OFFICE OF DIVERSITY AND EQUAL OPPORTUNITY 

NATIONAL AERONAUTICS AND SPACE 

ADMINISTRATION (NASA)

MODEL EQUAL EMPLOYMENT OPPORTUNITY 

PROGRAM STATUS REPORT: FY 2020
[this page intentionally blank]
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA) 

MODEL EQUAL EMPLOYMENT OPPORTUNITY PROGRAM STATUS REPORT:

FY 2020

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 

1. Demonstrated Commitment of Agency Leadership..................................... 3 

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

3. Management and Program Accountability .................................................. 5 

4. Proactive Prevention of Unlawful Discrimination........................................ 6 

5. Efficiency....................................................................................................... 6

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

Section III. Workforce Analyses.................................................................................. 7 

Section IV. FY 2020 Model EEO Program Accomplishments ..................................... 9 

Section V. FY 2021 Planned Activities........................................................................ 9 

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

Part G: Agency Self-Assessment Checklist - FY 2020 .......................................................13

Part H: Essential Element Deficiencies and Planned Activities........................................27

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

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

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

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

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

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

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

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

Section III: Plan to Recruit and Hire Individuals with Disabilities............................42

A. Plan to Identify Job Applicants with Disabilities...........................................42

B. Plan to Establish Contacts with Disability Employment Organizations........44

C. Progression Towards Goals (Recruitment and Hiring) ................................. 44
ii

Section IV: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities................................................................................................................47

A. Advancement Program Plan.........................................................................47

B. Career Development Opportunities.............................................................47

C. Awards..........................................................................................................48

D. Promotions...................................................................................................49

Section V: Plan to Improve Retention of Persons with Disabilities.........................53

A. Voluntary and Involuntary Separations........................................................53

B. Accessibility of Technology and Facilities.....................................................54

C. Reasonable Accommodation Program.........................................................55

D. Personal Assistance Services Allowing Employees to Participate in the

Workplace.........................................................................................................56

Section VI: EEO Complaint and Findings Data..........................................................57

A. EEO Complaint Data Involving Harassment..................................................57

B. EEO Complaint Data Involving Reasonable Accommodation.......................57

Section VII: Identification and Removal of Barriers.................................................57

Appendix A: Data Analyses ..............................................................................................61

Workforce Summary ................................................................................................61

Occupational Categories, by Race and Ethnicity......................................................62

Individuals with Disabilities......................................................................................64

Federal Employee Viewpoint Survey (FEVS) Results ...............................................65

Appendix B: Physical Science Barrier Analysis Plan and Initial Findings..........................67

Appendix C: Documents Required by EEOC.....................................................................72

Appendix D: List of Frequently Used Acronyms...............................................................73
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, 2019 to September 30, 2020.

PART A

Department

or Agency

Identifying

Information

Agency National Aeronautics and Space Administration

Address 300 E Street, SW

City, State, Zip Code Washington, DC 20546

CPDF Code NN00

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

PART B

Total

Employment

Permanent Workforce 17,458

Temporary Workforce 590

TOTAL EMPLOYMENT 18,048

PART C1

Head of 

Agency and 

Head of 

Agency 

Designee

Leadership Name Title

Head of Agency Bill Nelson Administrator

Head of Agency Designee

PART C2

Agency 

Official(s) 

Responsible 

for Oversight

of EEO 

Programs 

EEO Program Staff Name/Title

Occupational 

Series/Pay 

Plan and 

Grade

Phone 

Number Email Address

Principal EEO 

Director/Official

Stephen T. Shih, Associate 

Administrator, Office of 

Diversity and Equal 

Opportunity (ODEO)

0260/SES (202) 358-

2167

stephen.t.shih

@nasa.gov

Affirmative Employment 

Program Manager

Vincent Patterson, Acting 

Director, Diversity and 

Data/Analytics Division, 

ODEO

0260/GS-15 (202) 358-

0952

vincent.e.patterson

@nasa.gov

Complaint Processing 

Program Manager

Susan Cloud, Director, 

Complaints Management 

Division

0260/SES (256) 544-

5377

susan.l.cloud

@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
2 

Reasonable 

Accommodation Program 

Manager

Rebecca Doroshenk, 

Program Analyst

0343/GS-14 (202) 358-

0038

Rebecca.d.doroshenk

@nasa.gov

Anti-Harassment 

Program Manager

David Chambers, Equal 

Opportunity Compliance 

Manager

0360/GS-15 (202) 358-

3158

david.r.chambers

@nasa.gov

ADR Program Manager Yvette Harris, Equal 

Employment Manager

0260/GS-15 (216) 433-

8000

yvette.c.harris@nasa.

gov

Compliance Manager Dorenda King, Equal 

Opportunity Manager 

0260/GS-15 (202) 358-

0726

dorenda.r.king

@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, 2019 to September 30, 2020. 

EXECUTIVE SUMMARY

Section I. Agency Mission and Leadership

The mission of the National Aeronautics and Space Administration (NASA) is to “lead an innovative 

and sustainable program of exploration with commercial and international partners to enable human 

expansion across the solar system and bring new knowledge and opportunities back to Earth, support 

growth of the Nation’s economy in space and aeronautics, increase understanding of the universe 

and our place in it, work with industry to improve America’s aerospace technologies, and advance 

American leadership” (NASA 2018 Strategic Plan). The work of NASA benefits all Americans and all 

humanity. NASA inspires the world with exploration of new frontiers, discovery of new knowledge, 

and development of new technology. 

With top-level support from the NASA Administrator and leadership team, the Office of Diversity and 

Equal Opportunity (ODEO) engaged in significant activities in FY 2020 to advance equal employment 

opportunity (EEO) in the NASA workforce. NASA measures the success of its 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). FY 2020 program 

accomplishments and EEO successes are identified and discussed below. 

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

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

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

its EEO program reflecting a compliance rate of 96 percent. Utilizing the results of the selfassessment, 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. Demonstrated Commitment of Agency Leadership

During FY 2020, NASA continued to implement the enterprise-wide Unity Campaign launched in FY 

2019. The goal of the Campaign is to “power and propel” NASA’s workforce and internal 

organizations to work more effectively together to accomplish NASA’s missions. The NASA 
4 

Administrator instituted several new actions in support of the Campaign. These actions are as 

follows: 

• Unity Campaign Implementation Plans. To ensure Agency-wide accountability, NASA Centers

and major organizations developed Unity Campaign Implementation Plans.

• Diversity, Equity, and Inclusion Strategic Plan. In FY 2020, NASA initiated development of a

new diversity, equity, and inclusion strategic plan focused on people, mission, and culture.

• Recruitment, Training, and Advancement. The Administrator directed ODEO and the Office

of the Chief Human Capital Officer (OCHCO) to review how we address NASA values in the

recruiting, hiring, training, and management of our workforce. The goal of this action is to

identify areas that need improvement and institute new approaches to identifying talent,

onboarding new employees, and promoting mobility within our workforce.

• Policy Statements. The NASA Administrator issued updated policy statements for EEO,

Diversity and Inclusion (D&I), and Anti-Harassment.

• Employee Engagement. Between June and September 2020, NASA conducted more than 500

“Diversity Dialogues” reaching more than 10,000 NASA employees.

Further examples of leadership commitment to diversity and equal opportunity include renaming 

the NASA Headquarters (HQ) building the “Mary W. Jackson NASA HQ Building” after the first African 

American female engineer at NASA. 

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

On October 18, 2019, NASA conducted its first all-women spacewalk. While this was the 221st 

spacewalk performed in support of space station assembly, it was the first conducted entirely by 

women. On July 23, 2020, the Administrator announced the addition of a new NASA core value, 

“Inclusion” (the other core values are safety, integrity, 

teamwork, and excellence). The Administrator noted, “NASA 

is committed to a culture of diversity, inclusion, and equity, 

where all employees feel welcome, respected, and engaged. 

To achieve the greatest mission success, NASA embraces 

hiring, developing, and growing a diverse and inclusive 

workforce in a positive and safe work environment where 

individuals can be authentic. This value will enable NASA to 

attract the best talent, grow the capabilities of the entire 

workforce, and empower everyone to fully contribute.” 

NASA continues to be committed to attracting, selecting, 

developing, empowering, and retaining a highly capable and 

talented workforce to achieve its missions. Specifically, Strategic Objective 4.4 of the 2018 NASA 

Strategic Plan charges the agency to: “Cultivate a diverse and innovative workforce with the right 

balance of skills and experience to provide an inclusive work environment in which employees that 

possess varying perspectives, education levels, life experiences, and backgrounds can work together 
5 

and remain fully engaged in our mission.” The plan identifies strategies relating to equal employment 

opportunity, diversity, and inclusion for the NASA workforce, including: proactive efforts to prevent 

discrimination and ensure EEO in the workplace; regular assessment of the Federal Employee 

Viewpoint Survey (FEVS) New Inclusion Quotient (New IQ); measurement of participation rates of 

employee groups; targeted outreach and recruitment efforts to increase diversity in the Agency’s 

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

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

networking and shadowing) for both managers and employees.

3. Management and Program Accountability

On October 1, 2019, NASA ODEO underwent an organizational realignment that resulted in a shift in 

reporting for the 10 geographically dispersed Center ODEO offices. Under the new structure, these 

operational components became direct reports of the AA, ODEO. Previously, Center EEO offices 

reported to their respective Center Directors. This change allows for more direct program oversight, 

budgetary management, and development of staff.

Additionally, NASA managers and supervisors are accountable for advancing EEO in the workplace

through their performance evaluations. In FY 2020, NASA approved a new Unity performance 

requirement to all Senior Executive Service (SES) performance plans. NASA intends to include a 

similar requirement in all managerial and supervisory performance plans.

NASA ODEO reports quarterly on EEO and D&I performance outcomes at the quarterly agency senior 

leadership Baseline Performance Review (BPR) meeting. In addition, the AA, ODEO, is a full and 

active member of NASA’s senior leadership team and regularly participates on various decisionmaking 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 SES members; 

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

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

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

supervisors are responsible for the following: 

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

effectiveness and help achieve mission goals.

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

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

Federal Equal Opportunity Recruitment Program plans and barrier analyses.
6 

4. Proactive Prevention of Unlawful Discrimination

NASA’s Anti-Harassment Program (AHP) emphasizes a broad application of anti-harassment policy 

and procedures, going beyond legal compliance and focusing on workforce and mission. The goals 

of the program are to: 1) create an environment in which employees feel safe coming forward with 

their concerns; and 2) reinforce a reporting culture that enables NASA to identify issues at the 

earliest possible opportunity and to take prompt corrective actions, allowing individual and 

organizational focus to remain on mission success. In FY 2020, NASA received 66 reports of 

harassment under the AHP, achieving an expeditious average processing time of 65 days. NASA 

took corrective action in 35 percent of cases. Additionally, NASA continues to train the workforce 

with its award-winning, on-line “gamified” anti-harassment training; approximately 3,200 

individuals were trained in FY 2020. 

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

conferences and events, including the Black Engineer of the Year Awards, Society of Asian Scientists 

and Engineers national and regional conferences, American Indian Science and Engineering Society 

National Conference, Women of Color, Society for Advancement of Hispanics/Chicanos and Native 

Americans in Science conference, and the Society of Women Engineers conference. In addition, 

NASA provided an electronic Just-in-Time Disability Toolkit for Managers, which contains quick tips, 

print-and-go checklists, and other relevant resources to help managers hire and lead a disabilityinclusive workforce.

5. Efficiency

NASA initiated development of a new Reasonable Accommodation Management System (RAMS). 

The new RAMS tool will enable the Agency to better track and monitor trends in processing of 

reasonable accommodation (RA) requests. NASA expects to launch the new system in FY 2021.

Moreover, to improve effectiveness and efficiency in the NASA Affirmative Employment Program, 

the Agency procured barrier analysis training for approximately 50 EEO staff members. Due to the 

COVID-19 pandemic, this training will be delivered in FY 2021.

6. Responsiveness and Legal Compliance

NASA posted timely No FEAR Act data, met established deadlines for submitting the FY 2019 MD-715 

report, and submitted a timely Annual Statistical Report of Discrimination Complaints (EEOC Form 

462) to EEOC. In April 2020, ODEO underwent a Technical Assistance visit with representatives from

EEOC. EEOC highlighted several NASA best practices and provided guidance to NASA for correcting

program deficiencies. In addition, in FY 2020 NASA:

• Improved timeliness of its issuance of Final Agency Decisions (FADs). In particular, NASA

eliminated its backlog of FADs and improved the percentage of timely FADs from 21 percent
7 

in FY 2019 to 76 percent in FY 2020. NASA expects to timely issue 100 percent of its FADs in

FY 2021. 

• Awarded an Agency-wide Blanket Purchasing Agreement (BPA) for Personal Assistance

Services (PAS) in FY 2020. The BPA will result in greater efficiency and consistency in providing

PAS across the Agency.

• Provided training to an initial cadre of settlement officials to increase their knowledge and

develop their skills in settling disputes within the agency. NASA anticipates this will increase

the positive outcomes in ADR by having management officials who are knowledgeable about

the ADR process, and who are able to identify unique solutions tailored to settle the conflict.

• All qualified staff (100 percent) are current with regulatory annual EEO training requirements.

Moreover, in September 2020, agency EEO counselors participated in refresher training

covering a myriad of NASA-specific topics, including iComplaints, procedural dismissals, and

issues associated with contract workers.

Section III. Workforce Analyses

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

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

NASA monitors workforce composition data to determine if discrepancies exist in the participation

rate of any demographic group.1 The FY 2020 workforce composition data revealed the following 

triggers (see Appendix A, Table 1): 

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

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

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

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

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

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

• Similar to the workforce composition findings in FY 2019, some groups are underrepresented

in the higher grades and leadership positions:

 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. Each group makes up 8.4 percent of the

workforce, yet AAPI account for 4.3 percent of the SES and Hispanics account for 5.3

percent of the SES.

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

and Women make up a smaller proportion of SL positions than their overall

representation in the workforce: Blacks make up 11.1 percent of the NASA workforce,

yet are only 2.2 percent of those in SL positions. Hispanics account for 8.4 percent of the

NASA workforce but only occupy 4.5 percent of SL positions. Women are 34.2 percent of

the NASA workforce, yet are only 18.0 percent of SL employees. Blacks, Hispanics, and
8 

Women also account for smaller percentages of the ST workforce, compared to their

representation in the NASA workforce (these groups account for 2.4 percent, 3.5 percent, 

and 21.2 percent of ST positions, respectively). 

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

Force (RCLF) (see Appendix A, Tables 2-3).2 For example, Women account for 32.4 percent of NASA 

Physical Scientists (job series 1301), yet are 39.0 percent of Physical Scientists in the RCLF. AAPI make 

up 12.5 percent of Physical Scientists at NASA, but account for 14.9 percent of such positions in the 

RCLF. In addition, AAPI account for 6.4 percent of General Engineers (job series 0801), compared to 

10.7 percent in the RCLF. 

2 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>.

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

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

3). For example, 

• AAPI employees are 12.4 percent of NASA Accountants, but only 7.5 percent of

Accountants in the RCLF. AAPI also account for 7.3 percent of Human Resources

Specialists but are only 2.6 percent of similar positions in the RCLF.

• Black employees are employed at rates more than three times their representation in

the RCLF in Contract Specialist and Accountant positions. Blacks account for 27.1 percent 

of NASA Contract Specialists and 29.6 percent of NASA Accountants, but only 8.4 percent 

and 7.9 percent, respectively, in the RCLF.

• Hispanic employees are: 11.2 percent of Program Analysts, compared to 4.6 percent in

the RCLF; 10.5 percent Contract Specialists, compared to 7.1 percent in the RCLF; 7.2

percent of Information Technology Specialists, compared to 4.7 percentin the RCLF; and

8.9 percent of Accountants, compared to 5.1 percent in the RCLF.

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

Preliminary findings of the initial phases on the barrier analysis appear in Appendix B. Additionally, 

NASA completed revisions to its applicant flow data reports, which now align with the revised EEOC 

MD-715 tables.

As indicated in Part J of this report, NASA has made progress in achieving the Federal goals for the 

employment of individuals with disabilities (IWD) and individuals with targeted disabilities (IWTD). 

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 2 percent of 

employees in these grade categories. NASA exceeds the goals for grades GS-10 and below: IWD and 
9 

IWTD account for 21.6 percent and 5.8 percent of the employees in those grades, respectively. For 

grades GS-11 and above, NASA was just below the goal for IWD (11.4 percent of NASA employees in 

those grades) and just above the goal for IWTD (2.5 percent of those employees) (see Appendix A, 

Table 4). The Agency will continue to monitor overall employment data on IWD and IWTD with 

regard to recruitment, hiring, promotions, awards, and retention. 

3

3 NASA reached the employment goal for the employment of IWD in grades 11 and above by the end of the first quarter of FY 2021.

Section IV. FY 2020 Model EEO Program Accomplishments

In FY 2020, NASA focused on five program deficiencies identified in the previous fiscal year: 

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

Administrator. NASA addressed this deficiency in FY 2020; the Agency issued the updated

EEO policy statement on March 4, 2020 (see Part H-1).

2. The Agency head is not the immediate supervisor Agency EEO Director, nor does the EEO

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

offices. NASA discussed this deficiency with EEOC representatives in April 2020 and will

further consider how to address this deficiency with the new NASA Administrator (see

Part H-2).

3. NASA does not complete counseling within established timeframes. NASA improved

counseling timeliness from 89 percent of cases in FY 2019 to 93 percent in FY 2020 (see

Part H-5).

4. NASA does not complete investigations within established timeframes. The percentage

of timely investigations decreased to 86 percent in FY 2020 from 100 percent in FY 2019

(see Part H-7).

5. NASA does not complete FADs within established timeframes. NASA issued 76 percent

of FADs timely in FY 2020, compared to 21 percent in FY 2019. Of particular note, NASA

eradicated all backlogged FADs from prior fiscal years and issued all Final Actions

pertaining to FY 2020 complaints within the established timeframes (see Part H-9).

NASA also completed the development of revised applicant flow data tables for use in its barrier 

analyses (see Part I and Part J). In addition, NASA posted information regarding the Architectural 

Barriers Act complaint process on the Agency Web site (see Part J). 

Section V. FY 2021 Planned Activities

In FY 2021, NASA intends to execute the following activities to address program deficiencies and 

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

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

Administrator, pursuant to 29 CFR §1614.102(b)(4). A new NASA Administrator was sworn 
10

in on May 3, 2021. NASA will determine how to address this deficiency, which NASA 

identified in Part G of the FY 2019 MD-715 report, and EEOC highlighted in an April 2020 

Agency audit report (see Part H-2).

• Establish timeframes for completing inquiries of harassment allegations under the AntiHarassment Program. NASA has implemented new Anti-Harassment Procedures (NPR

3713.3A (see https://nodis3.gsfc.nasa.gov/displayDir.cfm?t=NPR&c=3713&s=3)) that

include EEOC-specified timeframes for initiating action on and completing the processing

of reports of harassment (see Part H-3).

• Revise exit surveys to include questions on how the Agency could improve the

recruitment, hiring, inclusion, retention, and advancement of individuals with

disabilities. NASA will incorporate specific disability employment- and diversity-related

questions into exit surveys by the third quarter of FY 2021 (see Part H-4).

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

CFR §1614.108. NASA will review monthly complaint processing data, hold Agency-wide

forums to discuss issues at the informal complaints stage, implement process

improvements, develop new Standard Operating Procedures, and provide training to all

NASA EEO Counselors (see Part H-5).

• Establish timeframes to issue acceptance letters/dismissal decisions within a reasonable

time after receipt of the written EEO Counselor report. In FY 2020, the average processing

time was 97 days. NASA will establish internal metrics to ensure acceptance/dismissal

decisions are issued within reasonable timeframes (see Part H-6).

• Ensure EEO investigations are timely completed, pursuant to 29 CFR §1614.108. NASA

will review monthly complaint processing data, implement process improvements, begin

the development of new Standard Operating Procedures, and provide training to all NASA

EEO Specialists responsible for coordinating and reviewing investigations (see Part H-7).

• 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). NASA will

review monthly complaint processing data, implement process improvements, and begin

the development of new Standard Operating Procedures for timely and compliant

processing of EEO complaints at all stages of the EEO process (see Part H-8).

• Ensure all FADs are issued within 60 calendar days, pursuant to 29 CFR §1614.110(b).

Having successfully eliminated its entire FAD backlog and implemented process and

tracking improvements in FY 2020, NASA expects to achieve timely issuance in 100 percent

of FADs (see Part H-9).

• Strengthen data analytics capabilities and conduct barrier analyses regarding Women,

AAPI, and Individuals with Disabilities. NASA will complete additional phases of its barrier

analysis regarding the employment of Women and AAPIs as Physical Scientists at NASA,

including tracking applicant flow data by sex and race and will continue to address issues

related to its disability program (see Parts I and J).
11 

PART f: CERTIFICATION OF ESTABLISHMENT OF CONTINUING EEO PROGRAMS 

MD-715

PARTF

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

CERTIFICATION of ESTABLISHMENT of CONTINUING EQUAL EMPLOYMENT 

OPPORTUNITY PROGRAMS 

I, 

Stephen T. Shih, Associate Administrator for Diversity 

and Equal Opportunity/0260/SES 

am the 

Principal EEO 

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

for: National Aeronautics and Space Administration 

(Insert Agency/Component Name) 

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

programs against the essential elements as prescribed by EEO MD 715. If an essential element 

was not fully compliant with the standards of EEO MD 715, a further evaluation was conducted 

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

included with this Federal Agency Annual EEO Program Status Report. 

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

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

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

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

Program Status Report. 

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

EEOC review upon request. 

Signature of Principal EEO Director/Official 

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

compliance with EEO MD 715 . 

6/25/21

Date 

Signature of Agency Head or Agency Head Designee Dite 
12

[this page intentionally blank]
13

PART G: AGENCY SELF-ASSESSMENT CHECKLIST - FY 2020

MD-715

PART G

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL

EEO PROGRAM STATUS REPORT

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP

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

opportunity and a discrimination-free workplace.

Indicator 

Measures

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

EEO policy statement.

Measure 

Met? Comments

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

EEO policy statement on agency letterhead that clearly 

communicates the agency’s commitment to EEO for all 

employees and applicants? If yes, provide the annual 

issuance date in the comments column. [MD-715, 

II(A)] 

Yes

NASA issued an updated EEO 

policy on March 4, 2020. 

See Part H-1.

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

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

sexual orientation and gender identity), genetic 

information, national origin, race, religion, and 

reprisal) contained in the laws EEOC enforces? [29 CFR 

§ 1614.101(a)]

Yes

Indicator 

Measures

A.2 – The agency has communicated EEO policies

and procedures to all employees.

Measure 

Met? Comments

A.2.a Does the agency disseminate the following policies and procedures to all employees:

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

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

1614.203(d)(3)] Yes

A.2.b Does the agency prominently post the following information in the workplace and on its public Web

site: 

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

EEO Counselors, EEO Officers, Special Emphasis

Program Managers? [29 CFR § 1614.102(b)(7)]

Yes

A.2.b.2 − Written materials concerning the EEO program,

laws, policy statements, and the operation of the

EEO complaint process? [29 CFR § 1614.102(b)(5)]

Yes

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

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

address in the comments column.

Yes 

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

splayDir.cfm?t=NPR&c=3713&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? [MD-110, Ch. 3(II)(C)] If yes,

provide how often. 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 Yes At least annually.
14

Unlawful Harassment by Supervisors (1999), § 

V.C.1] If yes, provide how often.

A.2.c.5 − Behaviors that are inappropriate in the workplace

and could result in disciplinary action? [5 CFR §

2635.101(b)] If yes, provide how often.

Yes At least annually.

Indicator 

Measures

A.3 – The agency assesses and ensures EEO

principles are part of its culture.

Measure 

Met? Comments

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

supervisors, managers, and units demonstrating 

superior accomplishment in equal employment 

opportunity? [29 CFR § 1614.102(a) (9)] If yes, 

provide one or two examples in the comments section.

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

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

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

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

Indicator 

Measures

B.1 - The reporting structure for the EEO program

provides the principal EEO official with

appropriate authority and resources to

effectively carry out a successful EEO program.

Measure 

Met? Comments

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

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

over the EEO office? [29 CFR §1614.102(b)(4)] No

The AA for ODEO formally 

reports to the Deputy Associate 

Administrator and has regular 

access to the Administrator. 

See Part H-2. 

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-2.

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 10/4/2019, 

and presented data at the 

Agency Baseline Performance 

Review on 4/23/2020.

B.1.d Does the EEO Director regularly participate in seniorlevel staff meetings concerning personnel, budget, 

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

Yes
15

Indicator 

Measures

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

EEO program.

Measure 

Met? Comments

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

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

employment program to promote EEO and to

identify and eliminate discriminatory policies,

procedures, and practices? [MD-110, Ch. 1(III)(A);

29 CFR §1614.102(c)]

Yes

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

CFR §1614.102(c)(4)] Yes

B.2.c − Overseeing the fair and thorough investigation of

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

B.2.d − Overseeing the timely issuance of final agency

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

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

1614.102(e); 1614.502] Yes

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

providing recommendations for improvement to the

agency head? [29 CFR §1614.102(c)(2)]

Yes

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

the EEO Director provide effective guidance and 

coordination for the components? [29 CFR §§ 

1614.102(c)(2) and (c)(3)]

Yes

Indicator 

Measures

B.3 - The EEO Director and other EEO

professional staff are involved in, and consulted

on, management/personnel actions.

Measure 

Met? Comments

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

meetings regarding workforce changes that might 

impact EEO issues, including strategic planning, 

recruitment strategies, vacancy projections, succession 

planning, and selections for training/career 

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

Yes

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

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

If yes, identify the EEO principles in the strategic plan 

in the comments column.

Yes

Objective 4.4, Manage Human 

Capital, references proactive 

efforts to ensure EEO and 

prevent workplace

discrimination. 

Indicator 

Measures

B.4 - The agency has sufficient budget and

staffing to support the success of its EEO

program

Measure 

Met? Comments

B.4.a Per 29 CFR §1614.102(a)(1), has the agency allocated sufficient funding and qualified staffing to 

successfully implement the EEO program, for the following areas: 

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

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

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

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

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); MD110, Ch. 1(IV)(D) & 5(IV); MD-715, II(E)]

Yes
16

B.4.a.4 − to provide all supervisors and employees with

training on the EEO program, including but not

limited to retaliation, harassment, religious

accommodations, disability accommodations, the

EEO complaint process, and ADR? [MD-715, II(B)

and III(C)] If not, identify the type(s) of training

with insufficient funding in the comments section.

Yes

B.4.a.5 − to conduct thorough, accurate, and effective field

audits of the EEO programs in components and the

field offices, if applicable? [29 CFR §1614.102(c)(2)]

Yes

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

harassment policies, EEO posters, reasonable

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

Yes

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

systems for the following types of data: complaint

tracking, workforce demographics, and applicant

flow data? [MD-715, 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?

[MD-715 Instructions, Sec. I; EEOC Enforcement

Guidance on Vicarious Employer Liability for

Unlawful Harassment by Supervisors (1999), §

V.C.1]

Yes

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

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

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

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

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

from other offices within the agency? [29 CFR § 

1614.102(a)(1)]

Yes

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

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

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

investigators, including contractors and collateral duty 

employees, receive the required 32 hours of training, 

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

Yes

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

counselors and investigators, including contractors and 

collateral duty employees, receive the required 8 hours 

of annual refresher training, pursuant to Ch. 2(II)(C) 

of MD-110?

Yes

Indicator 

Measures

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

retains supervisors and managers who have

effective managerial, communications, and

interpersonal skills.

Measure 

Met?

Comments

B.5.a Pursuant to 29 CFR § 1614.102(a)(5), have all managers and supervisors received training on 

their responsibilities under the following areas under the agency EEO program:
17

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? [MD715(II)(E)]

Yes

Indicator 

Measures

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

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

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

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

in developing agency EEO action plans (Part I, Part J, 

or the Executive Summary)? [MD-715 Instructions, 

Sec. I]

Yes

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

Plans and incorporate the EEO Action Plan Objectives 

into agency strategic plans? [29 CFR § 

1614.102(a)(5)]

Yes

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY

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

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

Indicator 

Measures

C.1 – The agency conducts regular internal audits

of its component and field offices.

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

Schedule of functional reviews 

of Center EEO offices – 

• FY 2020: LARC

• FY 2021: KSC, SSC, JSC,

ARC, AFRC, MSFC

• FY 2022: HQ

• To be determined: GRC,

GSFC

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? [MD-715, II(C)] Yes
18

Indicator 

Measures

C.2 – The agency has established procedures to

prevent all forms of EEO discrimination.

Measure 

Met?

Comments

C.2.a Has the agency established comprehensive antiharassment 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 

Anti-Harassment Coordinator and the EEO Director? 

[EEOC Report, Model EEO Program Must Have an 

Effective Anti-Harassment 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 10 days of notification) of all harassment 

allegations, including those initially raised in the EEO 

complaint process? [Complainant v. Dep’t of Veterans 

Affairs, EEOC Appeal No. 0120123232 (May 21, 2015); 

Complainant v. Dep’t of Defense (Defense Commissary 

Agency), EEOC Appeal No. 0120130331 (5/29/15)] If 

no, provide the percentage of timely-processed 

inquiries in the comments section. No

NASA uses an indicator of 60 

days for case completion. In 

FY 2020, NASA completed 61

percent of cases in a timely 

fashion. 

Additionally, NASA has 

implemented new AntiHarassment Procedures (NPR 

3713.3A) that include EEOCspecified timeframes for 

initiating action on reports of 

harassment within 10 days and 

completing the processing of 

reports of harassment within 

60 days. See Part H-3.

C.2.a.6 Do the agency’s training materials on its antiharassment 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
19

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/di

splayDir.cfm?t=NPR&c=3713&s

=1B 

Indicator 

Measures

C.3 - The agency evaluates managers and

supervisors on their efforts to ensure equal

employment opportunity.

Measure 

Met?

Comments

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

and supervisors have an element in their performance 

appraisal that evaluates their commitment to agency 

EEO policies and principles and their participation in 

the EEO program?

Yes

C.3.b Does the agency require rating officials to evaluate the performance of managers and supervisors 

based on the following:

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

including the participation in ADR proceedings?

[MD-110, Ch. 3.I]

Yes

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

supervision with EEO officials, such as counselors

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

Yes

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

discrimination, including harassment and retaliation?

[MD-715, II(C)]

Yes

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

managerial, communication, and interpersonal skills

to supervise in a workplace with diverse employees?

[MD-715 Instructions, Sec. I]

Yes

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

cause an undue hardship? [29 CFR

§1614.102(a)(7)]

Yes

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

cause an undue hardship? [29 CFR

§1614.102(a)(8)]

Yes
20

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

Indicator 

Measures

C.4 – The agency ensures effective coordination

between its EEO programs and Human Resources

(HR) program.

Measure 

Met? Comments

C.4.a

Do the HR Director and the EEO Director meet 

regularly to assess whether personnel programs, 

policies, and 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? [MD715 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
21

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

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

C.4.e.5 − Assist in preparing the MD-715 report? [MD-715,

II(C)] Yes

Indicator 

Measures

C.5 – Following a finding of discrimination, the

agency explores whether it should take a

disciplinary action.

Measure 

Met? Comments

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

of penalties that covers discriminatory conduct? [29 

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

Administration, 5 MSPR 280 (1981)]

Yes

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

sanction managers and employees for discriminatory 

conduct? [29 CFR §1614.102(a)(6)] If yes, state the 

number of disciplined/sanctioned individuals during 

this reporting period in the comments.

Yes No individuals were disciplined 

or sanctioned in FY 2020.

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

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

inform managers and supervisors about the 

discriminatory conduct? [MD-715, II(C)]

Yes

Indicator 

Measures

C.6 – The EEO office advises managers/

supervisors on EEO matters.

Measure 

Met? Comments

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

officials with regular EEO updates on at least an annual 

basis, including EEO complaints, workforce 

demographics and data summaries, legal updates, 

barrier analysis plans, and special emphasis updates? 

[MD-715 Instructions, Sec. I] If yes, identify the 

frequency of the updates in the comments column.

Yes At least annually.

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.

Indicator 

Measures

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 

No See Part H-3.
22

and advancement of individuals with disabilities? [29 

CFR 1614.203(d)(1)(iii)(C)]

Indicator 

Measures

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

D.2.c

Yes

Does the agency consider whether any group of 

employees or applicants might be negatively impacted 

prior to making human resource decisions, such as reorganizations and realignments? [29 CFR 

§1614.102(a)(3)]

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

of information to find barriers: complaint/ grievance 

data, exit surveys, employee climate surveys, focus 

groups, affinity groups, union, program evaluations, 

anti-harassment program, special emphasis programs, 

RA program; anti-harassment 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).

Indicator 

Measures

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

Indicator 

Measures

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 

Yes
23

agency until it meets the goals? [29 CFR 

1614.203(d)(7)(ii)]

Essential Element E: EFFICIENCY

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

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

Indicator 

Measures

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

impartial complaint resolution process.

Measure 

Met? Comments

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

CFR §1614.105] No

NASA completed 93 percent of 

counseling timely in FY 2020.

See Part H-5.

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? [MD110, Ch. 5(I)] Yes

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

decisions within a reasonable time (e.g., 60 days) after 

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

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

the comments section.

No The average processing time 

was 97 days. See Part H-6.

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] No 86 percent of its investigations 

were timely. See Part H-7.

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)]

No NASA does not issue 180-day 

letters. See Part H-8. 

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

does the agency timely issue the final agency decision? 

[29 CFR §1614.110(b)] 

No 76 percent of FADs were 

timely. See Part H-9.

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

NASA states timelines in the 

statement of work, provides 

templates to ensure 

consistency, and requires 

contractors to provide weekly 

status updates and to inform 

the Contracting Officer’s 

Representative (COR) 

immediately of any issues 

causing delays. The COR has 

regular meetings with 

contractors to address 

deficiencies and/or areas to 

improve.
24

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

of the EEO complaint process, does the agency hold 

them accountable for poor work product and/or delays 

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

Yes

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

documents in the proper format to EEOC through the 

Federal Sector EEO Portal? [29 CFR § 1614.403(g)]

Yes

Indicator 

Measures

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?

[MD-110, Ch. 1(IV)(D)] If yes, please explain in the 

comments column. 

Yes

The Office of General Counsel 

(OGC) 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 column.

Yes

The OGC 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

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

for the legal counsel’s sufficiency review for timely 

processing of complaints? [EEOC Report, Attaining a 

Model Agency Program: Efficiency (Dec. 1, 2004)]

Yes

Indicator 

Measures

E.3 - The agency has established and encouraged

the widespread use of a fair alternative dispute

resolution (ADR) program.

Measure 

Met?

Comments

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

during both the pre-complaint and formal complaint 

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

Yes

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

Indicator 

Measures

E.4 – The agency has effective and accurate data

collection systems in place to evaluate its EEO

program.

Measure 

Met? Comments
25

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 antiharassment 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

Indicator 

Measures

E.5 – The agency identifies and disseminates

significant trends and best practices in its EEO

program.

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

Throughout the year, NASA 

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 

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

yes, provide example in the comments section. Yes

NASA reviews other agencies’ 

MD-715 reports, holds

benchmarking meetings with 

other agencies, reviews EEOC 

best practice documents, 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? [MD715, 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.

Indicator 

Measures

F.1 – The agency has processes in place to

ensure timely and full compliance with EEOC

Orders and settlement agreements.

Measure 

Met? Comments

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

controls to ensure that its officials timely comply with 

EEOC orders/directives and final agency actions? [29 

CFR §1614.102(e); MD-715, II(F)]

Yes

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

controls to ensure the timely, accurate, and complete 

compliance with resolutions/settlement agreements? 

[MD-715, II(F)]

Yes
26

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

predictable processing of ordered monetary relief? 

[MD-715, II(F)]

Yes

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

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

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

the agency, does the agency hold its compliance 

officer(s) accountable for poor work product and/or 

delays during performance review? [MD-110, Ch. 

9(IX)(H)]

Yes

Indicator 

Measures

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

EEOC regulations, management directives,

orders, and other written instructions.

Measure 

Met?

Comments

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

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

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

agency timely forward the investigative file to the 

appropriate EEOC hearing office? [29 CFR 

§1614.108(g)]

Yes

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

subject of an appeal by the agency, does the agency 

ensure timely compliance with the orders of relief? [29 

CFR §1614.501]

Yes

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

timely forward the investigative file to EEOC’s Office of 

Federal Operations? [29 CFR §1614.403(e)]

Yes

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

promptly provide EEOC with the required 

documentation for completing compliance?

Yes

Indicator 

Measures

F.3 - The agency reports to EEOC its program

efforts and accomplishments.

Measure 

Met? Comments

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

and complete No FEAR Act report? [Public Law 107-

174 (May 15, 2002), §203(a)]

Yes

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

quarterly No FEAR Act data? [29 CFR §1614.703(d)] Yes
27

PART H: ESSENTIAL ELEMENT DEFICIENCIES AND PLANNED ACTIVITIES

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

FY 2019 and FY 2020. NASA completed Part H-1 in FY 2020; Parts H-3, H-4, H-6, and H-8 are new program 

deficiencies for FY 2020. 

MD-715

PART H-1

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY:

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

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

A.1.a)

OBJECTIVE: Issue EEO policy statement.

RESPONSIBLE 

OFFICIAL:

NASA Administrator; AA, ODEO

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

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed

2/28/2018 6/30/2019 6/30/2020 3/4/2020

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

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

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

6/30/2019 3.NASA Administrator signs policy statement. Yes 6/30/2020 3/4/2020

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: The NASA Administrator signed the updated EEO policy 

statement on March 4, 2020. 

Modifications to Objective: This objective is now complete.
28

MD-715

PART H-2

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY:

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

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

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

offices (Part G, Integration of EEO into the Agency’s Strategic Mission, Measure B.1.a and 

Measure B.1.a1) 

OBJECTIVE: 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

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

TBD 1. New NASA Administrator is nominated by the

President and confirmed by the Senate.

Yes

TBD 2. New NASA Administrator makes a decision on

how to address this deficiency.

Yes

TBD 3. NASA completes administrative actions,

including updating its organizational chart, to

implement the new reporting structure.

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: NASA discussed this deficiency with EEOC representatives in April

2020. NASA will further consider how to address this deficiency once a new Administrator is nominated 

and confirmed. 

Modifications to Objective: NASA identified this as an actionable program deficiency in FY 2020. The 

agency first reported this deficiency in FY 2019, noting no negative impact resulting from the AA, ODEO 

position in the organizational structure.
29

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 conduct a prompt inquiry (beginning within 10 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 inquiries of harassment allegations under the AntiHarassment Program.

RESPONSIBLE 

OFFICIAL: AA, ODEO, and Director, 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 1/12/2021

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

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: In FY 2020, NASA initiated revisions to its Anti-Harassment 

procedures (NASA Procedural Requirements (NPR) 3713.3). The revised procedures include a 

requirement for inquiries to begin within 10 days of receipt of an allegation and will specify a 60-day 

timeframe for taking final corrective action. NASA finalized these new procedures on January 12, 2021. 

Modifications to Objective: NASA identified this as a new program deficiency in FY 2020; it is now 

completed. 
30

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 exit surveys do not include adequate questions on how the agency could improve 

the recruitment, hiring, inclusion, retention, and advancement of individuals with 

disabilities (Part G, Proactive Prevention, Measure D.1.c) 

OBJECTIVE: Include specific questions regarding employees with disabilities in exit surveys.

RESPONSIBLE 

OFFICIAL: AA, ODEO, and Assistant Administrator, OCHCO

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

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed

8/31/2018 3/30/2021

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

8/31/2018 1. Establish ODEO working group to develop exit

survey questions related to IWD.

Yes 9/30/2018

9/30/2020 2. Draft exit survey questions. Yes 9/30/2020

9/30/2020 3. Meet with OCHCO regarding revisions to exit

surveys.

Yes 10/7/2020

9/30/2021 4. Launch revised exit survey format with additional

questions related to D&I and IWD.

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: NASA developed exit survey questions regarding D&I and IWD. 

Modifications to Objective: NASA identified this as a new program deficiency in FY 2020.
31

MD-715

PART H-5

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY:

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

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

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

The current timeliness rate is 93 percent.

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 9/30/2021

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 9/30/2021

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

informal complaints stage to increase timeliness.

Yes

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

on specific NASA-related EEO issues.

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: NASA improved its compliance with regulatory processing 

requirements for informal complaints. In FY 2020, NASA completed 93 percent of its counseling timely 

(compared to 89 percent in FY 2019). 

Modifications to Objective: Renumbered as H-5. Added activities 7 and 8; modified the target completion 

date for activity 6.
32

MD-715

PART H-6

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY:

NASA does not issue acceptance letters/dismissal decisions within a reasonable time (e.g., 

60 days) after receipt of the written EEO Counselor report. (Part G, Efficiency, Measure 

E.1.d)

OBJECTIVE: Establish internal metrics to ensure acceptance letters/dismissal decisions are issued 

within reasonable timeframes.

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

4/1/2021 9/30/2021

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

5/1/2021 1. Establish timeframes for issuing acceptance

letters/dismissal decisions.

Yes

5/1/2021 2. Provide guidance to staff regarding new

timeframes.

Yes

9/30/2021 3. Monitor progress on issuing acceptance letters/

dismissal decisions within established

timeframes.

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: N/A. 

Modifications to Objective: NASA identified this as a new program deficiency in FY 2020.
33

MD-715

PART H-7

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 9/30/2021

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 9/30/2021

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

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: The timeliness of investigations decreased from 100 percent in 

FY 2019 to 86 percent in FY 2020. To improve compliance, NASA increased the total number of 

contractors supporting investigations. 

Modifications to Objective: Renumbered as H-7. Added activities 6-11; modified the completion date.
34

MD-715

PART H-8

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

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 185 calendar 

days of when the formal complaint was filed. 

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: NASA identified this as a program deficiency in FY 2020.

Modifications to Objective: NASA identified this as a new program deficiency in FY 2020.
35

MD-715

PART H-9

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY:

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

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

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

RESPONSIBLE 

OFFICIAL: AA, ODEO

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

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed

9/28/2018 9/30/2019 9/30/2021

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE:

Target Date Planned Activities

Sufficient 

Funding & 

Staffing?

Modified 

Date

Completion 

Date

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

review and shortening the review and approval periods.

Yes 9/28/2018

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

address processing challenges and share/implement

changes, when and where needed.

Yes 9/30/2019

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

knowledgeable in Federal EEO complaints processing

from informal processing to FADs.

Yes 9/30/2019

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

for timely and quality processing of complaints.

Yes 9/30/2019

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

informal complaints) and Agency wide (formal processing)

to track compliance to regulatory requirements and

address timeliness and quality issues as expeditiously as

possible, as needed.

Yes 9/30/2019

9/30/2020 6. Eliminate backlog. Yes 9/30/2020

9/30/2021 7. Prioritize timeliness and dedicate resources to completing

all FADs within required timeframes.

Yes

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress and Accomplishments: In FY 2020, NASA issued timely FADs in 76 percent of EEO 

complaints, compared to 21 percent in FY 2019. NASA completely eliminated its backlog of FADs from 

prior fiscal years. NASA timely issued all Final Actions (100 percent) pertaining to FY 2020 complaints. 

NASA is on track to have 100 percent of its FADs issued timely in FY 2021.

Modifications to Objective: Renumbered as H-9. Modified completion date.
36

PART I: BARRIER ANALYSIS AND PLANNED ACTIVITIES

MD-715

PART I

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT

TRIGGER ANALYSIS

STATEMENT OF 

CONDITION THAT 

WAS A TRIGGER 

FOR A POTENTIAL 

BARRIER: Provide 

a brief narrative 

describing the 

condition at issue. 

How was the 

condition 

recognized as a 

potential barrier?

A comparison of FY 2020 NASA workforce data to the RCLF reveals that AAPI and Women

have lower than expected participation rates in Physical Science positions at NASA. 

Overall, AAPI account for 12.5 percent of Physical Scientists but account for 14.9 percent 

of such positions in the RCLF. In addition, Women make up 32.5 percent of Physical 

Scientists, compared to 39.0 percent in the RCLF. Moreover, compared to the RCLF, AAPI 

men account for a slightly smaller percentage of Physicists, and AAPI women account for 

somewhat lower percentages as Physical Scientists and Space Scientists. NASA has 

completed Phases 1 and 2 (of 7) of its barrier analysis (see Appendix B). 

SOURCE OF 

TRIGGER: 

NASA workforce data: Lower than expected participation rate as compared to the 

national RCLF benchmark. 

MD-715

WORKFORCE

DATA TABLE:

Table A6

EEO GROUP(S) 

AFFECTED BY 

TRIGGER:

Check all that apply:

All Men

All Women X 

Hispanic or Latino Males

Hispanic or Latino Females

White Males

White Females

Black or African American Males

Black or African American Females

Asian Males X 

Asian Females X 

Native Hawaiian or Other Pacific Islander Males X 

Native Hawaiian or Other Pacific Islander 

Females

X 

American Indian or Alaska Native Males X 

American Indian or Alaska Native Females X 

Two or More Races Males 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 Table A6

Complaint Data (Trends) No

Grievance Data (Trends) No

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

No

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

Exit Interview Data No

Focus Groups No

Interviews No
37

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, 2 of 7 phases completed.

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

STATEMENT OF 

IDENTIFIED 

BARRIER(S): 

(Description of 

Policy, Procedure, 

or Practice)

Barriers not yet identified; pending completion of barrier analysis on or about 

9/30/2022.

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 9/30/2020 Yes 9/30/2020

Complete barrier analysis. 10/1/2020 9/30/2022 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

OCHCO and the Science Mission Directorate, to strengthen

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

9/28/2018

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

ensure that the necessary data are available for conducting

barrier analyses related to EEO.

5/15/2019 5/15/2019

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

additional data tools such as: FEVS, NASA Human Capital

Management Workforce Analysis Business Intelligence

Tools, climate surveys, pulse surveys, and potential new

9/30/2020
38

database systems, to enhance our ability to analyze 

programs and practices at more granular levels. 

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

complaints, grievances, surveys, exit interviews, and reports

for any indicators of barriers regarding employment of

women and AAPI as physical scientists.

9/30/2021

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

Physical Scientist positions in FY 2020.

4/1/2021

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

analysis of women and AAPI physical scientists.

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.)

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.)

6/20/2022 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.)

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.)

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

FY 2020 Progress: NASA developed a formal barrier analysis plan and examined participation trends by 

race/ethnicity and gender in Physical Science positions. 

Modifications to Objective: Modified completion data for steps 4 and 5 and added steps 6 through 11, 

based on the formal barrier analysis plan. 
39

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

In FY 2020, IWD account for 21.6 percent of employees GS-1 to GS-10 and 11.4 percent of 

employees GS-11 to SES. NASA’s participation rate for IWD has increased over the past three 

years. 

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

In FY 2020, IWTD account for 5.8 percent of employees GS-1 to GS-10 and 2.5 percent of 

employees GS-11 to SES.

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

recruiters.

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

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

and all-hands meetings for supervisors. Data on employees with disabilities is regularly 

communicated to Center DPMs and their supervisors – with two trainings for Center DPMs and 

managers on MD-715 data requirements in FY 2020. NASA developed a workforce dashboard for 

easy access to current data and numerical goals for managers and supervisors. ODEO and OCHCO 

jointly sent a memo to the NASA workforce on August 27, 2020, explaining the purpose of and 

encouraging voluntary self-identification of employee disability status. As a result, the Agency had 

an increase of 88 self-identified employees with disabilities.
40

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 & 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 is also currently working with the Office of the 

Chief Information Officer (OCIO) to create public-facing 

webpages 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 a designated DPM who is 

responsible for processing RA requests. 

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 508 compliance end-user interest group on issues 

that arise, and the Agency DPM regularly 

communicates with OCIO on issues requiring 

technological solutions.
41

Disability Program Task

# of FTE Staff by 

Employment Status Responsible Official

Full (Name, Title, Office, Email)

Time

Part 

Time

Collateral 

Duty

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 ten NASA Centers have 

designated facilities engineers who are responsible for 

ensuring compliance at the operational level. In FY 

2020, ODEO met several times with the Facilities 

Engineering Division to communicate ABA compliance 

requirements and legal authorities.

Special Emphasis 

Program (SEP) for 

IWD/IWTD

10 NASA has DPMs at each of the ten Centers responsible 

for managing SEP activities. 

3. Has the agency provided disability program staff with sufficient training to carry out their

responsibilities during the reporting period? If yes, describe the training that disability program

staff have received. If no, describe the training planned for the upcoming year.

Yes X No 

In FY 2020, DPMs received training on MD-715 Part J reporting requirements, the new NASA 

disability toolkit, and managing mental health in the workplace. Center-level DPMs received 

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

hoc basis on a variety of topics, such as resources available through the OCIO technology 

accessibility team, Schedule A hiring through the Workforce Recruitment Program (WRP), 

Computer/Electronic Accommodations Program monthly updates, EEO and RA training

opportunities (particularly as related to COVID-19), 508 compliance access issues, and solutions, 

and services available through the Job Accommodation Network. 

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.
42

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.

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 leveraging disability employee resource groups and SEPs to encourage 

participation in job opportunities within the IWD population. 

Internally, ODEO and the Office of STEM Engagement (OSTEM) have coordinated to highlight 

interns with disabilities for National Disability Employment Awareness Month and other avenues 

to support interns with disabilities. This year, ODEO and OCHCO collaborated to produce 

recruitment resources reflective of diversity and held an information session on Schedule A hiring 

authorities supporting the Department of Labor’s WRP. Additionally, NASA is developing a publicfacing NASA Disability Resources webpage, which will contain information for NASA applicants with 

disabilities, including information on the Schedule A hiring process, disability-related materials and 

links, guidance for applicants with disabilities in the Federal hiring process, disability technology 

accessibility resources, and information on requesting an RA for the job interview process.

Specific examples of how the NASA enterprise identified job applicants with disabilities for FY 2020 

include: 

• Centers regularly share vacancy announcements with community partners; for example, this

year ARC shared vacancy announcements with Project Hired and the Department of

Rehabilitation. GRC used the U.S. Office of Personnel Management (OPM) Shared List of

People with Disabilities and the Ohio Means Jobs database to search for resumes of qualified

applicants with disabilities.

• NASA Centers regularly work with local colleges and universities in outreach. For example,

ARC partnered with San Jose State University and San Jose City College to conduct outreach

activities for veterans and IWD.

• JSC improved upon its Schedule A pilot program, which allows managers to request a

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

appointment who meets a staffing need in their organization. The program also encourages

managers recruit in a variety of ways (e.g., vocational centers, job fairs, etc.). The program

resulted in 12 Schedule A hires at JSC in FY 2020.
43

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). The number 

of NASA Schedule A hires has increased over a three-year period from 8 in FY 2017 to 74 in FY 

2020. 

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

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

EEO staff who conduct barrier and workforce data analysis. Additionally, ODEO provided training 

to DPMs and OCHCO hiring officials on Schedule A hiring through the WRP. 

NASA Centers provide regular training sessions for hiring officials, particularly for new managers 

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

consultation with their ODEO representatives and at various leadership meetings, Mission Support 

Future Architecture Program organization meetings, directorate staff meetings, and routine 

strategic recruitment discussions. While some Centers have conducted virtual training for hiring 

officials this year, others are planning to resume training next year, due to the pandemic.

NASA contracted with Cornell University to provide a Just-in-Time Disability Toolkit for Managers. 

The Toolkit contains quick tips, print-and-go checklists, and other relevant resources to help 

managers lead a disability-inclusive workforce, including hiring IWD. 
44

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 2020, 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 Department of Veterans Affairs. 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: American Job Centers, the 

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

Department of Labor WRP, and Employment Network Service providers. NASA engages with a 

number of other professional organizations for individuals with disabilities via social media, as well. 

NASA Centers also establish and maintain contacts with organizations that assist IWD and IWTD in 

securing and maintaining employment. For example, at GSFC, the DPM and the Center’s Equal 

Accessibility Advisory Committee have established a partnership with OSTEM to create a database 

that captures contacts from colleges and universities in order to forward job announcements to 

IWD and IWTD. 

C. Progression Towards Goals (Recruitment and Hiring)

1. Using the goals of 12% for IWD and 2% for IWTD as the benchmarks, do triggers exist for IWD or

IWTD among the new hires in the permanent workforce? If yes, describe the triggers below.

a. New Hires for Permanent Workforce (IWD) Yes No X

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

NASA meets or exceeds the goals for new hires (16 percent of all new hires were IWDs; 3 percent of 

all new hires were IWTDs). 

2. Using the qualified applicant pool as the benchmark, do triggers exist for IWD/IWTD among the

new hires for any of the MCOs? If yes, describe the triggers below.

a. New Hires for MCO (IWD) Yes X No 

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

Triggers exist for 3 of the 10 NASA MCOs (down from 7 of 10 in FY 2019) for IWD – Contracting;

General Physical Science, and Astronomy and Space Science. In particular, IWD accounted for 6.1 

percent of external qualified applicants for Contracting positions but only 2.4 percent of external 

selections. No IWD were hired for General Physical Science and Astronomy and Space Science

positions, although they accounted for 2.2 and 2.1 percent of qualified applicants, respectively. For 

IWTD, triggers exist for one NASA MCOs – Contracting; IWTD accounted for 2.5 percent of external 

qualified applicants but none were hired in FY 2020. (See Table J1.)
45

Table J1. New Hires for Mission Critical Occupations

Mission Critical Occupations Totals IWD IWTD

0301/MISCELLANEOUS ADMIN & 

PROGRAM MANAGEMENT

Qualified 2944 5.5% 3.3%

Hired 27 3.7% 3.7%

0343/MANAGEMENT AND PROGRAM 

ANALYSIS

Qualified 3540 5.8% 2.8%

Hired 27 11.1% 3.7%

0801/GENERAL ENGINEERING Qualified 8693 3.3% 1.6%

Hired 169 1.8% 0.0%

0850/ELECTRICAL ENGINEERING Qualified 448 1.3% 0.4%

Hired 14 0.0% 0.0%

0854/COMPUTER ENGINEERING Qualified 1288 3.9% 2.6%

Hired 41 7.3% 4.9%

0855/ELECTRONICS ENGINEERING Qualified 1314 2.9% 1.6%

Hired 54 1.9% 1.9%

0861/AEROSPACE ENGINEERING Qualified 11181 2.3% 0.9%

Hired 241 1.7% 0.4%

1102/CONTRACTING Qualified 1863 6.1% 2.5%

Hired 42 2.4% 0.0%

1301/GENERAL PHYSICAL SCIENCE Qualified 1117 2.2% 0.0%

Hired 24 0.0% 0.0%

1330/ASTRONOMY AND SPACE 

SCIENCE

Qualified 373 2.1% 0.0%

Hired 14 0.0% 0.0%

 Source: NASA MD-715 Table B6, derived from NASA STARS data as of 9/30/2020.

 Triggers highlighted in yellow. 

3. Using the relevant applicant pool as the benchmark, do triggers exist for IWD/IWTD among the

qualified internal applicants for any of the MCOs? If yes, describe the triggers below.

a. Qualified Applicants for MCO (IWD) Yes No X

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

There are no triggers among qualified internal applicants. (See Table J2.)

4. Using the qualified applicant pool as the benchmark, do triggers exist for IWD/IWTD among

employees promoted to any of the MCOs? If yes, describe the triggers below.

a. Promotions for MCO (IWD) Yes X No 

b. Promotions for MCO (IWTD) Yes X No 

Triggers exist for IWD in internal promotions in four mission critical occupations: Electrical and

Aerospace Engineering, Miscellaneous Administration and Program Management, and

Management and Program Analysis. For IWTD, triggers exist for Astronomy and Space Science and 

Miscellaneous Administration and Program Management (compared to 6 job series in FY 2019). In 

particular, while IWD and IWTD accounted for 22.0 and 16.7 percent, respectively, on those 

qualified for promotions in Astronomy and Space Science positions, no IWD or IWTD were selected 

(See Table J2.)
46

Table J2. Internal Competitive Promotions for Mission Critical Occupations

Mission Critical Occupations Totals IWD IWTD

0301/MISCELLANEOUS ADMIN & 

PROGRAM MANAGEMENT

Relevant Applicant Pool 5.3% 1.4%

Internal Qualified Applicants 471 18.1% 3.0%

Internal Selections 91 9.9% 1.1%

0343/MANAGEMENT AND 

PROGRAM ANALYSIS

Relevant Applicant Pool 5.5% 1.7%

Internal Qualified Applicants 571 16.1% 2.8%

Internal Selections 92 12.0% 3.3%

0801/GENERAL ENGINEERING

Relevant Applicant Pool 4.8% 1.3%

Internal Qualified Applicants 3220 8.0% 1.8%

Internal Selections 293 7.2% 1.0%

0850/ELECTRICAL ENGINEERING

Relevant Applicant Pool 3.2% 1.6%

Internal Qualified Applicants 51 5.9% 0.0%

Internal Selections 15 0.0% 0.0%

0854/COMPUTER ENGINEERING

Relevant Applicant Pool 4.8% 2.1%

Internal Qualified Applicants 138 4.3% 2.2%

Internal Selections 38 2.6% 2.6%

0855/ELECTRONICS ENGINEERING

Relevant Applicant Pool 3.8% 1.5%

Internal Qualified Applicants 182 4.9% 1.6%

Internal Selections 68 4.4% 1.5%

0861/AEROSPACE ENGINEERING

Relevant Applicant Pool 4.2% 1.1%

Internal Qualified Applicants 2804 8.5% 1.4%

Internal Selections 345 5.8% 2.3%

1102/CONTRACTING

Relevant Applicant Pool 5.6% 2.0%

Internal Qualified Applicants 180 9.4% 4.4%

Internal Selections 39 10.3% 5.1%

1301/GENERAL PHYSICAL SCIENCE

Relevant Applicant Pool 3.2% 1.6%

Internal Qualified Applicants 111 5.4% 1.8%

Internal Selections 24 4.2% 0.0%

1330/ASTRONOMY AND SPACE 

SCIENCE

Relevant Applicant Pool 4.5% 3.2%

Internal Qualified Applicants 18 22.2% 16.7%

Internal Selections 6 0.0% 0.0%

 Source: NASA MD-715 Table B6, derived from NASA STARS data as of 9/30/2020. Triggers highlighted in yellow. 
47

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.

NASA’s EEO and OCHCO communities have developed multiple strategies to track and monitor the 

professional development and advancement of IWD and IWTD. First, NASA reviews participation 

data for this population in key training and development opportunities across the Agency. Second, 

NASA monitors participation data for this population by grade level and occupational category and 

develops corrective action plans when triggers are identified. Third, NASA uses assistive technology 

to ensure professional development opportunities are made available to IWD and IWTD. NASA 

currently is developing a webpage to ensure that these assistive technologies are communicated in 

an organized, all-inclusive manner. Additionally, the Agency improved inclusivity within its training 

management system by adding a statement regarding the provision of RA to all training approval 

notifications to the NASA workforce.

B. Career Development Opportunities

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

NASA has not offered formal, Agency-wide leadership development programs in recent years. In 

FY 2020, NASA implemented the Talent Marketplace platform that ensures developmental 

opportunities are widely available to all NASA employees, including IWD and IWTD. Talent 

Marketplace provides information on the availability of opportunities such as job announcements, 

details, and rotational assignments. 

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 22,595 1,864 5.7% 6.0% -- --

Detail Programs 326 122 6.1% 6.6% 2.8% 2.5%

Fellowship Programs

Data not available or programs not conducted in FY 2020. 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.
48

3. Do triggers exist for IWD among the applicants and/or selectees for any of the career

development programs? (The benchmarks are the relevant applicant pool for the applicants and

the applicant pool for selectees.) If yes, describe the trigger(s) in the text box.

a. Applicants (IWD) Yes No X 

b. Selections (IWD) Yes No X 

Data available only for internship and detail programs. ODEO will work with OCHCO and OSTEM to

develop processes for collecting and monitoring data on IWD participation in development 

programs.

4. Do triggers exist for IWTD among the applicants and/or selectees for any of the career

development programs identified? (The benchmarks are the relevant applicant pool for applicants

and the applicant pool for selectees.) If yes, describe the trigger(s) in the text box.

a. Applicants (IWTD) Yes No X 

b. Selections (IWTD) Yes No X

Data available only for detail programs. ODEO will work with OCHCO and OSTEM to develop 

processes for collecting and monitoring data on IWTD participation in development programs. 

C. Awards

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving IWD/IWTD

for any level of the time-off awards, bonuses, or other incentives? If yes, describe the trigger(s).

a. Awards, Bonuses, & Incentives (IWD) Yes X No 

b. Awards, Bonuses, & Incentives (IWTD) Yes No X

In FY 2020, the inclusion rates for IWD (at all grade levels) was 9.9 percent. However, IWD 

accounted for 7.7 percent of those receiving cash awards of $3,000-$3,999 and 6.3 percent of 

those receiving case awards of $4,000-$4,999. NASA will continue to monitor the IWD and IWTD 

inclusion rates for awards. (See Table J3.)

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 No X

There were no triggers regarding quality step increases. (See Table J3.)

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 triggers regarding other types of performance awards. (See Table J3.)
49

Table J3. Employee Awards and Recognition

IWD IWTD

Inclusion Rates (all Grades) 9.9% 2.6%

Type of Award:

Time Off 

Awards

1-10 hours 11.4% 1.9%

11-20 hours 11.2% 2.5%

21-30 hours 11.0% 2.2%

31-40 hours 12.5% 3.0%

41 or more hours 11.5% 1.3%

Cash 

Awards

$500 and Under 13.5% 2.9%

$501 - 999 12.8% 2.8%

$1000 - $1999 11.0% 1.9%

$2000 - $2999 9.4% 1.8%

$3000 - $3999 7.7% 1.3%

$4000 - $4999 6.3% 1.1%

$5000 or More 8.8% 1.8%

Other 

Awards

Performance Award 8.4% 2.6%

Quality Step Increase 9.1% 1.8%

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

 (DOI); data as of 9/30/2020. 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 X No 

d. Grade GS-13

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes No X

For GS-14 positions, IWD account for 13.0 percent of internal qualified applicants but only 8.7 

percent of selections. NASA will continue to monitor the IWD inclusion rate for promotions. 

(See Table J4.) 

2. Does your agency have a trigger involving IWTD among the qualified internal applicants and/or

selectees for promotions to the senior grade levels? (The benchmarks are the relevant applicant

pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS

pay plans, please use the approximate senior grade levels. If yes, describe the trigger(s).
50

a. SES

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

b. Grade GS-15

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

c. Grade GS-14

i. Qualified Internal Applicants (IWTD) Yes No X

ii. Internal Selections (IWTD) Yes No X

d. Grade GS-13

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X

There are no triggers for IWTD. (See Table J4.)

Table J4. Internal Competitive Promotions for Senior Level Positions

Grade Levels Totals IWD IWTD

Promotions to GS-13

Relevant Applicant Pool 5.3% 1.9%

Internal Qualified Applicants 970 15.4% 5.4%

Internal Selections 187 15.0% 3.7%

Promotions to GS-14

Relevant Applicant Pool 5.5% 1.5%

Internal Qualified Applicants 3490 13.0% 2.4%

Internal Selections 549 8.7% 1.5%

Promotions to GS-15

Relevant Applicant Pool 4.3% 1.0%

Internal Qualified Applicants 4399 7.0% 1.3%

Internal Selections 505 5.3% 1.6%

Promotions to SES

Relevant Applicant Pool 2.8% 1.1%

Internal Qualified Applicants 300 5.7% 0.7%

Internal Selections 13 7.7% 0.0%

 Source: NASA MD-715 Table B7, derived from NASA STARS data as of 9/30/2020. Triggers highlighted in yellow.

3. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving

IWD among the new hires to the senior grade levels? For non-GS pay plans, please use the

approximate senior grade levels. If yes, describe the trigger(s) in the text box.

a. New Hires to SES (IWD) Yes X No 

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

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

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

IWD accounted for 1.7 percent, 0.8 percent, and 0.0 percent of those hired at the GS-13, GS-15, 

and SES levels. However, IWD accounted for 4.1 percent of qualified applicants for both GS-13 

and GS-15 positions and 5.3 percent of qualified applicants for SES positions. NASA will continue 

to monitor the IWD inclusion rate for new hires. (See Table J5.)
51

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving

IWTD among the new hires to the senior grade levels? For non-GS pay plans, please use the

approximate senior grade levels. If yes, describe the trigger(s) in the text box.

a. New Hires to SES (IWTD) Yes X No

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

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

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

NASA hired no IWTD at the SES and GS-15 levels, although IWTD accounted for 3.4 percent of 

qualified applicants for SES and 2.1 percent of qualified applicants for GS-15 positions. NASA will 

continue to monitor the IWTD inclusion rate for new hires. (See Table J5.)

Table J5. New Hires for Senior Level Positions

Senior Grades Totals IWD IWTD

GS-13 Positions Qualified 2,944 4.1% 2.0%

Hired 27 1.7% 1.0%

GS-14 Positions Qualified 3,540 4.2% 2.0%

Hired 27 5.2% 0.5%

GS-15 Positions Qualified 8,693 4.1% 2.1%

Hired 169 0.8% 0.0%

SES Positions Qualified 448 5.3% 3.4%

Hired 14 0.0% 0.0%

Source: NASA MD-715 Table B7, derived from NASA STARS data as of 

9/30/2020. Triggers highlighted in yellow. 

5. Does your agency have a trigger involving IWD among the qualified internal applicants and/or

selectees for promotions to supervisory positions? (The appropriate benchmarks are the relevant

applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If

yes, describe the trigger(s) in the text box.

a. Executives

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes No X 

b. Managers

i. Qualified Internal Applicants (IWD) Yes No data not available 

ii. Internal Selections (IWD) Yes No data not available 

c. Supervisors

i. Qualified Internal Applicants (IWD) Yes No X 

ii. Internal Selections (IWD) Yes No X 

There were no triggers among qualified applicants or internal selections for internal competitive 

promotions to SES and supervisory positions for IWD. (Note that NASA does not track applicants for 

managerial positions – this information appears only in the text of the job announcement and is not 

included in the applicant flow data.) (See Table J6.)
52

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 X 

ii. Internal Selections (IWTD) Yes No X 

b. Managers

i. Qualified Internal Applicants (IWTD) Yes No data not available

ii. Internal Selections (IWTD) Yes No data not available

c. Supervisors

i. Qualified Internal Applicants (IWTD) Yes No X 

ii. Internal Selections (IWTD) Yes No X 

There were no triggers among qualified applicants or internal selections for internal competitive 

promotions to SES and supervisory positions for IWTD. (Note that NASA does not track applicants 

for managerial positions – this information appears only in the text of the job announcement and is 

not included in the applicant flow data.) (See Table J6.)

Table J6. Internal Competitive Promotions for Executive and Supervisory Promotions

Grade Levels Totals IWD IWTD

Promotions to 

Executive Positions

Relevant Applicant Pool 2.8% 1.1%

Internal Qualified Applicants 300 5.7% 0.7%

Internal Selections 13 7.7% 0.0%

Promotions to 

Supervisory Positions

Relevant Applicant Pool 6.8% 1.2%

Internal Qualified Applicants 2186 7.7% 1.3%

Internal Selections 243 6.6% 1.2%

Source: NASA MD-715 Tables B7 and B8, derived from NASA STARS data as of 9/30/2020.

7. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving IWD

among selectees for new hires to supervisory positions? If yes, describe the trigger(s) in text box.

a. New Hires for Executives (IWD) Yes X No 

b. New Hires for Managers (IWD) Yes No data not available

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

NASA hired no IWD for SES positions, although IWD accounted for 5.3 percent of the qualified 

applicants. (NASA does not track applicants for managerial positions – this information appears only 

in the text of the job announcement and is not included in the applicant flow data.) (See Table J7.)

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).

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

b. New Hires for Managers (IWTD) Yes No data not available 

c. New Hires for Supervisors (IWTD) Yes X No 
53

NASA hired no IWTD for SES or supervisory positions, although IWTD accounted for 3.4 and 2.6 

percent of qualified applicants, respectively. (NASA does not track applicants for managerial 

positions – this information appears only in the text of the job announcement and is not 

recorded/measured in the applicant flow data.) (See Table J7.)

Table J7. New Hires for Executive and Supervisory Positions

Totals IWD IWTD

Executive Positions Qualified 448 5.3% 3.4%

Hired 14 0.0% 0.0%

Supervisory 

Positions

Qualified 5,874 5.1% 2.6%

Hired 58 3.4% 0.0%

 Source: NASA MD-715 Tables B7 and B8, derived from NASA STARS; data as of 

 9/30/2020. Triggers highlighted in yellow. 

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 X No N/A

In FY 2020, NASA converted 100 percent of the 20 Schedule A employees who were eligible for 

conversion. 

2. Using the inclusion rate as the benchmark, did the percentage of IWD among voluntary and

involuntary separations exceed that of persons without disabilities? If yes, describe trigger below.

a. Voluntary Separations (IWD) Yes X No 

b. Involuntary Separations (IWD) Yes X No

IWD accounted for 12.9 percent of voluntary separations (23 of 178) and 32.3 percent of involuntary 

separations (10 of 31), both of which are higher than the inclusion rate for IWD of 9.9 percent. NASA 

will continue to monitor the IWD inclusion rate for separations. (See Table J8.)

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 X No
54

IWTD accounted for 9.7 percent of the involuntary separations (3 of 31), which is higher than the 

IWTD inclusion rate of 2.6 percent. NASA will continue to monitor the IWD inclusion rate for 

separations. (See Table J8.)

4. If a trigger exists involving the separation rate of IWD and/or IWTD, please explain why they left

the agency using exit interview results and other data sources.

NASA conducts exit interviews but with limited questions regarding issues related to disability. ODEO 

has submitted additional D&I-related questions to OCHCO to improve exit interview questions to 

better indicate if triggers exist.

Table J8. Separations by Disability Status

Separation Type Total No Disability Unknown IWD IWTD

Removal 

(Involuntary)

# 31 17 4 10 3 

% 100% 54.8% 12.9% 32.3% 9.7%

Resignation 

(Voluntary)

# 178 138 17 23 3

% 100% 77.5% 9.5% 12.9% 1.7%

Retirement

# 566 479 15 72 16

% 100% 84.6% 2.6% 12.7% 2.8%

Other 

Separations

# 105 81 10 14 2 

% 100% 77.1% 9.5% 13.3% 1.9%

Total Separations

# 880 715 46 119 24

% 100% 81.2% 5.2% 13.5% 2.7%

Source: NASA MD-715 Table B-1 (Losses), prepared by DOI; data as of 9/30/2020. 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.

Web site: 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.

Web site: 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.
55

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 Agency-level DPM has held several information sessions with the Facilities Engineering 

Division to provide discuss 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. 

ODEO is working with OCIO to ensure a smoother transition to new technologies and to proactively 

avoid accessibility issues, with several notable successes this year. For example, ODEO and OCIO 

jointly developed a webpage of all accessibility technology options across NASA. This page will be 

available to employees and managers, as well as to applicants and the public. At a webinar on the 

Americans with Disabilities Act webinar, options for access was provided by both an American Sign 

Language interpreter and closed captioning, a practice NASA plans to use more often in the future. 

The NASA 508 Program Managers Coordination group is developing a 508 accessibility scanning tool, 

to be deployed Agency-wide. This tool will be a standardized process to scan NASA Web sites to 

identify and correct compliance issues. NASA will make certain aspects of the tool available in FY

2021, with full utilization across NASA by FY 2022. The 508 Program Managers Coordination group 

also is making changes in NASA purchasing card system to ensure it is compliance with Section 508. 

NASA established an IT procurement office to manage 508 compliance throughout the acquisition life

cycle. The group also is developing a new Web site to enhance their NASA-wide communication with 

end-users and others in the community of practice.

At the Center-level, DPMs manage all RA requests, including issues arising in the area of technology 

accessibility. For example, the KSC DPM procured eight iPads for deaf or hard of hearing employees

and sign language interpreters to improve effectiveness in the telework environment (as opposed to 

having to use small screen iPhones) during the pandemic. GSFC has an Assistive Technology 

Demonstration Lab available to employees.

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.)

Overall, NASA RA processing averages 30 days or less. (See Table J9 for average processing time by 

NASA Center.) 
56

Table J9. Average Processing Times for RA Requests 

Center Average No. 

of Days

Ames Research Center 17

Armstrong Flight Research Center 7 

Glenn Research Center 19

Goddard Space Flight Center 30

Headquarters 13

Johnson Space Center 15

Kennedy Space Center 26

Langley Research Center n/a

Marshall Space Flight Center 45

NASA Shared Services Center 9 

Stennis Space Center 20

Source: NASA RAMS, data for FY 2020. There were no RA 

requests at Langley Research Center.

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency’s

reasonable accommodation program. Examples of an effective program include timely processing

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

supervisors, and monitoring accommodation requests for trends.

In FY 2020, NASA trained more than 1,000 employees on their roles and responsibilities regarding 

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

interns. In addition, all ten NASA Centers have designated DPMs to process RA requests and to 

provide technical assistance to employees, interns, managers, and supervisors. 

NASA is currently developing a new Reasonable Accommodation Management System (RAMS), by 

which the Agency expects to increase timeliness and efficiency in processing requests. The new 

RAMS tool also will allow Agency leadership to better monitor trends in RA processing. 

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 awarded an Agency-wide BPA for 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 will monitor requests for trends and act as the Contracting Officer’s 

Representative to the PAS BPA to monitor Contractor timeliness and quality. NASA plans to provide 

training for managers, supervisors, and PAS technical monitors in FY 2021. Further, ODEO is leading 

an Agency-level EEO functional review of Centers, to include educating staff on the PAS process. 
57

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 X No N/A 

2. During the last fiscal year, did any complaints alleging harassment based on disability status result

in a finding of discrimination or a settlement agreement?

Yes No X N/A 

3. If the agency had one or more findings of discrimination alleging harassment based on disability

status during the last fiscal year, please describe the corrective measures taken by the agency.

N/A

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 X No 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 X No 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.

The identified management officials attended the required eight hours training on the 

Rehabilitation Act within 90 days of the date of the EEOC decision. 

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.
58

MD-715

PART J Affirmative Action Plan for Individuals with Disabilities

Triggers

The preceding analyses revealed several triggers:

• New Hires in MCOs: Triggers exist for IWD new hires in Contracting, General

Physical Science, and Astronomy and Space Science. There also is a trigger for

hiring of IWTD in Contracting positions (see Part J, section III, C).

• Internal Competitive Promotions in MCOs: Triggers exist for IWD in internal

competitive promotions in four MCOs – Electrical Engineering, Aerospace

Engineering, Miscellaneous Administration and Program Management, and

Management and Program Analysis. For IWTD triggers exist for promotions to

Astronomy and Space Science and Miscellaneous Administration and Program

Management positions (see Part J, section III, C).

• Senior and Supervisory Positions: Triggers exist for IWD new hires to GS-13,

GS-15, and SES positions and for IWTD in GS-15, SES, and supervisory positions

(see Part J, section IV, D).

• Performance Awards: The only triggers for awards were for IWD receiving

cash awards of $3,000-$3,999 and $4,000-$4,999 (see Part J, section IV, C).

• Separations: There are triggers for involuntary separations for both IWD and

IWTD and for voluntary separations for IWD (see Part J, section V, A).

NASA will continue to monitor these triggers and initiate appropriate action and 

activities if trends develop. 

Objective(s)

Improve the monitoring of IWD and IWTD employment at NASA through the following:

(1) obtain additional data and conduct further analyses to determine causes of

differences observed in the data categories described above and the causes for such 

differences; (2) develop improved systems for collecting demographic data pertaining

to career development programs; and (3) revise exit surveys to obtain additional data 

related to individuals with disabilities.

Responsible Official(s) Performance Standards Address the 

Plan? (Yes or No)

Director, Diversity and Data/Analytics Division, ODEO No. EEO matters in general are 

addressed. 

Target Date Planned Activities

Sufficient 

Staffing & 

Funding

Modified 

Date

Completion 

Date

9/28/2018 NASA ODEO will partner with OCHCO to 

strengthen data analytics capabilities to enable 

ODEO to conduct in-depth barrier analyses.

Yes 9/28/2018

9/28/2018 NASA will update and improve its standard data 

reports to ensure that the necessary data are 

available for conducting barrier analyses related 

to the disability program.

Yes 3/15/2019 3/15/2019
59

9/29/2019 Place information on the NASA Web site 

regarding the ABA and how to file a related 

complaint. 

Yes 6/30/2020 4/7/2020

9/30/2020 Leverage current NASA systems and develop 

additional data tools, including: the FEVS, NASA 

Human Capital Management Workforce Analysis 

Business Intelligence Tools, climate surveys, 

pulse surveys, and potential new database 

systems. These additional tools will enhance 

ODEO’s ability to analyze programs and 

practices at more granular levels.

Yes 9/30/2021

12/31/2020 Award a BPA for PAS to ensure efficiency and 

consistency across the Agency. 

Yes 9/28/2020

4/30/2021 Develop a Disability Resources webpage to 

provide employees and applicants with 

information on the application process, 

Schedule A hiring, requesting an RA in the 

application process, and the availability of 

resources to assist in creating a more accessible 

and inclusive workplace.

Yes

9/30/2021 Develop a new RAMS to increase RA efficiencies 

and permit greater insight into RA trends for 

leadership.

Yes

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

9/30/2021 Change the purchasing card system to be in line 

with 508 compliance. 

Yes

9/30/2022 Develop and deploy a 508 accessibility scanning 

tool to standardize the process of scanning for 

compliance issues. 

Yes

Fiscal Year Accomplishments

FY 2019 NASA made significant progress in updating data systems and automating data reports. 

ODEO and OCHCO continue to work together to expand data access to HR systems and 

ODEO will ensure training on these systems for EEO staff in FY 2020.

FY 2020 On April 7, 2020, NASA placed a statement on the NASA Web site regarding the ABA. 

ODEO also provided information and training to the Facilities Engineering Division 

regarding ABA requirements and legal bases. 

In FY 2020, NASA EEO and D&I Directors were realigned to report directly to the 

Agency-level ODEO, rather than to Center Directors. As part of this process, ODEO 

surveyed partners and stakeholders to gain a greater understanding of overlapping 

efforts in areas such as Reasonable Accommodation. To this end: (1) ODEO is heading 

an Agency-level functional review of Center EEO offices, to include an evaluation of 
60

Center Disability Program processes by the Agency DPM; (2) ODEO is developing a new

Agency-wide RAMS tool to track RA requests, with the expectation of installing the 

system in FY 2021; and (3) NASA awarded a PAS BPA for Agency-wide use, to increase 

consistency and efficiencies for PAS requests.

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

planned activities.

All planned activities are being conducted according to the anticipated completion dates, despite 

challenges presented by the pandemic.

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

activities toward eliminating the barrier(s).

Enhanced relationships between ODEO and OCHCO personnel have led to greater collaboration 

and a better understanding of data systems and data needs; enhancement of OCHCO exit 

interviews to include more diversity and disability-related questions is forthcoming. 

Collaboration between ODEO and OCIO has led to optimal solutions on several disability 

technological accessibility issues.

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
61

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

Table 1 reveals the following triggers (highlighted in yellow) for some groups at NASA, when compared 

to their total representation: 

• Asian Americans and Pacific Islanders (AAPI) make up 8.4 percent of the NASA workforce, yet

account for only 4.3 percent and 4.5 percent of those in NASA SES and SL positions, respectively.

In addition, AAPI account for 6.0 percent of those in Professional Administrative (PA) positions.

• Blacks and African Americans account for 11.1 percent of the NASA workforce but occupy a

lower percentage of SL (2.2 percent), ST (2.4 percent), Science and Engineering (S&E) (6.2

percent) and student (6.2 percent) employees.

• Hispanics and Latinos account for 8.4 percent of the NASA workforce, yet are 5.3 percent of

SES, 4.5 percent of ST, and 3.5 percent of SL employees.

• American Indians and Alaska Natives (AIAN) represent 1.0 percent of the NASA workforce,

similar to their representation in the NCLF (1.1 percent). Their small number (172 AIAN

individuals are employed by NASA in permanent positions), renders comparisons of smaller

groups to their total employment less meaningful.

• Women account 34.2 percent of the NASA workforce, yet comprise only 18.0 percent of those

in SL positions and 21.2 percent of ST positions. In addition, women account for 24.0 percent of

those in S&E positions and 31.9 percent of those in the SES.

• White Employees and Men account for lower percentages of PA and student employees than

their representation in the NASA workforce. Whites account for 70.6 percent of NASA

employees and are 61.1 and 64.5 percent of PA and student employees, respectively. Men are

65.8 percent of the NASA workforce and account for 43.5 percent and 62.7 percent of PA

employees and students.

4 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. EEOC, Instructions to Federal Agencies for EEO MD-715, “Section II: Barrier Identification and Elimination,” accessed 

at <https://www.eeoc.gov/federal/directives/715instruct/>. 5 EEOC identifies the appropriate benchmarks for comparison. The total agency workforce should be compared to the National 

Civilian Labor Force (NCLF), which includes all non-institutionalized civilians age 16 and over who are either employed or 

unemployed. U.S. Census Bureau, “Labor Force: Glossary,” accessed at <https://www.census.gov/topics/employment/laborforce/about/glossary.html>. Subgroups of the agency workforce (e.g., those in senior grades) should be compared to overall 

agency workforce. 

5

4
62

Table 1. NASA Employees (Selected Groups) by Race, Ethnicity, and Gender: FY 2020

NASA Permanent Workforce Total 

Number AAPI Black Hispanic MultiRacial AIAN White Male Female

All NASA Employees 17,458 8.4% 11.1% 8.4% 0.4% 1.0% 70.6% 65.8% 34.2% 

SES Employees 414 4.3% 11.4% 5.3% 0.5% 0.5% 78.0% 68.1% 31.9% 

GS Employees 16,869 8.5% 11.2% 8.5% 0.4% 1.0% 70.3% 65.6% 34.4% 

SL Employees 89 4.5% 2.2% 4.5% 0.0% 2.2% 86.5% 82.0% 18.0%

ST Employees 85 10.6% 2.4% 3.5% 0.0% 0.0% 83.5% 78.8% 21.2% 

Science & Engineering 11,338 9.7% 6.2% 8.0% 0.2% 0.8% 75.0% 76.0% 24.0%

Professional Administrative 5,182 6.0% 21.7% 8.9% 0.8% 1.4% 61.1% 43.5% 56.5% 

Student Employees 664 14.5% 6.2% 13.6% 0.6% 0.6% 64.5% 62.7% 37.0% 

Comparison Populations:

Federal STEM Workforce 333,842 9.3% 10.0% 6.2% 1.9% 0.8% 69.2% 70.1% 29.9% 

National Civilian Labor 

Force 4.0% 12.0% 10.0% 0.5% 1.1% 72.4% 51.9% 48.1% 

Notes: The table does not include Individuals who did not identify their race/ethnicity; thus, not all groups total to 100 

percent. Per EEOC instructions, this table includes only permanent employees. Triggers highlighted in yellow. 

Sources: Workforce Information Cubes for NASA (WICN) (data as of 10/1/2020); NASA MD-715 Table A-1, prepared for 

NASA by the U.S. Department of the Interior; OPM, FedScope, Federal Human Resources Data, Diversity Cube and 

Employment Cube (U.S.-based employees only) (data as of 9/30/2020), accessed at <https://www.fedscope.opm.gov>; 

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-eeomd-715-0>.

As shown in Table 1, the composition of the NASA workforce by race and ethnicity is similar to the 

NCLF, with three exceptions: NASA employs a higher percentage of AAPI and a lower percentage of 

both Hispanics and women than in the NCLF. (AAPI account for 8.4 percent of the NASA workforce, 

compared to 4.1 percent in the NCLF; Hispanics are 8.4 percent of the NASA workforce and 10.0 percent 

of the NCLF; and women are 34.2 percent of the NASA workforce and 48.2 percent of the NCLF.) 

However, because the NASA workforce is highly specialized (two-thirds of NASA employees are in S&E 

occupations), NASA also uses the Federal STEM workforce as a comparison. When these two 

populations are compared, NASA employees are similar to the Federal STEM workforce, with regard to 

race, ethnicity, and gender. However, the percentage of Blacks in the NASA S&E workforce (6.2 

percent) is lower than in the Federal STEM workforce (10.0 percent).

Occupational Categories, by Race and Ethnicity

Because the NASA workforce is highly specialized (two-thirds of NASA employees are in S&E 

occupations), it is useful to compare employees in specific occupations to the individuals in the civilian 

labor in similar occupations (the RCLF). In addition, data on recent college graduates provides insight 

into the pipeline for similar jobs. A current workforce ratio below the RCLF for any group is another 

trigger. Tables 2 and 3 reveal the following:

6 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 

6
63

• In mission critical engineering positions, Blacks, Hispanics, and Women are employed at higher

percentages at NASA than in the RCLF. However, AAPI are employed in lower percentages at

NASA than in the RCLF in Aerospace and General Engineering positions. (See Table 2.)

• Among Physical Scientists, Whites are well-represented at NASA compared to Physical Scientists

in the RCLF, and Blacks and Hispanics are employed in similar proportions to those in the RCLF.

However, Women account for 32.1 percent of Physical Scientists at NASA and 39.1 percent of

those in the RCLF. (See Table 3.)

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

occupations, while Whites and Males are underrepresented in PA positions. (See Table 4.)

• Whites and Males are underrepresented in several NASA S&E occupations, compared to the

RCLF. However, because they account for the majority of employees in those occupations, NASA

will focus on other triggers first.

Table 2. NASA Mission Critical S&E Occupations by Race, Ethnicity, and Gender: FY 2020

AAPI Black Hispanic Multiracial AIAN White Male Female

Engineering Occupations:

0861 - Aerospace 

Engineer (n=4,407

NASA: 9.3% 5.9% 8.0% 0.3% 0.8% 75.8% 78.4% 21.6%

RCLF: 12.1% 4.2% 5.6% 0.5% 0.6% 77.0% 88.2% 11.8% 

0801 - General Engineer 

(n=3,202)

NASA: 6.4% 6.5% 7.8% 0.2% 1.1% 78.0% 71.9% 28.1%

RCLF: 11.1% 4.4% 4.8% 0.6% 0.6% 78.7% 88.3% 11.7%

0855 - Electronics 

Engineer (n=943)

NASA: 16.0% 6.3% 9.8% 0.1% 0.5% 67.2% 85.2% 14.8%

RCLF: 11.8% 5.3% 5.5% 0.4% 0.6% 76.4% 91.3% 8.7%

0854 - Computer 

Engineer (n=777)

NASA: 14.2% 10.2% 8.4% 0.1% 0.6% 66.4% 73.6% 26.4%

RCLF: 15.7% 7.4% 5.7% 0.7% 0.8% 69.8% 84.6% 15.4%

0850 - Electrical 

Engineer (n=335)

NASA: 12.2% 8.4% 11.6% 0.3% 0.6% 66.9% 84.5% 15.5%

RCLF: 11.8% 5.3% 5.5% 0.4% 0.6% 76.4% 91.3% 8.7%

Physical Science Occupations:

1301 - Physical Scientist 

(n=465) 

NASA: 12.6% 2.8% 5.8% 0.0% 0.2% 78.7% 67.6% 32.4%

RCLF: 15.0% 3.6% 4.3% 0.5% 0.6% 76.0% 60.9% 39.1% 

1330 - Space Scientist 

(n=330)

NASA: 7.3% 1.5% 6.1% 0.0% 0.0% 85.2% 69.4% 30.6% 

RCLF: 7.0% 2.3% 4.0% 0.6% 0.6% 85.5% 84.2% 15.8%

1310 - Physicist (n=111) NASA: 8.9% 7.1% 2.7% 0.0% 0.0% 81.3% 83.9% 16.1% 

RCLF: 7.0% 2.3% 4.0% 0.6% 0.6% 85.5% 84.1% 15.8%

Notes: 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 Personnel Data Warehouse data (data as of 10/1/2020); U.S. Census 

Bureau EEO Tabulation from the 2006-2010 American Community Survey (data set EEO-CIT02R). 

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/>.
64

Table 3. NASA Mission Critical and Other Professional Administrative Occupations by Race, 

Ethnicity, and Gender: FY 2020

AAPI Black Hispanic Multiracial AIAN White Male Female

0301 - General 

Administrative* (n=943)

NASA: 4.5% 18.7% 7.1% 0.9% 1.5% 67.4% 38.6% 61.4%

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

1102 - Contract 

Specialist* (n=730)

NASA: 5.1% 27.1% 10.6% 0.7% 0.7% 55.9% 40.3% 59.7%

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

0343 - Program Analyst* 

(n=680)

NASA: 6.6% 18.7% 11.2% 0.9% 1.6% 61.0% 35.4% 64.6%

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

2210 - Information 

Technology Specialist 

(n=543)

NASA: 6.8% 17.1% 7.2% 0.9% 1.5% 66.3% 60.6% 39.4%

RCLF: 6.8% 11.1% 7.6% 0.6% 0.8% 73.1% 70.4% 29.6%

0510 - Accountant

(n=291)

NASA: 12.4% 29.6% 8.9% 0.3% 1.0% 47.4% 30.2% 69.8%

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

0501 - Finance (n=289) NASA: 6.2% 23.9% 9.0% 0.0% 0.7% 60.2% 29.8% 70.2%

RCLF: 5.0% 12.3% 9.8% 0.5% 1.2% 71.1% 43.7% 56.3% 

0201 - Human Resources 

Specialist (n=268)

NASA: 7.3% 29.0% 9.2% 1.9% 1.2% 51.5% 27.1% 72.9%

RCLF: 4.3% 10.4% 9.5% 0.5% 0.7% 74.6% 39.7% 60.3%

Notes: 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. * = Occupations that have been identified as mission critical. Sources: WICN (data 

as of 10/1/2020); U.S. Census Bureau EEO Tabulation from the 2006-2010 American Community Survey (data set EEOCIT02R). 

Individuals with Disabilities

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

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

grades GS-10 and below, is slightly below the goal for IWD in grades GS-11 and above, and is just above 

the goal for the employment of IWTD in grades GS-11 and above. (See Table 4.)

Table 4. NASA Employees with Disabilities: FY 2018 – FY 2020

FY 2018 FY 2019 FY 2020 Federal Goal

GS-10 and Below:

 IWD 21.6% 23.9% 24.3% 12%

 IWTD 6.4% 7.3% 6.5% 2%

GS-11 and Above:

 IWD 9.5% 10.6% 11.9% 12%

 IWTD 2.4% 2.4% 2.6% 2%

Source: NASA Workforce Data from BOBJ; data as of the last pay period in FY 2020. NASA revised its calculations in September 

2020 to better conform with EEOC requirements, which requires agencies to report only on full-time permanent employees. 

Data on ITD 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)).
65

Federal Employee Viewpoint Survey (FEVS) Results

In FY 2019, NASA continued to improve its FEVS scores. Because of the global pandemic, OPM 

administered the FEVS at a later date than in previous years; thus, data for FY 2020 are not yet available. 

7

Figure 1. NASA New Inclusion Quotient Index and Employee Engagement Scores, FY 2018-19 

79%

New Inclusion Quotient Index: 78%

62%

90%

Supportive 89%

79%

81%

Open 81%

61%

80%

Empowered 79%

61%

78%

Cooperative 77%

59%

67%

Fair 66%

49%

0% 20% 40% 60% 80% 100%

NASA Total - 2019 NASA Total - 2018 Government-wide - 2019

83%

Engagement Index: 82%

68%

85%

Intrinsic Work Experience 84%

72%

88%

Supervisors 88%

76%

75%

Leaders Lead 73%

57%

0% 20% 40% 60% 80% 100%

NASA Total - 2019 NASA Total - 2018 Government-wide - 2019

Source: OPM, 2019 FEVS Results. Percentages represent the percentage of responses that were positive.

Government-wide, there were 615,395 respondents; there were 10,789 NASA respondents. 

7 The FEVS is a climate survey conducted by OPM. The New IQ is calculated by averaging a subset of 20 FEVS questions

measuring five factors: Empowered, Supportive, Cooperative, Open, and Fair. The Employee Engagement Index is calculated by 

averaging a subset of FEVS questions measuring three factors: Intrinsic Work Experience, Supervisors, and Leaders.
66

Table 5. 2019 FEVS Index Scores, by Demographic Group

Demographic Group

FEVS Index Measure

New Inclusion 

Quotient

Employee 

Engagement Index

Global 

Satisfaction Index

Government-Wide 62.1% 68.5% 64.9%

NASA Workforce 79.2% 83.0% 81.5% 

Male 80.8% 84.0% 82.4%

Female 78.3% 83.1% 81.9%

Gay, Lesbian, or Bisexual 74.1% 78.0% 75.2%

Transgender 55.7% 57.1% 53.2%

White 80.7% 84.2% 83.0%

Black 77.7% 82.4% 82.4%

Hispanic 79.1% 83.5% 81.6%

AAPI 80.8% 85.1% 81.1%

AIAN 68.6% 76.9% 69.5%

IWD 74.9% 78.8% 75.3%

Veteran 79.2% 82.5% 80.2%

Under 40 80.9% 85.3% 81.9%

Over 40 79.4% 83.0% 82.2%

Source: OPM, 2019 FEVS Results. Percentages represent the percentage of responses that were positive.

Figure 2. FEVS Questions Focused on EEO, D&I, and Compliance: FY 2015-19

100%

90% 86%87% 86% 86% 84% 83% 84% 85% 82%

78% 78%79%80% 81% 80%

80%

70% 72% 70% 67% 70%

59%

60%

50%

40%

30%

20%

10%

0%

17. I can disclose a 34. Policies and programs 38. Prohibited Personnel 45. My supervisor/team 55. Managers/

suspected violation of any promote diversity in the Practices (e.g., illegally leader is committed to a supervisors/team leaders

law, rule or regulation workplace (e.g., recruiting discriminating for or workforce representative work well with employees

without fear of reprisal. minorities and women, against any employee/ of all segments of society. of different backgrounds.

training in awareness of applicant, obstructing a

diversity issues, person's right to compete 2015

mentoring). for employment, knowingly 2017

violating veterans' 2019

preference) are not Government-wide, 2019

tolerated.

Source: OPM, 2019 FEVS Results. Percentages represent the percentage of responses that were positive.
67

APPENDIX B: PHYSICAL SCIENCE BARRIER ANALYSIS PLAN AND INITIAL FINDINGS

Barrier Analysis Overview

Purpose: NASA identified workforce triggers for Women and Asian Americans and Pacific Islanders 

(AAPI) within Physical Science occupations, when compared to the Relevant Civilian Labor Force 

(RCLF). 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). 

10

9

8

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.

8 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.

9 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. 10 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>.
68

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

AAPI

 Men 8.7% 8.2% 8.1% 5.1% 3.6% 5.1%

 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%

Black

 Men 1.5% 1.4% 7.2% 2.1% 0.9% 2.1%

 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 Women 0.0% 0.2% 0.0% 0.2% 0.0% 0.2%

 Men 0.0% 0.3% 0.0% 0.4% 0.0% 0.4%

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%

White

 Men 53.9% 48.1% 65.8% 72.6% 61.5% 72.6%

 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. 
69

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 1, 3, and

5 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 5 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 on average (compared to 52.7 for White employees, 52 for Black

employees, and 48.1 for Hispanic employees).
70

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. Education does not appear to account for

the grade discrepancies identified in Phase 1.

• Women in the Physical Sciences:

1. For hires in the largest 3 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 5 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 4 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. When FEVS sub-indices are compared, Women score lower than Men on the Cooperative

(Men, 72.1; Women, 66.9) and Open (Men, 81.8; Women, 74.5) sub-indices of 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. 

Subsequent Phases and Approximate Timeline

Phase 3: 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 will 

analyze data such as: applicant flow data, years of service and retirement eligibility, training and 

development history, etc. Expected Completion: April 1, 2021.
71

Phase 4: Phase 4 is a middle point between phases involving the exploration of existing data sources 

and phases that involve the collection of new data. This step will use the EEOC barrier analysis questions 

to help identify additional areas of research. In this phase, ODEO will reach out to other offices, 

including OCHCO and the Science Mission Directorate, for additional insights. Staff will use information 

collected in this phase to inform the next two phases. Expected Completion: September 30, 2021. 

11

Phase 5: In Phase 5, NASA will use the data and information examined in the preceding phases to 

transform areas of concern into survey topics of inquiry. Staff will develop psychometric survey 

measures to further investigate, validate, and understand where barriers to equal employment 

opportunity might exist. Staff will distribute the survey to all NASA civil servant Physical Scientists and 

the data collected will be analyzed using quantitative inferential analytic techniques. Expected 

Completion: March 31, 2022. 

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: June 30, 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: September 30, 2022. 

11 EEOC, “Barrier Analysis: Questions to Guide the Process,” accessed at: <https://www.eeoc.gov/federal-sector/

management-directive/barrier-analysis-questions-guide-process>.
72

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 Recruitment 

Program (FEORP) Report 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.
73

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 

DAD Diversity and Data/Analytics 

Division

D&I Diversity and Inclusion

EEO Equal Employment 

Opportunity

EEOC Equal Employment 

Opportunity Commission

ERG Employee Resource Group

FEVS Federal Employee Viewpoint 

Survey

GRC Glenn Research Center 

GSFC Goddard Space Flight Center 

HQ NASA Headquarters

IWD Individuals with Disabilities

IWTD Individuals with Targeted 

Disabilities 

JSC Johnson Space Center 

KSC Kennedy Space Center 

LaRC Langley Research Center 

LGBTQ+ Lesbian, Gay, Bisexual, 

Transgender, and Queer 

and/or Questioning

MD-715 Management Directive 715

MSFC Marshall Space Flight Center 

NASA National Aeronautics and 

Space Administration

NCLF National Civilian Labor Force

NPD NASA Policy Directive

NPR NASA Procedural 

Requirement

NSSC NASA Shared Services Center

ODEO Office of Diversity and Equal 

Opportunity

OCHCO Office of the Chief Human 

Capital Officer

OPM Office of Personnel 

Management

PA Professional Administrative

RCLF Relevant Civilian Labor Force

S&E Science and Engineering

SEP Special Emphasis Program 

SES Senior Executive Service

SSC Stennis Space Center

STEM Science, Technology, 

Engineering, and Mathematics

WFF Wallops Flight Facility