OFFICE OF DIVERSITY AND EQUAL OPPORTUNITY 

NATIONAL AERONAUTICS AND SPACE 

ADMINISTRATION (NASA) 

MODEL EQUAL EMPLOYMENT OPPORTUNITY 

PROGRAM STATUS REPORT: FY 2021 
[this page intentionally blank] 
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA) 

MODEL EQUAL EMPLOYMENT OPPORTUNITY PROGRAM STATUS REPORT: 

FY 2021 

Table of Contents 

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

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

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

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

1. Demonstrated Commitment of Agency Leadership.....................................5 

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

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

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

5. Efficiency.......................................................................................................8 

6. Responsiveness and Legal Compliance ........................................................8 

Section III. Workforce Analyses..................................................................................8 

Section IV. FY 2021 Model EEO Program Accomplishments ...................................10 

Section V. FY 2022 Planned Activities ......................................................................11 

Part F: Certification of Establishment of Continuing EEO Programs ...............................13 

Part G: Agency Self-Assessment Checklist - FY 2021 .......................................................15 

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

Part I: Barrier Analysis and Planned Activities.................................................................35 

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........43 

C. Progression Towards Goals (Recruitment and Hiring) .................................44 
Section IV: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities ................................................................................................................45 

A. Advancement Program Plan.........................................................................45 

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

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

D. Promotions ...................................................................................................47 

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

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

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

C. Reasonable Accommodation Program .........................................................52 

D. Personal Assistance Services Allowing Employees to Participate in the 

Workplace .........................................................................................................53 

Section VI: EEO Complaint and Findings Data..........................................................54 

A. EEO Complaint Data Involving Harassment..................................................54 

B. EEO Complaint Data Involving Reasonable Accommodation.......................54 

Section VII: Identification and Removal of Barriers.................................................54 

Appendix A: Data Analyses ..............................................................................................58 

Workforce Summary ................................................................................................58 

Occupational Categories, by Race and Ethnicity......................................................59 

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

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

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

Appendix C: Documents Required by EEOC.....................................................................68 

Appendix D: List of Frequently Used Acronyms...............................................................69 

ii 
PARTS A-D: AGENCY INFORMATION 

MD-715

PART A - D 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

For period covering October 1, 2020 to September 30, 2021. 

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 17,387 

Temporary Workforce 952 

TOTAL EMPLOYMENT 18,339 

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 

James Yamanaka, 

Director Diversity and 

Data/Analytics Division 

0260/SES (202) 358-

2167

james.k.yamanaka@ 

nasa.gov 

Complaint Processing 

Program Manager 

Vincent Patterson, Acting 

Director, Complaints 

Management Division 

0260/GS-15 (202) 358-

0952

vincent.e.patterson 

@nasa.gov 

Diversity & Inclusion 

Officer 

Nicole Lassiter, Equal 

Opportunity Specialist 

0260/GS-15 (202) 358-

1932

nicole.e.lassiter 

@nasa.gov 

Hispanic Program 

Manager (SEPM) 

Nicole Lassiter, Equal 

Opportunity Specialist 

0260/GS-15 (202) 358-

1932

nicole.e.lassiter 

@nasa.gov 

Women's Program 

Manager (SEPM) 

Nicole Lassiter, Equal 

Opportunity Specialist 

0260/GS-15 (202) 358-

1932

nicole.e.lassiter 

@nasa.gov 

Disability Program 

Manager (SEPM) 

Rebecca Doroshenk, 

Program Analyst 

0343/GS-14 (202) 358-

0038

Rebecca.d.doroshenk 

@nasa.gov 

Selective Placement 

Program Coordinator 

(Individuals 

w/Disabilities) 

Esteban Morales, Human 

Resources Specialist 

0201/GS-14 (301) 286-

3093

Esteban.morales 

@nasa.gov 

Reasonable 

Accommodation Program 

Manager 

Rebecca Doroshenk, 

Program Analyst 

0343/GS-14 (202) 358-

0038

Rebecca.d.doroshenk 

@nasa.gov 

3 
Anti-Harassment 

Program Manager 

David Chambers, Equal 

Opportunity Compliance 

Manager 

0360/GS-15 (202) 358-

3158 

david.r.chambers 

@nasa.gov 

ADR Program Manager Randy Poynter, Equal 

Employment Manager 

0260/GS-15 (202) 880-

5205 

randy.g.poynter@ 

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. 

4 
PART E: EXECUTIVE SUMMARY 

MD-715 

PART E 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

National Aeronautics and Space Administration For period covering October 1, 2020 to September 30, 2021. 

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. 

In 2021, for the ninth consecutive year, NASA was named the Best Place to Work in Government 

among large agencies by the Partnership for Public Service. With top-level support from the NASA 

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

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

throughout the Agency. NASA measures the success of its EEO program against the six Essential 

Elements of a Model Equal Employment Opportunity (EEO) Program, as outlined by the U.S. Equal 

Employment Opportunity Commission (EEOC) Management Directive 715 (MD-715). FY 2021 program 

accomplishments and DEIA successes are identified and discussed below. 

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

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

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

program, reflecting a compliance rate of 97 percent. Utilizing the results of the self-assessment, the 

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

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

1. Demonstrated Commitment of Agency Leadership 

In 2021, the Partnership for Public Service ranked NASA as the top large agency in the Federal 

Government for leadership support for diversity. Throughout FY 2021, Agency leadership continued 

to demonstrate their commitment to DEIA. Administrator Bill Nelson was sworn in on May 3, 2021. 

During the fiscal year, Administrator Nelson demonstrated his commitment to DEIA and EEO through 

5 
a variety of means. For instance, on September 28, 2021, the Administrator issued a Policy Statement 

on Diversity, Equity, Inclusion, and Accessibility for NASA’s Workforce and Workplaces. The statement 

emphasized NASA’s commitment to DEIA, which includes the following priorities: reinforcing a culture 

in which our employees feel they can be authentic, welcomed, respected, included, and engaged; 

maintaining an environment where our employees consistently and systematically receive fair, just, 

and impartial treatment; and ensuring our employees can fully and independently access facilities, 

information and communication technology, programs, and services. This policy statement covers all 

aspects of DEIA, including equal employment opportunity, anti-harassment and reasonable 

accommodation, as required by EEOC and Executive Orders issued by the Administration. 

In September 2021, NASA held its first-ever Accessibility Conference in support of the Agency’s 

Disability Employment and Reasonable Accommodation Program. Over 500 employees virtually 

participated, and the 3-day conference served as the kickoff event for NASA’s FY 2021 National 

Disability Employment Awareness Month activities. Administrator Nelson opened the conference 

with a video message and introduction of the keynote speaker. The conference also featured a video 

message from the NASA Deputy Administrator and remarks from Associate Administrator. The 

conference included 31 speakers and 13 sessions, providing three days of valuable information and 

resources. All NASA employees and contractors were encouraged to attend. The conference was 

closed captioned and American Sign Language interpreters and 508 compliant presentation slides 

were provided. 

In FY 2021, NASA also sought, through the President’s funding request, the resources to advance 

America’s Moon to Mars space exploration plan, keeping the Agency on the path to land the first 

woman and first person of color on the Moon under the Artemis program. 

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

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

scientific missions to recruitment and development of its employees. In fact, LinkedIn selected NASA 

as the 2021 top diversity champion among U.S. employers with between 10,000 and 30,000 

employees. LinkedIn’s Talent Awards are a data-driven recognition of companies worldwide that have 

demonstrated remarkable adaptability, innovation, and creativity in the talent space. LinkedIn also 

recognized NASA for having the top internship program, above companies including Google. This is a 

prominent and visible recognition of DEIA success at NASA, and a credit to the Agency-wide emphasis 

and culture of DEIA and employee engagement as well as the important work of ODEO and other 

mission support organizations that lead DEIA strategy and programs, such as the Office of the Chief 

Human Capital Officer (OCHCO). 

Further, in FY 2021 NASA revised one of its Agency Honor Awards to further support NASA’s Core 

Value of Inclusion. The award was renamed the Diversity, Equity, and Inclusion Medal and the criteria 

for the award was updated to reflect current definitions of Diversity, Inclusion, and Equity as described 

in recent DEIA Executive Orders and NASA policy statements. 

6 
3. Management and Program Accountability 

NASA ODEO reports quarterly on EEO and DEIA performance outcomes at the quarterly Agency senior 

leadership Baseline Performance Review (BPR) meeting. In addition, the Associate Administrator (AA) 

for ODEO is a full and active member of NASA’s senior leadership team and regularly participates on 

various decision-making bodies, boards, panels, and councils, such as: the Senior Management 

Council, the Agency’s senior decision-making body for strategic direction and planning; the Mission 

Support Council, the Agency's senior decision-making body regarding the integrated mission support 

portfolio; the Performance Review Board, which conducts annual performance reviews of NASA’s 

Senior Executive Service (SES) members; and the Executive Resources Board, which provides advice, 

counsel, and recommendations for consideration by the Administrator relating to the management 

of executive human resources. 

In FY 2021, NASA added a new diversity and inclusion performance element to all GS-level supervisory 

performance plans. Further, per NASA Procedural Requirement (NPR) 3335.1, Merit Promotion and 

Placement Plan, supervisors are responsible for the following: 

• Integrating Diversity & Inclusion (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. 

Throughout FY 2021, NASA continued to refine its EEO and D&I reporting capabilities, including 

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

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

analyzed it for previous MD-715 reports, those data are not yet available for FY 2021. This is due 

to the adoption of a new staffing solution, USA Staffing, and the lag time needed to develop the 

applicant flow data tables within the new environment. 

4. Proactive Prevention of Unlawful Discrimination 

In support of recent DEIA Executive Orders, NASA implemented the following: 

• Developed an action plan to address the requirements of Executive Order (E.O.) 13988 

on Gender Identity and Sexual Orientation. The plan includes: Guidance on Gender 

Transition and Identity, Policy for Restroom Inclusivity, a review of badging and security 

procedures to remove barriers to EEO and accessibility for Lesbian, Gay, Bisexual, 

Transgender, and Queer and/or Questioning (LGBTQ+) employees, and a review of 

NASA’s Astronaut Selection and Retention Standards. 

• Conducted a DEIA assessment and identified DEIA best practices in response to E.O. 

14035 on Diversity, Equity, Inclusion, and Accessibility in the Federal Workforce. 

• Provided input to inform the White House on the development of a Government-wide 

strategy for advancing gender equity and equality, as required by E.O. 14020 on Gender 

Policy. 

7 
Further, throughout FY 2021, NASA organized numerous cultural awareness events during special 

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

more than 60 Employee Resource Groups (ERGs), which play a vital role in NASA’s retention and 

development efforts. As noted above, NASA held its first-ever Accessibility Conference to educate 

NASA managers, supervisors, and employees on the provision of reasonable accommodations to 

individuals with disabilities. In addition, NASA also emphasizes a broad application of anti-harassment 

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

legal compliance and focusing on workforce and mission. In FY 2021, NASA received 46 reports of 

harassment under the AHP, achieving an average processing time of 64 days (compared to 65 days in 

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

5. Efficiency 

NASA completed 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 requests. Moreover, to improve effectiveness and efficiency in the NASA 

Affirmative Employment Program, the Agency procured workforce barrier analysis training through 

the EEOC for approximately 50 ODEO staff members and provided several training sessions on data 

analytics. 

6. Responsiveness and Legal Compliance 

NASA posted timely No FEAR Act data, met established deadlines for submitting the FY 2020 MD-715 

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

462) to EEOC. In addition, in FY 2021 NASA: 

• Achieved 100 percent timeliness in issuance of Final Agency Decisions (FADs). NASA 

improved the percentage of timely FADs from 76 percent in FY 2020 to 100 percent in FY 

2021. 

• Provided training to a 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 Alternative Dispute Resolution (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. 

Section III. Workforce Analyses 

To attract and retain a diverse workforce, NASA works to ensure equal opportunity in all aspects of 

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

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

8 
any demographic group.1 The FY 2021 workforce composition data revealed the following triggers 

(see Appendix A, Table 1): 

• 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 8.7 percent of the 

workforce, yet each account for only 4.9 percent of the SES. 

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

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

representation in the workforce. Blacks make up 10.9 percent of the NASA workforce, 

yet are only 2.3 percent of those in ST positions and 1.1 percent of those in SL positions. 

Hispanics account for 8.7 percent of the NASA workforce, but only occupy 3.5 percent 

and 6.3 percent of ST and SL positions, respectively. Women are 34.9 percent of the 

NASA workforce, yet are only 19.8 percent and 17.9 percent of ST and SL employees, 

respectively. In addition, AAPI employees, who make up 8.7 percent of the NASA 

workforce, are underrepresented among SL employees, accounting for 4.2 percent of 

such positions (however, they are 12.8 percent of ST employees). 

• GS-14 through GS-15 and Supervisory positions: Women are underrepresented in GS-14 

through GS-15 positions, accounting for 30.6 percent of the employees in those grades 

(compared to their overall representation in the NASA workforce of 34.9 percent). AAPI 

employees account for just 5.6 percent of those in supervisory positions (compared to 

their overall representation of 8.7 percent). 

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 31.2 percent of NASA 

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

AAPI make up 13.2 percent of Physical Scientists at NASA, but account for 16.4 percent of such 

positions in the RCLF. In addition, AAPI account for 7.1 percent of General Engineers (job series 0801) 

compared to 12.1 percent in the RCLF. Further, Blacks or African Americans account for just 1.5 

percent of NASA Space Scientists (job series 1330), although they are 3.6 percent of Space Scientists 

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

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

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 A, Table 1). As defined by EEOC, a trigger is a situation that alerts the Agency to the possible existence 

of a barrier to EEO. For example, low participation (or representation) of a group in certain occupations, or among 

employees receiving promotions, awards, etc., may indicate that there is an Agency policy or practice that limits the full 

participation of that group. A trigger does not by itself demonstrate a barrier to equal opportunity; it indicates an area to 

be monitored or further analyzed. 

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>. 

9 
In contrast, AAPI, Blacks, Hispanics, and Women represent a greater proportion of those occupying 

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

Table 3). For example: 

• AAPI employees are 12.5 percent of NASA Accountants, compared to 8.6 percent of 

Accountants in the RCLF. AAPI also account for 6.7 percent of Human Resources 

Specialists at NASA and 4.3 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 30.6 percent of NASA Accountants, but only 8.5 percent 

and 8.1 percent, respectively, in the RCLF. 

• Hispanic employees are 11.1 percent of Management and Program Analysts, compared 

to 4.6 percent in the RCLF; 10.6 percent Contract Specialists, compared to 7.1 percent in 

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

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

individuals with targeted disabilities (IWTD) (see Part J). These goals are: (1) IWD should account for 

12 percent of employees in grades GS-10 and below and 12 percent of employees in grades GS-11 

and above, and (2) IWTD should account for two percent of employees in these grade categories. For 

grades GS-10 and below: IWD and IWTD account for 22.5 percent and five percent of the NASA 

employees in those grades, respectively. For grades GS-11 and above, IWD and IWTD are 13.1 percent 

and 2.6 percent of NASA employees in those grades. The Agency will continue to monitor overall 

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

retention. 

NASA continues to improve its data analytics capability and obtain data needed to monitor workforce 

demographics and conduct barrier analyses. In FY 2021, NASA implemented a new staffing solution 

and continues to develop new applicant flow data reports to meet EEOC’s specifications. Thus, 

although this data was included in past MD-715 reports, NASA was unable to analyze applicant flow 

data for FY 2021. 

Section IV. FY 2021 Model EEO Program Accomplishments 

In FY 2021, NASA corrected three of the eight program deficiencies identified in the previous fiscal 

year: 

1. Revise exit surveys to include questions on how the Agency could improve the recruitment, 

hiring, inclusion, retention, and advancement of individuals with disabilities. NASA 

redesigned its exit survey to be more user-friendly and added and/or revised questions to 

obtain information on former employees’ experiences, with regard to DEIA. The new survey 

was deployed in on October 4, 2021 (see Part H-3). 

10 
2. Establish timeframes to issue acceptance letters/dismissal decisions within a reasonable time 

after receipt of the written EEO Counselor report. NASA established a timeframe of 45 days 

for issuing acceptance/dismissal decisions and is monitoring its timeliness (see Part H-5). 

3. Complete FADs within established timeframes. NASA issued 100 percent of FADs timely in 

FY 2021, compared to 76 percent in FY 2020 (see Part H-8). 

Section V. FY 2022 Planned Activities 

No new program deficiencies were identified in FY 2021; work continues on five deficiencies 

identified in FY 2020: 

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

pursuant to 29 CFR §1614.102(b)(4). The NASA Administrator was sworn in on May 3, 2021. 

The AA, ODEO, now reports directly to the Deputy Administrator. 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-1). 

2. Establish timeframes for completing inquiries of harassment allegations under the AntiHarassment Program. In January 2021, NASA published new Anti-Harassment Procedures 

(NASA Procedure Requirement (NPR) 3713.3A) that include EEOC-specified timeframes for 

initiating action on and completing the processing of reports of harassment. To ensure 

timelines are met, NASA is developing a tracking system and will continue to provide training 

and technical assistance to Center Anti-Harassment Coordinators (see Part H-2). 

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

§1614.108. FY 2021, NASA completed 89 percent of its counseling timely (compared to 93 

percent in FY 2020). NASA has instituted “Coffee Chats” and bi-monthly meetings with 

counselors and provided EEO counselor refresher training provided March and April (see Part 

H-4). 

4. Ensure EEO investigations are completed timely, pursuant to 29 CFR §1614.108. The 

timeliness of investigations increased from 86 percent in FY 2020 to 95 percent in FY 2021 

(see Part H-6). 

5. 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 plans to 

issue 180-day letters, when appropriate, within 185 calendar days of when a formal 

complaint is filed (see Part H-7). 

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

regarding Women, AAPI, and IWD. NASA will complete additional phases of its barrier analysis 

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

interviews with subject matter experts, and will continue to address issues related to its disability 

program (see Parts I and J). 

11 
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12 
PART F: CERTIFICATION OF ESTABLISHMENT OF CONTINUING EEO PROGRAMS 

MD-715 

PART F 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

CERTIFICATION of ESTABLISHMENT of CONTINUING EQUAL EMPLOYMENT 

OPPORTUNITY PROGRAMS 

I, 

Stephen T. Shih, Associate Administrator for Diversity 

and Equal Opportunity/0260/SES 

am the 

Principal EEO 

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

for: National Aeronautics and Space Administration 

(Insert Agency/Component Name) 

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

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

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

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

included with this Federal Agency Annual EEO Program Status Report. 

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

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

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

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

Program Status Report. 

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

EEOC review upon request. 

6/14/2022

Signature of Principal EEO Director/Official 

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

compliance with EEO MD 715. 

Date 

5/31/2022

Signature of Agency Head or Agency Head Designee Date 

13 
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14 
PART G: AGENCY SELF-ASSESSMENT CHECKLIST – FY 2021 

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. 

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 September 28, 

2021. 

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

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

orientation and gender identity), genetic information, 

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

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

Yes 

A.2 – The agency 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/ 

displayDir.cfm?t=NPR&c=371 

3&s=1C 

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

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

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

A.2.c.2 − ADR process? [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 Unlawful Harassment 

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

often. 

Yes At least annually. 

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. 

15 
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. 

B.1 - The reporting structure for the EEO program provides the 

principal EEO official with appropriate authority and resources 

to effectively carry out a successful EEO program. 

Measure 

Met? Comments 

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

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

office? [29 CFR §1614.102(b)(4)] No 

The AA for ODEO formally 

reports to the Deputy 

Administrator and has regular 

access to the Administrator. 

See Part H-1. 

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

does the EEO Director report to the same agency head 

designee as the mission-related programmatic offices? If 

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

comments. 

No See Part H-1. 

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

reporting structure for the EEO office? [29 CFR 

§1614.102(b)(4)] 

Yes 

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

of advising the agency head and other senior management 

officials of the effectiveness, efficiency, and legal 

compliance of agency’s EEO program? [29 CFR 

§1614.102(c)(1); MD-715 Instructions, Sec. I] 

Yes 

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

the head of the agency, and other senior management 

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

essential elements of the model EEO program and the 

status of the barrier analysis process? [MD-715 

Instructions, Sec. I)] If yes, provide the date of the briefing 

in comments column. 

Yes 

ODEO briefed the NASA 

Administrator on 8/11/2021 

and presented data at the 

Agency Baseline Performance 

Review on a quarterly basis. 

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

staff meetings concerning personnel, budget, technology, 

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

Yes 

B.2 – The 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 

16 
B.2.b − Overseeing the completion of EEO counseling? [29 CFR 

§1614.102(c)(4)] Yes 

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

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

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

[29 CFR §1614.102(c)(5)] Yes 

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

1614.102(e); 1614.502] Yes 

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

providing recommendations for improvement to the 

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

Yes 

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

EEO Director provide effective guidance and coordination for 

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

Yes 

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

involved in, and consulted on, management/personnel actions. 

Measure 

Met? Comments 

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

regarding workforce changes that might impact EEO issues, 

including strategic planning, recruitment strategies, vacancy

projections, succession planning, and selections for 

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

Yes 

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

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

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

comments column. 

Yes 

Objective 4.4, Manage Human 

Capital, references proactive 

efforts to ensure EEO and 

prevent workplace 

discrimination. 

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

the success of its EEO program 

Measure 

Met? Comments 

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

successfully implement the EEO program, for the following areas: 

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

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

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

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

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

including EEO counseling, investigations, final agency 

decisions, and legal sufficiency reviews? [29 CFR § 

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

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

Yes 

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

the EEO program, including but not limited to retaliation, 

harassment, religious accommodations, disability 

accommodations, the EEO complaint process, and ADR? 

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

training with insufficient funding in the comments section. 

Yes 

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

of the EEO programs in components and the field offices, 

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

Yes 

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? [MDYes 

17 
715, II(E)]. If not, identify the systems with insufficient 

funding in the comments section. 

B.4.a.8 − to effectively administer its special emphasis programs 

(such as, Federal Women’s Program, Hispanic 

Employment Program, and People with Disabilities 

Program)? [5 USC § 7201; 38 USC § 4214; 5 CFR § 

720.204; 5 CFR § 213.3102(t) and (u); 5 CFR § 315.709] 

Yes 

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

Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1] 

Yes 

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

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

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

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

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

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

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

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

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

investigators, including contractors and collateral duty 

employees, receive the required 32 hours of training, 

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

Yes 

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

investigators, including contractors and collateral duty 

employees, receive the required 8 hours of annual refresher 

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

Yes 

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

supervisors and managers who have effective managerial, 

communications, and interpersonal skills. 

Measure 

Met? 

Comments 

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

responsibilities under the following areas under the agency EEO program: 

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

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

1614.102(d)(3)] Yes 

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

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

interpersonal skills in order to supervise most effectively 

in a workplace with diverse employees and avoid disputes 

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

Yes 

B.5.a.5 − ADR, with emphasis on the Federal government’s interest 

in encouraging mutual resolution of disputes and the 

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

Yes 

B.6 – The agency involves managers in the implementation of 

its EEO program. 

Measure 

Met? Comments 

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

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

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 

18 
B.6.d Do senior managers successfully implement EEO Action 

Plans and incorporate the EEO Action Plan Objectives into 

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

Yes 

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY 

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

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

C.1 – The agency conducts regular 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 

Agency ODEO reviews Center 

MD-715 plans annually, 

provides technical assistance 

as needed, and periodically 

conducts functional reviews. 

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

offices on their efforts to remove barriers from the 

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

schedule for conducting audits in the comments section. 

Yes 

Agency ODEO reviews Center 

MD-715 plans and 

accomplishments on an 

annual basis. 

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

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

C.2 – The agency has established procedures to prevent all 

forms of EEO discrimination. 

Measure 

Met? 

Comments 

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

policy and procedures that comply with EEOC’s enforcement 

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

Vicarious Employer Liability for Unlawful Harassment by 

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

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

Yes 

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

prevent or eliminate conduct before it rises to the level of 

unlawful harassment? [EEOC Enforcement Guidance on 

Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.1] 

Yes 

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

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

Yes 

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

EEO complaint process) to address harassment allegations? 

[Enforcement Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors, EEOC No. 915.002, § 

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

Yes 

C.2.a.4 Does the agency ensure that the EEO office informs the 

anti-harassment program of all EEO counseling activity 

alleging harassment? [Enforcement Guidance, V.C.] 

Yes 

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

ten days of notification) of all harassment allegations, 

including those initially raised in the EEO complaint 

process? [Complainant v. Dep’t of Veterans Affairs, EEOC 

Appeal No. 0120123232 (May 21, 2015); Complainant v. 

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 2021, NASA completed 

56.7 percent of cases in a 

timely fashion. See Part H-2. 

19 
C.2.a.6 Do the agency’s training materials on its anti-harassment 

policy include examples of disability-based harassment? [29 

CFR 1614.203(d)(2)] 

Yes 

C.2.b Has the agency established disability reasonable 

accommodation procedures that comply with EEOC’s 

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

Yes 

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

place to coordinate or assist with processing requests for 

disability accommodations throughout the agency?[29 CFR 

1614.203(d)(3)(D)] 

Yes 

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

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

1(IV)(A)] 

Yes 

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

receive RAs during the application and placement 

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

Yes 

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

process the request within a maximum amount of time 

(e.g., 20 business days), as established by the agency in its 

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

Yes 

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

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

provide percentage of timely-processed requests in the 

comments column. 

Yes 

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

requests for personal assistance services that comply with 

EEOC’s regulations, enforcement guidance, and other 

applicable executive orders, guidance, and standards? [29 

CFR 1614.203(d)(6)] 

Yes 

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

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

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

address in the comments column. 

Yes 

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

displayDir.cfm?t=NPR&c=371 

3&s=1B 

C.3 - The agency evaluates managers and supervisors on their 

efforts to ensure equal employment opportunity. 

Measure 

Met? 

Comments 

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

supervisors have an element in their performance appraisal 

that evaluates their commitment to agency EEO policies and 

principles and their participation in the EEO program? 

Yes 

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

based on the following: 

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

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

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

supervision with EEO officials, such as counselors and 

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

Yes 

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

discrimination, including harassment and retaliation? 

[MD-715, II(C)] 

Yes 

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

managerial, communication, and interpersonal skills to 

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

Yes 

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

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

20 
C.3.b.6 − Provide disability accommodations when it does not cause 

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

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

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

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

and correcting harassing conduct? [Enforcement 

Guidance, V.C.2] 

Yes 

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

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

Systems Protection Board, labor arbitrators, and the 

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

Yes 

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

improvements or corrections, including remedial or 

disciplinary actions, for managers and supervisors who have 

failed in their EEO responsibilities? [29 CFR 

§1614.102(c)(2)] 

Yes 

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

actions, are the recommendations regularly implemented by 

the agency? [29 CFR §1614.102(c)(2)] 

Yes 

C.4 – The agency ensures effective coordination between its 

EEO programs and Human Resources (HR) program. 

Measure 

Met? Comments 

C.4.a 

Do the HR Director and the EEO Director meet regularly to 

assess whether personnel programs, policies, and 

procedures conform to EEOC laws, instructions, and 

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

Yes 

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

regular intervals its merit promotion program, employee 

recognition awards program, employee development/ 

training programs, and management/ personnel policies, 

procedures, and practices for systemic barriers that may be 

impeding full participation in the program by all EEO 

groups? [MD-715 Instructions, Sec. I] 

Yes 

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

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

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

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

Yes 

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

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

surveys, and grievance data), upon request? [MD-715, 

II(C)] 

Yes 

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

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

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

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

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

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

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

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

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

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

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

whether it should take a disciplinary action. 

Measure 

Met? Comments 

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

penalties that covers discriminatory conduct? [29 CFR § Yes 

21 
1614.102(a)(6); see also Douglas v. Veterans 

Administration, 5 MSPR 280 (1981)] 

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 2021. 

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

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

managers and supervisors about the discriminatory 

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

Yes 

C.6 – The EEO office advises managers/ supervisors on EEO 

matters. 

Measure 

Met? Comments 

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

officials with regular EEO updates on at least an annual 

basis, including EEO complaints, workforce demographics 

and data summaries, legal updates, barrier analysis plans, 

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

I] If yes, identify the frequency of updates in comments. 

Yes At least annually. 

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

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

Sec. I] 

Yes 

Essential Element D: PROACTIVE PREVENTION 

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

and to identify and eliminate barriers to equal employment opportunity. 

D.1 – The agency conducts a reasonable assessment to monitor 

progress towards achieving equal employment opportunity 

throughout the year. 

Measure 

Met? Comments 

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

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

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

information for trigger identification: workforce data; 

complaint/grievance data; exit surveys; climate surveys; 

focus groups; affinity groups; union; program evaluations; 

special emphasis programs; reasonable accommodation 

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

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

Yes 

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

include questions on how the agency could improve the 

recruitment, hiring, inclusion, retention and advancement of 

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

Yes Completed in FY 2021. See 

Part H-3. 

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 Does the agency consider whether any group of employees 

or applicants might be negatively impacted prior to making 

human resource decisions, such as re-organizations and 

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

Yes 

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

information to find barriers: complaint/ grievance data, exit Yes Complaints, climate surveys (e.g., FEVS), anti-harassment 

22 
surveys, employee climate surveys, focus groups, affinity 

groups, union, program evaluations, anti-harassment 

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

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

sources in the comments section. 

program data, affinity groups, 

Special Emphasis Program 

(SEPs), employee pulse 

surveys, and other sources 

(when available). 

D.3 – The agency establishes appropriate action plans to 

remove identified barriers. 

Measure 

Met? 

Comments 

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

the identified barriers, in particular policies, procedures, or 

practices? [29 CFR §1614.102(a)(3)] 

Yes 

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

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

including meeting the target dates for the planned 

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

N/A See Part I. 

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

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

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

disabilities, including those with targeted disabilities. 

Measure 

Met? 

Comments 

D.4.a 

Does the agency post its affirmative action plan on its public 

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

internet address in the comments section. 

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

odeo/workforce-data 

D.4.b 

Does the agency take specific steps to ensure qualified 

people with disabilities are aware of and encouraged to 

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

Yes 

D.4.c 

Does the agency ensure that disability-related questions 

from members of the public are answered promptly and 

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

Yes 

D.4.d 

Has the agency taken specific steps that are reasonably 

designed to increase the number of persons with disabilities 

or targeted disabilities employed at the agency until it 

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

Yes 

Essential Element E: EFFICIENCY 

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

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

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

complaint resolution process. 

Measure 

Met? Comments 

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

§1614.105] No 

NASA completed 89 percent of 

counseling timely in FY 2021. 

See Part H-4. 

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

responsibilities in the EEO process during the initial 

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

Yes 

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

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

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

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

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

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

comments section. 

Yes 

Timeframes achieved in FY 

2021; the average processing 

time was 57 days. See Part 

H-5. 

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 

23 
E.1.f Does the agency timely complete investigations? [29 CFR 

§1614.108] Yes Achieved in FY 2021. See Part H-6. 

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-7. 

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

agency timely issue the final agency decision? [29 CFR 

§1614.110(b)] 

Yes Achieved in FY 2021. See 

Part H-8. 

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

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

decision? [29 CFR §1614.110(a)] 

Yes 

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

the EEO complaint process, does the agency hold them 

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

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

Yes 

Timelines in the statement of 

work, templates to ensure 

consistency, and contractors 

must provide weekly status 

updates and inform the 

Contracting Officer’s 

Representative (COR) 

immediately of any issues 

causing delays. The COR has 

regular meetings with 

contractors to address 

deficiencies or improvements. 

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

the EEO complaint process, does the agency hold them 

accountable for poor work product and/or delays during 

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

Yes 

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

documents in the proper format to EEOC through the 

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

Yes 

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

Met? Comments 

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

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

column. 

Yes 

The attorney who provides 

legal advice to ODEO does not 

serve as the Agency 

representative. 

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

have access to sufficient legal resources separate from the 

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

identify the source/location of the attorney who conducts 

the legal sufficiency review in the comments. 

Yes 

The attorney who provides 

legal advice to ODEO does not 

serve as the Agency 

representative. 

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

conduct the legal sufficiency review, is there a firewall 

between the reviewing attorney and the agency 

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

Yes 

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

not intrude upon EEO counseling, investigations, and final 

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

Yes 

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 

24 
E.3 - The agency has established and encouraged the 

widespread use of a fair 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 

E.4 – The agency has effective and accurate data collection 

systems in place to evaluate its EEO program. 

Measure 

Met? Comments 

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

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

complaints, the aggrieved individuals/ complainants, and 

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

Yes 

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

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

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

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

applicants’ race, national origin, sex, and disability 

status? [MD-715, II(E)] 

Yes 

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

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

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

program? [EEOC Enforcement Guidance on Vicarious 

Employer Liability for Unlawful Harassment by 

Supervisors (1999), § V.C.2] 

Yes 

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

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

E.5 – The agency identifies and 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 

NASA regularly reviews data 

on the workforce, EEO 

complaints, and harassment 

allegations and reports trends 

to leadership. 

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

adopt them, where appropriate, to improve the 

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, benchmarks 

with other agencies, reviews 

best practice, and adopts best 

practices when appropriate. 

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

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

II(E)] 

Yes 

25 
Essential Element F: RESPONSIVENESS AND LEGAL COMPLIANCE 

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

policy guidance, and other written instructions. 

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

full compliance with EEOC Orders and settlement agreements. 

Measure 

Met? Comments 

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

ensure that its officials timely comply with EEOC 

orders/directives and final agency actions? [29 CFR 

§1614.102(e); MD-715, II(F)] 

Yes 

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

ensure the timely, accurate, and complete compliance with 

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

Yes 

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

predictable processing of ordered monetary relief? [MD715, II(F)] Yes 

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

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

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

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

accountable for poor work product and/or delays during 

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

Yes 

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

regulations, management directives, orders, and other written 

instructions. 

Measure 

Met? 

Comments 

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

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

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

timely forward the investigative file to the appropriate EEOC 

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

Yes 

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

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

timely compliance with the orders of relief? [29 CFR 

§1614.501] 

Yes 

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

forward the investigative file to EEOC’s Office of Federal 

Operations? [29 CFR §1614.403(e)] 

Yes 

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

provide EEOC with the required documentation for 

completing compliance? 

Yes 

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

accomplishments. 

Measure 

Met? Comments 

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

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

15, 2002), §203(a)] 

Yes 

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

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

26 
PART H: ESSENTIAL ELEMENT DEFICIENCIES AND PLANNED ACTIVITIES 

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

G in FY 2020. NASA completed Parts H-3, H-5, H-6, and H-8 in FY 2021. NASA plans to complete 

Parts H-1, H-2, H-4, H-5, and H-7 in FY 2022. 

MD-715 

PART H-1 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

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

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

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

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

and Measure B.1.a1) 

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

RESPONSIBLE 

OFFICIAL: NASA Administrator; AA, ODEO 

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

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

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

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

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

address this deficiency. 

Yes 9/30/2023 

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

including updating its organizational chart, to 

implement the new reporting structure. 

Yes 9/30/2023 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: The Administrator was sworn-in on May 3, 2021. ODEO 

continues to discuss reorganization. The AA, ODEO, was realigned and elevated from reporting to the 

Deputy Associate Administrator to the Deputy Administrator. 

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

27 
MD-715 

PART H-2 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

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

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

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

OBJECTIVE: Establish timeframes for completing 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 9/30/2022 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

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

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

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

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

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

system for anti-harassment cases. 

Yes 

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

Center Anti-Harassment Coordinators on 

conducting immediate interviews. 

Yes 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: NASA revised its Anti-Harassment procedures (NPR 3713.3), 

which now include a requirement for inquiries to begin within ten days of receipt of an allegation and 

specifies a 60-day timeframe for Issuing final decision memoranda. NASA published the new 

procedures on January 12, 2021. 

Modifications to Objective: Added planned activities #5-6; modified completion date to 9/30/2022. 

28 
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 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 9/30/2021 10/4/2021 

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 DEIA and IWD. 

Yes 10/4/2021 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: In FY 2021, NASA redesigned its exit survey to be more userfriendly and added and/or revised questions to obtain information on former employees’ experiences 

with regard to DEIA. The new survey was deployed for Agency-wide collection efforts on October 4, 2021. 

Modifications to Objective: This objective is now complete. 

29 
MD-715 

PART H-4 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA does not complete EEO 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. 

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 9/30/2022 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

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

review and shortening the review and approval periods. 

Yes 9/28/2018 

9/30/2019 2. Provide training 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 9/30/2022 

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

informal complaints stage to increase timeliness. 

Yes 9/30/2021 

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

focusing on specific NASA-related complaint issues. 

Yes 4/7/2021 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: FY 2021, NASA completed 89 percent of its counseling timely 

(compared to 93 percent in FY 2020). NASA has instituted “Coffee Chats” and bi-monthly meetings with 

counselors and provided EEO counselor refresher training provided on March 31 and April 7, 2021. 

Modifications to Objective: Modified completion date to 9/30/2022. NASA will continue to review 

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

additional interventions, as necessary, to improve timeliness. 

30 
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 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 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 

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

timeframes. 

Yes 5/1/2021 

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

dismissal decisions within established 

timeframes. 

Yes 9/30/2021 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: NASA established a timeframe of 45 days for issuing acceptance 

letters/dismissal decisions and provided guidance to staff regarding the timeframe. NASA will continue 

to monitor its progress on issuing acceptance letters/dismissal decisions within the timeframe. 

Modifications to Objective: This objective is now complete. 

31 
MD-715 

PART H-6 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

DESCRIPTION 

AND TYPE OF 

PROGRAM 

DEFICIENCY: 

NASA does not complete 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 completed timely 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 9/30/2022 

PLANNED ACTIONS TOWARD COMPLETION OF OBJECTIVE: 

Target Date Planned Activities 

Sufficient 

Funding & 

Staffing? 

Modified 

Date 

Completion 

Date 

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

review and shortening the review and approval periods. 

Yes 9/28/2018 

9/30/2019 2. Provide training on formal complaints processing. Yes 9/30/2019 

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

address processing challenges and share/implement 

changes, when and where needed. 

Yes 9/30/2019 

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

knowledgeable in Federal EEO complaints processing. 

Yes 9/30/2019 

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

for timely and quality investigation of complaints. 

Yes 9/30/2019 

9/30/2019 6. Review monthly complaint processing data to track 

compliance to regulatory requirements and address 

timeliness and quality of processing issues as expeditiously 

as possible when there is a need. 

Yes 9/30/2019 

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

Agency Legal Representative to assist with timeliness. 

Yes 9/30/2020 

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

appropriate election rights are provided. 

Yes 9/30/2020 

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

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

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

with regulatory timeframes. 

Yes 9/30/22 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: The timeliness of investigations increased from 86 percent in 

FY 2020 to 95 percent in FY 2021 (19 of 20 cases were timely). NASA will closely monitor its investigations 

to ensure compliance with regulations. 

Modifications to Objective: Modified completion date to 9/30/2022. 

32 
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 notify complainants of the date by which the investigation will be completed 

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

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

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

RESPONSIBLE 

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

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

DATES: Date Initiated Target Completion Date Modified 

Date Date Completed 

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

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 9/30/22 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: NASA developed standard operating procedures for its 

complaints processing program. 

Modifications to Objective: Modified completion date to 9/30/2022. 

33 
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 complete FADs within the timeframes established by 29 CFR. Part 1614, 

section 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 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 9/30/2021 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress and Accomplishments: In FY 2021, NASA issued timely FADs in 100 percent of EEO 

complaints, compared to 76 percent in FY 2020 and 21 percent in FY 2019. 

Modifications to Objective: This objective is now complete. 

34 
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 2020-21 NASA workforce data to the RCLF reveals that AAPI and 

Women have lower than expected participation rates in Physical Scientist positions (U.S. 

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

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

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

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

Physical Scientists at NASA than they do in the RCLF. AAPI women are 3.8 percent of 

NASA Physical Scientists yet are 7.5 percent of physical scientists in the RCLF. Similarly, 

White women are 23.3 percent of NASA Physical Scientists, compared to 29.8 percent in 

the RCLF. 

SOURCE OF 

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

compared to the RCLF benchmark for certain groups. 

MD-715 

WORKFORCE 

DATA TABLE: 

Table A6 

EEO GROUP(S) 

AFFECTED BY 

TRIGGER: 

Check all that apply: 

All Men Asian Males X 

All Women Asian Females X 

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

Hispanic or Latino Females Native Hawaiian or Other Pacific Islander 

Females 

X 

White Males American Indian or Alaska Native Males 

White Females X American Indian or Alaska Native Females 

Black or African American Males Two or More Races Males 

Black or African American Females Two or More Races Females 

BARRIER ANALYSIS PROCESS 

SOURCES OF 

DATA: 

Sources Source Reviewed 

(Y/N)? 

Identify Information 

Collected 

Workforce Data Tables Yes Table A6 

Complaint Data (Trends) Yes 

Grievance Data (Trends) Yes 

Findings from Decisions (e.g., EEO, 

Grievance, MSPB, Anti-Harassment 

Processes) 

N/A 

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

Exit Interview Data No 

Focus Groups No 

Interviews Yes 

35 
Reports (e.g., Congress, EEOC, MSPB, 

GAO, OPM) 

No 

Other (Please Describe) N/A 

STATUS OF 

BARRIER 

ANALYSIS 

PROCESS: 

Barrier analysis process completed? (Y/N) No, four of seven phases completed. 

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

STATEMENT OF 

IDENTIFIED 

BARRIER(S): 

(Description of 

Policy, Procedure, 

or Practice) 

Barriers not yet identified; 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 

Implement a DEIA analytics 

capability within NASA’s 

Enterprise Data Platform to 

enable evidence-based 

awareness, planning, 

decisions, and assessments 

of the current and future 

state of DEIA at NASA. 

11/30/2021 9/30/2026 No 

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 (SMD), to 

9/28/2018 

36 
strengthen its data analytics capabilities to enable ODEO to 

conduct in-depth barrier analyses. 

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

ensure that the necessary data are available for conducting 

barrier analyses related to EEO. 

5/15/2019 5/15/2019 

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

additional data tools such as: FEVS, NASA Human Capital 

Management Workforce Analysis Business Intelligence 

Tools, climate surveys, pulse surveys, and potential new 

database systems, to enhance our ability to analyze 

programs and practices at more granular levels. 

9/30/2020 

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

complaints, grievances, surveys, exit interviews, and 

reports for any indicators of barriers regarding 

employment of women and AAPI as physical scientists. 

9/30/2021 9/30/2021 

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

for Physical Scientist positions in FY 2020. 

4/1/2021 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) 

4/1/2021 

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

Centers and organizations to better understand trends 

identified in the initial phases of the barrier analysis. 

(Phase 4) 

12/31/2021 12/10/2021 

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

NASA Physical Science employees to gain deeper insight 

into potential barriers and potential solutions to those 

barriers. (Phases 5 and 6) 

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) 

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

internal and external to NASA, to support DEIA analytics 

and reporting requirements. 

37 
9/30/2022 13. Create a DEIA data architecture that links data 

requirements to analytic questions and strategic and 

operational decisions. Identify gaps in data elements and 

data standards that NASA can mitigate internally as well as 

communicate data gaps to OMB, OPM, and other external 

data stewards who can help address. 

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

industry best-practice analytic tools to be able to exploit 

the benefits of cloud-based, big-data analytics. 

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

models aligned to NASA’s internal and external 

stakeholder and customer needs to improve decisionmaking, encourage data sharing, and improve 

accountability. 

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

Federal Government and NASA’s budget processes to 

successfully implement an effective analytics capability 

aligned with the new requirements extended by the 

Administration’s priorities as well as NASA’s internal 

requirements. 

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

ensure effective data management, stewardship, and 

security. 

9/30/2026 18. Assess current data governance and related policies to 

ensure effective data management, stewardship, and 

security. 

REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FY 2021 Progress: NASA reviewed additional workforce data, including training data, and interviewed key 

officials in OCHCO, SMD, and the Office of the Chief Scientist to obtain additional information regarding 

Physical Science positions at NASA. 

Modifications to Objective: None. 

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

RETENTION OF PERSONS WITH DISABILITIES 

MD-715 

PART J 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

To capture agencies’ affirmative action plans for IWD and IWTD, EEOC regulations (29 CFR. § 1614.203(e)) and 

MD-715 require agencies to describe how their plan will improve the recruitment, hiring, advancement, and 

retention of applicants and employees with disabilities. 

Section I: Efforts to Reach Regulatory Goals 

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

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

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving IWD by grade 

level cluster in the permanent workforce? If “yes,” describe the trigger(s) in the text box. 

a. Cluster GS-1 to GS-10 (IWD) Yes No X 

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

There are no triggers. In FY 2021, IWD account for 23 percent of employees GS-1 to GS-10 and 13 

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 

There are no triggers. In FY 2021, IWTD account for 5 percent of employees GS-1 to GS-10 and 3 

percent of employees GS-11 to SES. 

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

recruiters. 

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

June 2021, NASA sent a memo to the NASA workforce explaining the purpose of and encouraging 

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

of 101 self-identified employees with disabilities. Additionally, NASA held a three day Accessibility 

Conference for all employees, where among many disability-related topics, numerical goals and 

hiring strategies were discussed. 

39 
Section II: Model Disability Program 

Pursuant to 29 CFR. §1614.203(d)(1), agencies must ensure sufficient staff, training and resources to recruit 

and hire persons with disabilities and persons with targeted disabilities, administer the reasonable 

accommodation 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 and the Office of the Chief Information Officer 

(OCIO) developed a public-facing webpage containing 

resources for NASA applicants regarding numerous 

disability resources, including technology accessibility. 

Processing RA requests 

from applicants and 

employees 

10 All ten NASA Centers have a designated DPM who is 

responsible for processing reasonable accommodation 

(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 Section 508 compliance end-user interest group on 

issues that arise, and the Agency DPM regularly 

communicates with OCIO on issues requiring 

technological solutions. 

40 
# of FTE Staff by 

Employment Status Responsible Official Disability Program Task Full Part Collateral (Name, Title, Office, Email) 

Time Time 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. 

Special Emphasis 

Program (SEP) for 

IWD/IWTD 

10 NASA has DPMs at each of the ten Centers responsible 

for managing SEP activities. NASA also has seven 

disability-focused ERGs. 

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 2021, the Agency-level Disability Employment Program (DEP) sponsored a three day 

Accessibility Conference, with training for all NASA employees, including supervisors and managers 

and Center DPMs. Sessions included: Ensuring Inclusion for Employees with Disabilities in the 

Workplace, the Department of Labor’s Workforce Recruitment Program, Disabled Veteran Hiring 

Authorities and Retention, Hiring for Neurodiversity, Schedule A Hiring, ERGs Best Practices, 

Disability Etiquette, how to be an Ally to Individuals with Disabilities, Reasonable Accommodation, 

and Section 508 Compliance. As a follow-on to the Conference, the DEP sponsored a 3.5-hour RA 

training for Agency-wide use for employees and another such training for supervisors, trainings on 

making a document Section 508 compliant (PDF and Microsoft Suite documents), and Deaf 

Etiquette and an American Sign Language lesson. Center-level DPMs received technical assistance 

and training from the Agency’s DPM during quarterly meetings and on an ad hoc basis on a variety 

of topics, particularly concerning the processing of religious and medical, required by Presidential 

Executive Order (E.O.) 14043, issued on September 9, 2021. 

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. 

41 
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 ERGs and SEPs to encourage participation in job 

opportunities within the IWD population. 

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. The NASA Accessibility Conference included a session by the Project 

Director of the Entry Point! Program at American Association for the Advancement of Science to 

discuss increasing numbers of interns with disabilities; follow-on discussions were held between 

Entry Point! and NASA’s OSTEM Internship Program. Additionally, the DEP developed a publicfacing NASA Disability Resources webpage, which contains 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. 

NASA Centers regularly worked with local colleges and universities to conduct outreach in FY 2021. 

For example, Goddard Space Flight Center (GSFC) completed a pilot consisting of high school and 

college students meeting with leadership to encourage students with disabilities to apply for 

internships/employment with the Agency; the Johnson Space Center (JSC) DPM and 

representatives of Texas Instruments, Texas A&M University, and NASA Human Resources (HR) 

participated in an Employer Career Webinar Panel for students with disabilities; and the Kennedy 

Space Center (KSC) ERGs hosted a Disability Mentoring Day virtual event with KSC subject matter 

experts; the event had 527 registrations, representing 100 schools/universities/non-profits. 

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

2021 include: Glenn Research Center’s (GRC) use of the OPM Shared List of People with 

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

disabilities; Ames Research Center (ARC) posting Pathways internship positions online on the 

American Association for the Advancement of Science (AAAS) website; Headquarters (HQ) staff 

attending employment fairs and outreach activities for veterans and disabled veterans; and JSC’s 

participation in a job fair hosted by the Texas Veterans Leadership Program and Harris County, 

Texas. 

42 
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 DEP held 

sessions at the NASA Accessibility Conference on Schedule A, the U.S. Department of Labor (DOL) 

Workforce Recruitment Program (WRP), and Disabled Veteran Hiring Authorities. The DEP also 

facilitated a meeting between the Department of Veterans Affairs’ (VA) National Employment 

Coordinator and OCHCO to encourage an increase in the use of veterans hiring authorities. 

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 provided training this year through the three day Accessibility Conference in September 

2021, to all NASA employees, including managers and supervisors and Center DPMs, on Schedule A 

veterans' preference in hiring, and the WRP. 

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

and supervisors. This year, ODEO worked with OCHCO to create a new “HR101” training for new 

supervisors and managers, which included training on the full spectrum of hiring flexibilities; DEIA; 

Reasonable Accommodations for Employees with Disabilities; Anti-harassment, and EEO 

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

authority via consultation with their ODEO representatives and at various leadership meetings and 

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

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

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 2021, 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 

43 
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 VA. 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, DOL, and Employment 

Network Service providers. NASA engages with a number of other professional organizations for 

IWD via social media, as well. 

NASA Centers also 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 has established a partnership with OSTEM to create a database that captures 

contacts from colleges and universities to forward job announcements to IWD and IWTD. 

At the Agency level, the DEP partnered with the OPM, DOL, the VA, the MITRE Corporation, Sliding 

Doors STEM and Dyslexia Learning Center, and the Entry Point! Program at American Association 

for the Advancement of Science on numerous topics surrounding the hiring and retention of 

individuals with disabilities. 

C. Progression Towards Goals (Recruitment and Hiring) 

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

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

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

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

In FY 2021, ten percent of all new hires were IWDs and 1.6 percent of all new hires were IWTDs. 

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

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

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

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

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

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

reports and will evaluate the data when available. 

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

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

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

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

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

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

reports and will evaluate the data when available. 

44 
4. Using the qualified applicant pool as the benchmark, do triggers exist for IWD/IWTD among 

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

a. Promotions for MCO (IWD) Yes No N/A X 

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

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

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

reports and will evaluate the data when available. 

Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities 

Pursuant to 29 CFR §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement 

opportunities for employees with disabilities. Such activities might include specialized training and 

mentoring programs, career development opportunities, awards programs, promotions, and similar 

programs that address advancement. In this section, agencies should identify, and provide data on 

programs designed to ensure advancement opportunities for employees with disabilities. 

A. Advancement Program Plan 

Describe the Agency’s plan to ensure IWD and IWTD have sufficient opportunities for advancement. 

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

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

IWD, Women, and members of race and ethnicity groups are included. Further, the Agency 

conducts listening sessions with individuals who are members of underserved communities to 

understand their experience navigating the promotions process. 

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

rates and practices, including training and development history; employee tenure; and education 

level. In FY 2020, NASA implemented the Talent Marketplace automated platform that ensures 

developmental opportunities are widely announced to all NASA employees. Talent Marketplace 

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

rotational assignments. Data on applicants are collected for subsequent analyses of the applicant 

and selection process. 

B. Career Development Opportunities 

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

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

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

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

individual and organizational capabilities and competencies in accordance with Merit System 

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

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

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

45 
NASA is beginning to pilot professional development for targeted communities. Further, the NASA 

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

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

include a self-assessment that measures individual cultural diversity, which will set the stage for 

self-awareness and action for change. 

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

competition and/or supervisory recommendation/approval to participate. 

Career Development Opportunities Total Participants (#) IWD (%) IWTD (%) 

Applicants Selectees Applicants Selectees Applicants Selectees 

Internship Programs 44,236 2,344 7.3% 6.8% 

Detail Programs 3,132 175 9.6% 7.4% 3.4% 1.7% 

Fellowship Programs 

Data not available or programs not conducted in FY 2021. Mentoring Programs 

Coaching Programs 

Training Programs 

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

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

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

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

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

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

a. Applicants (IWD) Yes X No N/A 

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

There are no triggers for the internship program. For details, the IWD account for 13.1 percent of 

the relevant applicant pool but are only 9.6 percent of applicants. Further, IWD are only 7.4 

percent of selectees. 

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

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

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

a. Applicants (IWTD) Yes No X 

b. Selections (IWTD) Yes No X 

There are no triggers. 

C. Awards 

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

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

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

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

In FY 2021, the inclusion rates were 11.5 percent for IWD and 2.5 percent for IWTD (at all grade 

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

46 
awards of $3,000 or more. In addition, for cash awards of $4,000 or more, IWTD accounted for 

fewer than two percent of awards. NASA will continue to monitor the IWD and IWTD inclusion 

rates for awards. (See Table J1 below.) 

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

for quality step increases or performance-based pay increases? If yes, describe the trigger(s). 

a. Pay Increases (IWD) Yes No X 

c. Pay Increases (IWTD) Yes No X 

There were no significant triggers regarding quality step increases. (See Table J1.) 

3. If the agency has other types of employee recognition programs, are IWD/IWTD recognized 

disproportionately less than employees without disabilities? (The benchmark is the inclusion 

rate.) If yes, describe the recognition program and relevant data. 

a. Other Types of Recognition (IWD) Yes No X N/A 

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

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

Table J1. Employee Awards and Recognition 

IWD IWTD 

Inclusion Rates (all Grades) 11.6% 2.1% 

Type of Award: 

Time Off 

Awards 

1-10 hours 13.1% 2.8% 

11-20 hours 12.4% 2.6% 

21-30 hours 11.4% 1.7% 

31-40 hours 14.6% 2.8% 

41 or more hours 15.0% 1.5% 

Cash 

Awards 

$500 and Under 14.7% 3.3% 

$501 - 999 13.4% 2.6% 

$1000 - $1999 12.2% 2.6% 

$2000 - $2999 11.1% 2.1% 

$3000 - $3999 9.5% 1.8% 

$4000 - $4999 8.4% 1.3% 

$5000 or More 8.1% 1.1% 

Other 

Awards 

Performance Award 10.0% 1.5% 

Quality Step Increase 10.2% 1.4% 

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

(DOI); data as of 9/30/2021. Data include permanent employees only. 

Triggers highlighted in yellow. 

D. Promotions 

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

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

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

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

47 
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 

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

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

and will evaluate the data when available. 

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

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

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

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

a. SES 

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

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

b. Grade GS-15 

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

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

c. Grade GS-14 

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

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

d. Grade GS-13 

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

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

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

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

will evaluate the data when available. 

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

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

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

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

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

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

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

48 
Data not yet available. NASA implemented a new staffing solution in FY 2021; applicant flow 

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

and will evaluate the data when available. 

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

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

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

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

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

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

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

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

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

will evaluate the data when available. 

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

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

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

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

a. Executives 

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

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

b. Managers 

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

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

c. Supervisors 

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

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

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

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

will evaluate the data when available. 

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

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

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

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

a. Executives 

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

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

b. Managers 

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

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

c. Supervisors 

49 
i. Qualified Internal Applicants (IWTD) Yes No N/A X 

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

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

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

will evaluate the data when available. 

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

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

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

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

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

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

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

evaluate the data when available. 

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

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

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

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

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

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

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

evaluate the data when available. 

Section V: Plan to Improve Retention of Persons with Disabilities 

To be a model employer for persons with disabilities, agencies must have policies and programs in place to 

retain employees with disabilities. In this section, agencies should: (1) analyze workforce separation data 

to identify barriers retaining employees with disabilities; (2) describe efforts to ensure accessibility of 

technology and facilities; and (3) provide information on the reasonable accommodation program and 

workplace personal assistance services. 

A. Voluntary and Involuntary Separations 

1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability 

into the competitive service after two years of satisfactory service (5 CFR. § 213.3102(u)(6)(i))? If 

no, please explain why the agency did not convert all eligible Schedule A employees. 

Yes No X N/A 

Of the 61 Schedule A hires with disabilities eligible for conversion (hired in FY 2019), seven were not 

converted. (Of the seven not converted, two were reassigned to different organizations.) 

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. 

50 
a. Voluntary Separations (IWD) Yes No X 

b. Involuntary Separations (IWD) Yes X No 

IWD accounted for 19.0 percent of involuntary separations (4 of 21), which is higher than the 

inclusion rate for IWD of 11.6 percent. NASA will continue to monitor the IWD inclusion rate for 

separations. (See Table J2.) 

3. Using the inclusion rate as the benchmark, did the percentage of IWTD among voluntary and 

involuntary separations exceed that of persons without targeted disabilities? If yes, describe 

trigger below. 

a. Voluntary Separations (IWTD) Yes No X 

b. Involuntary Separations (IWTD) Yes No X 

IWTD accounted for a lower percentage of both voluntary and involuntary separations, compared to 

their overall inclusion rate. (See Table J2.) 

Table J2. Separations by Disability Status 

Separation Type Total IWD IWTD 

Inclusion Rate % 100.0% 11.6% 2.1% 

Removal 

(Involuntary) 

# 21 4 0 

% 100.0% 19.0% 0.0% 

Resignation 

(Voluntary) 

# 186 13 1 

% 100.0% 7.0% 0.5% 

Total Separations 

# 890 101 24 

% 100.0% 11.3% 2.7% 

Source: NASA MD-715 Table B-1 (Losses), prepared by DOI; 

data as of 9/30/2021. Triggers highlighted in yellow. 

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. 

Of the four involuntary separations of IWD, two were removed, one was terminated, and one was 

terminated during the probationary period. 

B. Accessibility of Technology and Facilities 

Pursuant to 29 CFR. § 1614.203(d)(4), federal agencies are required to inform applicants and employees of 

their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), concerning the 

accessibility of agency technology, and the Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), 

concerning the accessibility of agency facilities. In addition, agencies are required to inform individuals where 

to file complaints if other agencies are responsible for a violation. 

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

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

description of how to file a complaint. 

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

51 
2. Please provide the internet address on the agency’s public Web site for its notice explaining 

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

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

3. Describe any programs, policies, or practices that the agency has undertaken, or plans on undertaking over the next fiscal year, designed to improve accessibility of facilities and/or technology. 

NASA maintains an Agency-wide multi-year implementation plan that identifies the facility 

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

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

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

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

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

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

2021, the DEP hosted OCIO’s 508 Coordinators for a session to the workforce on 508 Compliance, at 

the Accessibility Conference in September, with a follow-on training on how to ensure documents are 

508 Compliant in October 2021. 

NASA developed a webpage of all accessibility technology options across NASA. This page is available 

to employees and managers, as well as to applicants and the public. At NASA’s Accessibility 

Conference, options for conference access were 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 websites to 

identify and correct compliance issues. NASA made 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 NASAs 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 developed a new website to enhance their NASA-wide communication with end-users 

and others in the community of practice. Currently, OCIO is developing a Self-Service Project to assist 

end-users with their accessibility technology needs. 

At the Center-level, DPMs manage all RA requests, including technology accessibility issues. For 

example, 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.) 

NASA RA processing averages 36 days or less at each Center. (See Table J3 for average processing 

time by NASA Center.) 

52 
Table J3. Average Processing Times for RA Requests 

Center Average No. 

of Days 

Ames Research Center 15 

Armstrong Flight Research Center 7.5 

Glenn Research Center 18 

Goddard Space Flight Center 30 

Headquarters 13 

Johnson Space Center 5 

Kennedy Space Center 36 

Langley Research Center 1 

Marshall Space Flight Center 8 

NASA Shared Services Center 9 

Stennis Space Center 3 

Source: NASA RAMS, data for FY 2021. 

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 2021, NASA trained more than 1,700 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. In addition, 

NASA developed 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 

allows Agency leadership to better monitor timeliness 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 has an Agency-wide Blanket Purchase Agreement (BPA) for personal assistance services (PAS), 

for greater efficiency and consistency in providing PAS across the Agency. Each Center has a PAS 

technical monitor to ensure timely PAS processing and services. The Agency-level DPM monitors 

requests for trends and act as the Contracting Officer’s Representative to the PAS BPA to monitor 

contractor timeliness and quality. NASA provided a PAS guide to PAS technical monitors in FY 2021. 

To date, NASA has not had a need to use the PAS BPA. 

53 
Section VI: EEO Complaint and Findings Data 

A. EEO Complaint Data Involving Harassment 

1. During the last fiscal year, did a higher percentage of IWD file a formal EEO complaint alleging 

harassment, as compared to the government-wide average of 19.7 percent? 

Yes No X N/A 

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

in a finding of discrimination or a settlement agreement? 

Yes No X N/A 

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

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

N/A – There were no findings. 

B. EEO Complaint Data Involving Reasonable Accommodation 

1. During the last fiscal year, did a higher percentage of IWD file a formal EEO complaint alleging 

failure to provide an RA, as compared to the government-wide average of 13.5 percent? 

Yes No X N/A 

2. During the last fiscal year, did any complaints alleging failure to provide RA in a finding of 

discrimination or a settlement agreement? 

Yes No X N/A 

3. If the agency had one or more findings of discrimination involving the failure to provide RA during 

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

N/A – There were no findings. 

Section VII: Identification and Removal of Barriers 

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a policy, 

procedure, or practice may be impeding the employment opportunities of a protected EEO group. 

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

employment opportunities for IWD and/or IWTD? 

Yes No X 

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

Yes No N/A X 

3. Identify each trigger and plan to remove the barrier(s), including the barrier(s), objective(s), 

responsible official(s), planned activities, and, where applicable, accomplishments. 

54 
MD-715 

PART J Affirmative Action Plan for Individuals with Disabilities 

Triggers 

The preceding analyses revealed the following triggers: 

• Performance Awards: There were triggers for cash awards of $3,000 

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

• Separations: There are triggers for involuntary separations of IWD (see 

Part J, section V, A). 

• Schedule A conversions: Not all FY 2019 Schedule A hires were 

converted to permanent positions with two years (see Part J, section V, 

A). 

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

not available for FY 2021. NASA will continue to monitor triggers and initiate 

appropriate action and activities if trends develop. 

Source of Trigger Workforce data tables. 

EEO Group(s) 

Affected Individuals with Disabilities and Individuals with Targeted Disabilities. 

EEO Sources 

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

Status of Barrier 

Analysis Process Barrier analysis not yet completed. 

Objective(s) for the 

EEO Plan 

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

following: (1) obtain additional data and conduct further analyses to determine 

causes of differences observed in the data categories described above and the 

causes for such differences; and (2) develop improved systems for collecting 

demographic data pertaining to career development programs. 

Plan to Address Barriers/Triggers Identified 

Responsible Official(s) Performance Standards Address 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 

Yes 3/15/2019 3/15/2019 

55 
conducting barrier analyses related to 

the disability program. 

9/29/2019 Place information on the NASA website 

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 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 6/16/2021 

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

efficiencies and permit greater insight 

into RA trends for leadership. 

Yes 4/19/2021 

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 9/30/2022 

9/30/2021 Change the procurement and purchasing 

card systems to be in line with 508 

compliance. 

Yes 9/30/2021 

9/30/2022 Develop and deploy a 508 accessibility 

scanning tool to standardize the process 

of scanning for compliance issues. 

Yes 9/30/2021 

Fiscal Year Accomplishments 

FY 2021 In FY 2021, ODEO DEP implemented the RAMS, which enhances standardization 

of RA processes and timeliness, and developed a comprehensive Disability 

Resources page for the ODEO website. This webpage includes an extensive 

amount of resources, links, educational information, and tools to assist NASA 

56 
leaders, managers, supervisors, and employees in fulfilling a wide range of 

disability-related inquiries. 

In addition, NASA held its first-ever Accessibility Conference. The conference 

was accessible to all employees through closed captioning, sign language 

interpretation, and full 508 compliance. NASA also developed a new “HR101” 

training for new managers and supervisors, including sessions on DEIA, AntiHarassment, Reasonable Accommodation, EEO Complaint Management, and 

the full spectrum of hiring flexibilities. 

The Agency made improvements in processes related to information 

technology (IT) acquisitions. These processes include reviews to ensure that 

Section 508 conformance and accessibility are considered for all acquisitions. 

Further, NASA has renewed an Agency license for Sortsite which allows 

websites to be scanned for Section 508/IT Accessibility issues. 

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. 

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

activities toward eliminating the barrier(s). 

In FY 2021, NASA revised it exit survey to include more diversity, and disability-related questions 

are forthcoming. 

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 

57 
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 triggers3 (highlighted in yellow) for some traditionally underrepresented 

groups at NASA, when compared to their total representation: 4 

• Asian Americans and Pacific Islanders (AAPI) are underrepresented in SES and SL positions (4.9 

percent and 4.2 percent, respectively) compared to their overall participation in the NASA 

workforce (8.7 percent). 

• Blacks and African Americans are underrepresented in ST, SL, and student positions (2.3 

percent, 1.1 percent, and 7.1 percent), compared to their overall participation in the NASA 

workforce (10.9 percent). 

• Hispanics and Latinos are underrepresented in SES, ST, and SL positions (4.9 percent, 3.5 

percent, and 6.3 percent, respectively) compared to their overall participation in the NASA 

workforce (8.7 percent). 

• American Indians and Alaska Natives (AIAN) represent 1.0 percent of the NASA workforce. 

Their small number (175 AIAN individuals are employed by NASA), renders comparisons of 

smaller subgroups to their total employment less meaningful. 

• Women are underrepresented in ST, SL, and GS-14 through GS-15 positions (19.8 percent, 17.9 

percent, and 30.6 percent, respectively) compared to their overall representation at NASA (34.9 

percent) of the NASA workforce. 

3 According to EEOC, a low participation rate for any group (in relation to a benchmark) is a “trigger” – EEOC defines a "trigger" 

as “a trend, disparity, or anomaly that suggests the need for further inquiry into a particular policy, practice, procedure, or 

condition” to determine if there are barriers to equal employment opportunity. In other words, low participation (or 

representation) of a group in certain occupations, or among employees receiving promotions, awards, etc., may indicate that 

there is an agency policy or practice that limits the full participation of that group. A trigger does not by itself demonstrate a 

barrier to equal opportunity; it indicates an area to be monitored or further analyzed. EEOC does not prescribe tests of statistical 

significance or other statistical tests to determine “underrepresentation,” leaving it instead to agencies to determine their level 

of tolerance. For larger groups, NASA uses a standard of a two-percentage point difference from the benchmark when identifying 

triggers. EEOC, Instructions to Federal Agencies for EEO MD-715, “Section II: Barrier Identification and Elimination,” accessed at 

<https://www.eeoc.gov/federal/directives/715instruct/>. 4 EEOC identifies the appropriate benchmarks for comparison. The total agency workforce should be compared to the Civilian 

Labor Force (CLF), 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/labor-force/about/

glossary.html>. Subgroups of the agency workforce (e.g., those in senior grades) should be compared to overall agency workforce. 

58 
Table 1. NASA Employees (Selected Groups) by Race, Ethnicity, and Gender: FY 2021 

NASA Workforce Total 

Number AAPI Black Hispanic AIAN White MultiRacial 

Undeclared Male Female 

All Employees: 18,339 8.7% 10.9% 8.7% 1.0% 70.0% 0.4% 0.4% 65.1% 34.9% 

Permanent 16,771 8.3% 11.3% 8.4% 1.0% 70.4% 0.4% 0.2% 65.3% 34.7% 

Temporary 952 11.6% 6.4% 9.6% 0.2% 68.7% 0.4% 3.2% 63.2% 36.8% 

Students 616 15.7% 7.1% 15.3% 0.8% 59.3% 0.6% 1.1% 63.1% 36.9% 

All Employees, by Grade: 

SES/Other Executives 430 4.9% 11.4% 4.9% 0.7% 77.7% 0.5% 0.0% 65.1% 34.9% 

ST 86 12.8% 2.3% 3.5% 0.0% 81.4% 0.0% 0.0% 80.2% 19.8% 

SL 95 4.2% 1.1% 6.3% 2.1% 86.3% 0.0% 0.0% 82.1% 17.9% 

GS-14 – GS-15 9,706 8.7% 9.4% 7.1% 0.9% 73.6% 0.2% 0.2% 69.4% 30.6% 

GS-11 – GS-13 6,857 8.5% 13.2% 10.5% 1.2% 65.7% 0.5% 0.4% 60.8% 39.2% 

GS-03 – GS-10 1,066 12.3% 12.8% 13.8% 0.6% 58.4% 0.8% 1.3% 51.0% 49.0% 

All Other Pay Rates 99 9.1% 2.0% 7.1% 0.0% 75.8% 1.0% 5.1% 64.6% 35.4% 

Other Groups: 

Supervisors 2,927 5.6% 12.5% 7.5% 0.7% 73.2% 0.3% 0.1% 63.9% 36.1% 

Comparison Populations: 

Federal STEM Workforce 346,123 9.8% 10.3% 6.4% 0.8% 70.4% 2.0% 0.3% 69.8% 30.2% 

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

Notes: Triggers highlighted in yellow. “All Other Pay Rates” includes: pay rates for Advisory Committee Members, Experts, 

and Consultants, and administrative determined rates. “Students” are interns hired through OPM’s Pathways program. 

Sources: NASA Personnel Data Warehouse (PDW) (data as of 09/30/2021); Office of Personnel Management (OPM), 

FedScope, Federal Human Resources Data, Diversity Cube and Employment Cube (U.S.-based employees only) (data as of 

6/30/2021, the most recent data available), accessed at <https://www.fedscope.opm.gov>; U.S. Census Bureau, EEO 

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

employment/equal-employment-opportunity-tabulation.html>; EEOC, Instructions to Federal Agencies for EEO MD-715, 

Section IV, “Interpretation and Completion of Workforce Data Tables,” accessed at: <https://www.eeoc.gov/federalsector/management-directive/ instructions-federal-agencies-eeo-md-715-0>. 

As shown in Table 1, the composition of the NASA workforce by race and ethnicity is similar to the CLF, 

with three exceptions: NASA employs a higher percentage of AAPI and a lower percentage of both 

Hispanics and Women than their representation in the CLF. (AAPI account for 8.7 percent of the NASA 

workforce, compared to 4.6 percent in the CLF; Hispanics are 8.47 percent of the NASA workforce and 

10.0 percent of the CLF; and women are 34.9 percent of the NASA workforce and 48.2 percent of the 

CLF.) However, because the NASA workforce is highly specialized (two-thirds of NASA employees are 

in science and engineering (S&E) occupations) and the CLF includes all occupations in the country, other 

benchmarks can be used. Comparing NASA to the Federal STEM workforce reveals few differences. In 

fact, NASA’s workforce is similar to the Federal STEM workforce with the exception of the employment 

of Hispanics and women, who are employed in higher percentages at NASA. 

Occupational Categories, by Race and Ethnicity 

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

occupations to the individuals in the civilian labor force in similar occupations (the RCLF). In addition, 

59 
data on recent college graduates provides insight into the pipeline for similar jobs. Thus, employment 

ratios below the RCLF for any group is another trigger.5 Tables 2 and 3 reveal the following: 

• 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 

Professional Administrative (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 2021 

AAPI Black Hispanic Multiracial AIAN White Male Female 

Engineering Occupations: 

0861 - Aerospace 

Engineer (n=4,474) 

NASA: 9.3% 5.9% 8.4% 0.2% 0.6% 75.2% 78.1% 21.9% 

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

0801 - General Engineer 

(n=3,326) 

NASA: 7.1% 6.7% 8.0% 0.3% 1.1% 76.6% 70.9% 291% 

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

0855 - Electronics 

Engineer (n=813) 

NASA: 16.6% 6.2% 9.7% 0.1% 0.5% 66.8% 84.9% 15.1% 

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

0854 - Computer 

Engineer (n=765) 

NASA: 15.0% 9.5% 9.0% 0.3% 0.7% 65.2% 73.5% 26.5% 

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

0850 - Electrical 

Engineer (n=340) 

NASA: 12.9% 7.1% 12.4% 0.3% 0.5% 66.8% 84.9% 15.1% 

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

Physical Science Occupations: 

1301 - Physical Scientist 

(n=468) 

NASA: 13.2% 3.2% 5.6% 0.0% 0.2% 77.6% 68.8% 31.2% 

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

1330 - Space Scientist 

(n=339) 

NASA: 7.1% 1.5% 7.1% 0.0% 0.0% 84.1% 68.7% 31.3% 

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

5 EEOC requires agencies to use representation in the agency workforce as the comparison group when analyzing representation 

by grade level and supervisory status, and in promotions, hiring, etc., such as in Table 1. When analyzing individuals by occupation, 

EEOC requires the use of the RCLF, which is comprised of occupations similar to occupations in the agency. EEOC, Instructions to 

Federal Agencies for EEO MD-715, “Guidance for Completing the EEOC FORM 715-01 Workforce Data Tables,” accessed at 

<https://www.eeoc.gov/federal/directives/715instruct/>. 

60 
Table 3. NASA Mission Critical and Other Professional Administrative Occupations by Race, 

Ethnicity, and Gender: FY 2021 

AAPI Black Hispanic Multiracial AIAN White Male Female 

0301 - General 

Administrative* (n=936) 

NASA: 4.9% 19.1% 7.9% 0.9% 13% 65.4% 37.4% 62.6% 

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

1102 - Contract 

Specialist* (n=755) 

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 – Management and 

Program Analyst* 

(n=737) 

NASA: 7.6% 16.4% 11.1% 0.5% 1.5% 62.1% 36.8% 63.2% 

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

2210 - Information 

Technology Specialist 

(n=559) 

NASA: 7.7% 17.2% 7.0% 0.9% 1.4% 65.5% 60.6% 39.4% 

RCLF: 6.8% 11.1% 7.6% 0.6% 0.8% 73.1% 70.4% 29.6% 

0510 - Accountant 

(n=288) 

NASA: 12.5% 30.6% 8.7% 0.0% 1.0% 46.9% 30.9% 69.1% 

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

0501 - Finance (n=304) NASA: 6.9% 23.7% 8.2% 0.0% 0.7% 60.5% 31.3% 68.8% 

RCLF: 5.0% 12.3% 9.8% 0.5% 1.2% 71.1% 43.7% 56.3% 

0201 - Human Resources 

Specialist (n=300) 

NASA: 6.7% 26.7% 9.0% 1.7% 1.0% 54.3% 27.7% 72.3% 

RCLF: 4.3% 10.4% 9.5% 0.5% 0.7% 74.6% 39.7% 60.3% 

Notes for Tables 2 and 3: The table does not include Individuals who did not identify their race/ethnicity; thus, not all groups 

total to 100 percent. Triggers highlighted in yellow. Sources: NASA PDW (data as of 9/30/2021); U.S. Census Bureau, EEO 

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

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

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 2019 FY 2020 FY 2021 Federal Goal 

GS-10 and Below: 

IWD 23.9% 24.3% 22.5% 12% 

IWTD 7.3% 6.5% 5.0% 2% 

GS-11 and Above: 

IWD 10.6% 11.9% 13.1% 12% 

IWTD 2.4% 2.6% 2.6% 2% 

Source: NASA PDW; 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)). 

61 
Federal Employee Viewpoint Survey (FEVS) Results 

NASA has continued to improve its FEVS scores.6 Although the FEVS’ New Inclusion Quotient (New IQ) 

was not calculated in the most recent survey, due to the limited number of New IQ questions asked, 

NASA’s scores on several questions related to DEIA and compliance increased. For example, between 

2019 and 2020, the percentage of employees stating that they agree or strongly agree the question, 

“My supervisor/team leader is committed to a workforce representative of all segments of society” 

increased from 86.3 percent to 90.8 percent (see Figure 1). In addition, the percentage of positive 

responses to the statement “NASA leaders take proactive steps to prevent harassment in the workplace 

(for example, senior leadership messages to the workforce, use of posters and other communication 

materials, training, dialogues, or similar activities)” increased from 80.3 percent in 2019 to 88.7 percent 

in 2020 (this question was first asked in 2019). 

Figure 1. FEVS Questions Focused on DEIA and Compliance: FY 2016-20 

100% 

94.0% 95% 92.3% 92.7% 91.9% 90.8% 91.0% 

90% 

85.6% 86.3%

84.9% 83.8% 84.2% 85% 81.8% 82.4%

79.8% 

80% 

75% 

70% 

82.3% 

I can disclose a suspected My supervisor/team leader is My supervisor treats me with 

violation of any law, rule or committed to a workforce respect. 

regulation without fear of representative of all segments of 

reprisal. society. 

2016 2017 2018 2019 2020 

Source: OPM, 2020 FEVS Results. Percentages represent the percentage of responses that were positive. Governmentwide, there were 624,800 respondents; there were 10,588 NASA respondents. Because of the COVID-19 global pandemic, 

OPM administered the 2020 FEVS at a later date than in previous years; thus, data were not available until FY 2021. 

Similarly, the 2021 FEVS was administered in the first quarter of FY 2022. 

6 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. 

62 
APPENDIX B: PHYSICAL SCIENCE BARRIER ANALYSIS PLAN AND INITIAL FINDINGS 

Barrier Analysis Overview 

Purpose: NASA identified workforce triggers7 for Women and Asian Americans and Pacific Islanders 

(AAPI)8 within Physical Science occupations, when compared to the Relevant Civilian Labor Force 

(RCLF).9 Thus, the Agency is undertaking the barrier analysis process to further explore potential 

underlying causes of these discrepancies in order to determine their root cause. The barrier analysis 

will focus on the Physical Science jobs with the highest numbers of employees, Physical Scientists (job 

series 1301), Physicists (job series 1310), and Space Scientists (job series 1330) (see Table 1). 

Process Overview: NASA will use a multiphase barrier analysis process to systematically assess 

representation in the Physical Science Occupational Series. Phase 1 examines general representation 

of demographic groups within the various Physical Science occupations. Phases 2 and 3 examine 

existing personnel data, such as data on losses and hires, to further explore the factors that may be 

contributing to discrepancies discovered in Phase 1. At Phase 4, NASA will deploy a systematic set of 

questions to gather more information about triggers uncovered in Phases 1-3. In Phases 5-6, the 

Agency will use qualitative and quantitative data collection techniques to obtain input from members 

of potentially affected demographic groups. Finally, at Phase 7, NASA will identify root causes of 

potential barriers and develop corrective actions. 

Table 1. NASA Physical Science Occupations: FY 2021 

Physical Science Job Series Number of NASA Employees 

1301 - Physical Scientist 465 

1306 - Health Physicist 6 

1310 - Physicist 111 

1311 - Physical Science Technician 4 

1313 - Geophysicist 14 

1320 - Chemist 5 

1330 - Space Scientist 330 

1340 - Meteorologist 22 

1360 - Oceanographer 15 

1386 - Photographic Technologist 4 

1399 - Physical Science Trainee 465 

Source: NASA Personnel Data Warehouse; data as of 10/1/2020. NASA has identified job series 1301 and 1310 as mission critical 

occupations because of their importance to NASA missions and the large numbers of employees those series. 

7 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. 

8 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. 9 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>. 

63 
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 

Men 0.0% 0.3% 0.0% 0.4% 0.0% 0.4% 

Women 0.0% 0.2% 0.0% 0.2% 0.0% 0.2% 

Total 0.0% 0.5% 0.0% 0.6% 0.0% 0.6% 

AIAN 

Men 0.2% 0.4% 0.0% 0.5% 0.0% 0.5% 

Women 0.0% 0.2% 0.0% 0.0% 0.0% 0.0% 

Total 0.2% 0.6% 0.0% 0.5% 0.0% 0.5% 

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. 

64 
NASA also examined representation by grade within the physical sciences. AAPI, Hispanic, and Women 

employees are not participating equally in higher grades: AAPI employees are not participating in SES 

positions equal to their workforce percentage. Hispanic employees are not participating in GS-14 and 

GS-15 positions equal to their workforce percentage. Women are not participating in GS-15 positions 

equal to their workforce percentage. 

Phase 2 

Purpose of Phase: The goal of Phase 2 was to look at additional personnel data to begin identifying 

why participation discrepancies might exist. This phase focused on the initial groups of concern: 

Women and AAPI. 

Data Examined: 

1. Hires and Separations. NASA examined hire and loss rates to see if discrepancies between NASA 

workforce participation and the RCLF are due to the inability to hire Women and AAPI versus 

high loss rates among those groups. 

2. Time-in-Grade/Position and Promotions. NASA examined differences in participation rates in 

senior grades, time-in-grade, and time-in-position, as well as participation over the last one, 

three, and five years. 

3. Average Age. NASA examined average employee age, to ensure that the discrepancies were 

not accounted for by a high percentage of early-career employees. 

4. Education. NASA reviewed data on educational attainment to determine whether there is a 

qualification or perceived qualification issue that may be slowing a group’s advancement. 

5. FEVS Data. The Agency reviewed sub-indices of FEVS Employee Engagement Index, New 

Inclusion Quotient (New IQ), and Global Satisfaction Index. These sub-indices can reveal 

differences by race, ethnicity, gender, and occupation that may indicate potential barriers to 

inclusion. 

Data Findings: NASA identified the following triggers with regard to AAPI and Women: 

• Asian Americans and Pacific Islanders in the Physical Sciences: 

1. NASA hires of AAPI employees have been above the Physical Science RCLF values, except 

for the 1301 series where they are just slightly below the RCLF. Losses have slightly 

exceeded the size of the workforce over the past five years (8.8 percent of losses and 8.5 

percent of the workforce in 2016). This trend is most notable in the 1301 series. At ARC, 

losses are slightly higher than AAPI representation in the workforce (8.3 percent of losses 

compared to 7.8 percent in the workforce). 

2. AAPI have more time-in-grade and time-in-position than other demographic groups. For 

example, excluding SES and GS-15 employees, AAPI employees have been in their positions 

an average of 3.7 years. This is higher than Black (1.9 years), Hispanic (2.9 years), and White 

(3.4 years) employees. 

3. With an average age of 53.8, AAPI employees in physical science occupations are the oldest 

demographic group (compared to 52.7 for White employees, 52 for Black employees, and 

48.1 for Hispanic employees). 

65 
4. In terms of educational level, 93.9 percent of AAPI employees in physical sciences have a 

graduate degree (compared to 93.6 percent of White employees, 91.1 percent of Hispanic 

employees, and 86.2 percent of Black employees. 

• Women in the Physical Sciences: 

1. For hires in the largest three physical science occupations, Women accounted for a higher 

percentage of hires than the occupation’s corresponding RCLF value. For instance, Women 

make up 39.0 percent of the physical scientist workforce, but they accounted for 45.8 

percent of the physical scientist hires in the last five years. For losses, Women did not leave 

at a rate substantially higher than their percentage in the workforce. Women accounted 

for 24.0 percent of the physical science workforce at the beginning of 2016 and have only 

accounted for 25.1 percent of the losses since that time. Thus, the data reveal no triggers 

related to hires and losses. 

2. Women appear to get promoted earlier and at higher rates than Men. For example, 

excluding SES and GS-15 employees, Women have been in their positions an average of 2.7 

years while Men have been in their positions an average of 3.6 years. 

3. Women are, on average, about four years younger than Men (Average Age: Men, 54.2; 

Women, 48.4), which could indicate that Women are earlier in their careers. 

4. Fewer Women have earned graduate degrees (Men, 94.1 percent; Women, 91.2 percent) 

and PhDs (Men, 83 percent; Women, 78.5 percent) compared to Men in these positions. 

5. Women score lower than Men in multiple areas within the New IQ. 

In addition to the findings mentioned above, Physical Scientists in general scored lower on the Global 

Satisfaction Index and the New IQ. There was insufficient data to further examine the Physical Scientist 

scores by demographic groups (see Table 3). 

Table 3. FEVS Index Scores for Selected Subgroups: 2019 

Index NASA 

Workforce 

Physical 

Scientists AAPI Female 

Employee Engagement 83.0% 81.2% 88.6% 82.1% 

Global Satisfaction 81.5% 78.8% 81.3% 82.5% 

New Inclusion Quotient (New IQ) 79.3% 76.3% 80.3% 74.2% 

Notes: Triggers highlighted in yellow. Index scores represent the percent of positive responses. 

Phase 3 

Purpose of Phase and Data Examined: Phase 3 is an expansion on Phase 2, involving a further analysis 

of personnel data. To gain additional insight before generating a strategy for subsequent phases of the 

barrier analysis, NASA analyzed applicant flow data, loss data, retirement eligibility disparities, and 

training data. 

Data Findings: 

• Asian Americans and Pacific Islanders in the Physical Sciences: With regard to retirement 

eligibility, it was found that this may be a contributing factor with 32.9 percent of the AAPI 

workforce currently eligible for retirement. This group had the highest retirement rate with 

66 
White employees having the second highest at 31.9 percent and all other demographic groups 

showing less than one-quarter of their physical science workforce retirement eligible. 

• Women in the Physical Sciences: An examination of training data yielded no insights on the 

low promotion rates among women in physical sciences. 

Phase 4 

Purpose: Phase 4 is designed to identify what is known about the workforce, and where there is a need 

for additional data. Thus, there are two goals of this phase: (1) systematically summarize the findings 

of Phases 1-4, and (2) ask additional questions to organization leaders and human resources to help 

identify what questions need to be asked in the subsequent phases of this barrier analysis. 

Date Examined: First, NASA reexamined that data and summaries on Phases 1-3 to identify 

strategically where we still have remaining questions that our current data can’t answer. Second, we 

used qualitative interviewing to address key questions currently unanswered in our current data. 

Findings: This phase is currently in the final stages; results are expected to be finalized in early FY 2022. 

Subsequent Phases and Approximate Timeline 

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. 

67 
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. 

68 
APPENDIX D: LIST OF FREQUENTLY USED ACRONYMS 

AA Associate Administrator 

AAPI Asian Americans and Pacific 

Islanders 

ADR Alternative Dispute 

Resolution 

AFRC Armstrong Flight Research 

Center 

AHP Anti-Harassment Program 

AIAN American Indians and Alaska 

Natives 

ARC Ames Research Center 

AST Aerospace Technology 

CAP Complaints and Programs 

Division 

D&I Diversity and Inclusion 

DAD Diversity and Data/Analytics 

Division 

DEIA Diversity, Inclusion, Equity, 

and Accessibility 

EEO Equal Employment 

Opportunity 

EEOC Equal Employment 

Opportunity Commission 

ERG Employee Resource Group 

FEVS Federal Employee Viewpoint 

Survey 

GRC Glenn Research Center 

GSFC Goddard Space Flight Center 

HQ NASA Headquarters 

IWD Individuals with Disabilities 

IWTD Individuals with Targeted 

Disabilities 

JSC Johnson Space Center 

KSC Kennedy Space Center 

LaRC Langley Research Center 

LGBTQ+ Lesbian, Gay, Bisexual, 

Transgender, and Queer 

and/or Questioning 

MD-715 Management Directive 715 

MSFC Marshall Space Flight Center 

NASA National Aeronautics and 

Space Administration 

NCLF National Civilian Labor Force 

NPD NASA Policy Directive 

NPR NASA Procedural 

Requirement 

NSSC NASA Shared Services Center 

ODEO Office of Diversity and Equal 

Opportunity 

OCHCO Office of the Chief Human 

Capital Officer 

OPM Office of Personnel 

Management 

PA Professional Administrative 

PAS Personal Assistance Services 

RA Reasonable Accommodation 

RCLF Relevant Civilian Labor Force 

S&E Science and Engineering 

SEP Special Emphasis Program 

SES Senior Executive Service 

SSC Stennis Space Center 

STEM Science, Technology, 

Engineering, and Mathematics 

WFF Wallops Flight Facility 

69