OFFICE OF DIVERSITY AND EQUAL OPPORTUNITY 

NATIONAL AERONAUTICS AND SPACE 

ADMINISTRATION (NASA)

MODEL EQUAL EMPLOYMENT OPPORTUNITY 

PROGRAM STATUS REPORT: FY 2022 
[this page intentionally blank]
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA) 

MODEL EQUAL EMPLOYMENT OPPORTUNITY PROGRAM STATUS REPORT:

FY 2022 

Table of Contents

Parts A-D: Agency Information ......................................................................................... 1 

Part E: Executive Summary ............................................................................................... 3 

Section I. Agency Mission and Leadership................................................................. 3 

Section II. The Six Essential Elements of a Model EEO Program ............................... 3 

Demonstrated Commitment of Agency Leadership........................................... 4 

Integration of EEO into the Agency’s Strategic Mission ..................................... 4 

Management and Program Accountability......................................................... 4 

Proactive Prevention of Unlawful Discrimination .............................................. 5 

Efficiency ............................................................................................................. 6 

Responsiveness and Legal Compliance............................................................... 6 

Section III. Workforce Analyses.................................................................................. 6 

Section IV. FY 2022 Model EEO Program Accomplishments ..................................... 8 

Section V. FY 2023 Planned Activities........................................................................ 8 

Part F: Certification of Establishment of Continuing EEO Programs ...............................11

Part G: Agency Self-Assessment Checklist – FY 2022 ......................................................13

Part H: Essential Element Deficiencies and Planned Activities........................................25

Part I: Barrier Analysis and Planned Activities................................................................. 30

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

of Persons with Disabilities..............................................................................................36

Section I: Efforts to Reach Regulatory Goals ...........................................................36

Section II: Model Disability Program........................................................................37

A. Plan to Provide Sufficient and Competent Staffing for the Disability 

Program.............................................................................................................37

B. Plan to Ensure Sufficient Funding for the Disability Program ......................38

Section III: Plan to Recruit and Hire Individuals with Disabilities............................38

A. Plan to Identify Job Applicants with Disabilities...........................................38

B. Plan to Establish Contacts with Disability Employment Organizations........40

C. Progression Towards Goals (Recruitment and Hiring) ................................. 41
ii

Section IV: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities................................................................................................................41

A. Advancement Program Plan.........................................................................41

B. Career Development Opportunities.............................................................42

C. Awards..........................................................................................................43

D. Promotions...................................................................................................44

Section V: Plan to Improve Retention of Persons with Disabilities.........................47

A. Voluntary and Involuntary Separations........................................................47

B. Accessibility of Technology and Facilities.....................................................48

C. Reasonable Accommodation Program.........................................................49

D. Personal Assistance Services Allowing Employees to Participate in the 

Workplace.........................................................................................................50

Section VI: EEO Complaint and Findings Data..........................................................50

A. EEO Complaint Data Involving Harassment..................................................50

B. EEO Complaint Data Involving Reasonable Accommodation.......................51

Section VII: Identification and Removal of Barriers.................................................51

Appendix A: Data Analyses ..............................................................................................54

Workforce Summary ................................................................................................54

External Benchmarks ........................................................................................54

Internal Benchmark ..........................................................................................55

Occupational Categories..........................................................................................58

Individuals with Disabilities......................................................................................60

Federal Employee Viewpoint Survey (FEVS) Results ...............................................61

Appendix B: Physical Science Barrier Analysis Plan and Initial Findings..........................63

Appendix C: Documents Required by EEOC.....................................................................69

Appendix D: List of Frequently Used Acronyms...............................................................70
1

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, 2021, to September 30, 2022

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 16,878

Temporary Workforce 1,321

TOTAL EMPLOYMENT 18,199

PART C1

Head of 

Agency 

Leadership Name Title

Head of Agency Bill Nelson Administrator 

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

James Yamanaka, 

Director Diversity and 

Data/Analytics Division

0301/SES (202) 358-

2167

james.k.yamanaka@

nasa.gov

Complaint Processing 

Program Manager

Eric Atilano, Equal 

Employment Manager 

0260-/GS-15 (202) 358-

2684

eric.atilano@nasa.gov

Diversity & Inclusion 

Officer

Nicole Lassiter, Equal 

Opportunity Specialist

0260/GS-15 (202) 358-

1932

nicole.e.lassiter

@nasa.gov

Hispanic Program 

Manager (SEPM)

Nicole Lassiter, Equal 

Opportunity Specialist

0260/GS-15 (202) 358-

1932

nicole.e.lassiter

@nasa.gov

Women's Program 

Manager (SEPM)

Nicole Lassiter, Equal 

Opportunity Specialist

0260/GS-15 (202) 358-

1932

nicole.e.lassiter

@nasa.gov

Disability Program 

Manager (SEPM)

Rebecca Doroshenk, 

Program Analyst

0343/GS-14 (202) 358-

0038

Rebecca.d.doroshenk

@nasa.gov

Selective Placement 

Program Coordinator 

(Individuals 

w/Disabilities)

Esteban Morales, Human 

Resources Specialist

0201/GS-14 (301) 286-

3093

Esteban.morales

@nasa.gov

Reasonable 

Accommodation Program 

Manager

Rebecca Doroshenk, 

Program Analyst

0343/GS-14 (202) 358-

0038

Rebecca.d.doroshenk

@nasa.gov

Anti-Harassment 

Program Manager

Previous: 

Randy Poynter, Equal 

Employment Manager

0260/GS-15 (202) 880-

5205

randy.g.poynter@ 

nasa.gov
2

Current:

Aleas Hammett, Equal 

Employment Manager

0260/GS-14 (202) 880-

5205

aleas.n.hammett@na

sa.gov

ADR Program Manager Randy Poynter, Equal 

Employment Manager

0260/GS-15 (202) 880-

5205

randy.g.poynter@ 

nasa.gov

Compliance Manager Eric Atilano, Equal 

Employment Manager 

026-/GS-15 (202) 358-

2684

eric.atilano@nasa.gov

Principal MD-715 

Preparer

Rebecca Kraus, Civil 

Rights Analyst

0160/GS-15 (202) 358-

2303

rebecca.s.kraus

@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 C.
3

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, 2021, to September 30, 2022 

EXECUTIVE SUMMARY

Section I. Agency Mission and Leadership 

The National Aeronautics and Space Administration’s (NASA) mission is to explore the unknown in air 

and space, innovate for the benefit of humanity, and inspire the world through discovery. As stated 

in the NASA 2022 Strategic Plan, “NASA inspires the world through exploration and discovery, leading 

scientific and technological advancements that benefit Americans and all humanity. Our efforts in 

space help to further the national economy, including through innovative commercial partnerships 

with American businesses. With the increasing threat of climate change, NASA’s efforts to study and 

understand the Earth are of critical global significance. In addition, NASA’s partnerships with 

academic institutions support a robust Science, Technology, Engineering, and Mathematics (STEM) 

workforce and promote diversity, equity, and inclusion in the fields of science and technology.” 

For an unprecedented 11th consecutive year, NASA was named the 2022 Best Place to Work in the 

Federal Government among large agencies by the Partnership for Public Service. NASA was also 

ranked among America’s Best Employers for Diversity by Forbes.

1 With top-level support from the 

NASA Administrator and leadership team, NASA and its Office of Diversity and Equal Opportunity 

(ODEO) engaged in significant activities to advance diversity, equity, inclusion, and accessibility (DEIA) 

throughout the Agency. NASA measures the success of its Equal Employment Opportunity (EEO) 

program against the six Essential Elements of a Model EEO Program, as outlined by the U.S. Equal 

Employment Opportunity Commission (EEOC) Management Directive 715 (MD-715). Fiscal Year (FY) 

2022 program accomplishments and DEIA 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 three deficiencies within

its program, reflecting a compliance rate of 98 percent. Utilizing the results of the self-assessment, 

the Agency developed plans to address program deficiencies (Part H) and workforce triggers regarding 

participation rates for certain groups in the workforce (Parts I and J). 

1 Jared Council, editor, “America’s Best Employers for Diversity: 2022,” Forbes, April 26, 2022, accessed at 

<http://www.forbes.com/lists/best-employers-diversity/?sh=5615895f6468 >.
4

Demonstrated Commitment of Agency Leadership

Throughout FY 2022, Agency leadership continued to demonstrate their commitment to DEIA and 

EEO through a variety of means. For instance, on January 18, 2022, Administrator Bill Nelson reissued 

NASA’s annual DEIA policy statement. The statement emphasizes NASA’s commitment to DEIA, 

including the following priorities: reinforcing a culture in which our employees feel they can be 

authentic, welcomed, respected, included, and engaged; maintaining an environment where 

employees consistently and systematically receive fair, just, and impartial treatment; and ensuring 

our employees can fully and independently access facilities, information and communication 

technology, programs, and services. This policy statement covers all aspects of DEIA, including equal 

employment opportunity, anti-harassment, and reasonable accommodation (RA), as required by 

EEOC and Executive Orders issued by the Administration. 

Throughout the year, the Administrator, Deputy Administrator, Associate Administrator, and other 

NASA leaders prioritized discussions with employees and employee resource groups (ERGs) and 

advocated for their inclusion in the development of DEIA policies and initiatives. Leadership at the 

NASA Center-level also support EEO And DEIA initiatives. For example, all NASA Centers have each 

established a DEIA Council comprised of Center senior leaders and representatives of offices across 

each Center, and senior leaders at NASA Centers continue to participate as champions and/or 

members of ERGs. Leaders also participated in a variety of special emphasis programs and outreach 

events (e.g., the Center Directors of Glenn Research Center (GRC), Johnson Space Center (JSC), 

Kennedy Space Center (JSC), and Marshall Space Flight Center (MSFC) participated in the American 

Astronautical Society’s annual Von Braun Space Symposium). 

Integration of EEO into the Agency’s Strategic Mission

NASA continues to ensure that EEO and DEIA are integrated into all aspects of its work, from its 

scientific missions to recruitment and development of its employees. In August 2022, NASA issued its 

DEIA Strategic Plan which provides a roadmap to help the Agency continue to empower its employees 

to share their unique experiences and skills for the betterment of the agency, while actively 

supporting individual progress and development. This plan will ensure NASA can accomplish goals 

that support Executive Order 14035, “Diversity, Equity, Inclusion, and Accessibility in the Federal 

Workforce,” and inspire others to join the NASA family. 

Management and Program Accountability

NASA regularly reports on EEO and DEIA performance outcomes at several Agency governance 

councils, including the NASA Executive Council and the Mission Support Performance Management 

Council. In addition, the Associate Administrator (AA) for ODEO is a full and active member of NASA’s 

senior leadership team and regularly participates on various decision-making bodies, boards, panels, 

and councils, such as: the Senior Management Council, the Agency’s senior decision-making body for 

strategic direction and planning; the Mission Support Council, the Agency's senior decision-making 

body regarding the integrated mission support portfolio; the Performance Review Board, which 

conducts annual performance reviews of NASA’s Senior Executive Service (SES) members; and the 
5

Executive Resources Board, which provides advice, counsel, and recommendations for consideration 

by the Administrator relating to the management of executive human resources. 

Throughout FY 2022, NASA continued to refine its EEO and DEIA reporting capabilities, including 

providing reports to NASA Centers on the diversity of their workforces and conducting a detailed 

barrier analysis of physical scientist positions. Although NASA collects applicant flow data and has

analyzed it for previous MD-715 reports, those data are not yet available for FY 2022. This is due to 

NASA’s adoption of a new staffing solution in 2021, updates to the system implemented by Office of 

Personnel Management (OPM) in 2022, and the lag time needed to develop the applicant flow data 

tables within the new environment.

Proactive Prevention of Unlawful Discrimination

In support of recent DEIA Executive Orders, NASA: 

• Published revised Guidance for Supporting Gender Transition/Affirmation in the 

Workplace (January 2022); 

• Submitted a Gender Equity and Equality Action Plan to the White House Gender Policy 

Council (July 2022); and 

• Issued its DEIA Strategic Plan (August 2022) and initiated the development of Center, 

Mission Directorate, and Lead Mission Support Office implementation plans (due in 

December 2022). 

Further, throughout FY 2022, NASA organized numerous cultural awareness events during special 

observance months to educate the workforce. NASA also encourages participation in the Agency’s 

more than 60 ERGs, which play a vital role in NASA’s retention and development efforts. NASA

Centers and organizations also initiated several activities aimed at proactive prevention of 

discrimination and enhancing DEIA:

• All NASA Centers displayed the Progress Pride Flag at their Centers for LGBTQIA+ Pride 

Month for the first time.

• The Ames Research Center (ARC) Associate Director is heading a Workplace Diversity 

Pipeline initiative, which is focused on reducing underrepresentation in the pipeline from 

pre-vacancy to hire. The initiative is comprised of several elements, including: supervisor 

access to diversity metrics; increased recruiting at Minority Serving Institutions (MSI); 

required diversity and unconscious bias training for hiring managers, interviewers, and 

selection officials; and the elevation of DEIA culture to the same level as safety culture. 

• The GRC Director ensured that accessibility improvements of GRC facilities continued 

during FY 2022. These improvements included road work to smooth streets, curb 

cutouts, truncated domes for sidewalks, and reserved parking spots for individuals with 

disabilities (IWD). GRC also established an additional gender-neutral restroom, bringing 

the total to 41. 
6

• Goddard Space Flight Center (GSFC) sponsors a Diversity Dialogue Project (DDP), a 

facilitated dialogue program that brings small groups of employees together in an open, 

non-judgmental, and safe environment to discuss differences based on the many 

dimensions of diversity that impact the workplace. The DDP has become the Center’s 

foundational D&I learning experience, with participation of employees and supervisors 

across several GSFC campuses. In FY 22, a virtual cross campus DDP 101 session was held, 

featuring participation from each of GSFC’s campuses. Preliminary survey analyses 

indicate success toward continuing both the virtual and the cross-campus aspects.

• NASA Headquarters (HQ) leadership identified two spaces to be designated for multifaith 

usage; these rooms will allow employees to have dedicated spaces to practice their faith, 

commune with others, and meet religious obligations without feeling the need to take 

leave and increase the ability of inclusive connection.

Efficiency 

On September 9, 2022, NASA awarded the first-ever Agency-wide Sign Language Interpretation (SLI) 

Blanket Purchasing Agreement (BPA). The SLI BPA will enable consistency in the services NASA 

provides to its deaf and hard-of-hearing employees, interns, applicants, and guests – no matter the 

individual’s geographical location within the Agency. In addition, NASA continues to improve its data 

analytics capability and to obtain data needed to efficiently and consistently monitor workforce 

demographics and conduct barrier analyses. In FY 2022, NASA issued a statement of work for 

contractor support to build data pipelines to obtain additional data for DEIA and MD-715 analytics. 

The contractor will build data dashboards and applications that will improve personnel and other data 

analytics capabilities across the Agency.

Responsiveness and Legal Compliance

In FY 2022, NASA posted timely No FEAR Act data, met established deadlines for submitting the FY 

2021 MD-715 report, and submitted a timely Annual Statistical Report of Discrimination Complaints 

(EEOC Form 462) to EEOC. In addition, NASA emphasizes a broad application of anti-harassment 

policy and procedures through its Agency Anti-Harassment Program (AHP), taking the Agency beyond 

legal compliance and focusing on workforce and mission. In FY 2022, NASA received 38 reports of 

harassment under the AHP, with an average processing time of 48 days, compared to 64 days in FY 

2021. NASA continues to train the workforce with its award-winning, on-line “gamified” antiharassment training.

Section III. Workforce Analyses

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. NASA 

monitors workforce composition data to determine if discrepancies exist in the participation rate of 
7

any demographic group.2 The FY 2022 workforce composition data revealed the following triggers

(see Appendix A, Table 2): 

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

(AAPI) and Hispanics account for a lower percentage of the SES compared to their 

overall representation in the NASA workforce. 

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

Hispanics, and Women make up a smaller proportion of both SL and ST positions than 

their overall representation in the workforce. AAPI employees are underrepresented 

in SL positions.

• GS-14 through GS-15 and Supervisory positions: Women are underrepresented in GS14 through GS-15 positions, accounting for 30.6 percent of the employees in those 

grades (compared to their overall representation in the NASA workforce of 34.9 

percent). AAPI and Hispanic employees are underrepresented in supervisory 

positions. 

Triggers also exist with regard to specific occupations when compared to the Relevant Civilian Labor 

Force (RCLF) (see Appendix A, Tables 3-4).3 For example, Women account for 32.6 percent of NASA 

Physical Scientists (job series 1301) yet are 43.4 percent of Physical Scientists in the RCLF. Similarly, 

AAPI make up 14.1 percent of Physical Scientists at NASA, but account for 16.4 percent of such 

positions in the RCLF. As noted in Part I of this report, NASA initiated a barrier analysis for Physical 

Science positions, the findings of which appear in Appendix B.

In contrast, AAPI, Blacks, Hispanics, and Women represent a greater proportion of those occupying

several Professional Administrative positions at NASA when compared to the RCLF (see Appendix A, 

Table 4). For example: 

• AAPI employees are 12.8 percent of NASA Accountants, compared to 8.6 percent of 

Accountants in the RCLF. 

• Black employees are employed at a rate approximately three times their 

representation in the RCLF in Contract Specialist and Accountant positions. Blacks 

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 A, 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.

3 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>. 
8

account for 25.3 percent of NASA Contract Specialists and 31.1 percent of NASA 

Accountants, compared to 8.5 percent and 8.1 percent, respectively, in the RCLF. 

• Hispanic employees are 11.9 percent of Management and Program Analysts, 

compared to 4.6 percent in the RCLF; 10.7 percent Contract Specialists, compared to 

7.1 percent in the RCLF; and 8.7 percent of Accountants, compared to 6.1 percent in 

the RCLF. 

NASA exceeds the Federal goals for the employment of IWD and individuals with targeted disabilities 

(IWTD) (see Part J). These goals are: (1) IWD should account for 12 percent of employees in grades 

GS-10 and below and 12 percent of employees in grades GS-11 and above, and (2) IWTD should 

account for two percent of employees in these grade categories. For grades GS-10 and below: IWD

and IWTD account for 24.9 percent and 7.5 percent of the NASA employees in those grades, 

respectively. For grades GS-11 and above, IWD and IWTD are 13.7 percent and 2.7 percent of NASA 

employees in those grades. (See Appendix A, Figures 3-4.) The Agency will continue to monitor overall 

employment data on IWD and IWTD, with regard to recruitment, hiring, promotions, awards, and 

retention. 

Section IV. FY 2022 Model EEO Program Accomplishments 

In FY 2022, NASA corrected the two program deficiencies: 

• Ensure EEO investigations are completed timely, pursuant to 29 CFR §1614.108 (see Part 

H-4). The timeliness of investigations increased from 95 percent in FY 2021 to 100 percent 

in FY 2022. NASA will continue to closely monitor its investigations to ensure compliance 

with regulations.

• Notify complainants of the date by which the investigation will be completed and of their 

right to request a hearing or file a lawsuit, pursuant to 29 CFR §1614.108(g) (see Part H5). In FY 2022, NASA developed standard operating procedures for its complaints 

processing program and now issues 180-day letters on cases even when they will not be 

untimely. 

Section V. FY 2023 Planned Activities

No new program deficiencies were identified in FY 2022; work continues on three deficiencies: 

• Revise Agency structure so that the AA, ODEO, reports directly to the NASA Administrator, 

pursuant to 29 CFR §1614.102(b)(4) (see Part H-1). NASA continues to determine how to 

address this deficiency.

• Conduct prompt inquiries of harassment allegations under the Anti-Harassment Program 

(beginning within ten days of notification) (see Part H-2). In FY 2022, NASA embedded its 

Workplace Safety and Harassment Prevention and Response Plan into its DEIA Strategic 

Plan and identified the implementation of a NASA-wide Anti-Harassment Campaign as a 

key performance goal in the DEIA Strategic Plan. In FY 2022, NASA completed 62.1 
9

percent of cases in a timely fashion compared to 56.7 percent in FY 2021. In FY 2023, 

NASA hired a dedicated Anti-Harassment and ADR Program Manager who will be 

responsible for initiating a new Anti-Harassment Campaign and delivering a training 

event for the Anti-Harassment Community of Practice focused on ensuring a victimcentered, trauma-informed approach. 

• Ensure EEO counseling is completed timely within 30 or 90 calendar days, pursuant to 29 

CFR §1614.108 (see Part H-3). FY 2022, NASA completed 95 percent of its counseling 

timely (compared to 89 percent in FY 2021). NASA will continue to review monthly 

complaint processing data to track compliance to regulatory requirements and will 

develop additional interventions, as necessary, to improve timeliness.

In addition, NASA continues to strengthen its data analytics capabilities and conduct barrier analyses

regarding Women, AAPI, and IWD. NASA intends to initiate a barrier analysis regarding grade 

progression for women and minorities, given that an analysis of employees by grade revealed that 

the percentage of minorities and women decreases as grade levels increase (see Part I). NASA also 

will continue to address issues related to its disability program (see Part J). 
10

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11

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 

OPPORTUNITY PROGRAMS

CONTINUING EQUAL EMPLOYMENT 

I, 

Elaine P. Ho, 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.

8/22/2023

Signature of Principal EEO Director/Official

Certifies that this Federal Agency Annual EEO 

compliance with EEO MD 715.

Program Status Report is in 

Date

5/16/2023

Signature of Agency Head or Agency Head Designee Date
12

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13

PART G: AGENCY SELF-ASSESSMENT CHECKLIST – FY 2022 

MD-715

PART G

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL

EEO PROGRAM STATUS REPORT

This 

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

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

opportunity and a discrimination-free workplace.

A.1 – The agency 

policy statement.

issues an effective, up-to-date EEO 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

and DEIA policy statement on 

January 18, 2022. 

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

A.2 – The agency 

procedures to all 

has communicated 

employees.

EEO policies and 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?

1614.203(d)(3)]

[29 CFR § Yes

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

site: 

in the workplace and on its public Web

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. Yes 

https://nodis3.gsfc.nasa.gov/

displayDir.cfm?t=NPR&c=371

3&s=1C

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? 

often. 

[MD-110, Ch. 3(II)(C)] If yes, provide how Yes At least annually.

A.2.c.3 − Reasonable accommodation program? [29 CFR § 

1614.203(d)(7)(ii)(C)] If yes, provide how often. Yes At least annually.

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.
14

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.

A.3 – The agency assesses 

are part of its culture.

and ensures EEO principles 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.

Yes

Examples: Agency Honor 

Awards – EEO Medal; Annual 

Robert H. Goddard Awards – 

Diversity/EEO Award; Ames 

EEO/Diversity Excellence 

Award; and KSC Diversity and 

Equal Opportunity Award.

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

This 

Essential Element B: INTEGRATION OF 

element requires that the agency’s EEO 

that is free from discrimination and 

EEO INTO THE AGENCY’S STRATEGIC MISSION

programs are structured to maintain a workplace 

support the agency’s strategic mission.

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)] No

The AA for ODEO formally 

reports to the Deputy 

Administrator and has regular 

access to the Administrator. 

See Part H-1.

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.

No See Part H-1.

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); MD-715 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. 

Yes

ODEO briefed the NASA 

Administrator on 9/27/2022

and presents updates 

throughout the year, including 

Baseline Performance Review 

and the Management Support 

Performance Management 

Council meetings.

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

B.2 – The 

program.

EEO Director controls all aspects of the EEO Measure 

Met? Comments
15

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

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.

Yes

Strategic Objective 4.1: 

Attract and develop a 

talented and diverse 

workforce 

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

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
16

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.1

0 

− to effectively manage its reasonable accommodation 

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

B.4.a.1

1 

− 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

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:

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

B.6 – The agency involves managers in the 

implementation of its EEO program.

Measure 

Met? Comments

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

Special Emphasis Programs? [MD-715 Instructions, Sec. I] Yes
17

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.

C.1 – The agency conducts regular 

component and field offices.

internal audits of its Measure 

Met? Comments

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.

Yes

Agency ODEO reviews Center 

MD-715 plans annually, 

provides technical assistance 

as needed, and periodically 

conducts functional reviews.

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.

Yes

Agency ODEO reviews Center 

MD-715 plans and 

accomplishments on an 

annual basis.

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

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

C.2 – The 

all forms 

agency has established 

of EEO discrimination.

procedures to prevent 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

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 

anti-harassment 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 

ten 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. 

No

NASA uses an indicator of 60 

days for case completion. In 

FY 2022, NASA completed 

62.1 percent of cases in a 

timely fashion. See Part H-2.
18

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.

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 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

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

https://nodis3.gsfc.nasa.gov/

displayDir.cfm?t=NPR&c=371

3&s=1B 

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? 

[MD-715, II(C)]

Yes

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

managerial, communication, and interpersonal skills to Yes
19

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

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.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 

procedures conform to EEOC laws, instructions, and 

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

Yes

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
20

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

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.

Yes One employee was issued a 

letter of reprimand. 

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

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 updates in comments.

Yes At least annually.

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

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

Sec. I]

Yes

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.

D.1 – The agency conducts a reasonable assessment 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; 

special emphasis programs; reasonable accommodation 

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

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

Yes

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 

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

Yes

D.2 – The agency identifies areas where barriers may 

exclude EEO groups (reasonable basis to act.)

Measure 

Met?

Comments

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 

§1614.102(a)(3)]

Yes
21

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 

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

Yes

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 

(e.g., FEVS), anti-harassment 

program data, affinity groups, 

Special Emphasis Program 

(SEPs), employee pulse 

surveys, and other sources 

(when available).

D.3 – The agency establishes appropriate action plans to 

remove identified barriers.

Measure 

Met?

Comments

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

the identified barriers, in particular policies, procedures, or 

practices? [29 CFR §1614.102(a)(3)]

Yes

D.3.b If the agency identified one or more barriers during the 

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

including meeting the target dates for the planned 

activities? [MD-715, II(D)] 

N/A See Part I.

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.

Measure 

Met?

Comments

D.4.a 

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.

Yes https://www.nasa.gov/offices/

odeo/workforce-data

D.4.b 

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)]

Yes

D.4.c 

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)]

Yes

D.4.d 

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)]

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.

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] No

NASA timely completed 95

percent of counselings in FY 

2022. See Part H-3.

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 Yes The average processing time was 68 days. 
22

receipt of the written EEO Counselor report? [MD-110, Ch. 

5(I)] If yes, provide the average processing time in the 

comments section.

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 See Part H-4. 

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

NASA issues 180-day letters

on cases even when they will 

not be untimely. 

See Part H-5.

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)] 

Yes

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

of the hearing file and the administrative judge’s (AJ) 

decision? [29 CFR §1614.110(a)]

Yes

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.

Yes

Timelines in the statement of 

work, templates to ensure 

consistency, and contractors

must provide weekly status 

updates and inform the 

Contracting Officer’s 

Representative (COR) 

immediately of any issues 

causing delays. The COR has 

regular meetings with 

contractors to address 

deficiencies or improvements.

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

E.2 – The agency has a neutral EEO process. Measure 

Met? Comments

E.2.a Has the agency established a clear separation between its 

EEO complaint program and its defensive function? [MD110, Ch. 1(IV)(D)] If yes, please explain in the comments 

column. 

Yes

The attorney who provides 

legal advice to ODEO does not 

serve as the Agency 

representative. 

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.

Yes

The attorney who provides 

legal advice to ODEO does not 

serve as the Agency 

representative. 

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
23

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

E.3 - The agency has established and encouraged 

widespread use of a fair ADR program.

the 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

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

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

II(A)(1)]

Yes

E.3.c Does the agency encourage all employees to use ADR, 

where ADR is appropriate? [MD-110, Ch. 3(IV)(C)] Yes

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

settlement authority is accessible during the dispute 

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

Yes

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

official named in the dispute from having settlement 

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

Yes

E.3.f Does the agency annually evaluate the effectiveness of its 

ADR program? [MD-110, Ch. 3(II)(D)] Yes

E.4 – The 

collection 

agency has 

systems in 

effective and accurate data 

place to evaluate its EEO program.

Measure 

Met? Comments

E.4.a Does the agency have systems in place to accurately collect, monitor, and analyze the following: 

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

complaints, the aggrieved individuals/ complainants, and 

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

Yes

E.4.a.2 − The race, national origin, sex, and disability status of 

agency employees? [29 CFR §1614.601(a)] Yes

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? [MD-715, II(E)]

Yes

E.4.a.5 − The processing of requests for reasonable 

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

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

program? [EEOC Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.2]

Yes

E.4.b Does the agency have a system in place to re-survey the 

workforce on a regular basis? [MD-715 Instructions, Sec. I] Yes

E.5 – The agency identifies and 

trends and best practices in its 

disseminates 

EEO program.

significant Measure 

Met? Comments

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

determine whether agency is meeting its obligations under 

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

example in the comments section.

Yes

NASA regularly reviews data 

on the workforce, EEO 

complaints, and harassment 

allegations, and reports trends 

to leadership.

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

adopt them, where appropriate, to improve the Yes NASA reviews other agencies’ MD-715 reports, benchmarks 
24

effectiveness of its EEO program? [MD-715, II(E)] If yes, 

provide example in the comments section.

with other agencies, reviews

best practicess, and adopts 

best practices when 

appropriate.

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

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

II(E)] 

Yes

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.

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? [MD715, 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

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

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
25

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

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

PART H: ESSENTIAL ELEMENT DEFICIENCIES AND PLANNED ACTIVITIES

NASA completed Parts H-4 and H-5 in FY 2022; no new deficiencies were identified. 

MD-715

PART H-1 

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: Revise Agency structure so that the AA, ODEO, reports directly to the NASA Administrator.

RESPONSIBLE 

OFFICIAL: NASA Administrator; AA, 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

10/1/2020 12/31/2021 9/30/2023 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

12/31/2021 1. NASA Administrator makes a decision on how 

address this deficiency.

to Yes 9/30/2023 

12/31/2021 2. NASA completes administrative actions, 

including updating its organizational chart, 

implement the new reporting structure.

to 

Yes 9/30/2023 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2022 Progress and Accomplishments: NASA continues to review its organizational structure. 

Modifications to Objective: Modified completion date to 9/30/2023. 
26

MD-715

PART H-2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY:

NASA does not conduct a prompt inquiry (beginning within ten days of notification) of all 

harassment allegations, including those initially raised in the EEO complaint process. (Part 

G, Management and Program Accountability, Measure C.2.5.a) 

OBJECTIVE: Establish timeframes for completing 

Harassment Program.

inquiries of harassment allegations under the AntiRESPONSIBLE 

OFFICIAL: AA, ODEO, and Director, Equal Opportunity 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

2/1/2020 1/31/2021 9/30/2023 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

3/30/2020 1. Draft revised procedures. Yes 3/30/2020

6/30/2020 2. Obtain feedback from other NASA offices. Yes 6/30/2020

11/30/2020 3. Make necessary revisions. Yes 11/30/2020

1/31/2021 4. Finalize and publish new procedures. Yes 1/12/2021

3/30/2022 5. Finalize development of and launch 

system for anti-harassment cases.

tracking Yes 10/1/2021

9/30/2022 6. Provide training and technical assistance to 

Center Anti-Harassment Coordinators on 

conducting immediate interviews.

Yes 9/30/2023

12/31/2022 7. Hire Anti-Harassment and ADR Program 

Manager. 

Yes

12/31/2022 8. Initiate Anti-Harassment Campaign 2.0 with 

NASA Administrator’s message to the workforce. 

Yes

9/30/2023 9. Deliver a training event for the Anti-Harassment 

Community of Practice focused on ensuring a 

victim-centered, trauma-informed approach.

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2022 Progress and Accomplishments: NASA embedded its Workplace Safety and Harassment 

Prevention and Response Plan into its DEIA Strategic Plan. Implementation of a NASA-wide AntiHarassment Campaign was developed as a key performance goal in the DEIA Strategic Plan. NASA 

committed funding and staffing for a position dedicated to managing the Anti-Harassment and ADR 

Programs.

Modifications to Objective: Added planned activities #7-9; modified completion date to 9/30/2023.
27

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 does not complete EEO counseling

1614, Section 105 and EEOC regulations. 

within the timeframes established by 

(Part G, Efficiency, Measure E.1.a)

29 CFR. Part 

OBJECTIVE: Ensure all EEO

requirements.

counselings are timely completed in accordance with all regulatory 

RESPONSIBLE 

OFFICIAL: AA, ODEO; Director, Complaints Management Division, ODEO; Center ODEO Directors

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 9/30/2023

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 9/30/2023 

9/30/2021 7. Provide forums to discuss Agency-wide issues at the 

informal complaints stage to increase timeliness.

Yes 9/30/2021

9/30/2021 8. Provide training, including EEO Refresher Training 

focusing on specific NASA-related complaint issues.

Yes 4/7/2021

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2022 Progress and Accomplishments: In FY 2022, NASA timely completed 95 percent of its counselings 

(compared to 89 percent in FY 2021). 

Modifications to Objective: Modified completion date to 9/30/2023. NASA will continue to review 

monthly complaint processing data to track compliance to regulatory requirements and will develop 

additional interventions, as necessary, to improve timeliness. 
28

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 EEO 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 EEO investigations are timely completed in accordance with all regulatory 

requirements.

RESPONSIBLE 

OFFICIAL: AA, ODEO; Director, Complaints Management 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 9/30/202

2 9/30/2022 

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. 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.

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 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

9/30/2020 7. Remove non-mandated reviews by Complainant and 

Agency Legal Representative to assist with timeliness.

Yes 9/30/2020

9/30/2020 8. Ensure record is closed, parties are notified, and 

appropriate election rights are provided.

Yes 9/30/2020

9/30/2020 9. Increase the number of contractors. Yes 9/30/2020 

9/30/2021 10. Increase the number of staff reviewing Investigation Plans. Yes 9/30/2021

9/30/2021 11. Track and monitor investigations to ensure full compliance 

with regulatory timeframes. 

Yes 9/30/2022 9/30/2022 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2022 Progress and Accomplishments: The timeliness of investigations increased from 95 percent in 

FY 2021 to 100 percent in FY 2022. NASA will continue to closely monitor its investigations to ensure 

compliance with regulations.
29

Modifications to Objective: Objective completed. 

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 notify complainants of the date by which the investigation will be completed 

and of their right to request a hearing or file a lawsuit, pursuant to 29 CFR §1614.108(g). 

(Part G, Efficiency, Measure E.1.g)

OBJECTIVE: Ensure all “180-day” letters are issued when appropriate. 

RESPONSIBLE 

OFFICIAL: AA, ODEO; Director, Complaints Management 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

10/1/2020 9/30/2021 9/30/2022 9/30/2022 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

9/30/2021 Issue 180-day letters, when appropriate, within 175 

calendar days of when the formal complaint was filed. 

Yes 9/30/2022 9/30/2022

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2022 Progress and Accomplishments: NASA developed standard operating procedures 

complaints processing program. 

Modifications to Objective: Objective completed. 

for its 
30

PART I: BARRIER ANALYSIS AND PLANNED ACTIVITIES

MD-715

PART I-1 

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?

A comparison of FY 2020-21 NASA workforce data to the RCLF revealed that AAPI and 

Women have lower than expected participation rates in Physical Scientist positions 

(U.S. Office of Personal Management (OPM) code 1301)) at NASA. Specifically, AAPI 

account for 13.2 percent of Physical Scientists at NASA compared to 16.4 percent in the 

RCLF. Women account for 31.2 percent of NASA Physical Scientists compared to 43.4 

percent in the RCLF. Both AAPI women and White women account for a lower 

percentage of Physical Scientists at NASA than they do in the RCLF. AAPI women are 

3.8 percent of NASA Physical Scientists yet are 7.5 percent of physical scientists in the 

RCLF. Similarly, White women are 23.3 percent of NASA Physical Scientists, compared 

to 29.8 percent in the RCLF. 

SOURCE OF 

TRIGGER: NASA has prolonged (FY 2018 to present), lower than expected, workforce 

participation compared to the RCLF benchmark for certain groups. 

MD-715 

WORKFORCE DATA 

TABLE:

Table A6

EEO GROUP(S) 

AFFECTED BY 

TRIGGER:

Check all that apply:

All Men Asian Males X 

All Women 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 X 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

Grievance Data (Trends) Yes

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

N/A

Climate Survey (e.g., FEVS) Yes FEVS Indexes
31

Exit Interview Data No

Focus Groups No

Interviews Yes

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, four of seven phases completed.

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

STATEMENT OF 

IDENTIFIED 

BARRIER(S): 

(Description of 

Policy, Procedure, 

or Practice)

Barriers not yet identified; 

9/30/2022.

pending completion of barrier analysis on or about 

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 9/30/2020

Track and monitor the 

participation rate of Women and 

AAPI in the Physical Scientists 

occupational category.

1/28/2019 Yes 9/30/2020

Complete barrier analysis. 10/1/2020 9/30/2020 Yes 11/15/2022

Implement a DEIA analytics 

capability within NASA’s 

Enterprise Data Platform to 

enable evidence-based 

awareness, planning, decisions, 

and assessments of the current 

and future state of DEIA at NASA. 

11/30/2021 9/30/2026 Yes

RESPONSIBLE 

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

AA, ODEO Stephen T. Shih Yes

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 

Office of the Chief Human Capital Officer (OCHCO) and the 

9/28/2018
32

Science Mission Directorate (SMD), to strengthen its data 

analytics capabilities to enable ODEO to conduct in-depth 

barrier analyses.

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, 

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

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.

9/30/2021 9/30/2021

9/30/2020 5. NASA will review applicant flow data by race and 

Physical Scientist positions in FY 2020.

gender for 4/1/2021 4/1/2021

10/1/2020 6. NASA will develop a formal barrier analysis plan 

analysis of women and AAPI physical scientists.

for barrier 10/1/2020

11/16/2020 7. NASA will examine participation triggers to include 

participation overall, by grade, and by position. (Phases 1-2 of 

the barrier analysis plan)

11/16/2020

4/1/2021 8. NASA will examine workforce data, training history, and other 

existing data sources for potential explanations for triggers 

identified in Phases 1-2 of the barrier analysis. (Phase 3)

4/1/2021

9/30/2021 9. NASA will collect qualitative information from NASA Centers 

and organizations to better understand trends identified in 

the initial phases of the barrier analysis. (Phase 4)

12/31/2021 12/10/2021

6/30/2022 10. NASA will collect qualitative and quantitative data from NASA 

Physical Science employees to gain deeper insight into 

potential barriers and potential solutions to those barriers. 

(Phases 5 and 6)

11/01/2022

9/30/2022 11. NASA will review all data collected in Phases 1-6 of the 

barrier analysis to determine whether barriers to equal 

employment opportunity exist for Women and AAPI in the 

Physical Sciences at NASA. (Phase 7)

11/15/2022

6/30/2022 12. Identify key data sources and new data collection, both 

internal and external to NASA, to support DEIA analytics and 

reporting requirements. 

6/30/2022
9/30/2022 13. Create a DEIA data architecture that links data requirements 

to analytic questions and strategic and operational 

decisions. Identify gaps in data elements and data standards 

that NASA can mitigate internally as well as communicate 

data gaps to OMB, OPM, and other external data stewards 

who can help address. 

9/30/2022

9/30/2022 14. Establish a technical infrastructure and implement industry 

best-practice analytic tools to be able to exploit the benefits 

of cloud-based, big-data analytics. 

9/30/2022

9/30/2026 15. Implement meaningful analytic products, dashboards, and 

models aligned to NASA’s internal and external stakeholder 

and customer needs to improve decision-making, encourage 

data sharing, and improve accountability. 

6/30/2022 16. Identify and acquire additional resources through the Federal 

Government and NASA’s budget processes to successfully 

implement an effective analytics capability aligned with the 

new requirements extended by the Administration’s 

priorities as well as NASA’s internal requirements. 

6/30/2022

9/30/2026 17. Assess current data governance and related policies to 

ensure effective data management, stewardship, and 

security. 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2022 Progress: NASA identified key data sources (e.g., NASA Personnel Data Warehouse, American 

Community Survey, OPM’s FedScope, and the Federal Employee Viewpoint Survey) and developed a 

roadmap for the Future State of DEIA Data Analytics. In addition, NASA issued a Statement of Work and 

onboarded contract Data Scientists and Data Engineers to begin the ingestion of data into the NASA 

Enterprise Data Platform. NASA also identified user needs for analytic dashboards and developed 

prototype DEIA dashboard in Tableau, which will be enhanced by the data contractors. 

In addition, in early FY 2022, NASA completed Phase 4 of the barrier analysis on Physical Science positions; 

this involved the collection of qualitative data from managers and human resource personnel. Findings of 

Phases 1-3 generated additional questions about root causes. These potential root causes were further 

explored in April 2022 with a psychometric survey. This survey yielded useful insights into root causes. The 

final phase of data collection and analysis, focus groups, is under way with anticipated completion in early 

November 2022. This final phase will identify remaining root causes and potential corrective actions. 

Modifications to Objective: None. 

33
34

MD-715

PART I-2 

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 

A review of NASA workforce data revealed that the percentage of minorities and 

women decreases as grade levels increase. For example, in FY 2022, Hispanics and 

Latinos accounted for 10.9 percent of NASA employees at grades GS-13 and below, 

BARRIER: Provide a 

brief narrative 

describing the 

condition at issue. 

How was the condition 

recognized as a 

potential barrier?

7.5 percent at grades GS-14 and GS-15, and 5.3 percent of the SES. Women account 

for 40.8 percent of those in grades GS-13 and below, 31.7 percent in grades GS-14 

and GS-15, and 36.5 percent of those in the SES. Although the percentages of 

minorities and women at each age group has increased slightly since FY 2017, this 

trend has remained. (See Appendix A.)

SOURCE OF TRIGGER: Smaller percentage of the workforce occupied by women and minorities at higher 

grades.

MD-715 WORKFORCE Tables A4 and A7

DATA TABLE:

EEO GROUP(S) Check all that apply:

AFFECTED BY 

TRIGGER:

All Men Asian Males X 

All Women X Asian Females X 

Hispanic or Latino Males X Native Hawaiian or Other Pacific Islander

(NHOPI) Males

X 

Hispanic or Latino Females X NHOPI Females X 

White Males American Indian or Alaska Native Males X 

White Females X American Indian or Alaska Native Females X 

Black or African American Males X Two or More Races Males X 

Black or African American Females X Two or More Races Females X 

BARRIER ANALYSIS PROCESS

SOURCES OF DATA: Sources Source Reviewed 

(Y/N)?

Identify Information 

Collected

Workforce Data Tables Yes Tables A4 and A7

Complaint Data (Trends) No

Grievance Data (Trends) No

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

N/A

Processes) 

Climate Survey (e.g., FEVS) Yes FEVS 

Exit Interview Data No

Focus Groups No

Interviews No

Reports (e.g., Congress, EEOC, MSPB, GAO, No

OPM)

Other (Please Describe) N/A
35

STATUS OF BARRIER 

ANALYSIS PROCESS:

Barrier analysis process completed? (Y/N) No; we will begin process in FY 2023

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

STATEMENT OF 

IDENTIFIED BARRIER(S): 

(Description of Policy, 

Procedure, or Practice)

Barriers not yet identified; 

9/30/2025.

pending completion of barrier analysis on or about 

EEO PLAN TO ELIMINATE IDENTIFIED BARRIER(S)

OBJECTIVE(S):

Objective Date 

Initiated

Target 

Date

Sufficient 

Funding/

Staffing

Modified 

Date

Date 

Completed

Track and monitor the 

participation rate of Women and 

minorities at higher grades

6/30/2022 9/30/2024 Yes

Complete barrier analysis. 10/30/2022 9/30/2025 Yes

Establish process for routine 

barrier analyses 11/30/2022 9/30/2023 Yes

RESPONSIBLE 

OFFICIAL(S): Title Name

Performance 

Standards Address 

Plan? (Y/N)

AA, ODEO Stephen T. Shih Yes

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities Modified 

Date

Date 

Completed

12/31/2022 1. Review relevant data sources such as EEO complaints, grievances, 

surveys, exit interviews, and reports for any indicators of barriers 

to advancement for women and minorities. 

02/28/2023 2. Examine participation triggers by location (NASA 

occupation, and other factors). 

Center, 

03/31/2023 3. Develop a formal barrier analysis plan for barrier analysis of the 

participation rates of Women and minorities at higher grades.

06/30/2023 4. Conduct initial analyses as identified in the barrier analysis plan. 

9/30/2023 5. Develop data dashboards to 

future barrier analyses. 

aid in the analysis of data for this and 

9/30/2023 6. Institute a routine barrier analysis program designed to address 

potential barriers more quickly and complete multiple barrier 

analyses each year.

9/30/2025 7. Complete barrier analysis of participation rates at higher grades.

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2022 Progress: NASA identified this trigger and began reporting progress regularly to the NASA Mission 

Support Performance Management Council and in progress updates to the NASA Strategic Plan and NASA 

DEIA Strategic Plan.

Modifications to Objective: This is a new objective for FY 2023. 
36

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 plans 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. 

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

There are no triggers. In FY 2022, IWD accounted for 25 percent of employees GS-1 to GS-10 and 

13 percent of employees GS-11 to SES. 

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

There are no triggers. In FY 2022, IWTD accounted for seven percent of employees GS-1 to GS-10 

and 3 percent of employees GS-11 to SES.

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

recruiters.

NASA continues to communicate disability numerical goals in various forums, including briefings 

for managers and supervisors, individual meetings with hiring and recruitment managers, and allhands meetings for supervisors. Data on employees with disabilities is regularly communicated to 

Center Disability Program Managers (DPMs) and their supervisors. Further, in September 2022, 

NASA sent a memo to the NASA workforce explaining the purpose of and encouraging voluntary 

self-identification of employee disability status. As a result, the Agency had an increase of 64 selfidentified employees with disabilities (60 non-targeted and four targeted), in the two weeks after 

the memo was sent.
37

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 program and special emphasis program, and oversee any other disability hiring and 

advancement program the agency has in place. 

A. Plan to Provide Sufficient and 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 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

1 10 NASA has a designated Selective Placement Coordinator 

Team in OCHCO that is responsible for responding to 

questions related to the Agency’s hiring practices related 

to disability. NASA Staffing Services receives and responds 

to questions from the public about hiring authorities, 

which includes disability. ODEO and the Office of the 

Chief Information Officer (OCIO) developed a public-facing 

webpage containing resources for NASA applicants 

regarding numerous disability resources, including 

technology accessibility.

Processing RA requests 

from applicants and 

employees

10 All ten NASA Centers have 

responsible for processing 

(RA) requests. 

a designated DPM who is 

reasonable accommodation 

Section 508 

Compliance 11 The NASA HQ Section 508 Compliance Officer manages 

the Agency’s Section 508 policy and practices. Each NASA 

Center has a designated Section 508 Compliance Officer 

who is responsible for ensuring compliance at the 

operational level. NASA DPMs work closely with the 

Section 508 compliance end-user interest group on issues 

that arise, and the Agency DPM regularly communicates 

with OCIO on issues requiring technological solutions. 

Architectural Barriers 

Act (ABA) Compliance 11 NASA has a designated Program Manager in the Facilities 

Engineering Division who manages the Agency’s strategic 

plan to ensure compliance in this arena. Additionally, all 
38

Disability Program Task

# of FTE Staff by 

Employment Status Responsible Official

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

ten NASA Centers have designated facilities engineers who 

are responsible for ensuring compliance at the operational 

level. 

Special Emphasis 

Program (SEP) for 

IWD/IWTD

10 NASA has DPMs at each 

managing SEP activities.

focused ERGs.

of the ten Centers responsible for 

 NASA also has seven disability3. 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 2022, the Agency-level Disability Employment Program (DEP) sponsored two 3.5-hour 

trainings for all NASA employees, including supervisors and managers and Center DPMs: 

Reasonable Accommodation for Supervisors and Managers and Reasonable Accommodation for 

Employees. The DEP also sponsored trainings on making a document Section 508 compliant (PDF 

and Microsoft Suite documents), and Deaf Etiquette and an American Sign Language lesson. 

Center-level DPMs received technical assistance and training from the Agency’s DPM during 

quarterly meetings and on an ad hoc basis on a variety of topics, particularly concerning the 

processing of religious and medical, required by Presidential Executive Order (E.O.) 14043, issued 

on September 9, 2021, as well as in cases following the abeyance of the Covid vaccination mandate 

regarding testing, masking, and remote work. 

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 IWD. 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. 
39

NASA’s external efforts to identify job applicants with disabilities and targeted disabilities include: 

participating in targeted job fairs and outreach events, and engaging in social networking platforms 

that support employment of IWDs; building and strengthening partnerships with local and Federal 

disability organizations, state and local rehabilitation and employment agencies, local colleges and 

universities, and programs (such as Centers for Independent Living, Department of Labor’s 

Workforce Recruitment Program, and Employment Network Service providers) to recruit and hire 

individuals with disabilities IWD and IWTD; and leveraging disability ERGs and SEPs to encourage 

participation in job opportunities within the IWD population, as well as to conduct outreach and 

mentoring opportunities for students with disabilities to increase the STEM pipeline to ensure 

future employees with disabilities/targeted disabilities. 

NASA uses its internship programs as the primary method for hiring early career employees. In FY 

2022, ODEO and the Office of STEM Engagement (OSTEM) coordinated to support interns with 

disabilities. The DEP developed a NASA Disability Resources packet of information for OSTEM and 

Pathways interns containing information for NASA interns with disabilities, including disabilityrelated materials and links, guidance for applicants with disabilities in the Federal hiring process, 

disability technology accessibility resources, and information on requesting an RA.

ODEO communicates as necessary with the OCHCO to ensure continuity of RAs for job applicants 

with disabilities and targeted disabilities. 

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. 

The NASA selective placement coordinator team works with managers and promotes recruitment 

utilizing special hiring authorities (i.e., Schedule A and disabled veterans’ programs). A critical 

piece of NASA’s recruitment strategy focuses on increasing workforce diversity, specifically 

targeting our veteran communities, by reaching new talent communities and establishing NASA as 

an employer that celebrates diversity and inclusion as key to its success. In addition, OCHCO has 

established communities of practice and tiger teams, and coordinated with ERGs across the Agency

(including disability ERGs) to streamline recruitment efforts and establish consistent employer 

value proposition messaging and outreach strategies with diversity groups. 

Specific initiatives included:

• Making NASA more accessible in our recruitment and social media messaging, especially to 

applicants with disabilities. 

• Targeting outreach using hiring campaigns on LinkedIn to reach passive quality talent.

• Developing campaigns and talent networks for diverse candidates to receive ongoing 

newsletters and communications about careers at NASA. 

• Hosting “question and answer” (Q&A) sessions on LinkedIn to interact with candidates 

about a career at NASA. 

• Using graphic posts or hiring manager videos to promote specific vacancies on LinkedIn or 

other agency social media channels. NASA provides guidance to employees, including 
40

disability ERGs, on how to share this content with their own networks to reach a broader 

candidate pool. 

• Leveraging relationships with organizations with diverse membership bases, as well as 

educational institutions. 

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, HR specialists provide information about the hiring authority and ask individuals if 

they are eligible. This enables HR 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 Centers provide regular training sessions for hiring officials, particularly for new managers 

and supervisors. ODEO participates quarterly in OCHCO’s “HR101” training for new supervisors 

and managers, which includes training on the full spectrum of hiring flexibilities, DEIA, Reasonable 

Accommodations for Employees with Disabilities, Anti-harassment, and EEO Complaints 

Management. Hiring managers are regularly reminded of the Schedule A hiring authority via 

consultation with their ODEO representatives and at various leadership meetings and recruitment 

discussions. Centers also conduct training for hiring officials on disability hiring authorities. 

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 2022, NASA DPMs worked with a variety of partner organizations to recruit IWD. Several 

NASA Centers are located near military installations and thus have many opportunities to engage 

the local veteran community. NASA participates in employment fairs and outreach activities for 

veterans and disabled veterans, and works with programs supporting employment of IWD and 

IWTD, including the Blinded Veterans Association National Conference, various state and local

vocational rehabilitation offices, and the Veterans Administration. NASA partners with Federal, 

state, and local employment organizations, local colleges, and disability-related organizations to 

recruit and hire IWD and IWTD; these partners include groups such as American Job Centers, the 

Veterans’ Vocational Rehabilitation and Employment Program, Centers for Independent Living, 

DOL, and Employment Network Service providers. NASA engages with a number of other 

professional organizations for IWD/IWTD via social media as well. 
41

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 X No 

b. New Hires for Permanent Workforce (IWTD) Yes X No 

In FY 2022, 10.0 percent of all new hires were IWDs and 1.6 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 No N/A X

b. New Hires for MCO (IWTD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to work to develop new 

reports and will evaluate the data when available. 

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 N/A X

b. Qualified Applicants for MCO (IWTD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to work to develop new 

reports and will evaluate the data when available.

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 No N/A X

b. Promotions for MCO (IWTD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to work to develop new 

reports and will evaluate the data when available.

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 and IWTD have sufficient opportunities for advancement.
42

NASA Centers regularly assess the demographics of employees applying for and receiving promotions

as well as assessing the diversity of selection panels and hiring officials, to ensure that IWD and other 

traditionally underrepresented groups are included. Further, the Agency conducts listening sessions 

with individuals who are members of underserved communities to understand their experience 

navigating the promotions process, as well as provides Executive Champions for under-represented 

employee groups. 

NASA is working on new systems and processes to collect the data necessary to evaluate promotion 

rates and practices, including training and development history, employee tenure, and education level. 

B. Career Development Opportunities 

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

NASA’s policy on employee and organizational development is to support the full utilization of the 

workforce in achieving the Agency’s strategic outcomes and managing its human capital. To do so, 

NASA makes training and developmental opportunities widely available to employees to enhance 

individual and organizational capabilities and competencies in accordance with Merit System 

Principles. NASA’s learning and development strategy adheres to the 70/20/10 model. Employee 

development takes place on applied hands-on projects (70 percent); mentoring, coaching, and 

feedback (20 percent); and formal training (ten percent). 

NASA is beginning to pilot professional development for targeted communities. Further, the NASA 

Emerging Leaders Program has a specific module dedicated to DEIA. This nine-month program will 

integrate DEIA into the fabric of the course rather than in a specific module. The program will include 

a self-assessment that measures individual cultural diversity, which will set the stage for selfawareness and action for change.

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 Programs 52,316 1,901 4.2% 4.6% -- --

Detail Programs 3,346 326 10.9% 5.8% 2.9% 2.1%

Fellowship Programs

Data not available or programs not conducted in FY 2022. Mentoring Programs

Coaching Programs

Training Programs

Sources: Internship Programs - NASA Office of STEM Engagement (the number of interns with disabilities is the number of 

persons who requested a reasonable accommodation; OSTEM does not require interns to disclose the nature of their 

disabilities, thus data on IWTD are not collected). Detail Programs – OCHCO, Talent Marketplace data.

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 X No N/A 
43

b. Selections (IWD) Yes X No N/A 

There are no triggers for the internship program. For details, the IWD account for 13.7 percent of 

the relevant applicant pool but are only 10.9 percent of applicants. Further, IWD are only 5.8

percent of selectees.

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 X

b. Selections (IWTD) Yes No X

There are no triggers.

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 X No 

In FY 2022, the inclusion rates were 11.6 percent for IWD and 2.6 percent for IWTD (at all grade 

levels). There were no triggers for time-off awards. However, there were triggers for IWD for cash 

awards of $4,000 or more: IWD accounted for 9.0 percent of those receiving awards between 

$4,000 to $4,999 and 8.6 percent of those receiving awards of $5,000 and above. IWTD accounted 

1.5 percent and 1.7 percent, respectively, of individuals in those award categories. NASA will 

continue to monitor the IWD and IWTD inclusion rates for awards. (See Table J1 below.)

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 No X

c. Pay Increases (IWTD) Yes X No 

IWTD accounted for 1.4 percent of those receiving quality step increases. (See Table J1.)

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 No X N/A 

b. Other Types of Recognition (IWTD) Yes No X N/A 

There were no significant triggers regarding other types of performance awards. (See Table J1.)
44

Table J1. Employee Awards and Recognition

IWD IWTD

Inclusion Rates (all Grades) 11.6% 2.6% 

Type of Award:

Time Off 

Awards

1-10 hours 14.5% 3.2%

11-20 hours 12.3% 2.5%

21-30 hours 10.7% 1.8%

31-40 hours 13.4% 2.5%

41 or more hours 14.2% 1.8%

Cash 

Awards

$500 and Under 14.4% 2.5%

$501 - 999 15.7% 2.8%

$1000 - $1999 14.2% 2.7%

$2000 - $2999 11.1% 2.0%

$3000 - $3999 10.4% 1.8%

$4000 - $4999 9.0% 1.5%

$5000 or More 8.6% 1.7%

Other 

Awards

Performance Award 10.4% 2.0%

Quality Step Increase 10.9% 1.4%

Source: NASA MD-715 Table B-9, prepared by Department of the Interior 

(DOI); data as of 9/30/2022. Data include permanent employees only.

Triggers highlighted in yellow.

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 No X 

b. Grade GS-15 

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes No X 

c. Grade GS-14 

i. Qualified Internal Applicants (IWD) Yes No X

ii. Internal Selections (IWD) Yes No X

d. Grade GS-13 

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes No X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to develop new reports 

and will evaluate the data when available.

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 
45

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 N/A X 

ii. Internal Selections (IWTD) Yes No N/A X 

b. Grade GS-15 

i. Qualified Internal Applicants (IWTD) Yes No N/A X 

ii. Internal Selections (IWTD) Yes No N/A X 

c. Grade GS-14 

i. Qualified Internal Applicants (IWTD) Yes No N/A X 

ii. Internal Selections (IWTD) Yes No N/A X 

d. Grade GS-13 

i. Qualified Internal Applicants (IWTD) Yes No N/A X 

ii. Internal Selections (IWTD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to develop new reports and 

will evaluate the data when available.

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 No N/A X

b. New Hires to GS-15 (IWD) Yes No N/A X

c. New Hires to GS-14 (IWD) Yes No N/A X 

d. New Hires to GS-13 (IWD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to develop new reports 

and will evaluate the data when available.

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 No N/A X

b. New Hires to GS-15 (IWTD) Yes No N/A X

c. New Hires to GS-14 (IWTD) Yes No N/A X 

d. New Hires to GS-13 (IWTD) Yes No N/A X 

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to develop new reports and 

will evaluate the data when available.

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 
46

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 N/A X 

ii. Internal Selections (IWD) Yes No N/A X 

b. Managers 

i. Qualified Internal Applicants (IWD) Yes No N/A X

ii. Internal Selections (IWD) Yes No N/A X

c. Supervisors 

i. Qualified Internal Applicants (IWD) Yes No N/A X

ii. Internal Selections (IWD) Yes No N/A X 

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to develop new reports and 

will evaluate the data when available.

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. 

a. Executives

i. Qualified Internal Applicants (IWTD) Yes No N/A X

ii. Internal Selections (IWTD) Yes No N/A X

b. Managers

i. Qualified Internal Applicants (IWTD) Yes No N/A X

ii. Internal Selections (IWTD) Yes No N/A X

c. Supervisors 

i. Qualified Internal Applicants (IWTD) Yes No N/A X

ii. Internal Selections (IWTD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

data reports are not yet available from the system. NASA continues to develop new reports and 

will evaluate the data when available.

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 No N/A X

b. New Hires for Managers (IWD) Yes No N/A X

c. New Hires for Supervisors (IWD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow data 

reports are not yet available from the system. NASA continues to develop new reports and will 

evaluate the data when available.

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). 
47

a. New Hires for Executives (IWTD) Yes No N/A X 

b. New Hires for Managers (IWTD) Yes No N/A X

c. New Hires for Supervisors (IWTD) Yes No N/A X

Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow data 

reports are not yet available from the system. NASA continues to develop new reports and will 

evaluate the data when available.

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 X N/A

Of the 70 Schedule A hires with disabilities eligible for conversion (FY 2020 permanent Schedule A 

hires with satisfactory service), 20 were not converted. Of those not converted, two were 

transferred to other Centers and one was reassigned to a different organization. 

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 No X

b. Involuntary Separations (IWD) Yes No X

IWD accounted for 33.3 percent of involuntary separations (5 of 15), which is higher than the 

inclusion rate for IWD of 11.6 percent; however, the small number of involuntary separations 

renders trigger analysis less meaningful. NASA will continue to monitor the IWD inclusion rate for 

separations. (See Table J2.)

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

Separations represent a small percentage of the total NASA workforce; thus, trigger identification is 

not meaningful. (See Table J2.)
48

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. 

Separations represent a small percentage of the total NASA workforce; thus, trigger identification is 

not meaningful. (See Table J2.)

Table J2. Separations by Disability Status

Separation Type Total IWD IWTD

Inclusion Rate % 100.0% 11.6% 2.6%

Removal # 15 5 1 

(Involuntary) % 100.0% 33.3% 6.7%

Resignation # 304 30 7 

(Voluntary) % 100.0% 9.9% 2.3%

Total Separations

# 1,212 170 34

% 100.0% 14.0% 2.8%

Source: NASA MD-715 Table B-1 (losses), prepared by Department of the Interior (DOI); data as of 

9/30/2022. Data include permanent employees only. Triggers highlighted in yellow.

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 Web site for its notice explaining 

employees’ and applicants’ rights under Section 508 of the Rehabilitation Act, including a 

description of how to file a complaint. 

Website: https://www.nasa.gov/accessibility/section508/sec508_overview.html

2. Please provide the internet address on the agency’s public Web site for its notice explaining 

employees’ and applicants’ rights under the ABA, including a description of how to file a complaint.

Website: https://www.nasa.gov/sites/default/files/atoms/files/aba_statement_final_tagged.pdf

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 multi-year implementation plan that identifies the facility 

accessibility needs of each NASA Center. Agency leadership routinely reviews this plan and assesses 

status. The facilities team creates an annual Architectural Barriers Act report on all Center facility 

accessibility deficits and progress. The Agency-level DPM has held several information sessions with 

the Facilities Engineering Division to discuss Architectural Barriers Act (ABA) requirements and related 

legal authorities. The NASA Section 508 Program Manager continues to host monthly meetings for 

Center 508 Coordinators to stay abreast of current updates and events related to accessibility. In FY 
49

2022, the DEP hosted OCIO’s 508 Coordinators for a training for the workforce on how to ensure 

documents are 508 Compliant.

NASA OCIO maintains a webpage of all accessibility technology options across NASA. This page is 

available to employees and managers, as well as to applicants and the public. The NASA 508 Program 

Managers Coordination group developed a 508-accessibility scanning tool to standardize the process 

to scan NASA websites to identify and correct compliance issues. Currently, OCIO is developing a 

Self-Service Project to assist end-users with their accessibility technology needs. In FY22, ODEO’s DEP 

participated on a hiring panel for a new position for the lead in OCIO’s Accessibility Customer 

Engagement Program, as a part of a proactive effort by OCIO to enhance 508 Compliance across the 

Agency. As part of NASA’s DEIA Plan for FY 2023, ODEO coordinated with OCIO on a memo to the 

workforce, sent on October 18, 2022, that communicated Agency roles and responsibilities for 508 

Compliance, as well as expectations of NASA employees.

At the Center-level, DPMs manage all RA requests, including technology accessibility issues, acting as 

liaisons between employees requiring accessibility technology and OCIO. 

C. Reasonable Accommodation Program

Pursuant to 29 CFR. § 1614.203(d)(3), agencies must adopt, post on their public Web site, 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.)

In FY 2022, NASA RA processing average was 25 days. (See Table J3 for average processing time by 

NASA Center.) 

Table J3. Average Processing Times for RA Requests

Center Average No. 

of Days

Ames Research Center 14

Armstrong Flight Research Center 20.5

Glenn Research Center 44

Goddard Space Flight Center 35

Headquarters 19

Johnson Space Center 18

Kennedy Space Center 25

Langley Research Center 10

Marshall Space Flight Center 11

NASA Shared Services Center 20.9

Stennis Space Center 11

Source: NASA RAMS, data for FY 2022. 

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 
50

requests, timely providing approved accommodations, conducting training for managers and 

supervisors, and monitoring accommodation requests for trends.

NASA routinely provides RA awareness briefings to new employees, new supervisors, and interns. In 

FY 2022, NASA Centers trained more than 800 employees on their roles and responsibilities 

regarding RA, including at least 242 managers and supervisors and, additionally, at least 86 new 

managers and supervisors. Further, ODEO DEP presents a session on Reasonable Accommodation at 

OCHCO’s quarterly HR101 trainings for new managers and supervisors across the Agency. In 

addition, all ten NASA Centers have designated DPMs to process RA requests and to provide 

technical assistance to employees, interns, managers, and supervisors. Also, NASA is in the process 

of adopting a new Reasonable Accommodation Management System (RAMS), by which the Agency 

expects to increase timeliness and efficiency in processing requests. The RAMS tool will allow 

Agency leadership to better monitor timeliness trends in RA processing. 

In FY 2022, ODEO created a Disability and Accessibility presentation and information package for 

OSTEM and Pathways interns, which contained information and resources on RA. This packet of 

information will be given to all interns in every new cohort.

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 has an Agency-wide BPA for personal assistance services (PAS), for greater efficiency and 

consistency in providing PAS across the Agency. Each Center has a PAS technical monitor to ensure 

timely PAS processing and services. The Agency-level DPM monitors requests for trends and acts as 

the Contracting Officer’s Representative to the PAS BPA to monitor contractor timeliness and 

quality. NASA includes policy and procedures on PAS in its extensive NPR 3713.1C, Reasonable 

Accommodations Procedures for Individuals with Disabilities. 

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 of 19.7 percent? 

Yes No X 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 
51

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

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 of 13.5 percent? 

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.

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

The preceding analyses revealed the following triggers:

• Performance Awards: There were triggers for cash awards of $4,000 or 

more (see Part J, section IV, C).

Triggers • Separations: Although the number of separations is small, there may be 

triggers for separations of IWD (see Part J, section V, A).

• Schedule A Conversions: Not all FY 2020 Schedule A hires were converted 

to permanent positions with two years (see Part J, section V, A).
52

Due to the implementation of a new staffing solution, applicant flow data were 

not available for FY 2022. NASA will continue to monitor triggers and initiate 

appropriate action and activities if trends develop. 

Source of Trigger Workforce data tables. 

Groups Affected Individuals with Disabilities and Individuals with Targeted Disabilities. 

Sources 

Reviewed Workforce data tables, complaints data, and FEVS data. 

Status of Barrier 

Analysis Process Barrier analysis not yet completed. 

Objective(s) for 

the EEO Plan

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; and (2) develop improved systems for collecting 

demographic data pertaining to career development programs. 

Plan to Address Barriers/Triggers Identified

Responsible Official(s) Performance Standards Address 

Plan? (Yes or No)

the 

Director, Diversity and Data/Analytics Division, ODEO No; DEIA generally addressed. 

Target Date Planned Activities

Sufficient 

Staffing & 

Funding

Modified 

Date

Completion 

Date

9/30/2021 Investigate reasons for differences between 

the IWD inclusion rates and hiring/promotion 

rates of IWD and IWTD in mission critical 

occupations.

Yes 9/30/2023

5/30/2022 Create presentation, video, and packet of 

information on disability and accessibility for 

OSTEM and Pathways interns with disabilities

Yes 5/30/2022

9/30/2022 Develop on-going training regarding the NASA 

Disability Employment Program and reasonable 

accommodations

9/30/2022

9/30/2022 Award Agency-wide Sign Language 

Interpretation Blanket Purchasing Agreement

Yes 9/9/2022

10/31/2022 Issue memo on 508 Compliance 

workforce

to the Yes 10/18/2022

1/31/2023 Implement new Reasonable Accommodations 

Management System

Yes

9/30/2023 Collaborate with OCIO’s Accessibility Customer 

Service Program to enhance accessibility 

technology customer support for end users.

Yes

Fiscal Year Accomplishments

FY 2022 In October 2021, the DEP held 2 Agency-wide Reasonable Accommodation trainings – 

one for managers/supervisors and one for employees, trainings on how to ensure 508 
53

Compliance in your documents – both Word Suite and PDFs, and a lunch-and-learn on 

Deaf Etiquette – with a lesson in American Sign Language. In addition, NASA 

developed a section on RA requirements for OCHCO’s quarterly HR101 training and 

conducted Center RA trainings throughout the year. 

On September 9, 2022, NASA awarded the first-ever Agency-wide SLI BPA. The SLI BPA 

will enable consistency in the services NASA provides its deaf/hard-of-hearing 

employees, interns, applicants, and guests – no matter the individual’s geographical 

location within the Agency.

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

planned activities.

Due to the allocation of resources focusing on developing the NASA DEIA Strategic Plan in adherence 

to Executive Order requirements, NASA was unable to complete the analysis of hiring and promotion 

rates of IWD and IWTD in mission critical occupations. However, as part of the key priority goals in 

the DEIA Strategic Plan, NASA has begun work on obtaining data (including applicant flow data) and 

developing automated applications to enhance barrier analysis. 

A large portion of FY 2022 also was spent working toward compliance with the Executive Order 

mandating that all Federal employees were vaccinated against COVID. Immeasurable labor hours and 

resources were expended in creating new policies and procedures and new standard forms; 

communicating with an anxious workforce and creating FAQs; processing medical and religious RA 

request for approximately 1200 employees; and participating in multiple weekly meetings with the 

Administrator’s Office, OGC, OCHCO, the Office of the Chief Health and Medical Officer, and union 

representatives. Considering such an extremely challenging year for Center RA Managers in dealing 

with the inundation of religious and medical Covid vaccination RAs, as well as the peripheral influx of 

testing, masking, and remote work RA requests after the court’s order for abeyance, the expediency 

of Center RA Managers in achieving an average RA processing time that is still under the policy 

demand of 30 days is to be commended.

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

activities toward eliminating the barrier(s).

NASA’s Agency-level award of an SLI BPA is a tremendous step toward ensuring equity in services for 

NASA’s deaf/hard-of-hearing workforce, no matter where an employee is located geographically. The 

creation of a Disability and Accessibility presentation and packet of information for OSTEM and 

Pathways interns will enhance NASA’s support for individuals with disabilities in the STEM pipeline. 

This is especially significant for NASA, as it is through our intern programs that many early career 

hires are made.

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
54

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

External Benchmarks

The U.S. Equal Employment Opportunity Commission (EEOC) requires agencies to compare the 

demographic profile of its employees to external benchmarks, such as the Civilian Labor Force (CLF)

and “alternative” benchmarks that may be more suitable comparators.

4 Thus, NASA also benchmarks 

its workforce against the Federal STEM workforce. 

Table 1. FY 2022 NASA Workforce and Comparison Populations

NASA Workforce AAPI Black Hispanic AIAN White MultiRacial 

Undeclared Male Female

All NASA Employees 8.9% 10.8% 8.8% 0.9% 69.1% 0.4% 1.1% 64.4% 35.6%

Alternate Benchmarks (Comparison Populations)

Civilian Labor Force 4.6% 12.3% 13.0% 0.6% 67.5% 2.1% -- 51.8% 48.2% 

Federal STEM Workforce 9.9% 10.4% 6.6% 0.8% 69.8% 2.1% 0.4% 69.3% 30.7%

Sources: NASA Personnel Data Warehouse (PDW) (data as of 09/30/2022); Office of Personnel Management 

(OPM), FedScope, Federal Human Resources Data, Diversity Cube and Employment Cube (U.S.-based employees 

only) (data as of 6/30/2022, the most recent data available), accessed at <https://www.fedscope.opm.gov>; U.S. 

Census Bureau, EEO Tabulation 2014-18 (American Community Survey data set EEO-CIT02R), accessed at 

<https://www.census.gov/topics/ employment/equal-employment-opportunity-tabulation.html>. 

Table 1 shows that the composition of the NASA workforce by race, ethnicity, and gender is similar to 

the CLF, with three exceptions: (1) NASA employs a higher percentage of AAPI (8.9 percent) than their 

representation in the RCLF (4.6 percent); (2) NASA has a lower percentage of Hispanics (8.8 percent) 

than the RCLF (13.0 percent); (3) the representation of women in the NASA workforce (35.6 percent) 

is lower than their representation in the CLF (48.2 percent). 

Because the NASA workforce is highly specialized (two-thirds of NASA employees are in science and 

engineering (S&E) occupations) and the CLF includes all occupations in the country, a comparison to 

the CLF may not provide a full picture of how well NASA is doing with regard to diversity.

5 Using the 

Federal STEM workforce provides a different viewpoint. In fact, comparing NASA to the Federal STEM 

workforce reveals few differences. NASA’s workforce is similar to the Federal STEM workforce with 

4 According to EEOC guidance, the total agency workforce should be compared to the CLF, which includes all non-institutionalized 

civilians aged 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>. Subgroups of the agency workforce (e.g., 

those in senior grades) should be compared to overall agency workforce. EEOC also notes that “Agencies can use alternative 

benchmarks that are more appropriate for their workforce.” EEOC, Instructions to Federal Agencies for EEO MD-715, Section II, 

“Barrier Identification and Elimination,” and Section IV, “Interpretation and Completion of Workforce Data Tables,” accessed at: 

<https://www.eeoc.gov/federal-sector/management-directive/ instructions-federal-agencies-eeo-md-715-0>. 5 A disparity between an agency’s workforce and the CLF does suggest the need for action; however, in many cases that action 

is a long-term, societal-level change of increasing opportunities for individuals to enter occupations specific to the agency. 
55

the exception of the employment of Hispanics and women, who are employed at a higher percentage 

at NASA: Hispanics account for 8.8 percent of the NASA workforce compared to 6.4 percent in the 

Federal STEM workforce; women are 35.6 percent of the NASA workforce and 30.2 percent of the 

Federal STEM workforce.

Nonetheless, data for the Federal STEM workforce only includes STEM positions (some of which are 

not present in the NASA workforce) and does not include positions such as management analysts and 

contract specialists. Thus, in FY 2022, NASA developed an alternative benchmark to better understand 

how the demographic composition of the NASA workforce compares to an Organizational CLF (OCLF), 

which is comprised of only those occupations present in the NASA workforce.6 The OCLF is a weighted 

average of the RCLF for each occupation present in the Agency; it indicates what NASA would look like 

demographically if it were hiring individuals in the same proportion as they are in the qualified applicant 

pool for the occupations in the NASA workforce (i.e., the RCLF). This metric is designed to bridge the 

gap between the non-specific CLF metric and the occupation-specific RCLF metrics (the RCLF is 

discussed below). 

Internal Benchmark 

Per EEOC guidance, agencies also should compare subgroups of their workforce to the total workforce 

when doing trigger analysis.7 Table 2 reveals the following triggers8 (highlighted in yellow) for some 

traditionally underrepresented groups at NASA, when compared to their total representation:

• Asian Americans and Pacific Islanders (AAPI) are underrepresented in SES and SL positions (4.8 

percent and 4.1 percent, respectively) compared to their overall participation in the NASA 

workforce (8.9 percent). AAPI employees also are underrepresented in supervisory positions, 

in which they account for 5.6 percent.

• Blacks and African Americans are underrepresented in ST, SL, and student positions (1.3 

percent, 1.0 percent, and 7.7 percent), compared to their overall participation in the NASA 

workforce (10.8 percent). 

• Hispanics and Latinos are underrepresented in SES, ST, and SL positions (5.3 percent, 3.8 

percent, and 6.2 percent, respectively) compared to their overall participation in the NASA 

workforce (8.8 percent). Hispanics also are underrepresented in supervisory positions, in which 

they account for 6.8 percent.

6 Similar benchmarks have been developed by other Federal agencies, including the U.S. Department of the Navy and the U.S. 

Department of Homeland Security.

7 EEOC, Instructions to Federal Agencies for EEO MD-715, Section IV, “Interpretation and Completion of Workforce Data Tables,” 

accessed at: <https://www.eeoc.gov/federal-sector/management-directive/ instructions-federal-agencies-eeo-md-715-0>. 8 According to EEOC, a low participation rate for any group (in relation to a benchmark) is a “trigger” – 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” to determine if there are barriers 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. 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. For larger groups, NASA uses a standard of a two-percentage point difference from the benchmark when identifying 

triggers. 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) represent 0.9 percent of the NASA workforce. 

Their small number (160 AIAN individuals are employed by NASA), renders comparisons of 

smaller subgroups to their total employment less meaningful. 

• Women are underrepresented in ST, SL, and GS-14/GS-15 positions (21.5 percent, 19.6 percent, 

and 31.7 percent, respectively) compared to their overall representation in the NASA workforce

(35.6 percent). 

These triggers are the same triggers identified in FY 2021. 

Table 2. NASA Employees (Selected Groups) by Race, Ethnicity, and Gender: FY 2022

NASA Workforce Total 

Number AAPI Black Hispanic AIAN White MultiRacial 

Undeclared Male Female

All Employees: 18,199 8.9% 10.8% 8.8% 0.9% 69.1% 0.4% 1.1% 64.4% 35.6%

Permanent 16,319 8.4% 11.2% 8.5% 0.9% 70.0% 0.4% 0.5% 65.0% 35.0%

11.5

Temporary 1,321 % 7.7% 10.1% 0.5% 63.6% 0.4% 6.3% 58.9% 41.1%

15.9

Students 559 % 7.7% 14.3% 0.2% 55.3% 0.5% 6.1% 62.4% 37.6%

All Employees, by Grade: 

SES/Other Executives 433 4.8% 10.4% 5.3% 0.5% 78.1% 0.7% 0.2% 63.5% 36.5%

ST 79 12.7

% 1.3% 3.8% 0.0% 82.3% 0.0% 0.0% 78.5% 21.5%

SL 97 4.1% 1.0% 6.2% 2.1% 86.6% 0.0% 0.0% 80.4% 19.6%

GS-14 – GS-15 9,824 8.8% 9.4% 7.5% 0.8% 72.6% 0.3% 0.6% 68.3% 31.7%

GS-13 and below 7,638 9.2% 12.9% 10.9% 1.1% 63.7% 0.6% 1.8% 59.2% 40.8%

All Other Pay Rates 128 8.6% 5.5% 7.0% 0.0% 72.7% 0.0% 6.3% 63.3% 36.7%

Other Groups:

Supervisors 2,243 5.6% 13.3% 6.8% 0.5% 73.0% 0.5% 0.3% 63.0% 37.0%

Source: NASA Personnel Data Warehouse (PDW) (data as of 09/30/2022). Triggers are highlighted in yellow. “All Other Pay 

Rates” include: pay rates for Advisory Committee Members, Experts, and Consultants, and administratively determined 

rates. “Students” are interns hired through OPM’s Pathways program. 

The percentage of minorities and women decreases as grade levels increase. For example, in FY 2022, 

Hispanics and Latinos accounted for 10.9 percent of NASA employees at grades GS-13 and below, 7.5 

percent at grades GS-14 and GS-15, and 5.3 percent of the SES. Women account for 40.8 percent of 

those in grades GS-13 and below, 31.7 percent in grades GS-14 and GS-15, and 36.5 percent of those 

in the SES. Although the percentages of minorities and women at each age group has increased slightly 

since FY 2017, this trend has remained. (See Figures 1 and 2.) In FY 2023, NASA plans to begin a barrier 

analysis to determine the root cause of this trend.
57

Figure 1. NASA Workforce by Race/Ethnicity and Grade Category: FY 2022

14.0% 12.9%

12.0%

10.4%

9.4% 10.0% 10.9%

8.0% 9.2% 8.8%

7.5% 6.0%

5.3%

4.0% 4.8%

2.0% 1.1% 0.8% 0.5%

0.0%

GS-13 and Below Leadership Pipeline (GS 14-15) Leadership (SES)

Black AAPI Hispanic AIAN

Figure 2. NASA Workforce by Gender and Grade Category: FY 2022

80.0%

68.3%

63.5%

59.2%

60.0%

40.8%

36.5% 40.0% 31.7%

20.0%

0.0%

GS-13 and Below Leadership Pipeline (GS 14-15) Leadership (SES)

% Men % Women

Source for Figures 1 and 2: NASA PDW (data as of 9/30/2022).
58

Occupational Categories

Because the NASA workforce is highly specialized, it is useful to compare employees in specific 

occupations to the individuals in the civilian labor force in similar occupations (the RCLF). Employment 

ratios below the RCLF for any group is another trigger.9 Tables 3 and 4 reveal the following:

• In most NASA mission critical occupations, minorities and women are employed at higher 

percentages at NASA than in the RCLF. In fact, there are no triggers by race, ethnicity, or gender 

for Electrical Engineers, Electronics Engineers, Aerospace Engineers, Space Scientists, General 

Administrative positions, Management and Program Analysts, and Contract Specialists. 

However, the following triggers were observed:

o Asian American and Pacific Islanders are employed in lower percentages at NASA than in 

the RCLF in General Engineering, Computer Engineering, and Physical Science positions. 

 AAPI account for 7.1 percent of General Engineering positions at NASA and 12.1 

percent in the RCLF. 

 Similarly, AAPI are 14.2 percent of NASA Computer Engineers, though they account 

for 19.1 percent in the RCLF.

 AAPI account for 14.1 percent of Physical Scientists at NASA and 16.4 percent in the 

RCLF. (In FY 2022, NASA completed its barrier analysis of AAPI and Women in 

Physical Science positions; see Appendix B.)

o Hispanics are underrepresented in Finance, occupying 7.3 percent of such positions at NASA 

and 9.8 percent in the RCLF.

o There is only one American Indian or Alaska Native in a Physical Science position at NASA 

and only 2 AIAN individuals in Finance positions. 

o Women account for 32.6 percent of Physical Scientists at NASA and 43.4 percent of those 

in the RCLF. 

• Compared to the RCLF, AAPI, Blacks, Hispanics, and Women are overrepresented in several 

Professional Administrative (PA) occupations, including Information Technology Specialists and 

Accountants, and Whites and males are underrepresented. However, because Whites and males

account for the majority of employees in those occupations, these are not considered triggers

for the purpose of barrier analysis. 

9 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., such as in Table 1. 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 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/>.
59

Table 3. NASA Mission Critical S&E Occupations by Race, Ethnicity, and Gender: FY 2022 

AAPI Black Hispanic Multiracial AIAN White Undeclared Male Female

0801 - General 

Engineer (n=3,391)

NASA: 7.1% 6.4% 8.3% 1.0% 0.4% 76.1% 0.9% 70.6% 29.4%

RCLF: 12.1% 4.8% 6.9% 2.0% 0.2% 74.0% -- 87.1% 12.9%

0850 - Electrical 

Engineer (n=330)

NASA: 13.3% 7.6% 13.3% 0.9% 0.3% 64.2% 0.3% 83.9% 16.1%

RCLF: 12.1% 5.6% 7.3% 2.1% 0.2% 72.8% -- 91.1% 8.9%

0854 - Computer 

Engineer (n=718)

NASA: 14.2% 9.3% 9.5% 0.6% 0.4% 65.6% 0.4% 73.0% 27.0%

RCLF: 19.0% 8.4% 6.7% 1.7% 0.1% 64.2% -- 85.9% 14.1%

0855 - Electronics 

Engineer (n=786)

NASA: 16.7% 6.0% 9.8% 0.5% 0.1% 66.0% 0.9% 84.2% 15.8%

RCLF: 12.1% 5.6% 7.3% 2.1% 0.2% 72.8% -- 91.1% 8.9%

0861 - Aerospace 

Engineer (n=4,429)

NASA: 9.6% 5.9% 8.5% 0.6% 0.2% 74.3% 0.8% 77.4% 22.6%

RCLF: 11.2% 4.2% 7.8% 2.4% 0.3% 74.1% -- 87.4% 12.6%

1301 - Physical 

Scientist (n=460)

NASA: 14.1% 2.8% 5.9% 0.2% 0.0% 75.7% 1.3% 67.4% 32.6%

RCLF: 16.4% 3.8% 5.6% 2.3% 0.2% 71.8% -- 56.6% 43.4%

1330 - Space 

Scientist (n=335)

NASA: 7.8% 1.8% 6.6% 0.0% 0.0% 83.3% 0.6% 69.0% 31.3%

RCLF: 8.6% 3.6% 4.7% 1.8% 0.2% 81.0% -- 81.0% 19.0%

Table 4. NASA Mission Critical and Other Professional Administrative Occupations by Race, 

Ethnicity, and Gender: FY 2022 

AAPI Black Hispanic Multiracial AIAN White Undeclared Male Female

0301 - General 

Administrative 

(n=930) 

NASA: 4.9% 19.2% 7.4% 1.3% 1.0% 64.8% 1.3% 38.0% 62.0%

RCLF: 6.3% 12.5% 8.7% 0.6% 1.0% 70.9% -- 36.7% 63.3%

0343 -Management 

and Program Analyst 

(n=838) 

NASA: 7.5% 16.7% 11.9% 1.3% 0.4% 61.2% 1.0% 34.8% 65.2%

RCLF: 5.9% 6.8% 4.6% 0.5% 0.6% 81.6% -- 58.4% 41.6%

0501 - Finance NASA: 6.6% 21.6% 7.3% 0.7% 0.0% 63.8% 0.0% 29.6% 70.4%

(n=301) RCLF: 5.0% 12.3% 9.8% 0.5% 1.2% 71.1% -- 43.7% 56.3%

0510 - Accountant 

(n=289) 

NASA: 12.8% 31.1% 8.7% 1.0% 0.0% 46.0% 0.3% 30.4% 69.6%

RCLF: 8.6% 8.1% 6.1% 0.5% 0.6% 76.0% -- 39.9% 60.1%

1102 - Contract 

Specialist (n=740) 

NASA: 7.0% 25.3% 10.7% 0.8% 0.5% 54.1% 1.6% 40.7% 59.3%

RCLF: 3.3% 8.5% 7.1% 0.4% 0.8% 80.0% -- 46.2% 53.8%

2210 - Information NASA: 7.9% 16.0% 7.0% 1.3% 0.9% 65.1% 1.8% 63.1% 36.9%

Technology Specialist 

(n=556) RCLF: 6.8% 11.1% 7.6% 0.6% 0.8% 73.1% -- 70.4% 29.6%

Notes for Tables 3 and 4: The table does not include Individuals who did not identify their race/ethnicity; thus, not all groups 

total to 100 percent. Triggers highlighted in yellow. Sources: NASA PDW (data as of 9/30/2022); U.S. Census Bureau, EEO 

Tabulation 2014-18 (American Community Survey data set EEO-CIT02R), accessed at <https://www.census.gov/topics/

employment/equal-employment-opportunity-tabulation.html>.
60

Individuals with Disabilities 

NASA has made progress in achieving Federal goals for the employment of individuals with disabilities 

over the past five years. NASA exceeds the Federal goal for the employment of IWD and IWTD in grades 

GS-10 and below and in grades GS-11 and above. (See Figure 3.) NASA continues to monitor the 

workforce participation of IWD and WITD and encourages individuals to update their disability status 

on an annual basis. 

Figure 3. NASA Employees with Disabilities: FY 2018-22 

Individuals with Targeted Disabilities (% of NASA Workforce)

7.5% 8.0% 7.3%

7.0% 6.4% 6.5%

6.0% 5.0%

5.0%

4.0%

2.6% 2.6% 2.7%

3.0% 2.4% 2.4%

2.0%

1.0%

0.0%

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

GS-10 and Below GS-11 and Above Federal Goal (2%)

Individuals with Disabilities (% of NASA Workforce)

30.0%

24.9% 23.9% 24.3%

25.0% 22.5% 21.6%

20.0%

15.0% 13.1% 13.7%

11.9% 10.6%

10.0% 9.5%

5.0%

0.0%

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

GS-10 and Below GS-11 and Above Federal Goal (12%)

Source: NASA PDW; data as of the last pay period in FY 2022. NASA revised its calculations in September 2020 to better conform 

with EEOC guidance, which require agencies to report only on full-time permanent employees. Data on IWD and ITWD include 

individuals who 1) all full-time, permanent non-student employees who identified as having a disability on OPM Standard Form 

(SF) 256; and 2) full-time, permanent disabled veterans who are classified as “10-Point/Compensable/30 Percent,” but who have 

not claimed a disability on SF 256 (pursuant to 29 CFR Part 1614, §1614.203(d)(6)(ii) (82 Fed. Reg. 680)). 
61

Federal Employee Viewpoint Survey (FEVS) Results

NASA’s FEVS scores remain high and scores on several questions related to DEIA and compliance have 

increased over the last five years.

10 For example, between 2018 and 2022, the percentage of 

employees stating that they agree or strongly agree the question, “My supervisor/team leader is 

committed to a workforce representative of all segments of society” increased from 85.6 percent to 

94.1 percent, peaking at 94.7 percent in 2021 (see Figure 4). 

Figure 4. FEVS Questions Focused on DEIA and Compliance: FY 2018-22 

96.0% 94.7% 94.1% 94.0% 94.5% 94.5%

94.0% 92.3% 92.7%

92.0% 90.8%

90.0%

88.0% 86.3% 85.4% 85.7% 85.6%

86.0% 84.9%

83.8%

84.0% 82.4%

82.0%

80.0%

78.0%

76.0%

I can disclose a suspected My supervisor/team leader is My supervisor treats me with

violation of any law, rule or committed to a workforce respect.

regulation without fear of representative of all segments of

reprisal. society.

2018 2019 2020 2021 2022

Sources: OPM and NASA, FEVS Results (NASA began conducting the FEVS in-house in FY 2021). Percentages represent the 

percentage of responses that were positive. In FY 2022, there were 13,411 NASA respondents. 

In 2022, OPM added several new questions to the FEVS focused on DEIA. An analysis of responses to 

those questions by demographic groups found that on those several measures, many members of 

minority groups have less positive responses than the NASA overall scores. For example, the overall 

NASA response for the question, “My supervisor demonstrates a commitment to workforce diversity 

(e.g., recruitment, promotion opportunities, development)” was 84.6 percent positive. However, AIAN 

and Black employees responded much less favorably (74.3 percent positive and 75.8 percent positive, 

respectively). Further, individuals who responded that they use another term for gender (other than 

male or female), Transgender individuals, Gay and Lesbian Employees, and individuals who responded 

they use a different term than the responses provided for sexual orientation had even lower positive 

responses. A similar pattern in responses was observed for other questions related to DEIA. (See 

Tables 5 and 6.)

10 The FEVS is a climate survey conducted by OPM. 
62

Table 5. Selected FEVS Responses by Ethnicity, Race, and Disability Status: FY 2022

FEVS Question NASA 

Total 

Ethnicity Race

IWD

Hispanic AIAN Asian Black NHOPI Multiracial White

My organization’s management 

practices promote diversity (e.g., 

outreach, recruitment, promotion 

opportunities).

84.6% 82.1% 74.3% 83.4% 75.8% 82.5% 81.7% 87.7% 80.3%

My supervisor demonstrates a 

commitment to workforce diversity 

(e.g., recruitment, promotion 

opportunities, development).

87.1% 84.3% 84.4% 84.1% 80.6% 78.0% 83.8% 89.9% 83.8%

My supervisor provides opportunities 

fairly to all employees in my work unit 

(e.g., promotions, work assignments).

84.9% 84.0% 70.8% 84.5% 80.4% 78.0% 82.0% 87.5% 79.1%

In my work unit, people’s differences 

are respected. 89.2% 87.6% 79.5% 90.4% 85.5% 80.9% 87.3% 91.2% 83.7%

I can be myself and be successful 

within my organization. 85.7% 84.6% 77.9% 87.3% 81.3% 83.3% 82.5% 88.1% 78.1%

My organization has an effective 

process for meeting accessibility needs 

(e.g., reasonable accommodations)

87.6% 86.8% 83.8% 88.0% 86.8% 80.6% 84.4% 88.9% 82.4%

Table 6. Selected FEVS Responses by Gender, Gender Identity, and Sexual Orientation: FY 2022

FEVS Question

Gender Gender 

Identity Sexual Orientation

Male Female Another 

Term

Transgender Straight Bisexual Gay or 

Lesbian

Different 

Term

My organization’s management 

practices promote diversity (e.g., 

outreach, recruitment, promotion 

opportunities).

87.2% 83.3% 46.5% 50.0% 86.5% 77.4% 76.0% 66.2%

My supervisor demonstrates a 

commitment to workforce diversity 

(e.g., recruitment, promotion 

opportunities, development).

89.3% 86.2% 63.4% 62.9% 88.7% 81.1% 84.3% 72.1%

My supervisor provides 

opportunities fairly to all employees 

in my work unit (e.g., promotions, 

work assignments).

87.6% 83.6% 60.0% 69.7% 86.7% 86.6% 82.2% 70.5%

In my work unit, people’s differences 

are respected. 91.2% 88.7% 64.9% 65.7% 90.7% 85.0% 84.9% 75.2%

I can be myself and be successful 

within my organization. 87.9% 85.9% 51.3% 59.5% 87.7% 77.6% 77.8% 69.5%

My organization has an effective 

process for meeting accessibility 

needs (e.g., reasonable 

accommodations)

90.1% 85.9% 54.4% 59.4% 89.1% 79.5% 81.2% 66.7%

Source for Tables 5 and 6: NASA Office of the Chief Human Capital Officer, Federal Employee Viewpoint Survey, 2022. 

Responses that are more than 2 percentage points below the NASA Total response (in Table 5) are highlighted in yellow.
63

APPENDIX B: PHYSICAL SCIENCE BARRIER ANALYSIS PLAN AND INITIAL FINDINGS

Barrier Analysis Overview

Purpose: NASA identified workforce triggers11 for Women and Asian Americans and Pacific Islanders 

(AAPI)12 within Physical Science occupations, when compared to the RCLF.13 Thus, the Agency is 

undertaking the barrier analysis process to further explore potential underlying causes of these 

discrepancies in order to determine their root cause. The barrier analysis will focus on the Physical 

Science jobs with the highest numbers of employees, Physical Scientists (job series 1301), Physicists 

(job series 1310), and Space Scientists (job series 1330) (see Table 1). 

Process Overview: NASA will use a multiphase barrier analysis process to systematically assess 

representation in the Physical Science Occupational Series. Phase 1 examines general representation 

of demographic groups within the various Physical Science occupations. Phases 2 and 3 examine 

existing personnel data, such as data on losses and hires, to further explore the factors that may be 

contributing to discrepancies discovered in Phase 1. At Phase 4, NASA will deploy a systematic set of 

questions to gather more information about triggers uncovered in Phases 1-3. In Phases 5-6, the 

Agency will use qualitative and quantitative data collection techniques to obtain input from members 

of potentially affected demographic groups. Finally, at Phase 7, NASA will identify root causes of 

potential barriers and develop corrective actions. 

Table 1. NASA Physical Science Occupations: FY 2021

Physical Science Job Series Number of NASA Employees

1301 - Physical Scientist 465

1306 - Health Physicist 6 

1310 - Physicist 111

1311 - Physical Science Technician 4 

1313 - Geophysicist 14

1320 - Chemist 5 

1330 - Space Scientist 330

1340 - Meteorologist 22

1360 - Oceanographer 15

1386 - Photographic Technologist 4 

1399 - Physical Science Trainee 465

Source: NASA Personnel Data Warehouse; data as of 10/1/2020. NASA has identified job series 1301 and 1310 as mission critical 

occupations because of their importance to NASA missions and the large numbers of employees those series.

11 According to EEOC, a trigger is a situation that alerts an 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.

12 In initial analyses, NASA examined data for Asian Americans and Native Hawaiians and Other Pacific Islanders (NHOPI) 

separately. Because of the small number of NHOPI in the workforce, however, this did not significantly impact the findings. 

Thus, the Agency combined these groups in subsequent analyses. 13 EEOC identifies the appropriate benchmarks for comparison. Agency representation in specific occupations should be 

compared to the RCLF, which measures individuals in the civilian labor force in occupations equivalent to occupations in the 

Federal Government. RCLF data are compiled by the U.S. Census Bureau for the EEOC. U.S. Census Bureau, “Equal Employment 

Opportunity Tabulation: FAQs,” accessed at <https://www.census.gov/topics/employment/equal-employment-opportunityabulation/about/faq.html#par_textimage_514458183>.
64

Phase 1

Purpose of Phase and Data Examined: In Phase 1, NASA focused its attention on surface-level 

indicators of potential barriers to inclusion, comparing its workforce to the RCLF to determine which 

demographic groups have lower than expected participation rates in Physical Science positions. 

Data Findings: When compared to the RCLF, the following groups have lower participation rates in the 

following NASA occupations (see Table 2): 

• Physical Scientists: AAPI Women and White Women are underrepresented. 

• Space Scientists: AAPI Women and White Men are underrepresented. 

• Physicists: AAPI Men, Black Men, and White Men are underrepresented. 

Further, while their numbers are also low in the RCLF, the following groups are absent from the NASA 

workforce: there are no Multiracial individuals or AIAN Women in NASA Physical Scientist positions; 

there are no Black Women, Hispanic Women, Multiracial individuals, or AIAN employed as NASA Space 

Scientists; and there are no AIAN in NASA Physicist positions. While triggers were identified for other 

groups, NASA will focus subsequent phases of the barrier analysis on AAPI and Women. 

Table 2. NASA Physical Science Workforce Compared to the RCLF

Physical Scientist Space Scientist Physicist

NASA RCLF NASA RCLF NASA RCLF

 Men 8.7% 8.2% 8.1% 5.1% 3.6% 5.1%

AAPI Women 3.8% 6.7% 0.9% 1.9% 3.6% 1.9%

Total 12.5% 14.9% 9.0% 7.0% 7.2% 7.0%

 Men 1.5% 1.4% 7.2% 2.1% 0.9% 2.1%

Black Women 1.5% 2.2% 0.0% 0.1% 0.6% 0.1%

Total 3.0% 3.6% 7.2% 2.2% 1.5% 2.2%

Hispanic

 Men 3.2% 2.4% 2.7% 3.4% 3.3% 3.4%

 Women 2.6% 1.9% 0.0% 0.6% 2.7% 0.6%

Total 5.8% 4.3% 2.7% 4.0% 6.0% 4.0%

Multiracial

 Men 0.0% 0.3% 0.0% 0.4% 0.0% 0.4%

 Women 0.0% 0.2% 0.0% 0.2% 0.0% 0.2%

Total 0.0% 0.5% 0.0% 0.6% 0.0% 0.6%

AIAN 

 Men 0.2% 0.4% 0.0% 0.5% 0.0% 0.5%

 Women 0.0% 0.2% 0.0% 0.0% 0.0% 0.0%

Total 0.2% 0.6% 0.0% 0.5% 0.0% 0.5%

 Men 53.9% 48.1% 65.8% 72.6% 61.5% 72.6%

White Women 24.5% 27.8% 15.3% 12.9% 23.6% 12.9%

Total 78.4% 75.9% 81.1% 85.5% 85.1% 85.5%

All Men 67.6% 60.8% 83.8% 84.1% 69.4% 84.1%

All Women 32.4% 39.0% 16.2% 15.7% 30.6% 15.7%

Notes: The table does not include Individuals who did not identify their race/ethnicity or gender; thus, not all groups total

to 100 percent. Triggers highlighted in yellow; groups absent from the workforce are highlighted in red. For the purposes 

of this analysis, a one percentage point difference between the NASA workforce and the RCLF was considered a trigger. 
65

NASA also examined representation by grade within the physical sciences. AAPI, Hispanic, and Women 

employees are not participating equally in higher grades: AAPI employees are not participating in SES 

positions equal to their workforce percentage. Hispanic employees are not participating in GS-14 and 

GS-15 positions equal to their workforce percentage. Women are not participating in GS-15 positions 

equal to their workforce percentage.

Phase 2

Purpose of Phase: The goal of Phase 2 was to look at additional personnel data to begin identifying 

why participation discrepancies might exist. This phase focused on the initial groups of concern: 

Women and AAPI. 

Data Examined: 

1. Hires and Separations. NASA examined hire and loss rates to see if discrepancies between NASA 

workforce participation and the RCLF are due to the inability to hire Women and AAPI versus 

high loss rates among those groups. 

2. Time-in-Grade/Position and Promotions. NASA examined differences in participation rates in 

senior grades, time-in-grade, and time-in-position, as well as participation over the last one, 

three, and five years. 

3. Average Age. NASA examined average employee age, to ensure that the discrepancies were 

not accounted for by a high percentage of early-career employees. 

4. Education. NASA reviewed data on educational attainment to determine whether there is a 

qualification or perceived qualification issue that may be slowing a group’s advancement. 

5. FEVS Data. The Agency reviewed sub-indices of FEVS Employee Engagement Index, New 

Inclusion Quotient (New IQ), and Global Satisfaction Index. These sub-indices can reveal 

differences by race, ethnicity, gender, and occupation that may indicate potential barriers to 

inclusion. 

Data Findings: NASA identified the following triggers with regard to AAPI and Women:

• Asian Americans and Pacific Islanders in the Physical Sciences: 

1. NASA hires of AAPI employees have been above the Physical Science RCLF values, except 

for the 1301 series where they are just slightly below the RCLF. Losses have slightly 

exceeded the size of the workforce over the past five years (8.8 percent of losses and 8.5 

percent of the workforce in 2016). This trend is most notable in the 1301 series. At ARC, 

losses are slightly higher than AAPI representation in the workforce (8.3 percent of losses 

compared to 7.8 percent in the workforce). 

2. AAPI have more time-in-grade and time-in-position than other demographic groups. For 

example, excluding SES and GS-15 employees, AAPI employees have been in their positions 

an average of 3.7 years. This is higher than Black (1.9 years), Hispanic (2.9 years), and White 

(3.4 years) employees. 

3. With an average age of 53.8, AAPI employees in physical science occupations are the oldest 

demographic group (compared to 52.7 for White employees, 52 for Black employees, and 

48.1 for Hispanic employees). 
66

4. In terms of educational level, 93.9 percent of AAPI employees in physical sciences have a 

graduate degree (compared to 93.6 percent of White employees, 91.1 percent of Hispanic 

employees, and 86.2 percent of Black employees). 

• Women in the Physical Sciences: 

1. For hires in the largest three physical science occupations, Women accounted for a higher 

percentage of hires than the occupation’s corresponding RCLF value. For instance, Women 

make up 39.0 percent of the physical scientist workforce, but they accounted for 45.8 

percent of the physical scientist hires in the last five years. For losses, Women did not leave 

at a rate substantially higher than their percentage in the workforce. Women accounted 

for 24.0 percent of the physical science workforce at the beginning of 2016 and have only 

accounted for 25.1 percent of the losses since that time. Thus, the data reveal no triggers 

related to hires and losses. 

2. Women appear to get promoted earlier and at higher rates than Men. For example, 

excluding SES and GS-15 employees, Women have been in their positions an average of 2.7 

years while Men have been in their positions an average of 3.6 years. 

3. Women are, on average, about four years younger than Men (Average Age: Men, 54.2; 

Women, 48.4), which could indicate that Women are earlier in their careers. 

4. Fewer Women have earned graduate degrees (Men, 94.1 percent; Women, 91.2 percent) 

and PhDs (Men, 83 percent; Women, 78.5 percent) compared to Men in these positions. 

5. Women score lower than Men in multiple areas within the New IQ.

In addition to the findings mentioned above, Physical Scientists in general scored lower on the Global 

Satisfaction Index and the New IQ. There was insufficient data to further examine the Physical Scientist

scores by demographic groups (see Table 3). 

Table 3. FEVS Index Scores for Selected Subgroups: 2019

Index NASA

Workforce

Physical 

Scientists AAPI Female

Employee Engagement 83.0% 81.2% 88.6% 82.1% 

Global Satisfaction 81.5% 78.8% 81.3% 82.5% 

New Inclusion Quotient (New IQ) 79.3% 76.3% 80.3% 74.2%

Notes: Triggers highlighted in yellow. Index scores represent the percent of positive responses. 

Phase 3

Purpose of Phase and Data Examined: Phase 3 is an expansion on Phase 2, involving a further analysis 

of personnel data. To gain additional insight before generating a strategy for subsequent phases of the 

barrier analysis, NASA analyzed applicant flow data, loss data, retirement eligibility disparities, and 

training data. 

Data Findings: 

• Asian Americans and Pacific Islanders in the Physical Sciences: With regard to retirement 

eligibility, it was found that this may be a contributing factor with 32.9 percent of the AAPI 

workforce currently eligible for retirement. This group had the highest retirement rate with 
67

White employees having the second highest at 31.9 percent and all other demographic groups 

showing less than one-quarter of their physical science workforce retirement eligible. 

• Women in the Physical Sciences: An examination of training data yielded no insights on the 

low promotion rates among women in physical sciences. 

Phase 4

Purpose: Phase 4 is designed to identify what is known about the workforce, and where there is a need 

for additional data. Thus, there are two goals of this phase: (1) systematically summarize the findings 

of Phases 1-4, and (2) ask additional questions to organization leaders and human resources to help 

identify what questions need to be asked in the subsequent phases of this barrier analysis. 

Data Examined: First, NASA reexamined the data and summaries on Phases 1-3 to identify strategically 

where we still have remaining questions that our current data can’t answer. Second, we used 

qualitative interviewing to address key questions currently unanswered in our current data.

Findings: The main goal of this phase it to make sense of the findings of phases 1-3. In addition to 

those findings (as outlined in previous sections), a few other areas of concern were discovered in the 

qualitative interviews with human resources and managerial personnel. First, position recruitment for 

these positions is not particularly structured. When targeted recruitment happens, it is by request by 

managers rather than being data driven or strategic. Second, hiring for these positions is not regulated 

very much from the top down. Managers at different centers are given some guidance from senior

Agency-level managers. However, local managers around the NASA centers are mostly in control of 

their hiring processes. Third, given the high percentage of GS-14 and GS-15 employees in these 

occupations, individual development plans are not used very often, which could potentially be 

hindering promotional rates to GS-15 and SES positions. 

Phase 5

Purpose: With phase 4 identifying all that is currently known with this segment of the workforce, the 

goal of phase 5 is to collect more data using a psychometric survey. This survey will look at underlying 

constructs that might explain lower participation or advancement rates. 

Data Examined: All of the data for phase 5 comes from a psychometric survey. Staff distributed the 

survey to all NASA civil servant Physical Scientists. This survey addressed the following constructs as 

potential root cause indicators: perceived fairness in hiring/promotion/development, intention to 

turnover, affective organizational commitment, perceived leadership quality, trust in executive 

leadership, trust in diversity culture, and supervisory support. 

Findings: For AAPI employees, Affective Commitment, Turnover, and Fairness in Selection were 

examined as potential causes for low participation. However, none of these constructs provided any 

insight into low participation rates. Fairness in developmental opportunities was also examined as a 

potential cause for low advancement rates. However, it did not yield any insight into the low 

advancement rates for AAPI employees. 

For women, fairness in developmental opportunities was examined as a potential cause for low 

advancement rates. However, it did not yield any insight into the low advancement rates for women. 

To address the low perceived inclusion among women in physical science occupations, several common 
68

correlates were examined as potential indicators for root causes. The results of the survey show that 

women in these positions have lower supervisory trust and have less trust that NASA is embracing 

diversity compared to men in these occupations. 

Subsequent Phases and Approximate Timeline

Phase 6: Based on the survey results, NASA will conduct interviews and/or focus groups with members 

of the affected demographic groups. This research will serve two purposes: (1) to explore where, when, 

why, and how some of these identified triggers may be problematic; and (2) to identify potential steps 

that might help to remove or mitigate potential barriers to equal employment opportunity for the 

group. Expected Completion: November 1, 2022.

Phase 7: The data collected from Phases 1 to 6 will be reviewed to determine whether barriers to equal 

employment opportunity exist for various demographic groups in the NASA workforce. The final report 

will not only include a list of challenges but will also identify actions to address each of the challenges. 

Expected Completion: November 15, 2022. 
69

APPENDIX C: 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 

Program (FEORP) Report

Recruitment 

NASA is participating in an OPM pilot to combine these reports. 

Disabled Veterans Affirmative Action The report will be provided upon request. 

Program (DVAAP) Report

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 1 and 2 in 

Appendix B for summary data. 
70

APPENDIX D: 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 

D&I Diversity and Inclusion

DAD Diversity and Data/Analytics 

Division

DEIA Diversity, Inclusion, Equity, 

and Accessibility

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 Officer

OPM Office of Personnel 

Management

PA Professional Administrative

PAS Personal Assistance Services

RA Reasonable Accommodation

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