sec. I] 

Yes 

B.1.c During this reporting period, did the EEO Director present to 

the head of the agency, and other senior management 

officials, the "State of the agency" briefing covering the six 

essential elements of the model EEO program and the status 

of the barrier analysis process? [MD-715 Instructions, Sec. 

I)] If yes, provide the date of the briefing in comments 

column. 

Presented data at the 

Agency Baseline 

Performance Review on

6/27/19, 9/26/19, and 

11/21/19; Administrator 

briefed on 10/4/2019. 

Yes 

18 
B.1.d Does the EEO Director regularly participate in senior-level 

staff meetings concerning personnel, budget, technology, 

and other related issues? [MD-715, II(B)] 

Yes 

Indicator 

Measures 

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

program.

Measure 

Met? Comments 

B.2. Is the EEO Director responsible for the following: 

B.2.a – The implementation of a continuing affirmative 

employment program to promote EEO and to identify and 

eliminate discriminatory policies, procedures, and 

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

Yes 

B.2.b – Overseeing the completion of EEO counseling? [29 CFR 

§1614.102(c)(4)] Yes 

B.2.c – Overseeing the fair and thorough investigation of EEO 

complaints? [29 CFR §1614.102(c)(5)] Yes 

B.2.d – Overseeing the timely issuance of final agency decisions? 

[29 CFR §1614.102(c)(5)] Yes 

B.2.e – Ensuring compliance with EEOC orders? [29 CFR §§ 

1614.102(e); 1614.502] Yes 

B.2.f – Periodically evaluating the entire EEO program and 

providing recommendations for improvement to the 

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

Yes 

B.2.g If the agency has subordinate level components, does the 

EEO Director provide effective guidance and coordination for 

the components? [29 CFR §§ 1614.102(c)(2) and (c)(3)] 

Yes 

Indicator 

Measures 

B.3 - The EEO Director and other EEO professional staff

are involved in, and consulted on,

management/personnel actions.

Measure 

Met? Comments 

B.3.a Do EEO program officials participate in agency meetings 

regarding workforce changes that might impact EEO issues, 

including strategic planning, recruitment strategies, vacancy 

projections, succession planning, and selections for 

training/career development opportunities? [MD-715, II(B)] 

Yes 

B.3.b Does the agency’s current strategic plan reference 

EEO/diversity and inclusion principles? [MD-715, II(B)] 

If yes, identify the EEO principles in the strategic plan in the 

comments column. 

Strategic Objective 4.4, 

Manage Human Capital, 

references proactive 

efforts to ensure EEO 

and prevent workplace 

discrimination, such as 

the Anti-Harassment 

and Reasonable 

Accommodation 

Programs (NASA 2018 

Strategic Plan, p. 40) 

Yes 

Indicator 

Measures 

B.4 - The agency has sufficient budget and staffing to

support the success of its EEO program

Measure 

Met? Comments 

B.4.a Per 29 CFR §1614.102(a)(1), has the agency allocated 

sufficient funding and qualified staffing to successfully 

implement the EEO program, for the following areas: 

B.4.a.1 – to conduct a self-assessment of the agency for possible 

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

B.4.a.2 – to enable the agency to conduct a thorough barrier 

analysis of its workforce? [MD-715, II(B)] Yes 

19 
B.4.a.3 – to timely, thoroughly, and fairly process EEO complaints, 

including EEO counseling, investigations, final agency 

decisions, and legal sufficiency reviews? [29 CFR § 

1614.102(c)(5) & 1614.105(b) – (f); MD-110, Ch. 

1(IV)(D) & 5(IV); MD-715, II(E)] 

Yes 

B.4.a.4 – to provide all supervisors and employees with training on 

the EEO program, including but not limited to retaliation, 

harassment, religious accommodations, disability 

accommodations, the EEO complaint process, and ADR? 

[MD-715, II(B) and III(C)] If not, identify the type(s) of 

training with insufficient funding in the comments section. 

Yes 

B.4.a.5 – to conduct thorough, accurate, and effective field audits of

the EEO programs in components and the field offices, if 

applicable? [29 CFR §1614.102(c)(2)] 

Yes 

B.4.a.6 – to publish and distribute EEO materials (e.g. harassment 

policies, EEO posters, reasonable accommodations 

procedures)? [MD-715, II(B)] 

Yes 

B.4.a.7 – to maintain accurate data collection and tracking systems 

for the following types of data: complaint tracking, 

workforce demographics, and applicant flow data? [MD715, II(E)]. If not, identify the systems with insufficient 

funding in the comments section. 

Yes 

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)? [5 USC § 

7201; 38 USC § 4214; 5 CFR § 720.204; 5 CFR § 

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

Yes 

B.4.a.9 – to effectively manage its anti-harassment program? [MD715 Instructions, Sec. I; EEOC Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1] 

Yes 

B.4.a.10 – to effectively manage its reasonable accommodation 

program? [29 CFR § 1614.203(d)(4)(ii)] Yes 

B.4.a.11 – to ensure timely and complete compliance with EEOC 

orders? [MD-715, II(E)] Yes 

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

other offices within the agency? [29 CFR § 1614.102(a)(1)] Yes 

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

defined? [MD-110, Ch. 1(III)(A), 2(III), 6(III)] Yes 

B.4.d Does the agency ensure that all new counselors and 

investigators, including contractors and collateral duty 

employees, receive the required 32 hours of training, 

pursuant to Ch. 2(II)(A) of MD-110? 

Yes 

B.4.e Does the agency ensure that all experienced counselors and 

investigators, including contractors and collateral duty 

employees, receive the required 8 hours of annual refresher 

training, pursuant to Ch. 2(II)(C) of MD-110? 

Yes 

Indicator 

Measures 

B.5 – The agency recruits, hires, develops, and retains

supervisors and managers who have effective

managerial, communications, and interpersonal skills.

Measure 

Met?

Comments 

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

and supervisors received training on their responsibilities 

under the following areas under the agency EEO program: 

20 
B.5.a.1 – EEO Complaint Process? [MD-715(II)(B)] Yes 

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

1614.102(d)(3)] Yes 

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

B.5.a.4 – Supervisory, managerial, communication, and 

interpersonal skills in order to supervise most effectively in

a workplace with diverse employees and avoid disputes 

arising from ineffective communications? [MD-715, II(B)] 

Yes 

B.5.a.5 – ADR, with emphasis on the federal government’s interest 

in encouraging mutual resolution of disputes and the 

benefits associated with utilizing ADR? [MD-715(II)(E)] 

Yes 

Indicator B.6 – The agency involves managers in the

implementation of its EEO program.

Measure 

Met? Comments 

Measures 

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

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

B.6.b Do senior managers participate in the barrier analysis 

process? [MD-715 Instructions, Sec. I] Yes 

B.6.c When barriers are identified, do senior managers assist in 

developing agency EEO action plans (Part I, Part J, or the 

Executive Summary)? [MD-715 Instructions, Sec. I] 

Yes 

B.6.d Do senior managers successfully implement EEO Action Plans 

and incorporate the EEO Action Plan Objectives into agency 

strategic plans? [29 CFR § 1614.102(a)(5)] 

Yes 

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY 

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

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

Indicator C.1 – The agency conducts regular internal audits of

its component and field offices.

Measure 

Met? Comments 

Measures 

C.1.a Does the agency regularly assess its component and field 

offices for possible EEO program deficiencies? [29 CFR 

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

audits in the comments section.

NASA ODEO reviews 

Center MD-715 plans 

and accomplishments 

annually. NASA intends 

to conduct a functional 

review of field offices in 

FY 2020. 

Yes 

C.1.b Does the agency regularly assess its component and field 

offices on their efforts to remove barriers from the 

workplace? [29 CFR §1614.102(c)(2)] If yes, provide the 

schedule for conducting audits in the comments section. 

NASA ODEO reviews 

Center MD-715 plans 

and accomplishments on 

an annual basis. 

Yes 

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

comply with the recommendations of the field audit? [MD715, II(C)] Yes 

Indicator

Measures 

C.2 – The agency has established procedures to

prevent all forms of EEO discrimination.

Measure 

Met?

Comments 

C.2.a Has the agency established comprehensive anti-harassment 

policy and procedures that comply with EEOC’s enforcement 

guidance? [MD-715, II(C); Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (Enforcement Guidance), EEOC No. 915.002, § 

V.C.1 (6/18/99)]

Yes 

 

21 
 

C.2.a.1 Does the anti-harassment policy require corrective action to 

prevent or eliminate conduct before it rises to the level of 

unlawful harassment? [EEOC Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1] 

Yes 

C.2.a.2 Has the agency established a firewall between the AntiHarassment Coordinator and the EEO Director? [EEOC 

Report, Model EEO Program Must Have an Effective AntiHarassment Program (2006)] 

Yes 

C.2.a.3 Does the agency have a separate procedure (outside the 

EEO complaint process) to address harassment allegations? 

[Enforcement Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors, EEOC No. 915.002, § 

V.C.1 (6/18/99)]

Yes 

C.2.a.4 Does the agency ensure that the EEO office informs the antiharassment program of all EEO counseling activity alleging 

harassment? [Enforcement Guidance, V.C.] 

Yes 

C.2.a.5 Does the agency conduct a prompt inquiry (beginning within 

10 days of notification) of all harassment allegations, 

including those initially raised in the EEO complaint process? 

[Complainant v. Dep’t of Veterans Affairs, EEOC Appeal No. 

0120123232 (May 21, 2015); Complainant v. Dep’t of 

Defense (Defense Commissary Agency), EEOC Appeal No. 

0120130331 (5/29/15)] If no, provide the percentage of 

timely-processed inquiries in the comments section. 

Yes 

C.2.a.6 Do the agency’s training materials on its anti-harassment 

policy include examples of disability-based harassment? [29 

CFR 1614.203(d)(2)] 

Yes 

C.2.b Has the agency established disability reasonable 

accommodation (RA) procedures that comply with EEOC’s 

regulations and guidance? [29 CFR 1614.203(d)(3)] 

Yes 

C.2.b.1 Is there a designated agency official or other mechanism in 

place to coordinate or assist with processing requests for 

disability accommodations throughout the agency? [29 CFR 

1614.203(d)(3)(D)] 

Yes 

C.2.b.2 Has the agency established a firewall between the RA 

Program Manager and the EEO Director? [MD-110, Ch. 

1(IV)(A)] 

Yes 

C.2.b.3 Does the agency ensure that job applicants can request and 

receive RAs during the application and placement processes? 

[29 CFR 1614.203(d)(1)(ii)(B)] 

Yes 

C.2.b.4 Do the RA procedures clearly state that the agency should 

process the request within a maximum amount of time (e.g., 

20 business days), as established by the agency in its 

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

Yes 

C.2.b.5 Does the agency process all RA requests within the time 

frame set forth in its RA procedures? [MD-715, II(C)] If no, 

provide percentage of timely-processed requests in the 

comments column. 

Yes 

C.2.c Has the agency established procedures for processing 

requests for personal assistance services that comply with 

EEOC’s regulations, enforcement guidance, and other 

applicable executive orders, guidance, and standards? [29 

CFR 1614.203(d)(6)] 

Yes 

22 
Indicator 

Measures 

C.3 - The agency evaluates managers and supervisors 

on their efforts to ensure equal employment 

opportunity. 

Measure 

Met?

Comments 

C.3.a Pursuant to 29 CFR §1614.102(a)(5), do all managers and 

supervisors have an element in their performance appraisal 

that evaluates their commitment to agency EEO policies and 

principles and their participation in the EEO program? 

Yes 

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

performance of managers and supervisors based on the 

following: 

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

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

C.3.b.2 – Ensure full cooperation of employees under his/her 

supervision with EEO officials, such as counselors and 

investigators? [29 CFR §1614.102(b)(6)] 

Yes 

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

discrimination, including harassment and retaliation? [MD715, II(C)] Yes 

C.3.b.4 – Ensure that subordinate supervisors have effective 

managerial, communication, and interpersonal skills to 

supervise in a workplace with diverse employees? [MD715 Instructions, Sec. I] 

Yes 

C.3.b.5 – Provide religious accommodations when it does not cause 

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

C.3.b.6 – Provide disability accommodations when it does not cause 

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

C.3.b.7 – Support the EEO program in identifying and removing 

barriers to equal opportunity? [MD-715, II(C)] Yes 

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

correcting harassing conduct? [Enforcement Guidance, 

V.C.2]

Yes 

C.3.b.9 – Comply with settlement agreements and orders issued by 

the agency, EEOC, and EEO-related cases from the Merit 

Systems Protection Board, labor arbitrators, and the 

Federal Labor Relations Authority? [MD-715, II(C)] 

Yes 

C.3.c Does the EEO Director recommend to the agency head 

improvements or corrections, including remedial or 

disciplinary actions, for managers and supervisors who have 

failed in their EEO responsibilities? [29 CFR §1614.102(c)(2)]

Yes 

C.3.d When the EEO Director recommends remedial or disciplinary 

actions, are the recommendations regularly implemented by 

the agency? [29 CFR §1614.102(c)(2)] 

Yes 

C.2.c.1 Does the agency post its procedures for processing requests 

for personal assistance services on its public Web site? [29 

CFR § 1614.203(d)(5)(v)] If yes, provide the internet 

address in the comments column. 

Yes 

Published on 4/22/19; 

posted at: 

https://nodis3.gsfc.nasa

.gov/displayDir.cfm?t=N

PR&c=3713&s=1B 

Indicator 

Measures 

C.4 – The agency ensures effective coordination

between its EEO programs and Human Resources (HR)

program.

Measure 

Met? Comments 

C.4.a

Do the HR Director and the EEO Director meet regularly to 

assess whether personnel programs, policies, and Yes 

23 
procedures conform to EEOC laws, instructions, and 

management directives? [29 CFR §1614.102(a)(2)] 

C.4.b Has agency established timetables/schedules to review at 

regular intervals its merit promotion program, employee 

recognition awards program, employee development/ 

training programs, and management/ personnel policies, 

procedures, and practices for systemic barriers that may be 

impeding full participation in the program by all EEO groups? 

[MD-715 Instructions, Sec. I] 

Yes 

C.4.c Does the EEO office have timely access to accurate and 

complete data (e.g., demographic data for workforce, 

applicants, training programs, etc.) required to prepare the 

MD-715 workforce data tables? [29 CFR §1614.601(a)]

Yes 

C.4.d Does the HR office timely provide the EEO office with access 

to other data (e.g., exit interview data, climate assessment 

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

Yes 

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

collaborate with the HR office to: 

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

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

C.4.e.2 – Develop and/or conduct outreach and recruiting 

initiatives? [MD-715, II(C)] Yes 

C.4.e.3 – Develop and/or provide training for managers and 

employees? [MD-715, II(C)] Yes 

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

workplace? [MD-715, II(C)] Yes 

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

Indicator

Measures 

C.5 – Following a finding of discrimination, the agency

explores whether it should take a disciplinary action.

Measure 

Met? Comments 

C.5.a Does the agency have a disciplinary policy and/or table of 

penalties that covers discriminatory conduct? [29 CFR § 

1614.102(a)(6); see also Douglas v. Veterans 

Administration, 5 MSPR 280 (1981)] 

Yes 

C.5.b When appropriate, does the agency discipline or sanction 

managers and employees for discriminatory conduct? [29 

CFR §1614.102(a)(6)] If yes, state the number of 

disciplined/sanctioned individuals during this reporting period

in the comments. 

N/A – There were no

findings of 

discrimination in FY 

2019.

N/A 

C.5.c If the agency has a finding of discrimination (or settles cases 

in which a finding was likely), does the agency inform 

managers and supervisors about the discriminatory conduct? 

[MD-715, II(C)] 

Yes 

Indicator

Measures 

C.6 – The EEO office advises managers/ supervisors

on EEO matters.

Measure 

Met? Comments 

C.6.a Does the EEO office provide management/supervisory 

officials with regular EEO updates on at least an annual 

basis, including EEO complaints, workforce demographics 

and data summaries, legal updates, barrier analysis plans, 

and special emphasis updates? [MD-715 Instructions, Sec. I] 

If yes, identify the frequency of the updates in the comments

column. 

Yes At least annually 

24 
C.6.b Are EEO officials readily available to answer managers’ and 

supervisors’ questions/concerns? [MD-715 Instructions, Sec. Yes 

I] 

 

 

Essential Element D: PROACTIVE PREVENTION 

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

and to identify and eliminate barriers to equal employment opportunity. 

Indicator D.1 – The agency conducts a reasonable assessment

Measures to monitor progress towards achieving equal

employment opportunity throughout the year.

Measure 

Met? Comments 

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

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

D.1.b Does the agency regularly use the following sources of 

information for trigger identification: workforce data; 

complaint/grievance data; exit surveys; climate surveys; 

focus groups; affinity groups; union; program evaluations; Yes 

special emphasis programs; reasonable accommodation 

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

interest groups? [MD-715 Instruct. Sec. I] 

D.1.c Does the agency conduct exit interviews or surveys that 

include questions on how the agency could improve the 

recruitment, hiring, inclusion, retention and advancement of Yes 

individuals with disabilities? [29 CFR 1614.203(d)(1)(iii)(C)] 

Indicator D.2 – The agency identifies areas where barriers may Measure Comments 

Measures exclude EEO groups (reasonable basis to act.) Met? 

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

triggers to find possible barriers? [MD-715, (II)(B)] Yes 

D.2.b Does the agency regularly examine the impact of 

management/personnel policies, procedures, and practices 

by race, national origin, sex, and disability? [29 CFR Yes 

§1614.102(a)(3)]

D.2.c Does the agency consider whether any group of employees 

or applicants might be negatively impacted prior to making 

human resource decisions, such as re-organizations and Yes 

realignments? [29 CFR §1614.102(a)(3)] 

D.2.d Does the agency regularly review the following sources of 

information to find barriers: complaint/ grievance data, exit 

surveys, employee climate surveys, focus groups, affinity 

groups, union, program evaluations, anti-harassment 

program, special emphasis programs, RA program; antiharassment program; and/or external special interest 

groups? [MD-715 Instructions, Sec. I] If yes, identify data 

sources in the comments section. 

Yes 

Complaints, climate 

surveys (FEVS), antiharassment program 

data, affinity groups, 

special emphasis 

programs. Other data 

used, as available. 

Indicator D.3 – The agency establishes appropriate action plans Measure Comments 

Measures to remove identified barriers. Met? 

D.3.a. Does the agency effectively tailor action plans to address the 

identified barriers, in particular policies, procedures, or Yes 

practices? [29 CFR §1614.102(a)(3)] 

D.3.b If the agency identified one or more barriers during the NASA has not completed 

reporting period, did the agency implement a plan in Part I, 

including meeting the target dates for the planned activities? N/A its barrier analysis. 

[MD-715, II(D)] 

25 
D.3.c Does the agency periodically review the effectiveness of the 

plans? [MD-715, II(D)] Yes 

D.4 – The agency has an affirmative action plan for

people with disabilities, including those with targeted

disabilities.

Indicator

Measures 

Measure

Met?

Comments 

Does the agency post its affirmative action plan on its public 

Web site? [29 CFR 1614.203(d)(4)] If yes, provide the 

internet address in the comments section. 

https://www.nasa.gov/o

ffices/odeo/workforcedata 

D.4.a Yes 

Does the agency take specific steps to ensure qualified 

people with disabilities are aware of and encouraged to apply

for job vacancies? [29 CFR 1614.203(d)(1)(i)] 

D.4.b Yes 

Does the agency ensure that disability-related questions 

from members of the public are answered promptly and 

correctly? [29 CFR 1614.203(d)(1)(ii)(A)] 

D.4.c Yes 

Has the agency taken specific steps that are reasonably 

designed to increase the number of persons with disabilities 

or targeted disabilities employed at the agency until it meets

the goals? [29 CFR 1614.203(d)(7)(ii)] 

D.4.d Yes 

Essential Element E: EFFICIENCY 

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

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

Indicator

Measures 

E.1 - The agency maintains an efficient, fair, and

impartial complaint resolution process.

Measure 

Met? Comments 

E.1.a Does the agency timely provide EEO counseling? [29 CFR 

§1614.105]

The timeliness of 

processing is improving. 

See Part H-4 

No 

E.1.b Does the agency provide written notification of rights and 

responsibilities in the EEO process during the initial 

counseling session? [29 CFR §1614.105(b)(1)] 

Yes 

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

upon receipt of a formal complaint? [MD-110, Ch. 5(I)] Yes 

E.1.d Does the agency issue acceptance letters/dismissal decisions

within a reasonable time (e.g., 60 days) after receipt of the 

written EEO Counselor report? [MD-110, Ch. 5(I)] If yes, 

provide the average processing time in the comments 

section. 

The average processing 

time is 67 days. Yes 

E.1.e Does the agency ensure all employees fully cooperate with 

EEO counselors and EEO personnel in the EEO process, 

including granting routine access to personnel records 

related to an investigation? [29 CFR §1614.102(b)(6)] 

Yes 

E.1.f Does the agency timely complete investigations? [29 CFR 

§1614.108] Yes 

E.1.g If the agency does not timely complete investigations, does 

the agency notify complainants of the date by which the 

investigation will be completed and of their right to request a

hearing or file a lawsuit? [29 CFR §1614.108(g)] 

Yes 

E.1.h When the complainant does not request a hearing, does the 

agency timely issue the final agency decision? [29 CFR 

§1614.110(b)]

No See Part H-6 

E.1.i Does the agency timely issue final actions following receipt 

of the hearing file and the administrative judge’s decision? 

[29 CFR §1614.110(a)] 

Yes 

26 
E.1.j If the agency uses contractors to implement any stage of the 

EEO complaint process, does the agency hold them 

accountable for poor work product and/or delays? [MD-110, 

Ch. 5(V)(A)] If yes, describe how in the comments. 

NASA states timelines in

the statement of work, 

provides templates to 

ensure consistency, and 

requires contractors to 

provide weekly status 

updates and to inform 

the Contracting Officer’s 

Representative (COR) 

immediately of any 

issues causing delays. 

The COR has regular 

meetings with 

contractors to address 

deficiencies and/or 

areas to improve. 

Yes 

E.1.k If the agency uses employees to implement any stage of the 

EEO complaint process, does the agency hold them 

accountable for poor work product and/or delays during 

performance review? [MD-110, Ch. 5(V)(A)] 

Yes 

E.1.l Does the agency submit complaint files and other documents

in the proper format to EEOC through the Federal Sector EEO

Portal? [29 CFR § 1614.403(g)] 

Yes 

Indicator

Measures 

Measure

Met? E.2 – The agency has a neutral EEO process. Comments 

E.2.a The Office of General 

Counsel (OGC) attorney 

who provides legal 

advice to ODEO does 

not serve as the Agency 

representative. 

Has the agency established a clear separation between its 

EEO complaint program and its defensive function? [MD-110,

Ch. 1(IV)(D)] If yes, please explain in the comments 

column. 

Yes 

E.2.b When seeking legal sufficiency reviews, does the EEO office 

have access to sufficient legal resources separate from the 

agency representative? [MD-110, Ch. 1(IV)(D)] If yes, 

identify the source/location of the attorney who conducts the 

legal sufficiency review in the comments column. 

The OGC attorney who 

provides legal advice to 

ODEO does not serve as 

the Agency 

representative. 

Yes 

E.2.c If the EEO office relies on the agency’s defensive function to 

conduct the legal sufficiency review, is there a firewall 

between the reviewing attorney and the agency 

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

Yes 

E.2.d Does the agency ensure that its agency representative does 

not intrude upon EEO counseling, investigations, and final 

agency decisions? [MD-110, Ch. 1(IV)(D)] 

Yes 

E.2.e If applicable, are processing time frames incorporated for the

legal counsel’s sufficiency review for timely processing of 

complaints? [EEOC Report, Attaining a Model Agency 

Program: Efficiency (Dec. 1, 2004)] 

Yes 

Indicator

Measures 

E.3 - The agency has established and encouraged the

widespread use of a fair alternative dispute resolution

(ADR) program.

Measure

Met? 

Comments 

E.3.a Has the agency established an ADR program for use during 

both the pre-complaint and formal complaint stages of the 

EEO process? [29 CFR §1614.102(b)(2)] 

Yes 

27 
 

E.3.c

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

participate in ADR once it has been offered? [MD-715, Yes 

II(A)(1)] 

Does the agency encourage all employees to use ADR, where Yes ADR is appropriate? [MD-110, Ch. 3(IV)(C)] 

E.3.d Does the agency ensure a management official with 

settlement authority is accessible during the dispute Yes 

resolution process? [MD-110, Ch. 3(III)(A)(9)] 

E.3.e Does the agency prohibit the responsible management 

official named in the dispute from having settlement Yes 

authority? [MD-110, Ch. 3(I)] 

E.3.f Does the agency annually evaluate the effectiveness of its Yes ADR program? [MD-110, Ch. 3(II)(D)] 

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

Measures Met?

program.

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

monitor, and analyze the following data: 

E.4.a.1 – Complaint activity, including the issues and bases of the 

complaints, the aggrieved individuals/ complainants, and Yes 

the involved management official? [MD-715, II(E)] 

E.4.a.2 – The race, national origin, sex, and disability status of Yes agency employees? [29 CFR §1614.601(a)] 

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

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

applicants’ race, national origin, sex, and disability status? Yes 

[MD-715, II(E)] 

E.4.a.5 – The processing of requests for reasonable Yes accommodation? [29 CFR § 1614.203(d)(4)] 

E.4.a.6 – The processing of complaints for the anti-harassment 

program? [EEOC Enforcement Guidance on Vicarious Yes Employer Liability for Unlawful Harassment by Supervisors 

(1999), § V.C.2] 

E.4.b Does the agency have a system in place to re-survey the Yes workforce on a regular basis? [MD-715 Instructions, Sec. I] 

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

Measures Met?

program.

E.5.a Does the agency monitor trends in its EEO program to Throughout the year, 

determine whether agency is meeting its obligations under NASA reviews data on 

the statutes EEOC enforces? [MD-715, II(E)] If yes, provide the workforce, EEO 

example in the comments section. Yes complaints, and 

harassment allegations 

and reports trends 

quarterly to leadership. 

E.5.b Does the agency review other agencies’ best practices and NASA regularly reviews 

adopt them, where appropriate, to improve the effectiveness best practices reports 

of its EEO program? [MD-715, II(E)] If yes, provide example published by EEOC and 

in the comments section. Yes included in other 

agencies’ MD-715 

reports and adopts as 

them as appropriate. 

28 
 

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

process to other federal agencies of similar size? [MD-715, Yes 

II(E)] 

Essential Element F: RESPONSIVENESS AND LEGAL COMPLIANCE 

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

policy guidance, and other written instructions. 

Indicator 

Measures 

F.1 – The agency has processes in place to ensure 

timely and full compliance with EEOC Orders and 

settlement agreements. 

Measure 

Met? Comments 

F.1.a Does the agency have a system of management controls to 

ensure that its officials timely comply with EEOC 

orders/directives and final agency actions? [29 CFR 

§1614.102(e); MD-715, II(F)]

Yes 

F.1.b Does the agency have a system of management controls to 

ensure the timely, accurate, and complete compliance with 

resolutions/settlement agreements? [MD-715, II(F)] 

Yes 

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

predictable processing of ordered monetary relief? [MD-715,

II(F)] 

Yes 

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

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

F.1.e When EEOC issues an order requiring compliance by the 

agency, does the agency hold its compliance officer(s) 

accountable for poor work product and/or delays during 

performance review? [MD-110, Ch. 9(IX)(H)] 

Yes 

Indicator 

Measures 

F.2 – The agency complies with the law, including

EEOC regulations, management directives, orders, and

other written instructions.

Measure 

Met?

Comments 

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

orders? [29 CFR §1614.502; MD-715, II(E)] Yes 

F.2.a.1 When a complainant requests a hearing, does the agency 

timely forward the investigative file to the appropriate EEOC 

hearing office? [29 CFR §1614.108(g)] 

Yes 

F.2.a.2 When there is a finding of discrimination that is not the 

subject of an appeal by the agency, does the agency ensure 

timely compliance with the orders of relief? [29 CFR 

§1614.501]

Yes 

F.2.a.3 When a complainant files an appeal, does the agency timely 

forward the investigative file to EEOC’s Office of Federal 

Operations? [29 CFR §1614.403(e)] 

Yes 

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

provide EEOC with the required documentation for 

completing compliance? 

Yes 

Indicator 

Measures 

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

and accomplishments.

Measure 

Met? Comments 

F.3.a Does the agency timely submit to EEOC an accurate and 

complete No FEAR Act report? [Public Law 107-174 (May 15, 

2002), §203(a)] 

Yes 

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

quarterly No FEAR Act data? [29 CFR §1614.703(d)] 

https://www.nasa.gov/o

ffices/odeo/no-fear-act Yes 

29 
 

 

PART H: ESSENTIAL ELEMENT DEFICIENCIES AND PLANNED ACTIVITIES 

The following planned actions and accomplishments address program deficiencies identified in Part 

G in FY 2018; objectives H-2 and H-4 were completed in FY 2019. 

MD-715 

PART H-1 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA did not issue an FY 2018 EEO policy statement on Agency letterhead signed by 

the Administrator (Part G, Demonstrated Commitment From Agency Leadership, 

Measure A.1.a) 

OBJECTIVE: Issue EEO policy statement. 

RESPONSIBLE 

OFFICIAL: AA, ODEO, and NASA Administrator 

DO THE RESPONSIBLE OFFICIAL’S PEFORMANCE STANDARDS ADDRESS THIS PLAN? (Yes or No) No. 

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

2/28/2018 6/30/2019 6/30/2020 3/5/2020 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

9/28/2018 1. Draft NASA EEO policy statement. Yes 9/30/2018 

3/30/2019 2. Draft policy statement put into Agency review. Yes 3/30/2020 1/13/2020 

6/30/2019 3. NASA Administrator signs policy statement. Yes 6/30/2020 3/5/2020 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2019 Progress and Accomplishments: The NASA Administrator signed the updated EEO policy 

statement on March 5, 2020. 

Modifications to Objective: This objective is now complete. 

30 
 

 

 

 

 

MD-715 

PART H-2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

The Agency head is not the immediate supervisor of the person (“EEO Director”) who 

has day-to-day control over the EEO office [29 CFR §1614.102(b)(4)], nor does the EEO 

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

programmatic offices (Part G, Integration of EEO into the Agency’s Strategic Mission, 

Measure B.1.a and Measure B.1.a1) 

OBJECTIVE: 

RESPONSIBLE 

OFFICIAL: 

DO THE RESPONSIBLE OFFICIAL’S PEFORMANCE STANDARDS ADDRESS THIS PLAN? (Yes or No) 

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

Currently, there is no action plan for this item as there has been no observable impact resulting from 

the AA’s position in the organizational structure. 

31 
 

 

 

 

 

 

 

 

MD-715 

PART H-3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA has not finalized its RA policy and procedures and placed them on the Agency 

Web site (Part G, Management and Program Responsibility, Measure C.2.c.1) 

OBJECTIVE: Revise NASA RA policy to include procedures for the provision of PAS to ensure 

alignment with requirements to revised EEOC regulations pursuant to Section 501 of 

the Rehabilitation Act (29 CFR § 1614.203) 

RESPONSIBLE 

OFFICIAL: Director of Diversity and Data/Analytics Division, and Disability Program Manager 

(DPM), ODEO 

DO THE RESPONSIBLE OFFICIAL’S PEFORMANCE STANDARDS ADDRESS THIS PLAN? (Yes or No) No. 

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

3/21/2017 2/28/2018 4/30/2019 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

2/28/2018 1. Establish a working group to align the current 

RA procedures (NPR 3713.1B) with the new 

regulatory requirements, including the 

provision of PAS. 

Yes 2/28/2018 

2/28/2018 2. Develop new accommodation procedures for 

the provision of PAS and reassignment for IWD. 

Yes 3/29/2019 4/22/2019 

2/28/2019 3. Post revised procedures on the NASA Web site; 

ensure the procedures are made available to 

employees, job applicants, and student interns. 

Yes 4/30/2019 

2/28/2019 4. Ensure all managers and supervisors are aware 

of the new procedures. 

Yes 4/30/2019 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2019 Progress and Accomplishments: NASA NPR 3713.1C, Reasonable Accommodations Procedures 

for Individuals with Disabilities, which includes provisions for PAS, was published on 4/22/19 on the 

NASA Web site at: https://nodis3.gsfc.nasa.gov/displayDir.cfm?t=NPR&c=3713&s=1B 

Modifications to Objective: Changed the wording of Activity #4. This objective is now complete. 

32 
 

MD-715 

PART H-4 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA does not complete counseling within the timeframes established by 29 CFR. Part 

1614, section 105 and EEOC regulations (Part G, Efficiency, Measure E.1.a) 

OBJECTIVE: Ensure all counseling is timely completed in accordance with all regulatory requirements. 

RESPONSIBLE 

OFFICIAL: AA and Director of Complaints and Programs Division, ODEO 

DO THE RESPONSIBLE OFFICIAL’S PEFORMANCE STANDARDS ADDRESS THIS PLAN? (Yes or No) Yes. 

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

9/28/2018 9/30/2019 9/30/2020 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

9/28/2018 1. Streamline processes by eliminating duplicative 

layers of review and shortening the review and 

approval periods. 

Yes 9/28/2018 

9/30/2019 2. Provide training in informal complaints processing, 

counseling techniques, writing counselor’s reports, 

and framing claims. 

Yes 9/30/2019 

9/30/2019 3. Conduct quarterly discussions with responsible staff 

to address processing challenges and share/ 

implement changes, when and where needed. 

Yes 9/30/2019 

9/30/2019 4. Utilize Agency cadre of counselors. Yes 9/30/2019 

9/30/2019 5. Hold responsible staff, including contractors, 

responsible for timely and quality investigation of 

complaints. 

Yes 9/30/2019 

9/30/2019 6. Review monthly complaint processing data by 

Center to track compliance to regulatory 

requirements, send reminders, and address 

timeliness and quality of processing issues as 

expeditiously as possible. 

Yes 9/30/2020 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2019 Progress and Accomplishments: NASA significantly improved its compliance with regulatory 

processing requirements for informal complaints. In FY 2019, NASA completed 89 percent of its 

counseling timely (compared to 75 percent in FY 2018). 

Modifications to Objective: Modified the target completion date. 

33 
 

MD-715 

PART H-5 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA does not complete investigations within the timeframes established by 29 CFR. 

Part 1614, section 108 and EEOC regulations (Part G, Efficiency, Measure E.1.f) 

OBJECTIVE: Ensure all investigations are timely completed in accordance with all regulatory 

requirements. 

RESPONSIBLE 

OFFICIAL: AA and Director of Complaints and Programs Division, ODEO 

DO THE RESPONSIBLE OFFICIAL’S PEFORMANCE STANDARDS ADDRESS THIS PLAN? (Yes or No) Yes 

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

9/28/2018 9/30/2019 9/30/2019 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

9/28/2018 1. Streamline processes by eliminating duplicative layers 

of review and shortening the review and approval 

periods. 

Yes 9/28/2018 

9/30/2019 2. Provide training on formal complaints processing, i.e., 

drafting and framing claims, sufficiency reviews of 

investigative reports, etc. 

Yes 9/30/2019 

9/30/2019 3. Conduct quarterly discussions with responsible staff 

to address processing challenges and 

share/implement changes, when and where needed. 

Yes 9/30/2019 

9/30/2019 4. Engage contractors who are experienced, skilled, and 

knowledgeable in Federal EEO complaints processing 

from informal processing to FADs. 

Yes 9/30/2019 

9/30/2019 5. Hold responsible staff, including contractors, 

responsible for timely and quality investigation of 

complaints. 

Yes 9/30/2019 

9/30/2019 6. Review monthly complaint processing data by Center 

(informal complaints) and Agency wide (formal 

processing) to track compliance to regulatory 

requirements and address timeliness and quality of 

processing issues as expeditiously as possible when 

there is a need. 

Yes 9/30/2019 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2019 Progress and Accomplishments: NASA experienced consistent and significant progress in this 

area. In FY 2019, 100 percent of investigations were timely, compared to 94 percent in FY 2018. 

Modifications to Objective: This objective is now complete. 

34 
 

 

 

MD-715 

PART H-6 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA does not complete FADs within the timeframes established by 29 CFR. Part 1614, 

section and 110, and EEOC regulations (Part G, Efficiency, Measure E.1.h) 

OBJECTIVE: Ensure all FADs are timely completed in accordance with all Federal regulatory 

requirements. 

RESPONSIBLE 

OFFICIAL: AA, ODEO 

DO THE RESPONSIBLE OFFICIAL’S PEFORMANCE STANDARDS ADDRESS THIS PLAN? (Yes or No) Yes. 

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

9/28/2018 9/30/2019 9/30/2020 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

9/28/2018 1. Streamline processes by eliminating duplicative layers of 

review and shortening the review and approval periods. 

Yes 9/28/2018 

9/30/2019 2. Conduct quarterly discussions with responsible staff to 

address processing challenges and share/implement 

changes, when and where needed. 

Yes 9/30/2019 

9/30/2019 3. Engage personnel who are experienced, skilled and 

knowledgeable in Federal EEO complaints processing 

from informal processing to FADs. 

Yes 9/30/2019 

9/30/2019 4. Hold responsible staff, including contractors, responsible 

for timely and quality processing of complaints. 

Yes 9/30/2019 

9/30/2019 5. Review monthly complaint processing data by Center 

(for informal complaints) and Agency wide (formal 

processing) to track compliance to regulatory 

requirements and address timeliness and quality issues 

as expeditiously as possible, as needed. 

Yes 9/30/2019 

9/30/2020 6. Eliminate backlog. Yes 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2019 Progress and Accomplishments: In FY 2019, NASA issued 21 percent of FADs timely, 

compared to 17 percent in FY 2018. NASA reduced the inventory of untimely complaints pending 

adjudication from 17 to 7. NASA continues to work towards completing the remaining cases. 

Modifications to Objective: Added Activity #6 and modified the completion date. 

35 
 

 

PART I: BARRIER ANALYSIS AND PLANNED ACTIVITIES 

MD-715 

PART I 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

TRIGGER ANALYSIS 

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? 

Comparing FY 2019 NASA workforce data to the RCLF reveals that AAPI and women are 

underrepresented in Physical Science positions at NASA. AAPI account for 10.1 percent 

of NASA Physical Scientists, but are 14.4 percent of the RCLF. Women occupy 27.4 

percent of Physical Science positions at NASA, compared to 37.3 percent in the RCLF. 

SOURCE OF 

TRIGGER: 

NASA workforce data: Underrepresentation as compared to the national benchmark 

(RCLF) 

MD-715 

WORKFORCE 

DATA TABLE: 

Table A6 

EEO GROUP(S) 

AFFECTED BY 

TRIGGER: 

Check all that apply: 

All Men Asian Males X 

All Women X Asian Females X 

Hispanic or Latino Males Native Hawaiian or Other Pacific Islander Males X 

Hispanic or Latino Females Native Hawaiian or Other Pacific Islander 

Females 

X 

White Males American Indian or Alaska Native Males 

White Females American Indian or Alaska Native Females 

Black or African American Males Two or More Races Males 

Black or African American Females Two or More Races Females 

BARRIER ANALYSIS PROCESS 

SOURCES OF 

DATA: 

Sources Source Reviewed 

(Y/N)? 

Identify Information 

Collected 

Workforce Data Tables Yes Table A6 

Complaint Data (Trends) Yes Complaints by occupation 

Grievance Data (Trends) Yes Complaints by occupation 

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

Yes Findings from EEO 

complaints and AntiHarassment allegations 

Climate Survey (e.g., FEVS) Yes FEVS questions 22 and 33 

Exit Interview Data No 

Focus Groups No 

36 
 

 

 

Interviews No 

Reports (e.g., Congress, EEOC, MSPB, 

GAO, OPM) 

No 

Other (Please Describe) N/A 

STATUS OF 

BARRIER 

ANALYSIS 

PROCESS: 

Barrier analysis process completed? (Y/N) No 

Barrier(s) identified? (Y/N) Not completed 

STATEMENT OF 

IDENTIFIED 

BARRIER(S): 

(Description of 

Policy, Procedure, 

or Practice) 

Barriers not yet identified; pending completion of barrier analysis. 

EEO PLAN TO ELIMINATE IDENTIFIED BARRIER(S) 

OBJECTIVE(S): 

Objective Date 

Initiated 

Target 

Date 

Sufficient 

Funding/ 

Staffing 

Modified 

Date 

Date 

Completed 

NASA will strengthen its 

data analytics capabilities 

and conduct in-depth 

barrier analyses to identify 

specific opportunities for 

positive change.

 1/2/2018 9/30/2020 Yes 

Track and monitor the 

participation rate of 

Women and AAPI in the 

Physical Scientists 

occupational category.

 1/28/19 9/30/2020 Yes 

RESPONSIBLE 

OFFICIAL(S): Title Name Performance Standards Address Plan? (Y/N) 

AA, ODEO Stephen T. Shih No 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities Modified 

Date 

Completion 

Date 

9/28/2018 1. ODEO will partner with other NASA organizations, including 

OCHCO and the Science Mission Directorate, to strengthen 

its data analytics capabilities to enable ODEO to conduct indepth barrier analyses. 

 9/28/2018 

9/30/2018 2. NASA will update and improve its standard data reports to 

ensure that the necessary data are available for conducting 

barrier analyses related to EEO. 

5/15/2019 5/15/2019 

9/30/2020 3. ODEO will leverage current NASA systems and develop 

additional data tools such as: FEVS, NASA Human Capital 

Management Workforce Analysis Business Intelligence Tools, 

37 
 

 

climate surveys, pulse surveys, and potential new database 

systems, to enhance our ability to analyze programs and 

practices at more granular levels. 

9/30/2020 4. ODEO will review relevant data sources such as EEO 

complaints, grievances, surveys, exit interviews, and reports 

for any indicators of barriers regarding employment of 

women and AAPI as physical scientists. 

9/30/2020 5. NASA will track applicant flow data by race and gender for 

Physical Scientist positions in FY 2020. 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2019 Progress: ODEO continued to partner with OCHCO to address data needs. The two offices worked 

together to revise the MD-715 tables to conform to new EEOC requirements. In addition, NASA EEO/D&I 

Data Analytics Working Group continued to streamline processes for sharing and analyzing workforce data. 

Modifications to Objective: None. 

38 
PART J: SPECIAL PROGRAM PLAN FOR THE RECRUITMENT, HIRING, ADVANCEMENT, 

AND RETENTION OF PERSONS WITH DISABILITIES 

MD-715

PART J

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

 

 

 

 

To capture agencies’ affirmative action plan for IWD and IWTD, EEOC regulations (29 CFR. § 

1614.203(e)) and MD-715 require agencies to describe how their plan will improve the recruitment, 

hiring, advancement, and retention of applicants and employees with disabilities. All agencies, 

regardless of size, must complete this Part of the MD-715 report. 

Section I: Efforts to Reach Regulatory Goals 

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

increasing the participation of persons with reportable and targeted disabilities in the Federal Government. 

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving IWD 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 (IWD) Yes No X 

b. Cluster GS-11 to SES (IWD) Yes No X 

N/A 

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving IWTD 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 (IWTD) Yes No X 

b. Cluster GS-11 to SES (IWTD) Yes No X 

N/A 

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

recruiters.

EEO personnel continue to communicate new numerical goals in various forums, including: 

briefings for managers and supervisors, individual meetings with hiring and recruitment managers, 

and all-hands meetings for supervisors. 

39 
 

 

 

 

 

 

 

 

 

 

 

Section II: Model Disability Program 

Pursuant to 29 CFR. §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 (RA) 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.

Yes X No 

NASA has an Agency Disability Program Manager (DPM) and a Center DPM at each NASA Center. 

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 

Full (Name, Title, Office, Email) 

Time 

Part 

Time 

Collateral 

Duty 

Processing applications 

from IWD and IWTD 

10 All ten NASA Centers have designated Human 

Capital personnel responsible for processing 

applications, including those from IWD. 

Answering questions from 

the public about hiring 

authorities that take 

disability into account 

10 Each NASA Center has a designated Selective 

Placement Coordinator in the Human Capital 

Office who is responsible for responding to 

questions related to the Agency’s hiring 

practices related to disability. 

Processing RA requests 

from applicants and 

employees 

10 All ten NASA Centers each have designated 

DPMs who are responsible for processing 

accommodation requests. 

Section 508 Compliance 11 The NASA Headquarters (HQ) Section 508 

Compliance Officer manages the Agency’s 

policy and practices in this arena. Additionally, 

each NASA Center has a designated Section 

508 Compliance Officer who is responsible for 

ensuring compliance at the operational level. 

Architectural Barriers Act 

Compliance 

11 NASA has a designated Program Manager in 

the HQ Facilities Engineering Division who 

manages the Agency’s strategic plan to ensure 

compliance in this arena. Additionally, all ten 

NASA Centers have designated Facilities 

40 
 

 

 

 

 

 

 

 

 

 

 

 

Disability Program Task 

# of FTE Staff by 

Employment Status Responsible Official 

Full (Name, Title, Office, Email) 

Time 

Part 

Time 

Collateral 

Duty 

Engineers who are responsible for ensuring 

compliance at the operational level. 

Special Emphasis Program 

for IWD and IWTD 

10 NASA has DPMs at each of the ten Centers 

responsible for managing SEP programs and 

activities. 

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.

Yes X No 

In FY 2019, Agency procedures were updated to align with the revised disability regulations. As 

such, DPMs will be trained on the new requirements in FY 2020. Center-level DPMs also receive 

technical assistance and training from the Agency’s DPM during monthly meetings and on an ad 

hoc basis. 

B. Plan to Ensure Sufficient Funding for the Disability Program

Has the agency provided sufficient funding and other resources to successfully implement the 

disability program during the reporting period? If no, describe the agency’s plan to ensure all 

aspects of the disability program have sufficient funding and other resources. 

Yes X No 

Adequate resources are provided for agency-wide implementation of the Disability Program. 

Section III: Plan to Recruit and Hire Individuals with Disabilities 

Pursuant to 29 CFR. § 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 IWD and IWTD. 

A. Plan to Identify Job Applicants with Disabilities

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

including individuals with targeted disabilities.

NASA’s efforts to identify job applicants with disabilities include: (1) participating in targeted job 

fairs and outreach events and engaging in social networking platforms that support employment of 

IWDs (e.g., LinkedIn, Facebook, and Twitter); (2) building, sustaining, and strengthening 

partnerships with local and Federal disability organizations, state and local rehabilitation and 

41 
 

 

 

 

 

 

employment agencies, and local colleges and universities; (3) leveraging disability ERGs and SEPMs 

to communicate and encourage participation in job opportunities within the IWD population; and 

(4) utilizing the Pathways Program to convert interns to career-conditional or term appointments. 

Specific examples for FY 2019 include: 

• Ames Research Center held learning sessions on navigating usajobs.gov and special hiring

authorities, such as Schedule A. 

• Armstrong Flight Research Center worked with the Veterans Administration regarding 

internship opportunities for disabled veterans. 

• Johnson Space Center designed a Schedule A pilot, allowing managers to: 1) request a 

noncompetitive hire when they have identified an individual eligible for a Schedule A 

appointment who meets a staffing need in their organization; and 2) actively recruit in a variety 

of ways (e.g. vocational centers, job fairs, etc.). 

2. Pursuant to 29 CFR. § 1614.203(a)(3), describe the agency’s use of hiring authorities that take

disability into account (e.g., Schedule A) to recruit IWD and IWTD for positions in the permanent

workforce.

NASA Center selective placement coordinators work with managers and promote recruitment 

utilizing special hiring authorities (i.e., Schedule A and 30 percent or more disabled veterans) to 

increase opportunities to hire IWD and IWTD. 

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.

When applicants apply to NASA announcements open to individuals eligible under the Schedule A 

hiring authority, they are provided information about the hiring authority and are asked if they 

are eligible. This enables human resources specialists to identify and refer these individuals to 

hiring officials and provide information and guidance to hiring officials on using the authority. If 

selected under the Schedule A authority, the individual is asked to provide proof of eligibility 

before appointment. 

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.

Yes No X N/A 

NASA has trained Center DPMs on Schedule A, veterans' preference in hiring, and conversion to 

permanent appointments. ODEO and Center EEO staff continue to identify appropriate training 

for EEO staff who conduct barrier and workforce data analysis. 

42 
 

 

 

 

 

 

 

 

 

 

B. Plan to Establish Contacts with Disability Employment Organizations

Describe the agency’s efforts to establish and maintain contacts with organizations that assist 

IWD, including IWTD, in securing and maintaining employment. 

In FY 2019, NASA DPMs worked with a variety of partner organizations to recruit IWD. Several 

NASA Centers are near military installations and have many opportunities to engage the local 

veteran community, such as at the 2019 Naval Air Station Oceana Air Show in Virginia Beach, VA, 

near Langley Research Center. NASA participates in targeted employment fairs and outreach 

activities for veterans and engaging social networking platforms such as LinkedIn, Facebook, 

Twitter, and programs supporting employment of transitioning veterans, including Operation 

Warfighter, Wounded Warrior Project, and various state vocational rehabilitation agencies. 

NASA partners with Federal, state, and local employment organizations, such as the Department 

of Labor Veterans' Employment and Training Services and local colleges/universities, as well as 

with American Job Centers, the Veterans’ Vocational Rehabilitation and Employment Program, 

Centers for Independent Living, Departments of Labor and Defense’s Workforce Recruitment 

Program, and Employment Network Service providers to recruit and hire IWD and IWTD. 

C. Progression Towards Goals (Recruitment and Hiring)

1. Using the goals of 12% for IWD and 2% for IWTD as the benchmarks, do triggers exist for IWD or

IWTD among the new hires in the permanent workforce? If yes, describe the triggers below.

a. New Hires for Permanent Workforce (IWD) Yes No X 

b. New Hires for Permanent Workforce (IWTD) Yes No X 

NASA meets or exceeds the goals for new hires (19 percent of all new hires were IWDs; 3 

percent of all new hires were IWTDs). 

2. Using the qualified applicant pool as the benchmark, do triggers exist for IWD/IWTD among the

new hires for any of the MCOs? If yes, describe the triggers below.

a. New Hires for MCO (IWD) Yes X No 

b. New Hires for MCO (IWTD) Yes X No 

Triggers exist for 7 of the 10 NASA MCOs – General, Electrical, Computer, and Aeronautical 

Engineering (occupational codes 0801, 0850, 0854, and 0861, respectively); Contracting (1102); 

Miscellaneous Administration & Program Analysis (0301); and Management and Program 

Analysis (0343). In particular, there were no IWD or IWTD hired for 0301 and 0343 vacancies, 

although IWD accounted for 7.1 percent of qualified applicants for 0301 and 10.8 percenr of 

qualified for 0343, and IWTD accounted for 4.0 percent and 6.4 percent of qualified applicants 

for 0301 and 0343, respectively. 

For General Physical Science (1301) and Astronomy and Space Science (1330), no IWD or IWTD 

were hired, although there were fewer than 5 qualified applicants with disabilities for each 

occupational category. There were no triggers for Electronics Engineering (0855). 

43 
 

 

 

 

 

 

 

 

 

3. Using the relevant applicant pool as the benchmark, do triggers exist for IWD/IWTD among the

qualified internal applicants for any of the MCOs? If yes, describe the triggers below.

a. Qualified Applicants for MCO (IWD) Yes No X 

b. Qualified Applicants for MCO (IWTD) Yes No X 

N/A 

4. Using the qualified applicant pool as the benchmark, do triggers exist for IWD/IWTD among

employees promoted to any of the MCOs? If yes, describe the triggers below.

a. Promotions for MCO (IWD) Yes X No 

b. Promotions for MCO (IWTD) Yes X No 

Triggers exist for IWD in internal promotions in the following job series: General, Electrical, Computer, 

Electronics, and Aerospace Engineering; Contracting; Miscellaneous and Program Administration; and 

Management and Program Analysis. For IWTD, triggers exist for Electrical, Computer, and Aerospace 

Engineering; Contracting; Miscellaneous Administration and Program Analysis; and Management and 

Program Analysis. For each of these occupations, the percentage of IWD or IWTD who were qualified 

was at least 2 percentage points higher than the percentage of IWD or IWTD selected. 

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

Pursuant to 29 CFR §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 IWD, including IWTD, have sufficient opportunities for 

advancement. 

NASA’s ODEO and Human Capital communities have developed multiple strategies to track and monitor 

the professional development and advancement of IWD and IWTD. First, NASA reviews participation 

data for this population in key training and development opportunities across the Agency. Second, 

NASA monitors participation data for this population by grade level and occupational category, and 

develops corrective action plans when triggers are identified. Third, NASA uses assistive technology to 

ensure professional development opportunities are made available to IWD and IWTD. 

44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

B. Career Development Opportunities

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

employees.

NASA’s HR function underwent a major reorganization in FY 2018; thus, data for most of these 

programs is not currently available. In FY 2019, NASA developed a new resource called the Talent 

Marketplace, which provides information on the availability of opportunities such as job 

announcements, details, and rotational assignments. This innovative tool will reinforce equal 

employment opportunities by enabling NASA, for the first time, to widely and inclusively share 

information to the entire NASA workforce on the availability of career-enhancing opportunities. 

This system will collect relevant employee data, and NASA will provide this in information in 

subsequent MD 715 reports once it has been compiled. 

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 (#) IWD (%) IWTD (%) 

Applicants Selectees Applicants Selectees Applicants Selectees 

Internship Programs5 14,349 1,987 6.3% 6.7% -- --

Fellowship Programs

Mentoring Programs

Coaching Programs

Training Programs

Detail Programs

Other Career Development Programs 

3. Do triggers exist for IWD among the applicants and/or selectees for any of the career

development programs? (The 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.

a. Applicants (IWD) Yes No X 

b. Selections (IWD) Yes No X 

Data available only for internship programs. 

4. Do triggers exist for IWTD among the applicants and/or selectees for any of the career

development programs identified? (The benchmarks are the relevant applicant pool for

applicants and the applicant pool for selectees.) If yes, describe the trigger(s) in the text box.

a. Applicants (IWTD) Yes No data not currently available 

b. Selections (IWTD) Yes No data not currently available 

Data currently unavailable. 

5 The number of interns with disabilities reflects the number of persons who requested a reasonable accommodation. 

NASA does not require interns to disclose the nature of their disabilities. 

45 
 

 

 

 

 

 

 

 

 

 

 

 

 

C. Awards

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving IWD/IWTD

for any level of the time-off awards, bonuses, or other incentives? If yes, describe the trigger(s).

a. Awards, Bonuses, & Incentives (IWD) Yes X No 

b. Awards, Bonuses, & Incentives (IWTD) Yes No X 

In FY 2019, the inclusion rate for IWD (at all grade-levels) was 11.2 percent and IWD accounted for 8.9 

percent of those receiving time-off and/or cash awards. NASA will continue to monitor the IWD and 

IWTD inclusion rates for awards. 

2. Using the inclusion rate as the benchmark, does your agency have a trigger involving IWD/IWTD

for quality step increases or performance-based pay increases? If yes, describe the trigger(s).

a. Pay Increases (IWD) Yes X No 

c. Pay Increases (IWTD) Yes X No 

In FY 2019, the inclusion rates for IWD and IWTD (at all grade-levels) were 11.2 percent and 1.9 

percent, respectively. IWD accounted for 7.3 percent of those receiving QSIs; IWTD accounted for 0.4 

percent. NASA will continue to monitor the IWD and IWTD inclusion rates for awards. 

3. If the agency has other types of employee recognition programs, are IWD/IWTD recognized

disproportionately less than employees without disabilities? (The benchmark is the inclusion

rate.) If yes, describe the recognition program and relevant data.

a. Other Types of Recognition (IWD) Yes X No N/A 

b. Other Types of Recognition (IWTD) Yes No X N/A 

IWD received 8.1 percent of Space Act and Honor Awards in FY 2019 (compared to the inclusion rate of 

11.2 percent ). Space Act Awards recognize outstanding scientific or technical innovations that further 

NASA’s mission, including the NASA Invention of the Year Award. Agency Honor Awards, NASA’s most 

prestigious honor awards, are presented to a number of carefully selected individuals and groups, both 

Government and non-Government, who have distinguished themselves by making outstanding 

contributions to the Agency’s mission. NASA will continue to monitor the IWD and IWTD inclusion rates 

for awards. 

D. Promotions

1. Does your agency have a trigger involving IWD among the qualified internal applicants and/or

selectees for promotions to the senior grade levels? (The 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).

a. SES

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes X No 

b. Grade GS-15 

i. Qualified Internal Applicants (IWD) Yes No X 

46 
 

 

 

 

 

 

 

 

ii. Internal Selections (IWD) Yes X No 

c. Grade GS-14 

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes X No 

d. Grade GS-13 

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes No X 

For internal promotions, there were no triggers among qualified internal applicants. However, 

there are triggers for internal selections to grades GS-14 and above. IWD account for 11.2 percent 

of qualified applicants for GS-14 positions, but are only 5.0 percent of those selected. For GS-15 

positions, IWD account for 9.2 percent of qualified applicants and 6.6 percent of the selections. 

For SES, IWD were 4.5 percent of qualified applicants but 0.0 percent of those selected (note that 

only one person was selected at the SES level). NASA will continue to monitor the IWD inclusion 

rate for promotions. 

2. Does your agency have a trigger involving IWTD among the qualified internal applicants and/or

selectees for promotions to the senior grade levels? (The 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).

a. SES

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

b. Grade GS-15 

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

c. Grade GS-14 

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

d. Grade GS-13 

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes X No 

For sections for internal promotions to grade GS-13, there is a trigger for IWTD. IWTD account for 

6.6 percent of qualified applicants and 3.8 percent of those selected. NASA will continue to monitor 

the IWTD inclusion rate for internal promotions to senior positions. 

3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving IWD

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.

a. New Hires to SES (IWD) Yes X No 

b. New Hires to GS-15 (IWD) Yes X No 

c. New Hires to GS-14 (IWD) Yes X No 

d. New Hires to GS-13 (IWD) Yes No X 

47 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The were no IWD hired at the SES and GS-15 levels, although IWD accounted for 3.5 percent of 

qualified applicants for SES and 5.0 percent of the applicants for GS-15 (note there was only one SES 

hired among external applicants). For GS-14 new hires, IWTD accounted for 4.4 percent of qualified 

applicants and 1.5 percent of new hires. NASA will continue to monitor the IWTD inclusion rate for 

new hires. 

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving

IWTD 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.

a. New Hires to SES (IWTD) Yes X No 

b. New Hires to GS-15 (IWTD) Yes X No 

c. New Hires to GS-14 (IWTD) Yes X No 

d. New Hires to GS-13 (IWTD) Yes No X 

The were no IWTD hired at the SES and GS-15 levels, although IWTD accounted for 2.3 percent of 

qualified applicants for SES and 2.5 percent of the applicants for GS-15 (note there was only one SES 

hired among external applicants). For GS-14 new hires, IWTD accounted for 2.5 percent of qualified 

applicants and 0.7 percent of new hires. 

5. Does your agency have a trigger involving IWD 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.

a. Executives

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes X No 

b. Managers

i. Qualified Internal Applicants (IWD) Yes No data not available 

ii. Internal Selections (IWD) Yes No data not available 

c. Supervisors

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes X No 

For Executives (SES), IWD were 4.5 percent of qualified applicants, but 0.0 percent of those selected 

(note that only one person was selected at the SES level). For supervisory positions, IWD accounted 

for 8.9 percent of the qualified applicants but only 6.1 percentof those selected. NASA does not track 

applicants for managerial positions – this information appears only in the text of the job 

announcement and is not recorded/measured in the applicant flow data. 

6. Does your agency have a trigger involving IWTD 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.

48 
 

 

 

 

 

 

 

 

 

 

 

 

a. Executives

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

b. Managers

i. Qualified Internal Applicants (IWTD) Yes No data not available 

ii. Internal Selections (IWTD) Yes No data not available 

c. Supervisors 

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

There were no triggers for IWTD among qualified applicants or internal selections for executive and 

supervisory positions. NASA does not track applicants for managerial positions – this information 

appears only in the text of the job announcement and is not recorded/measured in the applicant flow 

data. 

7. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving IWD

among selectees for new hires to supervisory positions? If yes, describe the trigger(s) in text box.

a. New Hires for Executives (IWD) Yes X No 

b. New Hires for Managers (IWD) Yes No data not available 

c. New Hires for Supervisors (IWD) Yes X No 

There were no IWD hired for executive or supervisory positions, although IWD accounted for 3.5 

percent of the qualified applicants for SES positions and 5.2 percent of the qualified applicants for 

supervisory positions. NASA does not track applicants for managerial positions – this information 

appears only in the text of the job announcement and is not recorded/measured in the applicant flow 

data. 

8. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving

IWTD among the selectees for new hires to supervisory positions? If yes, describe the trigger(s) in

text box.

a. New Hires for Executives (IWTD) Yes X No 

b. New Hires for Managers (IWTD) Yes No data not available 

c. New Hires for Supervisors (IWTD) Yes X No 

There were no IWTD hired for executive or supervisory positions, although IWTD accounted for 2.3 

percent of the qualified applicants for SES positions and 2.6 percent of the qualified applicants for 

supervisory positions. NASA does not track applicants for managerial positions – this information 

appears only in the text of the job announcement and is not recorded/measured in the applicant flow 

data. 

49 
 

 

 

 

 

 

 

 

Section V: Plan to Improve Retention of Persons with Disabilities 

To be a 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 personal 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 CFR. § 213.3102(u)(6)(i))? If

no, please explain why the agency did not convert all eligible Schedule A employees.

Yes No N/A data not available. 

Currently, NASA does not track Schedule A conversions at the Agency level. OCHCO is in the process of 

determining the best way to provide this information. 

2. Using the inclusion rate as the benchmark, did the percentage of IWD among voluntary and

involuntary separations exceed that of persons without disabilities? If yes, describe trigger below.

a. Voluntary Separations (IWD) Yes X No 

b. Involuntary Separations (IWD) Yes X No 

In FY 2019, IWD accounted for 13.8 percent of the voluntary separations and 18.8 percent of the 

involuntary separations. (The inclusion rate for IWD is 11 percent.) (Note that the number of 

separations is low for NASA overall and, thus, further analyses is required to determine if this number 

represents a concern to the Agency.) NASA will continue to monitor the IWD inclusion rate for 

separations. 

3. Using the inclusion rate as the benchmark, did the percentage of IWTD among voluntary and

involuntary separations exceed that of persons without targeted disabilities? If yes, describe

trigger below.

a. Voluntary Separations (IWTD) Yes No X 

b. Involuntary Separations (IWTD) Yes No X 

N/A 

4. If a trigger exists involving the separation rate of IWD and/or IWTD, please explain why they left

the agency using exit interview results and other data sources.

NASA conducts exit interviews but with limited questions regarding issues related to disability. ODEO 

is currently working with OCHCO to improve exit interview questions to better indicate if triggers exist. 

50 
 

 

 

 

 

 

 

 

 

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.

Web site: https://www.nasa.gov/accessibility/section508/sec508_overview.html 

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 (ABA), including a

description of how to file a complaint.

NASA’s Web site currently does not include information on the ABA complaint process. The Agency 

will post such information during FY 2020. 

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 facilities and/or technology.

NASA maintains an Agency-wide plan that identifies the facility accessibility needs of each NASA 

Center as well as a multi-year implementation plan. Agency leadership routinely reviews this plan and 

assesses status. The Agency Section 508 Program Manager continues to host monthly meetings for 

NASA’s 508 Coordinators to stay abreast of current updates and events related to accessibility. 

C. Reasonable Accommodation Program

Pursuant to 29 CFR. § 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 timeframe for processing initial requests for reasonable

accommodations during the reporting period. (Do not include previously approved requests with

repetitive accommodations, such as interpreting services.)

On average, NASA processes RA requests in 34 days (improvement from 39 days in FY 2018). 

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency’s

reasonable accommodation program. 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.

Examples of the effectiveness of NASA’s RA program are: (1) over 1,000 employees have been trained 

on their roles/responsibilities regarding RA; (2) RA awareness briefings across the Agency are 

routinely provided to new employees; new supervisors; and interns; and (3) all ten NASA Centers 

have designated DPMs to process RA requests and to provide technical assistance to employees, 

interns, managers, and supervisors. 

51 
 

 

 

 

 

 

 

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 policies/procedures/practices to implement the PAS requirement. 

Examples of an effective program include timely processing PAS requests, timely providing approved 

services, conducting training for managers and supervisors, and monitoring requests for trends. 

NASA began providing PAS in January 2018. NASA intends to pursue the establishment of an 

Agency-wide Blanket Purchasing Agreement, in FY 2020, for greater ease in providing PAS across the 

Agency. 

Section VI: EEO Complaint and Findings Data 

A. EEO Complaint Data Involving Harassment

1. During the last fiscal year, did a higher percentage of IWD file a formal EEO complaint alleging

harassment, as compared to the government-wide average?

Yes X No N/A 

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?

Yes No X N/A 

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.

N/A – there were no findings. 

B. EEO Complaint Data Involving Reasonable Accommodation (RA)

1. During the last fiscal year, did a higher percentage of IWD file a formal EEO complaint alleging

failure to provide an RA, as compared to the government-wide average?

Yes No X N/A 

2. During the last fiscal year, did any complaints alleging failure to provide RA in a finding of

discrimination or a settlement agreement?

Yes No X N/A 

3. If the agency had one or more findings of discrimination involving the failure to provide RA

during the last fiscal year, please describe the corrective measures taken by the agency.

N/A – there were no findings. 

52 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Section VII: Identification and Removal of Barriers 

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a policy, 

procedure, or practice may be impeding the employment opportunities of a protected EEO group. 

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

employment opportunities for IWD and/or IWTD?

Yes No X 

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

Yes No N/A X 

3. Identify each trigger and plan to remove the barrier(s), including the barrier(s), objective(s),

responsible official(s), planned activities, and, where applicable, accomplishments.

MD-715

PART J Affirmative Action Plan for Individuals with Disabilities 

Triggers 

The preceding analyses revealed several triggers. IWD and IWTD continue to be 

selected for internal competitive promotions at lower rates than their representation 

among those referred to hiring managers. For example, for all MCOs combined, IWD 

and IWTD account for 11 percent and 3 percent, respectively, of referred applicants, 

but IWD are 7 percent and IWTD are 1 percent of those selected. (See Part J, III, C.) 

For internal competitive promotions to senior grades, more IWD are referred than are 

selected GS-14 and more IWTD are qualified than are selected for the SES. Among new 

hires for senior grades, triggers exist both IWD and IWTD for GS-14 and GS-15 positions. 

(See Part J, IV, D.) NASA does not systematically track data by race, ethnicity, gender, 

or disability for all of its career development programs (see Part J, IV, B). 

With regard to awards and recognition, compared to the NASA inclusion rate of 11 

percent, IWD account for only 9 percent of those who received cash awards, 8 percent 

of those who received Space Act and Honor Awards, and 7 percent of those receiving 

QSIs. IWTD accounted for 2 percent of the NASA workforce, yet were only 0.4 percent 

of those receiving QSIs. (See Part J, IV, C.) 

Compared to their overall representation at NASA (11 percent), IWD account for 13.8 

percent of those who voluntarily separated from the Agency and 18.8 percent of those 

who involuntarily separated. (Though, NASA’s overall separation rates are low.) (See 

Part J, V, A.) 

Objective(s) 

Improve the monitoring of IWD and IWTD employment at NASA through the following: 

1. Obtain additional data and conduct further analyses to determine causes of

differences observed in the data categories described above and the causes for

such differences.

2. Develop improved systems for collecting demographic data pertaining to career

development programs; better track Schedule A hiring and conversions; and revise

exit interviews to obtain additional data related to individuals with disabilities.

53 
 

 

 

 

 

 

3. Conduct additional research on the triggers above as data become available.

Responsible Official(s) 

Performance Standards Address the Plan? 

(Yes or No) 

Director, Diversity and Data/Analytics Division, ODEO No – these specific steps are not in the 

plan; EEO matters in general are addressed. 

Target Date Planned Activities Sufficient 

Staffing & 

Funding 

Modified 

Date 

Completion 

Date 

9/28/2018 NASA ODEO will partner with OCHCO to 

strengthen its data analytics capabilities 

to enable ODEO to conduct in-depth 

barrier analyses. 

Yes 9/28/2018 

9/28/2018 NASA will update and improve its 

standard data reports to ensure that the 

necessary data are available for 

conducting barrier analyses related to 

the disability program. 

Yes 3/15/2019 3/15/2019 

9/29/2019 Place information regarding the 

Architectural Barriers Act and how to file 

a related complaint on the NASA Web 

site. 

Yes 6/30/2020

9/30/2020 ODEO will leverage current NASA 

systems and develop additional data 

tools, including: the FEVS, NASA Human 

Capital Management Workforce Analysis 

Business Intelligence Tools, climate 

surveys, pulse surveys, and potential new 

database systems. These additional tools 

will enhance ODEO’s ability to analyze 

programs and practices at more granular 

levels. 

Yes 

9/30/2021 Investigate reasons for differences 

between the IWD inclusion rates and 

hiring and promotion rates of IWD and 

IWTD in mission critical occupations. 

Yes 

Fiscal Year Accomplishments 

FY 2018 ODEO and OCHCO continued to work together to address data and systems-related 

issues with regard to the new EEOC regulations and changes made to the Office of 

Personnel Management’s Standard Form 256, “Self-Identification of Disability.” NASA 

continues to strengthen its efforts with regard to the usage of special hiring authorities 

for individuals with disabilities such as Schedule A. 

54 
 

 

 

 

 

FY 2019 NASA made significant progress in updating data systems and automating data reports. 

ODEO and OCHCO continue to work together to expand data access to HR systems and 

ODEO will ensure training on these systems for EEO staff in FY 2020. 

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

planned activities.

All planned activities are being conducted according to the anticipated completion dateswith the 

exception of placing a statement on the NASA Web site regarding the Architectural Barriers Act. 

NASA continues to work to ensure all NASA facilities are accessible under the Architectural 

Barriers Act. 

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

activities toward eliminating the barrier(s).

Enhanced relationships with OCHCO personnel have led to greater collaboration and a better 

understanding of data systems and data needs. 

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.

N/A 

55 
 

 

 

 

 

 

 

 

 

 

APPENDIX A: DATA ANALYSES 

Note: The tables below are a subset of the tables provided to EEOC with the annual MD-715 

submission; these tables were created for the purposes of conducting barrier and trigger analyses. 

Workforce Summary 

The Equal Employment Opportunity Commission (EEOC) recommends comparing the Agency’s 

workforce to relevant populations to determine of the participation of any group in the Agency 

workforce is low. For example, EEOC suggests comparing the total Agency workforce to the NCLF 

and comparing employees in specific occupation to the RCLF. According to EEOC, a low participation 

rate for any group (in relation to a comparison group) should be considered a “trigger” – a situation 

that alerts the Agency to the possible existence of a barrier to equal employment opportunity. In 

other words, low participation (or representation) of a group in certain occupations, or among 

employees receiving promotions, awards, etc., may indicate that there is an agency policy or 

practice that limits the full participation of that group.6 A trigger does not by itself demonstrate a 

barrier to equal opportunity; it indicates an area to be monitored or further analyzed. EEOC does 

not prescribe tests of statistical significance or other statistical tests to determine 

“underrepresentation,” leaving it instead to agencies to determine their level of tolerance. 

As shown in Table 1, the composition of the NASA workforce by race and ethnicity is similar to the 

NCLF, with two exceptions: NASA employs a higher percentage of AAPI and a lower percentage of 

Hispanics than in the NCLF. In addition, women occupy a much lower percentage of the NASA 

workforce compared to the NCLF. However, because the NASA workforce is highly specialized (twothirds of NASA employees are in science and engineering (S&E) occupations), NASA also uses the 

Federal STEM workforce as a comparison. When these two populations are compared, NASA 

employees are similar to the Federal STEM workforce, with regard to race, ethnicity, and gender. 

A “snapshot” of the NASA workforce reveals additional triggers for the following groups, when 

compared to their total representation at NASA (see triggers highlighted in Table 1): 

• Asian Americans and Pacific Islanders (AAPI) make up approximately 8 percent of the NASA 

workforce, yet account for only 4 percent of those in NASA Senior Executive Service (SES) 

positions. 

• Blacks and African Americans account for almost 12 percent of the NASA workforce but 

represent 6 percent of NASA’s S&E workforce and only 2 percent of SL and ST employees. 

• Hispanics and Latinos account for nearly 8 percent of the NASA workforce, yet are just under 

5 percent of SES, ST, and SL employees. 

6 EEOC defines a "trigger" as “a trend, disparity, or anomaly that suggests the need for further inquiry into a particular 

policy, practice, procedure, or condition.” EEOC, Instructions to Federal Agencies for EEO MD-715, “Section II: Barrier 

Identification and Elimination,” accessed at <https://www.eeoc.gov/federal/directives/715instruct/>. 

56 
 

 

 

 

 

 

 

 

 

 

 

 

 

• American Indians and Alaska Natives (AIAN) only 175 AIAN individuals are employed by 

NASA (one percent of the NASA workforce), rendering comparisons of smaller groups to their 

total employment less meaningful. However, this is 11 fewer than in FY 2018. Thus, NASA 

has an opportunity to increase the overall number of AIAN employees. 

• Women account for just over 34 percent of the NASA workforce, yet comprise only 18 

percent of those in ST and SL positions and 24 percent of those in S&E positions. 

• Individuals with disabilities (IWD) comprise almost 9.5 percent of the NASA workforce, but 

only 7 percent of GS-14 and GS-15 employees. They account for 6.6 percent of those in S&E 

positions. IWD are further discussed below. 

Table 1. NASA Employees by Race, Ethnicity, Gender, and Disability Status: FY 2019 

AAPI Black Hispanic 

MultiRacial AIAN White Male Female IWD* IWTD* 

All NASA Employees 

(non-students) (n=16,872) 7.9% 11.5% 7.9% 0.3% 1.0% 71.3% 65.7% 34.3% 9.5% 1.9% 

SES Employees (n=396) 4.3% 11.9% 4.8% 0.3% 0.8% 78.0% 67.7% 32.3% 7.3% 1.8% 

Supervisors (n=2,065) 5.9% 13.1% 6.5% 0.3% 0.7% 73.5% 65.3% 34.7% 7.8% 1.3% 

SL and ST (n=168) 7.1% 2.4% 4.8% 0.0% 1.2% 84.5% 82.1% 17.9% 6.5% 1.8% 

GS-14 and GS-15 (n=9,150) 8.0% 9.0% 6.7% 0.2% 0.9% 75.1% 70.4% 29.6% 7.0% 1.3% 

Science & Engineering 

(n=10,968) 9.2% 6.2% 7.6% 0.2% 0.8% 76.0% 76.5% 23.5% 6.6% 1.4% 

Comparison Populations: 

Federal STEM Workforce 

(n=299,185) 9.4% 10.1% 5.8% 1.7% 0.9% 69.0% 71.3% 28.7% -- --

National Civilian Labor Force 4.1% 12.0% 10.0% 0.6% 1.1% 72.3% 51.8% 48.2% -- --

Individuals who did not identify their race/ethnicity are excluded from the table; thus, percentages do not equal 100 

percent. Triggers are highlighted in yellow. 

Sources: Workforce Information Cubes for NASA (WICN) (data as of 10/1/2019); NASA MD-715 Table A-1, prepared for 

NASA by the U.S. Department of the Interior (data on National Civilian Labor Force); U.S. Office of Personnel Management, 

FedScope, Federal Human Resources Data, Diversity Cube and Employment Cube, data as of December 2018 (data not 

available for 2019), accessed at <https://www.fedscope.opm.gov>. 

* IWD = Individuals with Disabilities; IWTD = Individuals with Targeted Disabilities. Comparable data for IWD and IWTD are

not available for the Federal STEM workforce; data for IWTD are not available for the NCLF. The EEOC goals for the

employment of IWD are: 12 percent of employees in grades GS-10 and below and 12 percent of employees in grades GS11 and above. The goals for IWTD are 2 percent of employees in each grade category.

57 
 

Occupational Categories, by Race and Ethnicity 

A comparison of occupational categories by race and ethnicity reveals that some groups occupy 

much greater percentages of certain occupational categories (See Figure 1). 

Figure 1. NASA Occupational Categories by Race and Ethnicity, FY 2019 

White, 71% White, 76% White, 62% White, 44% White, 77% 

Black, 12% Black, 6% Black, 22% Black, 42% Black, 10% 

Hispanic, 8% Hispanic, 8% Hispanic, 9% Hispanic, 8% Hispanic, 8% AAPI, 8% AAPI, 9% AAPI, 6% AAPI, 4% AAPI, 3% 

AIAN, 1% AIAN, 1% AIAN, 1% AIAN, 1% AIAN, 2% 

0.0% 

10.0% 

20.0% 

30.0% 

40.0% 

50.0% 

60.0% 

70.0% 

80.0% 

90.0% 

100.0% 

All Employees S & E Prof'l Admin Clerical Technician 

(n=16,872) (n=10,968) (n=5,273) (n=165) (n=466) 

Source: WICN (data as of 10/1/2019). Individuals who did not identify their race/ethnicity are excluded from this 

analysis; thus, percentages do not equal 100%. 

Note: In the NASA WICN data, Science and Engineering occupations include the following OPM occupational categories 

and codes: Biological Sciences (04xx), Medical (06xx), Engineering (08xx), Physical Sciences (13xx), and Mathematics 

(15xx). Professional Administrative occupations include the following OPM occupational categories and codes: Social 

Sciences (01xx); Human Resources (02xx); General Administrative (03xx); Accounting and Budget (05xx); Business and 

Industry (11xx); Patent and Trademark (12xx); Library and Archives (14xx); Equipment, Facilities, and Services (16xx); 

Education (17xx); Investigations (18xx); Quality Assurance (19xx); Supply (20xx); Transportation (21xx); and Information 

Technology (22xx). 

Because the NASA workforce is highly specialized (two-thirds of NASA employees are in S&E 

occupations), it is useful to compare employees in specific occupations to the individuals in the 

civilian labor in similar occupations (the RCLF). In addition, data on recent college graduates 

provides insight into the pipeline for similar jobs. A current workforce ratio below the relevant 

civilian labor force (RCLF) for any group is another trigger.7 Tables 2-4 reveal the following: 

7 EEOC requires agencies to use representation in the agency workforce as the comparison group when analyzing 

representation by grade level and supervisory status, and in promotions, hiring, etc. When analyzing individuals by occupation, 

EEOC requires the use of the RCLF, which is comprised of occupations similar to occupations in the agency. EEOC, Instructions 

58 
 

 

 

 

 

 

 

 

• Among Engineers, Hispanics, Women, and IWD are employed at higher percentages at NASA 

than in the RCLF. However, AAPI account for just under 9 percent of NASA Engineers, which 

3 percentage lower than their representation in the RCLF. (See Table 2.) 

• Among Physical Scientists, Whites and IWD are well-represented at NASA compared to 

Physical Scientists in the RCLF, and Blacks and Hispanics are employed in similar proportions 

to those in the RCLF. However, AAPI account for 10 percent of NASA Physical Scientists, 

compared to 14 percent in the RCLF. In addition, Women account for 27 percent of Physical 

Scientists at NASA and 37 percent of those in the RCLF. (See Table 3.) 

• AAPI, Blacks, Hispanics, Women, and IWD are overrepresented in several PA Occupations, 

compared to the RCLF, while Whites and Men are underrepresented in PA positions. (See 

Table 4.) 

Table 2. NASA Engineers by Race, Ethnicity, and Gender: FY 2019 

AAPI Black Hispanic AIAN White Male Female IWD 

Engineers (n=10,182) 8.8% 6.7% 7.9% 0.9% 75.5% 74.6% 22.5% 7.1% 

2010 RCLF 11.8% 4.8% 5.2% 0.6% 77.2% 88.8% 11.2% 3.3% 

2015 Graduates 15.7% 5.1% 9.7% 0.3% 61.6% 78.5% 21.5% --

Table 3. NASA AST Physical Scientists by Race, Ethnicity, and Gender: FY 2019 

AAPI Black Hispanic AIAN White Male Female IWD 

Physical Scientists (n=877) 10.1% 3.0% 5.0% 0.1% 81.8% 72.6% 27.4% 5.6% 

2010 RCLF 14.4% 3.5% 4.3% 0.6% 76.7% 62.6% 37.3% 3.2% 

2015 Graduates 7.2% 3.0% 7.9% 0.2% 73.3% 78.0% 22.0% --

Triggers are highlighted in yellow. Sources for Tables 2-3: WICN (data as of 9/28/2019); U.S Census Bureau EEO 

Tabulation from the 2006-2010 American Community Survey (data set EEO-CIT02R). Data for college graduates are 

provided for comparison only. These data include all earned Bachelor’s, Master’s, and Doctoral degrees in the 

relevant fields in 2013 (the most recent year for which data are available). 

to Federal Agencies for EEO MD-715, “Guidance for Completing the EEOC FORM 715-01 Workforce Data Tables,” accessed at 

<https://www.eeoc.gov/federal/directives/715instruct/>. Additional data tables and planned actions to address these and 

other challenges are presented in Section C below along with a discussion of the RCLF. 

59 
 

 

 

 

 

Table 4. NASA Professional Administrative Employees, by Race, Ethnicity, and Gender: FY 2019 

Occupation 

(OPM Occupation Code) AAPI Black Hispanic AIAN White Male Female IWD 

Human Resources 

Specialist (0201) (n=267) 

NASA 7.9% 28.8% 9.4% 0.7% 51.7% 28.5% 71.5% 21.7% 

RCLF 4.3% 10.4% 9.5% 0.7% 74.6% 39.7% 60.3% 3.7% 

Information Technology 

Specialist (2210) (n=497) 

NASA 6.8% 18.1% 7.0% 1.6% 65.2% 59.6% 40.4% 17.1% 

RCLF 6.8% 11.1% 7.6% 0.8% 73.1% 70.4% 29.6% 4.9% 

Finance (0501, 0505) 

(n=322) 

NASA 5.9% 22.4% 9.3% 0.9% 61.5% 31.7% 68.3% 13.0% 

RCLF 5.0% 13.2% 9.8% 1.2% 71.1% 43.7% 56.3% 4.5% 

Accounting (5010, 5011) 

(n=328) 

NASA 12.2% 27.1% 8.8% 0.3% 50.3% 31.4% 68.9% 15.5% 

RCLF 8.6% 8.1% 6.1% 0.6% 76.0% 39.9% 60.1% 3.5% 

Program Analyst (0343) 

(n=652) 

NASA 6.3% 18.9% 9.8% 1.7% 32.4% 36.8% 63.2% 12.7% 

RCLF 5.9% 6.8% 4.6% 0.6% 81.6% 58.4% 41.6% 4.0% 

Contract Specialist 

(1102) (n=714) 

NASA 5.6% 28.7% 9.4% 0.4% 55.5% 40.4% 59.9% 11.5% 

RCLF 3.3% 8.5% 7.1% 0.8% 80.0% 46.2% 53.8% 5.0% 

Sources: WICN (data as of 9/28/2019); U.S Census Bureau EEO Tabulation from the 2006-2010 American Community 

Survey (data set EEO-CIT02R). 

Within-group comparisons show that some groups have a larger percentage of individuals in certain 

occupational categories than other groups. For example, among all of NASA AAPI employees, just 

over three-quarters (76 percent) are in S&E jobs. In contrast, only 35 percent of Black employees 

are in S&E occupations at NASA. (See Figure 2.) 

Figure 2. NASA Employee Groups by Occupational Category: FY 2019 

NASA Workforce (n=16,872) 65% 31% 4%

AAPI (n=1,328) 77% 22% 1%

Male (n=11,088) 76% 20% 4%

White (n=12,023) 69% 27% 4%

Hispanic (n=1,332) 62% 34% 4%

Targeted Disabilities (n=324) 49% 43% 8%

AIAN (n=175) 48% 44% 7%

Any Disability (n=1,600) 46% 46% 7%

Female (n=5,784) 45% 51% 4%

Black (n=1,948) 35% 59% 6%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Science and Engineering Professional Administrative Clerical or Technician 

Source: WICN (data as of 10/1/2019). 

60 
Individuals with Disabilities 

NASA has made progress in achieving Federal goals for the employment of IWD. NASA is just under 

the goals for IWD and IWTD in grades GS-11 and above. In fact, the percentage of IWD and IWTD in 

both grade categories (GS-10 and below and GS-11 and above) has increased over the past five 

years. (See Figure 3.) 

Figure 3. NASA Employees with Disabilities, by Grade Category: FY 1999-2019 

9.0% 9.8% 

13.6% 14.3% 

23.8% 

5.1% 5.7% 6.1% 

7.4% 

10.6% 

IWD GS-10 and Below 

IWD GS-11 and Above 

Federal Goal = 12% 

End of FY 1999 End of FY 2004 End of FY 2009 End of FY 2014 End of FY 2019 

2.7% 2.6% 

4.4% 4.6% 

6.1% 

0.7% 0.9% 0.9% 

1.2% 

1.8% 

IWTD GS-10 and Below 

IWTD GS-11 and Above 

Federal Goal = 2% 

End of FY 1999 End of FY 2004 End of FY 2009 End of FY 2014 End of FY 2019 

 

 

Source: WICN (data as of 9/28/2019). Data include: 1) all permanent non-student employees who identified as having 

a disability on OPM Standard Form (SF) 256; 2) disabled veterans who are classified as “10-Point/Compensable/30 

Percent,” but who have not claimed a disability on SF 256; and 3) employees hired under Schedule Abut classified in 

WICN as “non-permanent.” 

61 
 

 

Federal Employee Viewpoint Survey (FEVS) Results 

NASA continues to improve its FEVS scores on the New Inclusion Quotient Index,8 Employee 

Engagement Index,9 and individual FEVS questions focused on EEO, D&I, safety, and compliance, 

and NASA’s scores in these areas exceed the Government-wide average. (See Figures 4-5.) 

Figure 4. NASA New Inclusion Quotient Index and Employee Engagement Scores, FY 2018-19 

New Inclusion Quotient Index: 

Supportive 

Open 

Empowered 

Cooperative 

Fair 

0% 

NASA Total - 2019 

79% 

78% 

62% 

90% 

89% 

79% 

81% 

81% 

61% 

80% 

79% 

61% 

78% 

77% 

59% 

67% 

66% 

49% 

20% 40% 60% 80% 100% 

NASA Total - 2018 Government-wide - 2019 

Engagement Index: 

Intrinsic Work Experience 

Supervisors 

Leaders Lead 

0% 

NASA Total - 2019 

83% 

82% 

68% 

85% 

84% 

72% 

88% 

88% 

76% 

75% 

73% 

57% 

20% 40% 60% 80% 100% 

NASA Total - 2018 Government-wide - 2019 

8

 The FEVS is a climate survey conducted by the U.S. Office of Personnel Management (OPM). The New Inclusion 

Quotient Index is calculated by averaging a subset of 20 FEVS questions measuring five factors: Empowered, Supportive, 

Cooperative, Open, and Fair. 9

 The Employee Engagement Index is calculated by averaging a subset of FEVS questions measuring 3 factors: Intrinsic 

Work Experience, Supervisors, and Leaders. 

62 
Figure 5. FEVS Questions Focused on EEO, D&I, and Compliance: FY 2015-19 

100% 

90% 

82% 83%86%87%

81%84%86% 85%86% 

59% 

70% 

80% 

70% 

78% 

72% 

84% 

79%80% 78% 80% 

67% 70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

17. I can disclose a 34. Policies and programs 38. Prohibited Personnel 45. My supervisor/team 55. Managers/

suspected violation of any promote diversity in the Practices (e.g., illegally leader is committed to a supervisors/team leaders 

law, rule or regulation workplace (e.g., recruiting discriminating for or workforce representative work well with employees 

without fear of reprisal. minorities and women, against any employee/ of all segments of society. of different backgrounds. 

training in awareness of applicant, obstructing a 

diversity issues, person's right to compete 

mentoring). for employment, 

knowingly violating 

veterans' preference) are 

not tolerated. 

2015 

2017 

2019 

Government-wide, 2019 

 

Source for Figures 4-5: U.S. Office of Personnel Management, 2019 Federal Employee Viewpoint Survey Results. 

Percentages represent the percentage of responses that were positive. Government-wide, there were 615,395 

respondents; there were 10,789 NASA respondents. 

63 
 

 

APPENDIX B: DOCUMENTS REQUIRED BY EEOC 

EEOC requires agencies to include several documents with their MD-715 report submissions. The 

required documents are available on the Web sites identified in the table below: 

Mandatory Documents Web site 

Organizational Chart https://www.nasa.gov/about/org_index.html 

EEO Policy Statement https://www.nasa.gov/offices/odeo/policy-and-publications 

Strategic Plan https://www.nasa.gov/news/budget/index.html 

Anti-Harassment Policy and Procedures https://www.nasa.gov/offices/odeo/policy-and-publications 

Reasonable Accommodation Procedures https://www.nasa.gov/offices/odeo/policy-and-publications 

Personal Assistance Services 

Procedures https://www.nasa.gov/offices/odeo/policy-and-publications 

Alternative Dispute Resolution 

Procedures https://www.nasa.gov/offices/odeo/policy-and-publications 

Agencies have the option of submitting the documents listed in the following table. In addition, the 

appendices in this report are not required by EEOC,but will be submitted with the MD-715 report as 

optional documents. 

Optional Documents Description and/or Web site 

Federal Equal Opportunity Recruitment 

Program (FEORP) Report 

NASA completed this report and submitted it to the Office of 

Personnel Management. It will be provided upon request. 

Disabled Veterans Affirmative Action 

Program (DVAAP) Report 

NASA completed this report and submitted it to the Office of 

Personnel Management. It will be provided upon request. 

Operational Plan for Increasing 

Employment of Individuals with 

Disabilities under Executive Order 

13548 

Part J of this document serves as the plan for increasing the 

employment of individuals with disabilities. 

Diversity and Inclusion Plan under 

Executive Order 13583 https://www.nasa.gov/offices/odeo/diversity-and-inclusion 

Diversity Policy Statement https://www.nasa.gov/offices/odeo/policy-and-publications 

Human Capital Strategic Plan This document will be provided upon request. 

EEO Strategic Plan This report constitutes NASA’s EEO Strategic Plan. 

Results from most recent FEVS or 

Annual Employee Survey 

NASA uses the results of the FEVS in conducting its trigger and 

barrier analyses for the MD-715 plan. See Figures 4 and 5 in 

Appendix B for summary data. 

64 
APPENDIX C: LIST OF FREQUENTLY USED ACRONYMS 

AA Associate Administrator 

AAPI Asian Americans and Pacific 

Islanders 

ADR Alternative Dispute 

Resolution 

AFRC Armstrong Flight Research 

Center 

AHP Anti-Harassment Program 

AIAN American Indians and Alaska 

Natives 

ARC Ames Research Center 

AST Aerospace Technology 

CAP Complaints and Programs 

Division 

DAD Diversity and Data/Analytics 

Division 

D&I Diversity and Inclusion 

EEO Equal Employment 

Opportunity 

EEOC Equal Employment 

Opportunity Commission 

ERG Employee Resource Group 

FEVS Federal Employee Viewpoint 

Survey 

GRC Glenn Research Center 

GSFC Goddard Space Flight Center 

HQ NASA Headquarters

IWD Individuals with Disabilities 

IWTD Individuals with Targeted 

Disabilities 

JSC Johnson Space Center 

KSC Kennedy Space Center 

LaRC Langley Research Center 

LGBTQ+ Lesbian, Gay, Bisexual, 

Transgender, and Queer 

and/or Questioning 

MD-715 Management Directive 715 

MSFC Marshall Space Flight Center 

NASA National Aeronautics and 

Space Administration 

NCLF National Civilian Labor Force 

NPD NASA Policy Directive 

NPR NASA Procedural 

Requirement 

NSSC NASA Shared Services Center 

ODEO Office of Diversity and Equal 

Opportunity 

OCHCO Office of the Chief Human 

Capital Office 

OPM Office of Personnel 

Management 

PA Professional Administrative 

RCLF Relevant Civilian Labor Force 

S&E Science and Engineering 

SEP Special Emphasis Program 

SES Senior Executive Service 

SSC Stennis Space Center 

STEM Science, Technology, 

Engineering, and Mathematics 

WFF Wallops Flight Facility 

65 
From: Parish, Linda S. (HQ-AH000) 

To: Webb-queen, Sonya (HQ-AH000) 

Subject: RE: FOR REVIEW: ODEO MD-715 package A/2020-00087 

Date: Friday, April 10, 2020 11:55:11 AM 

Concur. 

Linda Parish 

Executive Secretariat