EEOC FORM 

715-02 

PART A - D 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

PART A 

Department 

or Agency 

Identifying 

Information 

PART B 

Total 

Employment 

1. Agency 

1.a 2nd level reporting component 

2. Address 

3. City, State, Zip Code 

1. Railroad Retirement Board 

N/A 

2. 844 N. Rush Street 

3. Chicago, IL 60611 

4. Agency Code 5. FIPS code(s) 4. RR00 5. 

1. Enter total number of permanent full-time and part-time employees 

2. Enter total number of temporary employees 

3. TOTAL EMPLOYMENT [add lines B 1 through 2] 

PART C 

Agency Official(s) Responsible 

For Oversight of EEO 

Program(s) 

Title Type Name Title 

Head of Agency Erhard R. Chorlé Chairman of the Board 

Head of Agency John Bragg Labor Member of the Board 

Head of Agency Thomas R. Jayne Management Member of the Board 

Principal EEO Director/Official Shiri Ndang Director of Equal Opportunity 

Other EEO Staff Kathy Robinson EEO Specialist 

17 

1. 745 

2. 16 

4. 761 

Page 1 
Page 2 

EEOC FORM 

715-02 

PART A - D 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

For period covering October 1, 2021 to September 30, 2022 

PART D 

List of Subordinate Components Covered in 

This Report 

Subordinate Component and Location 

(City/State) 

Country Agency Code 

EEOC FORMS and Documents Required Uploaded 

Reasonable Accommodation 

Procedure 

Y Y 

Anti-Harassment Policy and 

Procedures 

Y Y 

Organization Chart Y Y 

EEO Policy Statement Y Y 

Agency Strategic Plan Y Y 

Alternative Dispute Resolution 

Procedures 

Y Y 

Personal Assistance Services 

Procedures 

Y Y 

Human Capital Strategic Plan N N 

EEO Strategic Plan N N 

Disabled Veterans Affirmative 

Action Program (DVAAP) Report 

N N 

Results from most recent Federal 

Employee Viewpoint Survey or 

Annual Employee Survey 

N N 

Diversity Policy Statement N N 

Federal Equal Opportunity 

Recruitment Program (FEORP) 

Report 

N N 
EEOC FORM 

715-02 

PART E.1 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: MISSION 

Overview 

This Equal Employment Opportunity (EEO) Program Status Report for Fiscal Year (FY) 2022 is prepared and submitted pursuant to the Equal Employment 

Opportunity Commission’s Management Directive 715 (MD-715) and accompanying instructions and guidance. MD-715 provides a roadmap for creating 

effective EEO programs for all federal employees as required by Title VII and the Rehabilitation Act.  The stated objective of MD-715 is to ensure that all 

employees and applicants for employment enjoy equality of opportunity in the federal workplace, regardless of race, sex, national origin, color, religion, 

disability, or reprisal for engaging in prior protected activity. Additionally, the EEOC seeks to ensure the same opportunities to all groups regardless of age, 

genetic information, pregnancy, or other prohibited bases. 

MD-715 requires agencies to take appropriate steps to ensure that all employment decisions are free from discrimination. It sets forth standards by which 

the Agency’s EEO programs will be reviewed by the EEOC, including, but not limited to, the requirement that agencies conduct periodic self-assessments 

and barrier analysis to identify and remove barriers which may preclude access to equal employment opportunities in the workplace. This report highlights 

accomplishments by the Railroad Retirement Board (RRB or the Agency) in FY 2022 in continuing to establish and solidify its EEO Program. 

This report also identifies areas where the RRB will take further actions to enhance its EEO Program.  As required by the EEOC, this report was completed 

utilizing data compiled at the end of fiscal year FY 2022 and covers the period from October 1, 2021, through September 30, 2022. The workforce data 

utilized includes permanent employees and was obtained from the Agency’s Bureau of Human Resources. 

Mission of the Railroad Retirement Board 

The Railroad Retirement Board (RRB) is an independent agency in the Executive Branch of the Federal Government. Its mission is to 

administer retirement/survivor and unemployment/sickness insurance benefit programs for the railroad workers and their families under the 

Railroad Retirement Act and the Railroad Unemployment Insurance Act. These programs provide income protection during senior age and 

in the event of disability, death or temporary unemployment and sickness. The RRB also administers aspects of the Medicare program and 

has administrative responsibilities under the Social Security Act and the Internal Revenue Code. 

The RRB is the only Federal Agency headquartered in Chicago, Illinois. Of the 761 employees, approximately 257 employees work in 53 

district offices located throughout the United States with the remainder of our employees in Chicago, Illinois. 

The work we do affects the lives of over half a million people who receive various types of benefits from the agency. In response to 

changing national demographics, the RRB is positioning itself to better meet the needs of the 21st century by becoming an employer of 

choice in the Federal government, regardless of race, sex (including pregnancy, sexual orientation, and gender identity), age, color, national 

origin, disability, religion, and genetic information. This will not only infuse the RRB with the best and the brightest employees available, 

but it will also improve our ability to understand and appreciate each other, while serving an increasingly diverse railroad community. 

RRB is achieving its mission and vision through data-driven analysis, innovative use of technology, flexible work arrangements, valuing 

great teamwork and top talent. RRB strives to recruit and retain a highly qualified and diverse workforce to carry out this mission. RRB is 

using data purposefully to support informed decision-making in all internal and external functions. RRB strives to be an innovative, 21st 

century agency in its approach to technology. Finally, RRB invests in world-class training, development, and support to create an 

environment that encourages employees at all levels to tackle complex challenges.  

To accomplish these goals, RRB is divided into eight Divisions: 

• Bureau of the Actuary and Research 

• Bureau of Field Service (FS) 

• Bureau of Fiscal Operations (BFO) 

• Bureau of Information Services (BIS) 

• Office of Administration (OA) 

• Office of General Counsel (OGC) 

• Office of Programs (OP) 

• Office of Equal Opportunity (OEO) 

Office of Equal Opportunity (OEO) 

The Office of Equal Opportunity (OEO) works to ensure that RRB complies with all federal EEO laws and related civil rights protections; 

provides a neutral forum for the discussion, investigation, and resolution of certain EEO matters; and strives to integrate EEO into RRB’s 

everyday work. OEO also works to empower employees to participate constructively to their fullest potential in support of RRB’s mission. 

Page 3 
EEOC FORM 

715-02 

PART E.1 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: MISSION 

OEO endeavors to ensure that RRB reflects the rich diversity of the nation and provides a full and fair opportunity for all employees and 

applicants, and that RRB employees have the working environment that will support them in their efforts to protect consumers. 

Among other services, OEO provides policy and technical advice on EEO and civil rights to the Board and senior leadership and manages 

the Agency’s EEO complaint process pursuant to 29 C.F.R. Part 1614. OEO works to ensure the EEOC’s six essential elements of a model 

EEO Program are incorporated into the fabric of the Agency, thus supporting the goal of maintaining a discrimination-free workplace for all. 

The Director of OEO reports directly to the 3-member Board. OEO emphasizes and maintains its neutrality and impartiality, which is 

critical to having an efficient and fair EEO complaint resolution process. This ensures that employees and managers know that the precomplaint and investigation stages of the Part 1614 process are not adversarial, that OEO will provide a neutral and impartial factual record, 

and that, when requested, OEO will issue a final decision assessing the facts and law to determine whether or not one or more of the 

applicable employment discrimination laws have been violated.  

The OEO Director exercises full authority to carry out the Part 1614 functions of OEO without the involvement of the agency’s Legal 

Component (i.e., General Counsel), thus ensuring impartiality and removing any possible conflict of interest. Legal resources within OEO 

make this possible (i.e., the OEO Director is an Attorney). OEO staff, sometimes with the assistance of contractors, conducts legal 

sufficiency reviews of EEO matters, which includes issuing accept/dismiss decisions addressing jurisdiction over and scope of claims set 

forth in formal complaints, Reports of Investigations (ROIs), and Final Agency Decisions (FADs). The Office of General Counsel (OGC), 

which defends the RRB in these matters, is firewalled from all activities within OEO and only participates during adversarial portions of the 

EEO process (hearings and appeals), and during settlement negotiations, or to provide appropriate legal advice or assistance when a 

manager or supervisor requests it during the course of an EEO investigation. All other RRB offices are similarly firewalled and kept 

separate as necessary and appropriate to avoid conflicting or competing interests. 

At the same time, while OEO maintains primary responsibility for the Agency’s overall EEO program, it collaborates extensively with both 

Board staff and the RRB’s Office of Administration (OA) to ensure fairness and equality under the law for all employees and applicants for 

employment. OEO cooperates with the Office of Administration, in particular, regarding the reasonable accommodation processing and antiharassment prevention programs OA administers. OEO maximizes appropriate partnerships with Bureau leadership, Executive 

management, diversity committees (such as the Agency’s Employees with Disabilities Advisory Council, Federal Women’s Program 

Committee, and the Workplace Diversity Committee), and Employee Resource Groups (e.g., American Legion), to achieve OEO’s and the 

RRB’s mission and vision. 

Page 3 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

Equality of opportunity to participate and advance in the federal workforce is paramount to achieving the federal government’s goal of 

becoming a model employer. 

Throughout FY 2022, RRB made significant strides in developing a model EEO Program by conducting self assessments pursuant to 

MD-715.  RRB also implemented various action items delineated in its FY 2021 Program Status Report.  The Agency incorporated each of 

the six Essential Elements for a model EEO program outlined in MD-715: 

• Demonstrated commitment from Agency leadership; 

• Integration of EEO into the Agency’s strategic mission; 

• Management and program accountability; 

• Proactive prevention of unlawful discrimination; 

• Efficiency; and 

• Responsiveness and legal compliance. 

Essential Element A: Demonstrated Commitment from Agency Leadership 

Management Directive 715 requires agency heads and other senior management officials to demonstrate a firm commitment to equality of 

opportunity for all employees and applicants for employment. 

According to MD-715: 

Agencies must translate equal opportunity into everyday practice and make those principles a fundamental part of agency culture.  

This commitment to equal opportunity must be embraced by agency leadership and communicated through the ranks from the top 

down. It is the responsibility of each agency head to take such measures as may be necessary to incorporate the principles of equal 

employment opportunity into the agency’s organizational structure.  To this end, agency heads must issue a written policy 

statement expressing their commitment to equal employment opportunity (EEO) and a workplace free of discriminatory 

harassment. 

During FY 2022, RRB demonstrated its commitment to ensuring that talented and diverse staff have equal employment opportunities and 

are treated fairly and with respect. RRB is dedicated to maintaining a workplace that promotes professionalism and productivity, respects 

the dignity of all, and embraces education of employees about their EEO rights and responsibilities.   

Further demonstrating commitment from RRB leadership, the Board ensures that all EEO policy statements are timely and current. Every 

year, the Agency reissues EEO policy/antiharassment statements. The 3-member board issued the most recent EEO policy/anti-harassment 

statement in May 2022, reaffirming the Agency’s zero tolerance for workplace discrimination, harassment, or retaliation. The Office of 

Equal Opportunity also updated the agency’s public website (which is available to all RRB employees, former employees, and applicants) in 

March 2022 to include No FEAR Act information and notices. 

RRB provides all new employees with the No FEAR Act notice, the EEO policy/antiharassment statement, and other relevant policies 

during orientation/onboarding and provides them again to all employees promoted to supervisory ranks. These policy statements affirm that 

the Board Members, Executive Committee Members, the OEO Director, RRB managers, and front-line supervisors will uphold and enforce 

EEO and merit system principles. The EEO policy statement and No FEAR Act notice make it clear that equal employment opportunities 

exist for all employees and applicants for employment, regardless of their race, color, religion, sex (including pregnancy, sexual 

orientation, gender identity or expression), national origin, age, disability, genetic information, prior protected EEO-related activity, and/or 

whistleblower activity. 

Further, the Board and senior leadership have publicly demonstrated commitment to the EEO program in additional ways. In FY 2022, the 

Board Members included the OEO Director in Board briefings and meetings, reflecting their recognition of the importance of this role to the 

Agency’s diversity and inclusion and EEO compliance efforts. Board Staff and the Senior Executive Officer (SEO) also met monthly with 

the OEO Director to stay apprised of important EEO-related developments and trends. The Senior Executive Officer also participated and 

provided feedback on the Agency’s special emphasis observance activities. 

These are just a few examples of the many actions agency leaders have taken to demonstrate their strong personal commitment to 

guaranteeing equal employment opportunities for all employees. 

Page 4 
  

EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

Essential Element B: Integration of EEO into Agency’s strategic mission 

Management Directive 715 notes that equality of opportunity is essential to attracting, developing, and retaining the most qualified 

workforce to support an agency’s achievement of its strategic mission. To this end, under MD-715 (and in addition to the regulatory 

requirements found at 29 C.F.R. § 1614.102(b)(4), as interpreted in Management Directive 110) the RRB must: 

• Maintain a reporting structure that provides the Agency’s EEO Director with regular access to the Agency head and other senior 

management officials for reporting on the effectiveness, efficiency, and legal compliance of the Agency’s Title VII and Rehabilitation 

Act programs. To emphasize the importance of the position, the Agency head should be involved in the selection and performance 

review of the EEO Director. 

• Ensure EEO professionals are involved with, and consulted on, the management and deployment of human resources. The EEO 

Director should be a regular participant in senior staff meetings and regularly consulted on human resources issues. 

• Allocate sufficient resources to create and/or maintain Title VII and Rehabilitation Act programs that (1) identify and eliminate barriers 

that impair the ability of individuals to compete in the workplace because of race, national origin, sex, or disability; (2) establish and 

maintain training and education programs designed to provide maximum opportunity for all employees to advance; and (3) ensure that 

unlawful discrimination in the workplace is promptly corrected and addressed. 

• Attract, develop, and retain EEO staff with the strategic competencies necessary to accomplish the Agency’s EEO mission, and 

interface with Agency officials, managers, and employees. 

• Recruit, hire, develop, and retain supervisors and managers who have effective managerial, communications, and interpersonal skills. 

Provide managers and supervisors with appropriate training and other resources to understand and successfully discharge their duties 

and responsibilities. 

• Involve managers and employees in the implementation of the Agency’s Title VII and Rehabilitation Act programs. 

• Use various media to distribute EEO information concerning federal EEO laws, regulations and requirements, rights, duties, and 

responsibilities and to promote best workplace practices. 

These aspects of integrating EEO into the Agency’s strategic mission are discussed in greater detail below. 

Reporting structure 

RRB’s reporting structure allows the OEO Director to have direct and regular access to Board members and their staff. OEO’s physical 

space is located on the same floor in Headquarters as the Board Offices. The OEO Director reports directly to the 3-member board. This 

reporting structure allows the EEO program to be run efficiently and effectively. Critically, this reporting structure provides the OEO 

Director with the autonomy and authority needed to carry out a successful EEO Program while also leveraging synergies between the work 

of OEO and the Executive Committee. 

The major duties and responsibilities of the OEO Director are clearly defined and include developing, implementing, and managing 

comprehensive, broad-scope RRB EEO policies, programs, and services. The OEO Director also serves as the principal technical advisor to 

the Board Members and to the Agency’s leadership on EEO and civil rights issues and policies, and is readily available for consultation 

purposes. 

Further, the OEO Director has access to other senior management officials for reporting on the effectiveness, efficiency, and legal 

compliance of the Agency’s EEO program. In FY 2022, the OEO Director met monthly with the Senior Executive Officer (SEO) and has 

continued these monthly meetings with his successor (Chief of the Executive Committee). 

Collaboration 

To ensure integration of EEO into the Agency’s strategic mission, the OEO Director collaborates closely with the Office of Administration 

(OA) the Bureau of Human Resources (HR), as well as other stakeholders (e.g., Bureau of Information Services)  across RRB. Positive 

working relationships have been established that support information-sharing and best practices among the offices. The  Director of Human 

Resources and OEO Director meet to discuss whether personnel programs, policies, and procedures are in conformity with instructions 

contained in EEOC regulations, Management Directives, and other guidance. Further, Office of Administration (OA) and Board staff confer 

with OEO for advice and consultation for guidance on diversity outreach strategy and approach, training curriculum and goals, and 

operational improvements that support compliance and diversity before making decisions. For instance, OEO has: 

Page 4 
  

  

EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• Continued to participate in the RRB’s efforts to implement the agency’s Diversity, Equity, Inclusion and Accessibility (DEIA) Plan. 

This plan outlines RRB’s affirmative employment and diversity and inclusion goals and priorities, and the specific actions that will 

support them. 

• Continued to collaborate with the Chief Learning Officer to enhance supervisory and employee training offered by Bureau of Human 

Resources on RRB University, to ensure that EEO compliance, diversity and inclusion concepts are addressed in New Employee 

Orientation, supervisory development and leadership excellence seminars, performance management training, etc. 

• Continued to work with the Bureau of Human Resources to encourage the staff to maintain relationships with, and outreach to, 

professional organizations that represent Veterans, Disabled Veterans, and other minority constituencies. This includes posting 

vacancies on bulletin boards geared to these groups of professionals. 

• Partnered with the Bureau of Human Resources to revise and reinstitute the agency’s use of an exit survey to examine employee 

perceptions of the organization across demographic groups. 

• Continued to be an active participant on the Agency’s Equity Team. 

• Partnered and advised on the development and implementation of the Agency’s reinstituted EEO Awards and Recognition program, 

established to recognize RRB employees and groups for their exceptional efforts in promoting equal employment opportunity in the 

workplace. 

Resources for the EEO program 

The agency is fully compliant with the 29 CFR § 1614.102(a)(1), which requires the agency’s EEO office to have a budget that is separate 

from other offices within the agency. During FY 2022, the Agency allocated additional resources OEO requested to enhance and ensure that 

the EEO Program remains successful and operates in an effective manner. This has proved vital to ensuring integration of EEO into the 

Agency’s strategic mission. 

During FY 2022, OEO secured approval to hire a consulting firm to perform DEIA workforce trend and other data analyses, such as 

identifying triggers and barriers to EEO agencywide. In addition, OEO procured approval to hire a Pathways intern (EEO Student Trainee) 

to assist in maintaining and enhancing the quality and timeliness of all aspects of the Part 1614 complaint process. 

OEO also has resources available through staff, ad hoc EEO counselors and contractors to ensure that allegations of unlawful discrimination 

in the workplace are processed in accordance with 29 C.F.R. Part 1614 requirements. 

Finally, RRB has allocated financial resources to create and/or maintain necessary Title VII and Rehabilitation Act programs. 

Attracting, developing, and retaining EEO staff 

One vital element to ensuring that EEO is integrated into the mission of the Agency is to attract, train, and keep well-qualified staff within 

OEO. During FY 2022, the Board hired an OEO Director who had previously worked at EEOC and is a licensed attorney. As also 

mentioned above, in FY 2022 OEO was allocated additional resources to address critical programmatic needs, such as barrier analysis and 

accurate EEO data collection. During FY 2022, OEO retained both of its permanent, full-time staff members. 

OEO staff has also received training to maintain the competencies necessary to accomplish RRB’s EEO functions and mission. Some of 

these trainings involve personnel from other Board divisions, such as HR and OGC, presenting excellent opportunities for knowledgesharing and collaboration across the Agency. 

Recruiting, hiring, developing, and retaining supervisors and managers 

To ensure the Agency integrates EEO into its daily mission, RRB works to hire, develop, and retain supervisors and managers who have 

effective managerial, communication, and interpersonal skills to supervise most effectively in a workplace with diverse employees and to 

avoid disputes arising from ineffective communications. One of RRB’s top diversity and inclusion goals is to recruit talent from a diverse 

group of potential applicants to develop a high performing workforce drawn from all segments of American society. Each year, Board staff 

and Executive Committee Members, in consultation with the Bureau of Human Resources (HR), collaborate to develop a critical hire list. 

HR has focused on utilizing online platforms and organizations that best align with RRB’s hiring needs. To develop and retain managers 

and supervisors, the Agency provides appropriate and critical training. This helps ensure RRB managers and supervisors have – and feel 

properly equipped with – the skills and competencies needed to fulfill their responsibilities and duties under the Agency’s EEO program, as 

well as the ability to properly supervise a diverse staff of employees.   

Distributing EEO information 

Page 4 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

The RRB uses various media and other innovative means to distribute EEO information.  These efforts assist in ensuring that EEO is 

integrated into the Agency’s strategic mission and crucial EEO-related information is readily accessible at all times. 

The Agency publicizes EEO events and activities to all employees through email announcements, notices on the Agency’s internal (intranet) 

page, and on posters in RRB offices. 

Further, the OEO internal (intranet) page on Boardwalk is an excellent resource for individuals wanting information about the EEO process. 

The OEO internal (intranet) page clearly describes the Part 1614 process, contains links to all pertinent policies and procedures, that is 

updated and augmented routinely. The OEO internal (intranet) page also contains contact and location information for OEO, including 

contact information for all OEO staff, to ensure that employees can easily seek OEO’s assistance in person or virtually. 

In FY 2022, informational materials and forms were updated and made available to employees (and to the public) in electronic format via 

the agency’s internal and external-facing web presences. The OEO public-facing webpages provide detailed information regarding the EEO 

complaint process (to include explicit notification of the 45-calendar day requirement for entry into the EEO complaint process); agency 

workforce statistics; copies of mandated annual and quarterly reports; EEO training resource information; information regarding Section 

508 and Architectural Barriers Act noncompliance complaints processes; a detailed overview of the agency’s Alternative Dispute 

Resolution Program; and information regarding the agency’s Reasonable Accommodation Program and Personal Assistance Services. Hard 

copies of updated EEO Program posters remained posted within prominent areas at all RRB locations. 

Additionally, the OEO Director ensured EEO principles remained ingrained within the agency’s strategic mission, ensuring all employees 

received important EEO-relevant information via the EEO “Working Together” Quarterly Newsletter, which is emailed to every RRB 

employee. During FY 2022, OEO ensured inclusion of newsletter articles and information with specific regard to diversity, equity, 

inclusion, accessibility; acceptable and unacceptable employee conduct in the workplace, and supervisors’ responsibility to address 

unacceptable behavior; Alternative Dispute Resolution and mediation; identification and addressing acts of workplace bullying; Sexual 

Harassment prevention and response; and Reasonable Accommodation. 

The Agency has an active Special Emphasis Program, which is a joint effort by OEO, Employees with Disabilities Advisory Council 

(EDAC), Federal Women’s Program Committee (FWPC) and the Workplace Diversity Committee (WDC) whose role is to advocate and 

address the concerns of employees. 

OEO also conducts, collaborates in presenting, and/or sponsors numerous virtual trainings, as well. 

Essential Element C: Management and Program Accountability 

Management Directive 715 explains that a model Title VII and Rehabilitation Act program will hold managers, supervisors, EEO officials, 

and personnel officers accountable for the effective implementation and management of an agency’s EEO program. Per MD-715, in 

ensuring such accountability, the RRB must: 

• Conduct regular internal audits, on at least an annual basis, to assess the effectiveness and efficiency of the Title VII and Rehabilitation 

Act programs and to ascertain whether the Agency has made a good faith effort to identify and remove barriers to equality of 

opportunity in the workplace. 

• Establish procedures to prevent all forms of discrimination, including harassment, retaliation, and failure to provide reasonable 

accommodation to qualified individuals with disabilities. 

• Evaluate managers and supervisors on efforts to ensure equality of opportunity for all employees. 

• Maintain clearly defined, well-communicated, consistently applied, and fairly implemented personnel policies, selection, and 

promotion procedures, evaluation procedures, rules of conduct, and training systems. 

• Implement effective reasonable accommodation procedures that comply with applicable executive orders, EEOC guidance, the 

Architectural Barriers Act, the Access Board’s Uniform Federal Accessibility Standards and Electronic, and Information Technology 

Accessibility Standards. 

• Be mindful of the Agency’s disability program obligations, including the provision of reasonable accommodations, when negotiating 

collective bargaining agreements with recognized labor organization(s) representing Agency employees. 

• Ensure effective coordination between the Agency’s EEO programs and related human resource programs, including the Federal Equal 

Opportunity Recruitment Program (FEORP), the Selective Placement Programs, and the Disabled Veterans Affirmative Action 

Program (DVAAP). 

• Review each finding of discrimination to determine the appropriateness of taking disciplinary action against Agency officials involved 

in the matter. Track these decisions and report trends, issues, and problems to Agency leadership for appropriate action. 

Page 4 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• Ensure compliance 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. 

Audits and Reviews of RRB programs 

RRB uses internal audits and assessments (among other methods) to ensure management and program accountability. In FY 2022, RRB 

conducted or was involved in various audits and reviews of its EEO program to ascertain whether the Agency has made a good faith effort 

to identify and remove barriers to equal opportunities in the workplace and promote diversity and inclusion Agency-wide. 

Most notably, as part of the EEOC’s oversight responsibility for federal agency EEO programs and per the EEOC’s Federal Sector 

Complement Plan (FCP), the EEOC’s Office of Federal Operations (OFO) conducts technical assistance visits to various federal agencies 

each year. For FY 2022, RRB was one of the several agencies EEOC selected for a technical assistance visit. On February 3, 2022, OFO 

staff met with OEO staff to review the status of RRB’s EEO program with respect to its: (1) EEO Director’s Participation in Senior-Level 

Meetings; (2) Employee and Manager Recognition for EEO Accomplishments; (3) Exit Interview Data Collection; (4) Timetables to review 

agency programs for systemic barriers analysis; (5) Workforce and Applicant Flow Data; and (6) Model Disability Program compliance. In 

a letter to the OEO Director and Chair of the Board dated August 1, 2022, the EEOC stated (among other things): 

• We commend RRB for using innovative techniques to provide training for its employees. The agency established a training portal 

(“RRB University”), which offers a roadmap to success for managers, supervisors, and HR personnel regarding hiring and retaining 

employees. The portal also includes nearly 9,000 skill soft courses for agency employees to obtain training. 

• In Part G, Question B.1.d of its FY 2020 MD-715 report, RRB acknowledged that the EEO Director does not regularly participate in 

senior-level staff meetings. The agency established a plan in Part H.2 to address this deficiency by January 31, 2021. In response to our 

Notice Letter, RRB stated the agency is currently working on a plan of action for the EEO Director to attend Board meetings as well as 

have a recurring bi-weekly meeting with the agency’s Senior Executive Officer (SEO) to discuss agency operations and policy issues. 

As a result, the EEO Director has recurring bi-weekly meetings with the Senior Executive Officer (SEO) and weekly meetings with the 

Senior Executive Committee Members to discuss personnel, budget, technology, and other workforce issues. We commend RRB for 

demonstrating meaningful progress towards correcting this deficiency and look forward to reviewing the agency’s continued progress 

in the next MD-715 report. 

• In Part G, Question A.3.a of its FY 2020 MD-715 report, RRB acknowledged that the agency does not recognize staff for superior 

EEO accomplishments. In Part H.1, RRB established a plan to correct this deficiency by December 15, 2022. The objective of the plan 

is to include an EEO element in the performance appraisals of employees and managers. Since the only planned activity addresses the 

addition of a sub-element in managers’ performance appraisals, we request that the agency clarify whether employees will also have an 

EEO element in their performance appraisal. Nevertheless, we are pleased to note that in FY 2021, RRB added EEO language as a subelement in managers’ appraisals and intends to share the appraisal “write-ups” showing superior accomplishments with the EEO office. 

During our meeting, RRB also stated that the Awards Policy has been updated to include two EEO Recognition Awards. Currently, the 

EEO Director, the Senior Executive Leader, and Director of Human Resources are working to implement the policy. We look forward 

to reviewing RRB’s continued progress toward correcting this deficiency in its next MD-715 report. 

• In Part G, Question C.4.b of its FY 2020 MD-715 report, RRB acknowledged that the agency has not established timetables to review 

its Merit Promotion, Employee Recognition/Awards, and Employee Development/Training programs. Although RRB created a plan in 

Part H.3 to address this deficiency by October 1, 2023, the agency did not include any planned activities.  In response to our Notice 

Letter, RRB stated the agency intends to provide its EEO staff with training on MD-715 and Barrier Analysis, so they can identify 

systemic barriers in policies.  We expect RRB to revise Part H by including planned activities to ensure EEO staff receives barrier 

analysis trainng and to establish a schedule to review its programs. 

• Each federal agency must “provide sufficient resources to its equal employment opportunity program to ensure efficient and successful 

operation.” 29 C.F.R § 1614.102 (a)(1). Applicant flow data is an essential tool in evaluating where barriers may exist within the 

agency. Part G, Question B.4.a.7 of the FY 2018 MD-715 report establishes that all agencies, regardless of size, must collect accurate 

and complete applicant flow data for (1) new hires, (2) internal promotions, and (3) participation in the career development program. In 

Part G, Questions E.4.a.2 and E.4.a.4 of its FY 2020 MD-715 report, RRB stated that the agency collects the required demographic and 

applicant flow data. However, after reviewing the agency’s FY 2020 workforce data tables, we found that the tables do not include the 

required data. We expect RRB to establish a plan to correct this deficiency in Part H of its next MD-715 report. 

• In Part G, Question D.1.c of its FY 2020 MD-715 report, RRB acknowledged the agency does not conduct exit interviews that include 

the disability-related questions. The agency commented that the HR office discontinued exit interviews due to the lack of staffing. The 

agency established a plan in Part H.4, requiring the EEO office to meet with the Director of HR about re-establishing exit surveys by 

October 1, 2022. In response to our Notice Letter, RRB advised that the exit interview survey went live via Microsoft Forms and two 

departing employees have completed the survey online. We remind the agency that the exit interview survey must include questions on 

how the agency could improve the recruitment, hiring, inclusion, retention, and advancement of employees with disabilities. We expect 

RRB to revise the objective and planned activities so the agency will ensure the disability-related questions are added to its exit 

interview survey. 

Page 4 
  

  

EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• After reviewing RRB’s FY 2020 [Affirmative Action Plan], EEOC has determined that the agency has satisfied all three minimum 

requirements: (1) issued compliant reasonable accommodation procedures; (2) posted personal assistance services procedures on its 

public website; and (3) established regulatory goals for people with disabilities (PWD) and people with targeted disabilities (PWTD). 

• As part of the agencies’ obligation to engage in affirmative action, EEOC amended its regulations implementing Section 501 of the 

Rehabilitation Act of 1973 to require agencies to provide personal assistance services (PAS). Personal assistance services helps 

individuals who, because of targeted disabilities, require assistance to perform basic activities of daily living (e.g., eating and using the 

restroom), but the services are not related to their job performance. Pursuant to 29 C.F.R. 1614.203(d)(5)(v), agencies must adopt and 

post their PAS procedures on their public website by January 3, 2018. Our records show that RRB has posted PAS procedures on its 

public website. We thank RRB for complying with this requirement. 

• EEOC regulation, 29 C.F.R. § 1614.203(d)(7)(i), requires agencies to adopt the goals of achieving a 12% representation rate for people 

with disabilities (PWD) at the GS-11 and above (including SES) and at the GS-10 level and below. Using the same grade level clusters, 

agencies must also adopt goals for individuals with targeted disabilities (PWTD) to reach 2%. Only permanent, full-time, non-seasonal 

employees count toward the goals. A review of RRB’s Affirmative Action Plan (AAP) shows that the agency established the goals for 

PWD and PWTD in the two grade level clusters. We commend RRB for implementing these goals for PWD and PWTD. 

• In FY 2020, RRB established a plan to gradually increase the number of PWD and PTWD by communicating the numerical goals to 

hiring officials through its Plan for Increasing and Maintaining the Employment of Individuals with Disabilities. This plan was shared 

with the Executive Committee who disseminated it to their staff with hiring authority. We are also pleased to note that RRB has 

provided its vacancy announcements to organizations that assist people with disabilities in seeking employment. To meet all of the 

regulatory goals, we urge RRB to expand its plan to include (1) conducting additional outreach and recruitment efforts for PWTD in 

the senior grade levels, (2) offering training, internship, and mentoring programs for PWTD to reach the senior grade levels, and (3) 

providing disability-related training to its managers and employees. We look forward to reviewing the agency’s progress in its next 

AAP. 

• We commend RRB for ensuring that its disability program has sufficient funding and training. Although RRB stated the disability 

program has sufficient qualified staffing, the agency did not identify staff who are responsible for processing applications from PWD 

and PWTD. We commend the agency’s HR office for designating a HR Specialist to assist in contacting different organizations that 

assist PWD in seeking employment. In its next AAP, we expect RRB to demonstrate continued progress toward fully staffing its 

disability program. 

• According to its FY 2020 AAP, RRB has developed a comprehensive plan that uses different programs and resources to identify and 

hire job applicants with disabilities, including those with targeted disabilities. We recognize that the Railroad Retirement Act requires 

RRB to fill positions through the competitive service, which prevents the agency from using the hiring authorities that take disability 

into account. To improve its recruitment of PWD and PWTD, RRB has established and maintained contacts with 11 organizations that 

assist PWD and PWTD. These organizations include the Chicago Lighthouse, Aspire Non-Profit, Trinity Services, Inc., Search, Inc., 

Goodwill Chicago, America Works, the City of Chicago’s Department of Human Services, Independent Living and Transition 

Advocate Progress Center, and Southwest American Job Center. After securing a contact person at each organization, RRB sends its 

vacancy notices to the organizations for disbursement to their clients. We are also pleased to note that the agency’s Employees with 

Disabilities Advisory Council assists in finding organizations that assist people with disabilities. We look forward to reviewing RRB’s 

continued progress in recruiting and hiring PWD and PWTD. 

• All agencies must establish a comprehensive retention strategy for its employees with disabilities. Pursuant to 29 C.F.R. § 1614.203(d) 

(4), federal agencies are required to inform job applicants and employees of their rights concerning the accessibility of agency 

technology and facilities. See Section 508 of the Rehabilitation Act of 1973, 29 U.S.C. § 794(b); Architectural Barriers Act of 1968 

(ABA), 42 U.S.C. § 4151 – 4157. Since RRB has posted the ABA and Section 508 notices on its public website, we commend the 

agency for complying with this requirement. 

• After reviewing RRB’s AAP, we noted that RRB has not created a plan to investigate any triggers involving PWD and PWTD for 

potential barriers to equal opportunity. As noted above, we have identified several triggers for PWD and PWTD involving the 2210 

series, the senior grade levels, and possibly separations. While RRB does not need to conduct barrier analysis on all triggers next year, 

the agency must establish a schedule for investigating the triggers. In its next AAP, we expect RRB to establish a plan and demonstrate 

meaningful progress in its efforts to conduct barrier analysis. 

Notably, the EEOC did not infer or conclude that RRB had engaged in any unlawful employment practice, and did not identify any specific 

barrier to equal employment opportunity for any demographic group. As feasible given competing demands and limited resources, the 

Agency is focusing on incorporating all of the best practices identified as part of the EEOC’s technical assistance. 

OEO is currently working with various stakeholders, including Board staff, Director of Administration, Director of Human Resources, and 

the Executive Committee (EC), to ensure EEOC’s suggestions are incorporated into the Agency’s EEO program. For instance, OEO has 

consulted with the Bureau of Human Resources on a process to update its applicant flow data collection practices as well as a timetable for 

conducting barrier analysis. RRB has established a Barrier Analysis Workgroup and timetable to review its programs for systemic barriers. 

The Director of Human Resources has designated an HR staff member to assist with OEO’s barrier analysis workgroup. The Bureau of 

Human Resources is also working diligently to provide exit survey summary results to the Board, Executive Committee and OEO on a 

Page 4 
  

EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

quarterly basis. In May 2022, the Board approved reinstituting Equal Employment Opportunity (EEO) Awards to recognize RRB 

employees, groups or organizations for their achievements, contributions, and efforts in supporting equal employment opportunity in the 

RRB workplace. The FY 2022 RRB EEO Award was handed out in during an agency-wide award ceremony in November 2022. 

During FY 2022, the Bureau of Human Resources reinstated formal Exit Survey procedures and revised the Exit Survey Questionnaire to 

include disability-related questions.  The OEO Director plans to review and analyze the FY 2023 aggregate exit survey data on a quarterly 

and annual basis and compare it to results from the previous fiscal year (FY 2022) to determine whether triggers exist, and further analysis 

is necessary to identify any potential barriers to equal employment opportunities. If any of the anonymized responses indicate potential 

discrimination, the OEO Director will take appropriate action to investigate and address the matter. 

With respect to disability recruitment, hiring, and retention, the OEO Director will continue to work with Board staff and EC members to 

ensure the agency’s recruitment, training and professional development policies and procedures are reviewed. The Agency’s efforts to 

implement the EEOC’s recommendations regarding barrier analysis and its Model Disability Program are addressed in greater detail in Part 

H of this report. OEO also carefully monitors and incorporates employee feedback on its EEO program and overall diversity and inclusion 

efforts. For instance, during FY 2022 OEO drafted and implemented a new survey specifically soliciting feedback from agency employees 

and relevant stakeholders about its Special Emphasis Programs and events. As a follow-up to the EEOC’s technical assistance visit, and in 

line with MD-715 guidance, in FY 2022, RRB established procedures and timelines for conducting barrier analysis. This progress is 

addressed in greater detail in Part H of this report.  

Evaluating Managers and Supervisors 

RRB has taken measures to ensure that managers and supervisors are evaluated on their efforts to ensure equal opportunity for all 

employees. Specifically, Senior Executive Service (SES) members’ performance plans evaluate their ability to “leverage diversity,” and 

whether they foster and develop an inclusive workplace where a diverse set of talents and perspectives are valued in accomplishing the 

vision and mission of the Agency. Additionally, an EEO sub-element standard was adopted in FY 2020 and fully implemented in FY 2023 

to the performance plans for all non-executive supervisors (GS 15 and below). 

The Agency’s Office of Equal Opportunity (OEO) collaborates with HR staff to implement EEO and diversity-related goals, objectives, and 

initiatives. OEO and HR staff communicate regularly to address HR and EEO issues, including HR management initiatives to improve 

employee morale, performance management, diversity, reasonable accommodations, upward mobility and training and development. 

Finally, in all trainings related to any EEO topics, managers and supervisors are reminded that equal employment opportunity – including, 

critically, freedom from retaliation – is essential to attracting, developing, and retaining the most qualified workforce, and that a diverse 

workforce and a fair workplace are essential to ensuring that the RRB achieves its mission. This emphasizes to managers that they are 

responsible for the success of the EEO Program, and relatedly, to the success of the employees they supervise.  

Essential Element D: Proactive Prevention of Unlawful Discrimination 

According to Management Directive 715: 

Agencies have an ongoing obligation to prevent discrimination on the bases of race, color, national origin, religion, sex, age, 

reprisal, and disability, and eliminate barriers that impede free and open competition in the workplace.  As part of this ongoing 

obligation, agencies must conduct a self-assessment on at least an annual basis to monitor progress, identify areas where barriers 

may, operate to exclude certain groups and develop strategic plans to eliminate identified barriers. 

This element requires agencies to conduct a self-assessment at least annually to: identify barriers and potential barriers to EEO and diversity 

in the workforce; develop strategic and action plans to eliminate identified barriers; and to assess the progress and effectiveness of the 

Agency’s strategies and initiatives to remove barriers to EEO and promote diversity in the workforce. 

Self-assessments 

As discussed above, RRB has conducted or participated in various self-assessments, audits, and reviews that began or continued during FY 

2022. Proactively, and in response to specific recommendations made by EEOC, the Agency has invested substantial resources in building a 

workplace that fosters collaboration, leverages diverse viewpoints, and offers development and advancement opportunities to all employees. 

OEO staff performed monthly evaluation, trending, and reporting of the agency’s workforce statistics.  These statistics were compiled and 

Page 4 
  

EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

reported by gender; race; pay band/grade distribution; disability; and veteran preference status. The monthly administrative reports were 

submitted to the Board as well as personally provided by the OEO Director to the Senior Executive Officer (SEO) in FY 2022. 

Policies and procedures 

To help proactively prevent discrimination, the RRB has promulgated and enforces clear and concise EEO and anti-discrimination policies 

and procedures. These policies detail employee rights and responsibilities under EEO laws. Managers and supervisors share the 

responsibility for successful implementation of these policies, and as a result, the EEO Program. The OEO Director regularly reviews these 

policies and procedures to ensure they are up to-date, legally sufficient, well communicated, applied consistently, and implemented fairly. 

Ensuring that employees are treated with dignity and respect is critical to effective management. Employees are encouraged to discuss 

concerns with their managers and supervisors. Employees may also raise EEO-related concerns with OEO, and work-related concerns, 

including EEO related issues, with the Bureau of Human Resources (HR), the Employee Assistance Program or the AFGE union. The 

Agency also has an Alternative Dispute Resolution (ADR) Program, which encourages employees, managers, and supervisors to informally 

resolve workplace disputes at the lowest level possible. 

The Agency’s reasonable accommodation procedures, which were approved by EEOC, are posted on the Agency’s intranet and externalfacing public website. The Director of Human Resources has designated one person to carry out the responsibilities of the RRB’s 

Reasonable Accommodation program – a Reasonable Accommodation Coordinator (RAC). The Reasonable Accommodation program also 

receives legal support from the Office of General Counsel (OGC) to ensure it is complying with all legal obligations; support from the 

Bureau of Information Services (BIS) Section 508 Program Coordinator for technology issues; and technical assistance from OEO staff as 

needed. 

RRB ensures all managers and employees are thoroughly trained on the Agency’s EEO and diversity policies, which prohibit unlawful 

discrimination and harassment and promote diversity and inclusion in the workplace. 

Essential Element E: Efficiency 

Management Directive 715 explains that agencies must: 

• Have an efficient and fair dispute resolution process and effective systems for evaluating the impact and effectiveness of their EEO 

programs. 

• Maintain an efficient, fair, and impartial complaint resolution process. Agencies should benchmark against EEOC regulations at 29 

C.F.R. Part 1614 and other federal agencies of similar size highly ranked in EEOC’s Annual Report on the federal sector complaints 

process. 

• Ensure that the investigation and adjudication function of the Agency’s complaint resolution processes are kept separate from the legal 

defense arm of the agency or other agency offices with conflicting or competing interests. 

• Establish and encourage the widespread use of a fair alternative dispute resolution (ADR) program that facilitates the early, effective, 

and efficient informal resolution of disputes. Appoint a senior official as the dispute resolution specialist of the agency charged with 

implementing a program to provide significant opportunities for ADR for the full range of employment-related disputes. Whenever 

ADR is offered in a particular workplace matter, ensure that managers at all appropriate levels will participate in the ADR process. 

• Use a complaint tracking and monitoring system that permits the Agency to identify the location, status, and length of time elapsed at 

each stage of the Agency’s complaint resolution process, the issues, and the bases of the complaints, the aggrieved individuals/ 

complainants, the involved management officials, and other information necessary to analyze complaint activity and identify trends. 

• Identify, monitor, and report significant trends reflected in complaint processing activity. Analysis of data relating to the nature and 

disposition of EEO complaints can provide useful insight into the extent to which an agency is meeting its obligations under Title VII 

and the Rehabilitation Act. 

• Ensure timely and complete compliance with EEOC orders and the provisions of settlement/resolution agreements. 

• Maintain a system that collects and maintains accurate information on the race, national origin, sex, and disability status of agency 

employees. 

• Maintain a system that tracks applicant flow data, which identifies applicants by race, national origin, sex, and disability status and the 

disposition of all applications. 

• Maintain a tracking system of recruitment activities to permit analyses of these efforts in any examination of potential barriers to 

equality of opportunity. 

• Identify and disseminate best workplace practices. 

Page 4 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

To these ends, RRB continuously evaluates its EEO complaint resolution process to ensure it is efficient, fair, and impartial. 

Neutrality 

As noted above, the OEO Director reports directly to the 3-Member Board. OEO emphasizes and maintains its neutrality and impartiality, 

which is critical to having an efficient and fair EEO complaint resolution process. This ensures that employees and managers know that the 

pre-complaint and investigation stages of the Part 1614 process are not adversarial, that OEO will provide a neutral and impartial factual 

record, and that, when requested, OEO will issue a final decision assessing the facts and law to determine whether or not one or more of the 

applicable employment discrimination laws have been violated. 

The OEO Director exercises full authority to carry out the Part 1614 functions of OEO without the Office of General Counsel’s (OGC) 

involvement, thus ensuring impartiality and removing any possible conflict of interest. Legal resources added to OEO in FY 2022 make this 

possible. OEO staff, sometimes with the assistance of contractors, conducts legal sufficiency reviews of EEO matters, which includes 

issuing accept/dismiss decisions related to formal complaints, Reports of Investigations (ROIs), and Final Agency Decisions (FADs). OGC, 

which defends the RRB in these matters, is firewalled from all activities within OEO and only participates during adversarial portions of the 

EEO process (hearings and appeals), and during settlement negotiations, or to provide appropriate legal advice or assistance when a 

manager or supervisor requests it during the course of an EEO investigation. All other RRB components are similarly firewalled and kept 

separate as necessary and appropriate to avoid conflicting or competing interests.   

EEO Counseling and investigations 

OEO works to ensure that its counseling and investigations are done within the regulatory timeframes, and that all EEO counselor reports 

and ROIs are created with a high standard of quality and fairness to both parties. In FY 2022, OEO completed all counseling, investigations, 

final agency decisions within the prescribed regulatory timeframes. 

By conducting EEO counseling and investigation services through qualified Ad Hoc EEO Counselors and third-party contractors from the 

GSA Schedule, RRB provides a fair and effective dispute resolution system in accordance with 29 C.F.R. Part 1614. All Ad Hoc EEO 

Counselors and contractors meet the 32 hours of training and eight hours of refresher training requirements set by the EEOC’s Management 

Directive 110, and OEO seeks to hold counselors and contactors accountable for counseling and investigation processing timeframes.  

Alternative Dispute Resolution (ADR) program 

RRB has an ADR Policy, and OEO provides additional information about the benefits of ADR on the Agency’s intranet. These materials 

explain the ADR process, why employees should consider ADR, the different types of ADR (mediation, informal settlements), and how an 

employee can request ADR. The RRB’s ADR Policy makes clear that although ADR is voluntary for EEO filers, supervisors and managers 

must participate in good faith if a filer elects ADR. The goals in having this strong ADR policy include resolving conflicts at an early stage, 

improving workplace communication and morale and creating a more efficient EEO Program. 

OEO offers ADR during the pre-complaint and formal complaint stages of the EEO process, including while cases are pending before the 

EEOC for hearing or on appeal.  

Complaint and workforce tracking and monitoring systems 

During FY 2022, OEO staff used an Excel spreadsheet for EEO complaint tracking, reporting, and managing the overall effectiveness of 

RRB’s EEO Program. 

The RRB also has in place various data systems that allow for periodic examinations of the agency’s workforce profiles by demographic 

characteristics. These systems maintain information on the race, national origin, sex, and disability status of RRB employees. Further, these 

systems allow OEO and the Bureau of Human Resources to monitor the data to determine whether triggers may exist that could lead to 

barriers for equal employment opportunities. During FY 2022, OEO staff was provided training on barrier analysis and MD-715 reporting. 

RRB also initiated analyses of its demographic data system and exit survey data. 

Page 4 
EEOC FORM 

715-02 

PART E.2 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

Essential Element F: Responsiveness and Legal Compliance 

According to Management Directive 715, Federal agencies must: 

• Ensure that they are in full compliance with the law, including EEOC regulations, orders, and other written instructions. 

• Report Agency program efforts and accomplishments to EEOC and respond to EEOC directives and orders in accordance with EEOC 

instructions and time frames. 

• Ensure that management fully and timely complies with final EEOC orders for corrective action and relief in EEO matters. 

RRB is committed to ensuring full compliance with the law and incorporating EEO best practices into its everyday business. OEO staff is 

tasked with monitoring and complying with all orders and directives by EEOC Administrative Judges and the EEOC’s Office of Federal 

Operations. 

The OEO Director’s performance standards require compliance with EEOC orders. OEO staff is also responsible for compliance with 

EEOC orders and has received formal training in EEO compliance. 

In FY 2022, RRB timely processes EEO complaints, conducted EEO activities and issued reports in accordance with EEOC regulations, 

directives, and policy guidance. The Agency has also complied with regulatory requirements to submit an annual Form 462 Report, EEOC 

MD 715 Report, the Disabled Veterans Affirmative Action Program (DVAAP) Report, and quarterly and annual No FEAR Act reports. 

Page 4 
Page 5 

EEOC FORM 

715-02 

PART E.3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

The workforce profile data represents the demographics of the RRB workforce by race, sex, national origin, and disability and was retrieved 

from RRB database systems. The data is based on information as of September 30, 2022. 

RRB has three (3) Presidential appointed board members and seven (7) Executive Committee (EC) members to assist in managing its missi, 

responsibilities, and goals. 

As of the end of FY 2022, the total RRB workforce was 761 employees, including 745 permanent employees and 16 temporary employees. 

The total workforce reduced by ninety-six (96) during FY 2022, representing a rate of change of 11.2 percent. During FY 2022, several 

EEO populations experienced net reduction except for Asian males, White males, Hawaiian/Pacific Islander, and Native American Indian/ 

Alaska Native males and females. Compared to the U.S. Census Civilian National Labor Force (CLF), overall RRB demographics have not 

changed significantly. White employees comprise the largest racial group in RRB, followed by Black employees, respectively. 

Table 1: RRB Workforce by Race, Ethnicity, and Gender as of September 30, 2022 

Race 

and 

Ethnicity 

Female Male All 

Total 410 

(54%) 

351 

(46%) 

761 

(100%) 

Unidentified 0 

(0%) 

0 

(0%) 

0 

(0%) 

White 149 

(43%) 

200 

(75%) 

349 

(45.9%) 

Black 204 

(71%) 

84 

(29%) 

288 

(37.8%) 

Hispanic 38 

(53%) 

34 

(47%) 

72 

(9.5%) 

Asian 15 

(37%) 

26 

(63%) 

41 

(5.4%) 

Hawaiian or Other 

Pacific Islander 

1 

(0.33%) 

2 

(0.67%) 

3 

(0.4%) 

Native American 

Indian or Alaska 

Native 

3 

(0.43%) 

4 

(0.57%) 

7 

(0.9%) 

Two or more 

Races 

0 

(0%) 

1 

(0.1%) 

1 

(0.1%) 
EEOC FORM 

715-02 

PART E.3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

Ethnic and Race Indicators 

In FY 2022, the ethnic and race indicators were as follows: 

White males represented 26.3 percent (200) of the RRB workforce. No significant change from FY 2021. 

White females represented 19.6 percent (149) of the RRB workforce. This represents a net reduction of 1.1 percent (24) in FY 2022 

compared to FY 2021 when White female representation was 20.7 percent (173). 

African American/Black males represented 11 percent (84) of the RRB workforce. No net change from FY 2021 statistics of 11.2 percent 

(94). 

African American/Black females represented 26.8 percent (204) of the RRB workforce. This represents a net reduction of 2.1 percent 

compared to FY 2021 when African American/Black female representation was 28.9 percent (242). 

Native American Indian/Alaska Native males (AIAN) represented 0.5 percent (4) of the RRB workforce. This represents a net growth of 0.4 

(3) in FY 2022 from 0.1 percent (1) in FY 2021. 

American Indian/Alaskan females (AIAN) represented 0.4 percent (3) of the RRB workforce. This represents a net growth of 0.2 (2) in FY 

2022 from 0.1 percent (1) in FY 2021. 

Asian males represented 3.4 percent (26) of the RRB workforce. This represents a net growth of 0.6 (3) in FY 2022 from 2.8 percent (23) in 

FY 2021. 

Asian females represented 1.8 percent (15) of the RRB workforce. This represents a slight reduction of 0.1 percent (1) from 1.9 percent 

(16) in FY 2021. 

Hispanic males represented 4.5 percent (34) of the RRB workforce. This represents an increase of 0.8 percent (3) in FY 2022 from 3.7 

percent (31) in FY 2021. 

Hispanic females represented 5 percent (38) of the RRB workforce. No change from FY 2021. 

Native Hawaiian/Pacific Islander (NHOPI) males represented 0.3 percent (2) of the RRB workforce. No change from FY 2021. 

Native Hawaiian/Pacific Islander (NHOPI) females represented 0.1 percent (1) of the RRB workforce. No change from FY 2021. 

EEOC provides an opportunity for federal employees and applicants to self-identify as having "Two or more Races." 

“Two or more Races” males comprised 0.1 percent (1) of the RRB workforce. This represents a net reduction of 0.7 percent (6) compared to 

FY 2021 when “Two or More Races” male representation was 0.8 percent (7). “Two or more Races” females comprised 0 percent (0) of the 

RRB workforce. This represents a total reduction of 0.4 percent (3) from FY 2021. 

Whites comprised the majority of the RRB workforce in FY 2022 at 45.9 percent (349) followed by African Americans/Blacks at 37.8 

percent (288). Hispanics comprised 9.5 percent (72) while Asians comprised 5.4 percent (41). Other racial/ethnic groups (i.e., American 

Indian/Alaskan Native, Native Hawaiian/Other Pacific Islander, and Two or More Races/Ethnicity) comprised 1.4 percent (11) of RRB’s 

workforce in FY 2022. 

As in previous years, American Indians/Alaskan Natives (AIAN), Hawaiian/Other Pacific Islanders (NHOPI) and persons of Two or More 

Races continue to remain largely absent from RRB’s permanent workforce. 

Gender Distribution 

Page 5 
EEOC FORM 

715-02 

PART E.3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

RRB continues to have a higher participation rate for females. In FY 2021, males comprised 364 or 43.5 percent and females 

comprised 473 or 56.5 percent of the workforce.  In FY 2022, males comprised 351 or 46.1 percent and females comprised 

410 or 53.9 percent. 

Table 2: RRB Workforce by Gender as of September 30, 2022 

GENDER/SEX 

GENDER # % 

Total 761 100 

Female 410 53.9 

Male 351 46.1 

Other 0 0 

Employees with Disability Demographics 

In FY 2022, Persons with a disability (PWD) made up 21 percent (160) of RRB’s total workforce, exceeding EEOC’s goal of 12.00%. In 

addition, persons with a targeted disability (PWTD) made up 2.62 percent (20) of the workforce, also exceeding EEOC’s goal of 2.00%. 

Table 3: RRB Workforce by Disability Status as of September 30, 2022 

DISABILITY STATUS 

Disability 

Status 

# % 

Total 761 

No Disability 581 

Not Identified 78 

Non-Targeted 

Disability 

82 

Targeted 

Disability 

20 

100 

76 

10 

.11 

.03 

New Hires 

In FY 2022, RRB hired a total of thirty-two (32) new employees, 78.1 percent (25) into permanent positions and 21.9 percent (7) into 

temporary positions. This represents a reduction of 54 percent (37) from 69 new hires in FY 2022. 

Page 5 
EEOC FORM 

715-02 

PART E.3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

The distribution of the new hires into permanent positions (25) during FY 2022 was: 

• African American/Black males = 3 

• African American/Black females = 5 

• American Indian/Alaskan Native males = 0 

• American Indian/Alaskan Native females = 0 

• Asian American males = 6 

• Asian American females = 0 

• Hispanic males = 1 

• Hispanic females = 1 

• Native Hawaiians/Pacific Islander males = 0 

• Native Hawaiians/Pacific Islander females = 1 

• White males = 8 

• White females = 0 

• “Two or more Races” males = 0 

• “Two or more Races” females = 0 

Separations 

In FY 2022, a total of 123 employees separated from the agency. Separations include resignations, terminations, transfers, and retirements. 

The demographic distribution of RRB employee separations in FY 2022 were: 

• African American/Black males = 16 

• African American/Black females = 48 

• American Indian/Alaskan Native males = 0 

• American Indian/Alaskan Native females = 0 

• Asian American males = 3 

• Asian American females = 2 

• Hispanic males = 1 

• Hispanic females = 1 

• Native Hawaiians/Pacific Islander males = 0 

• Native Hawaiians/Pacific Islander females = 0 

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EEOC FORM 

715-02 

PART E.3 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

• White males = 21 

• White females = 31 

• “Two or more Races” males = 0 

• “Two or more Races” females = 0 

The breakdown on the  Separations types in FY 2022 were: Resignations (18), Retirements (57), Transfers to other federal agencies (41), 

Terminations (0), Removal (5), and Death (2) 

African American/Black females, at 48 (or 39 percent), were the largest group separated. Other high rates of separation include White 

females, at 31 (or 25.2 percent); White males, at 21 (or 17.1 percent); and African American/Black males, at 16 (or 13 percent). 

Workforce Participation by Grade Level 

In FY 2022, the majority of RRB’s permanent employees are in higher-graded professional and administrative positions.  Majority of RRB 

employees were at the GS-12 grade level.  During FY 2022, the grade level distribution for the 745 permanent employees was: 

Permanent employees in grades GS 1 through 10 positions = 234 

Permanent employees in GS-11 positions = 119 

Permanent employees in GS-12 positions = 173 

Permanent employees in GS-13 position = 93 

Permanent employees in GS-14 positions = 75 

Permanent employees in GS-15 positions = 42 

Permanent SES employees = 9 

In FY 2022, minority representation in higher grades (i.e., 13, 14, 15, and SES) continues to be disparate compared to whites.  For all 

grades-13 through SES, White permanent employees had the highest levels in the workforce. Overall, the participation rate of African 

American/Blacks, Asians, Hispanics, and Other race/ethnic groups decreased as the grades increased. 

SES Participation by Race 

There were a total of 9 employees in SES positions, of which 6 were White (67 %), 3 were African-American/Black (22 %) and 1 was 

Hispanic (11%). 

GS-15 Participation by Race 

There were a total of 42 employees in GS-15 positions, of which 30 were White (71%), 5 were African-American/Black (12%), 4 were 

Asian (10%), 3 were Hispanic (7%). 

GS-14 Participation by Race 

There were a total of 75 employees in GS-14 positions, of which  47 were White (63%), 17 were African American/Black (23%), 9 were 

Asian (12%), and  2 were Hispanic (3%). 

GS-13 Participation by Race 

There were 93 employees in GS-13 positions, of which 44 were White (47%), 28 were African American/Black (30%), 8 were Asian (9%), 

10 were Hispanic (11%), 3 were American Indian/Alaska Native (3%). 

Page 5 
EEOC FORM 

715-02 

PART E.4 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: ACCOMPLISHMENTS 

The RRB is strongly committed to the principles of EEO and diversity and to a work environment free of discrimination, retaliation, and 

harassment. This section highlights the agency’s efforts to align its activities with the goals of a model EEO Program. 

Accomplishments for RRB during FY 2022 included: 

The 3-Member Board established and communicated their commitment to ensuring all employees and applicants are provided equal 

opportunity and are protected under the law. In FY 2022, the board members disseminated the following policies to managers and 

employees: 

•EEO Policy Statement – Declaration of the agency’s commitment to cultivate a work environment that provides every individual 

with equal opportunity in employment programs and occupational activities. Reminded all RRB employees and managers to fully 

and timely cooperate when contacted by an OEO representative during the EEO process. Served as a call to action for all employees 

to take responsibility for reporting and addressing discriminatory conduct and to foster a work environment free from discrimination, 

harassment, and intimidation. 

•Anti-Harassment (AH) Policy Statement – Prevents or mitigates harm to any employee subjected to harassment or bullying. 

Seeks to address harassing and bullying conduct before it reaches the level of unlawful harassment. Provides updated procedures and 

timeframes for managers to follow upon receiving allegations of harassment, inappropriate conduct or bullying. 

The RRB collaborated with its Special Emphasis Groups (Workplace Diversity Committee, Employees with Disabilities Advisory Council, 

Federal Women’s Program Committee) to conduct special emphasis activities for Black History, Women’s History, Asian-American/Pacific 

Islander, Hispanic Heritage Month and National Disability Employment Awareness Month (NDEAM). 

In September 2022, the Office of Equal Opportunity (OEO) collaborated with Economic Systems, Inc. (EconSys) to conduct exploratory 

analysis on the RRB diversity and inclusion data and processes with the goal of identifying opportunities for process improvement and 

optimization. 

The agency incorporated guidance from the EEOC 2022 Technical Assistance Review (TAR) to establish an exit survey, EEO awards and a 

timetable for conducting barrier analysis. 

The Railroad Retirement Board has a strong record of employing individuals (veterans) who have served in the military. The range of 

opportunities in human resource management, claims examining, law enforcement (OIG), information technology, and administration align 

particularly well with the experience and interest of many military veterans. In 2022, RRB employed more than 158 veterans (20.8%) which 

represents close to one-fourth of our workforce. 

Training Development/Delivery: The Office of Equal Opportunity (OEO) collaborated with staff from OGC, HR and OIG to provide 

awareness and training on EEO and diversity-related topics. RRB provided training on reasonable accommodation, handling whistleblower 

complaints, harassment and EEO complaint procedures. The agency also provided mandatory training for all new supervisory employees to 

increase their awareness and understanding of the importance of diversity and inclusion and how it enhances the overall effectiveness of the 

Agency. 

The RRB has prominently posted and displayed all policies and procedures related to Anti-Harassment, Equal Employment Opportunity, 

Reasonable Accommodations, and Alternative Dispute Resolution on bulletin boards across the Agency and on Intranet/Internet sites. 

Implemented and recognized employee efforts to foster diversity and inclusion through Agency incentive awards program. 

The RRB has also complied with regulatory requirements to submit an annual Form 462 Report, EEOC MD-715 Report, the Disabled 

Veterans Affirmative Action Program (DVAAP) Report, and quarterly and annual No FEAR Act reports. 

Page 6 
EEOC FORM 

715-02 

PART E.5 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

EXECUTIVE SUMMARY: PLANNED ACTIVITIES 

The Affirmative Employment Program has eight (8) primary plans for FY23 and beyond: 

EEO Performance Element for RRB Managers (GS-15 and below) 

Office of Equal Opportunity (OEO) will ensure that RRB Managers are being evaluating on fostering diversity and inclusion by conducting 

a post-implementation audit of the FY 2023 performance appraisals of GS 15 and below managers (random sampling from each component 

of the performance plans for all RRB managers (GS-15 and below) 

DEIA Strategy and Roadmap 

The Director of Equal Opportunity will also have continued discussions with Board staff to better define roles and responsibilities among 

OEO and the Bureau of Human Resources, and then to acquire and assign additional personnel resources, as necessary, to support the EEO 

Program and DEIA strategy (FY 22-24). 

Barrier Analysis 

Establishing and maintaining effective ongoing programs of barrier analysis by broadening outreach to appropriate subject matter experts 

and members of relevant constituent groups, providing tailored training to barrier analysis teams, and using effective program management 

to establish and systematically achieve investigative goals. 

Data Collection 

Continue to work on improving RRB workforce and applicant data systems to provide complete and accurate data to support MD-715 data 

tables and Part J requirements in accordance with EEOC Instructions to Federal Agencies for EEO MD-715. Secondarily, improving the 

data systems in order to automate production of relevant data tables and/or trigger analysis tools. The lack of ability to acquire and 

aggregate accurate Applicant Flow Data will continue to be addressed by the agency (FY 22-24). 

Reasonable Accommodation Data Protocol 

Developing and implementing protocols for incorporating data from requests for reasonable accommodations into disability status 

information derived from the self-identification process. 

Model Disability Program 

Continued improvement of the Agency’s Plan for PWD and PWTD, with emphasis on both establishing mechanisms for supplying all 

mandatory data and answering all Part J questions, and developing and implementing relevant plans to improve recruitment, hiring, 

advancement, and retention of PWD and PWTD. 

Reasonable Accommodation Firewall 

Establishing a firewall for Reasonable Accommodation request processing to address conflict of interests with the Bureau of Human 

Resources staff in accordance with EEOC’s Management Directive 110 (MD-110). 

Career Development for RRB Employees 

The Bureau of Human Resources will sponsor workshops on proactive career development. RRB will continue to identify qualifying career 

development programs and related courses, as well as produce a report in compliance with MD-715, using data from our Learning 

Management System (RRB University) to identify personnel who participated in those courses and data from the human resources systems 

to obtain personnel attributes. 

Page 7 
EEOC FORM 

715-02 

PART F 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

CERTIFICATION of ESTABLISHMENT of CONTINUING 

EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS 

am the 

(Insert Name Above) (Insert official 

title/series/grade above) 

Principal EEO Director/Official for 

(Insert Agency/Component Name above) 

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 work force profiles and conducted barrier analyses aimed at detecting whether any 

management or personnel policy, procedure or practice is operating to disadvantage any group based on race, national origin,

 gender or disability. EEO Plans to Eliminate Identified Barriers, as appropriate, are included with this Federal Agency Annual

 EEO Program Status Report. 

I certify that proper documentation of this assessment is in place and is being maintained for EEOC review upon request. 

Signature of Principal EEO Director/Official 

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

EEO MD-715. 

Date 

Signature of Agency Head or Agency Head Designee Date 

Page 8 
 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Essential Element: A Demonstrated Commitment From agency Leadership 

Compliance 

Indicator 

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

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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”, please 

provide the annual issuance date in the comments column. [see MD-715, ll(A)] 

X Yes, the EEO 

policy statement 

is signed by the 3 

Board Members 

and posted in 

clear view on 

every floor in 

headquarters and 

in every field 

office. 

5/23/2022 

A.1.b. Does the EEO policy statement address all protected bases (age, color, disability, sex (including X The additional 

pregnancy, sexual orientation and gender identity), genetic information, national origin, race, religion, and bases covered in 

reprisal) contained in the laws EEOC enforces? [see 29 CFR § 1614.101(a)] If the EEO policy statement covers our agency's EEO 

any additional bases (e.g., marital status, veteran status and political affiliation), please list them in the policy statement 

comments column. are parental 

status, marital 

status, political 

affiliation, 

military service 

and other nonmerit based 

factors. 

Page 9 
 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

A.2. The agency has communicated EEO policies and procedures to all employees. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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

A.2.a.1. Anti-harassment policy? [see MD 715, ll(A)] X The AntiHarassment 

Policy is on the 

agency public 

website as well as 

the agency's 

internal intranet 

which can be 

accessed by all 

employees. It is 

also summarized 

on an allinclusive poster 

along with other 

EEO programs 

that is posted 

throughout 

headquarters and 

in every field 

office. 

A.2.a.2. Reasonable accommodation procedures? [see 29 CFR § 1614.203(d)(3)] X The Reasonable 

Accommodation 

Procedure is on 

the agency's 

public website as 

well as the 

agency's internal 

intranet which 

can be accessed 

by all employees. 

It is also 

summarized on an 

all-inclusive 

poster along with 

other EEO 

programs that is 

posted throughout 

headquarters and 

in every field 

office. 

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

website: 

Page 10 
 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

A.2.b.1. The business contact information for its EEO Counselors, EEO Officers, Special Emphasis Program X The OEO 

Managers, and EEO Director? [see 29 C.F.R § 1614.102(b)(7)] Director's name is 

posted in the 

headquarter 

building lobby, on 

the agency's 

public website, 

the agency's 

internal intranet 

and on an EEO 

poster posted in 

every RRB office 

and every floor in 

headquarters. The 

diversity 

committee 

members and 

EEO Specialist 

names are listed 

on the agency's 

intranet. EEO 

Counselors are 

not listed because 

employees must 

contact the OEO 

Director. 

A.2.b.2. Written materials concerning the EEO program, laws, policy statements, and the operation of the EEO X Our agency 

complaint process? [see 29 CFR §1614.102(b)(5)] created a poster 

listing and 

summarizing the 

EEO Programs: 

Anti-Harassment 

Policy and 

Procedure, 

Discrimination 

Complaint 

Program, ADR, 

Reasonable 

Accommodation 

Program, Section 

504 and Section 

508. 

A.2.b.3. Reasonable accommodation procedures? [see 29 CFR § 1614.203(d)(3)(i)] If so, please provide the X https:// 

internet address in the comments column. www.rrb.gov/ 

Resources/ 

OfficeOfEqualOpportunity/ 

EEOPolicies. 

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

Page 11 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

A.2.c.1. EEO complaint process? [see 29 CFR §§ 1614.102(a)(12) and 1614.102(b)(5)] If “yes”, please provide X The complaints 

how often and the means by which such training is delivered. process is always 

posted on the 

agency's intranet, 

public website 

and in every RRB 

installation. 

Employees are 

informed during 

initial onboarding 

and subsequently 

via biennial 

training. 

Employees who 

are supervisors or 

managers receive 

formal EEO 

training, which is 

required within 

one year of 

accession or 

assignment to 

those positions, 

and at least once 

every 3 years 

thereafter. 

A.2.c.2. ADR process? [see MD-110, Ch. 3(II)(C)] If “yes”, please provide how often. X The ADR process 

is always posted 

on the intranet 

(Boardwalk). 

Employees are 

informed during 

initial onboarding 

and subsequently 

via biennial 

training. 

Employees who 

are supervisors or 

managers receive 

formal EEO 

training, which is 

required within 

one year of 

accession or 

assignment to 

those positions, 

and at least once 

every 3 years 

thereafter. 

Page 12 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

A.2.c.3. Reasonable accommodation program? [see 29 CFR § 1614.203(d)(7)(ii)(C)] If “yes”, please provide X Reasonable 

how often. Accommodation 

information is 

provided to all 

employees during 

New Employee 

Orientation 

(NEO) and the 

agency's 

Reasonable 

Accommodation 

Coordinator 

provides a 

briefing to all new 

employees during 

NEO on 

reasonable 

accommodation 

procedures. In 

addition, the 

information is 

available on the 

intranet 

(Boardwalk). 

A.2.c.4. Anti-harassment program? [see EEOC Enforcement Guidance on Vicarious Employer Liability for X OEO provides 

Unlawful Harassment by Supervisors (1999), § V.C.1] If “yes”, please provide how often. training regarding 

Harassment, 

Agency policy, 

and inappropriate 

behaviors/ethics 

in the workplace. 

During these 

sessions, 

managers & 

employees are 

provided 

information tools 

such as RRBs 

Anti-harassment 

Policy and the 

Agency's EEO 

Policy Statement 

to give notice to 

federal employees 

of inappropriate 

behaviors in the 

workplace and the 

potential result of 

such actions. 

A.2.c.5. Behaviors that are inappropriate in the workplace and could result in disciplinary action? [5 CFR X Employees are 

§2635.101(b)] If “yes”, please provide how often. informed during 

initial onboarding 

and subsequently 

via biennial 

training. In 

addition, annual 

notices are sent 

by email to all 

RRB employees. 

Page 13 
 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Compliance 

Indicator 

A.3. The agency assesses and ensures EEO principles are part of its culture. 

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

A.3.a. Does the agency provide recognition to employees, supervisors, managers and units demonstrating 

superior accomplishment in equal employment opportunity? [see 29 CFR § 1614.102(a)(9)] If “yes”, provide 

one or two examples in the comments section. . 

X EEO Recognition 

Awards and 

Plaques. 

A.3.b. Does the agency utilize the Federal Employee Viewpoint Survey or other climate assessment tools to 

monitor the perception of EEO principles within the workforce? [see 5 CFR Part 250]' 

X 

Page 14 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Essential Element: B Integration of EEO into the agency's Strategic Mission 

Page 15 
 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

B.1. The reporting structure for the EEO program provides the principal EEO the space below or 

official with appropriate authority and resources to effectively carry out a complete and 

successful EEO program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.1.a. Is the agency head the immediate supervisor of the person (“EEO Director”) who has day-to-day control X The head of the 

over the EEO office? [see 29 CFR §1614.102(b)(4)] RRB is a threemember board 

appointed by the 

President of the 

U.S (POTUS). 

The OEO 

Director reports 

directly to the 3-

member board. 

B.1.a.1. If the EEO Director does not report to the agency head, does the EEO Director report to the same X The OEO 

agency head designee as the mission-related programmatic offices? If “yes,” please provide the title of the Director reports 

agency head designee in the comments. directly to the 3-

member board 

(Chair, Labor 

Member and 

Management 

Member). 

B.1.a.2. Does the agency’s organizational chart clearly define the reporting structure for the EEO office? [see 29 X 

CFR §1614.102(b)(4)] 

B.1.b. Does the EEO Director have a regular and effective means of advising the agency head and other senior X OEO's physical 

management officials of the effectiveness, efficiency and legal compliance of the agency’s EEO program? [see office is located 

29 CFR §1614.102(c)(1); MD-715 Instructions, Sec. I] on the same floor 

with the 3-

member board 

offices. The 

Board members 

and/or their 

assistants are 

always open to 

meeting with the 

OEO Director on 

issues about the 

efficiency and 

legal compliance 

of the agency's 

EEO program. In 

addition, the OEO 

Director briefs the 

board members 

through 

submission of 

monthly 

administrative 

reports and meets 

with Board staff 

monthly. 

Page 16 
 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

B.1.c. During this reporting period, did the EEO Director present to the head of the agency, and other senior X The OEO 

management officials, the "State of the agency" briefing covering the six essential elements of the model EEO Director provides 

program and the status of the barrier analysis process? [see MD-715 Instructions, Sec. I] If “yes”, please provide monthly 

the date of the briefing in the comments column. administrative 

reports and 

briefings to the 

Board Members 

and their 

assistants. 

B.1.d. Does the EEO Director regularly participate in senior-level staff meetings concerning personnel, budget, X 

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

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

B.2. The EEO Director controls all aspects of the EEO program. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.2.a. Is the EEO Director responsible for the implementation of a continuing affirmative employment program X 

to promote EEO and to identify and eliminate discriminatory policies, procedures, and practices? [see MD-110, 

Ch. 1(III)(A); 29 CFR §1614.102(c)] If not, identify the office with this authority in the comments column. 

B.2.b. Is the EEO Director responsible for overseeing the completion of EEO counseling? [see 29 CFR X 

§1614.102(c)(4)] 

B.2.c. Is the EEO Director responsible for overseeing the fair and thorough investigation of EEO complaints? X The OEO 

[see 29 CFR §1614.102(c)(5)] [This question may not be applicable for certain subordinate level components.] Director and the 

EEO Specialist 

oversee the fair 

and thorough 

investigation of 

EEO complaints. 

B.2.d. Is the EEO Director responsible for overseeing the timely issuance of final agency decisions? [see 29 X 

CFR §1614.102(c)(5)] [This question may not be applicable for certain subordinate level components.] 

B.2.e. Is the EEO Director responsible for ensuring compliance with EEOC orders? [see 29 CFR §§ X 

1614.102(e); 1614.502]' 

B.2.f. Is the EEO Director responsible for periodically evaluating the entire EEO program and providing X 

recommendations for improvement to the agency head? [see 29 CFR §1614.102(c)(2)] 

B.2.g. If the agency has subordinate level components, does the EEO Director provide effective guidance and X The agency does 

coordination for the components? [see 29 CFR §§ 1614.102(c)(2); (c)(3)] not have 

subordinate level 

components. 

Page 17 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or B.3. The EEO Director and other EEO professional staff are involved in, and complete and consulted on, management/personnel actions. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.3.a. Do EEO program officials participate in agency meetings regarding workforce changes that might impact X 

EEO issues, including strategic planning, recruitment strategies, vacancy projections, succession planning, and 

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

B.3.b. Does the agency’s current strategic plan reference EEO / diversity and inclusion principles? [see X The RRB 

MD-715, II(B)] If “yes”, please identify the EEO principles in the strategic plan in the comments column. Strategic Plan 

states that "The 

RRB will 

continue to recruit 

and hire a highperforming 

workforce and 

foster a leadership 

environment that 

inspires, 

motivates and 

guides employees 

toward our 

strategic goals, 

allows them to 

link their 

responsibilities 

with the agency’s 

strategic vision, 

and results in a 

stable workforce 

that ...reflects the 

diversity of all 

segments of 

American society. 

Page 18 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or B.4. The agency has sufficient budget and staffing to support the success of its complete and EEO program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.4.a. Pursuant to 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? [see MD-715, II(D)] X On a monthly 

basis, the OEO 

Director obtains 

and reviews HR 

data on 

accessions, 

separations, 

harassment 

complaints and 

grievances. 

B.4.a.10. to effectively manage its reasonable accommodation program? [see 29 CFR §1614.203(d)(4)(ii)] X The agency has a 

designated 

Reasonable 

Accommodation 

Coordinator 

within the Bureau 

of Human 

Resources that 

oversees RRB's 

Reasonable 

Accommodation 

process. 

B.4.a.11. to ensure timely and complete compliance with EEOC orders? [see MD-715, II(E)] X 

B.4.a.2. to enable the agency to conduct a thorough barrier analysis of its workforce? [see MD-715, II(B)] X In September 

2022, RRB 

contracted with a 

consulting firm 

(EconSys) to 

conduct a barrier 

analysis to assist 

the Agency in 

evaluating its 

recruitment and 

advancement 

policies, 

procedures, and 

practices with 

respect to 

minority groups, 

including persons 

with disabilities. 

Project objectives 

included 

identification of 

barriers to equal 

opportunity, 

retention and 

advancement. 

Page 19 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

B.4.a.3. to timely, thoroughly, and fairly process EEO complaints, including EEO counseling, investigations, X 

final agency decisions, and legal sufficiency reviews? [see 29 CFR §§ 1614.102(c)(5); 1614.105(b) – (f); 

MD-110, Ch. 1(IV)(D) & 5(IV); MD-715, II(E)] 

B.4.a.4. to provide all supervisors and employees with training on the EEO program, including but not limited to X 

retaliation, harassment, religious accommodations, disability accommodations, the EEO complaint process, and 

ADR? [see MD-715, II(B) and III(C)] If not, please identify the type(s) of training with insufficient funding in 

the comments column. 

B.4.a.5. to conduct thorough, accurate, and effective field audits of the EEO programs in components and the X RRB does not 

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

subcomponent 

EEO programs 

but does access 

workforce data at 

the component 

and field office 

level. 

B.4.a.6. to publish and distribute EEO materials (e.g. harassment policies, EEO posters, reasonable X The agency has a 

accommodations procedures)? [see MD-715, II(B)] print shop that 

prints our EEO 

literature and/or 

materials for 

various programs. 

Policies are 

posted throughout 

the agency in 

plain view as well 

as in every Field 

office. We also 

have an internal 

and external 

website where we 

post our various 

policies and 

information on 

our EEO 

programs. 

B.4.a.7. to maintain accurate data collection and tracking systems for the following types of data: complaint X At RRB, we use 

tracking, workforce demographics, and applicant flow data? [see MD-715, II(E)] If not, please identify the an excel 

systems with insufficient funding in the comments section. spreadsheet to 

track all 

complaint data, 

analyze and 

compare the data 

for any trends or 

similar 

complaints in the 

same department 

or under the same 

management. We 

also track whether 

there are similar 

issues occurring 

within the same 

department or 

unit, etc. 

Page 20 
 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

B.4.a.8. to effectively administer its special emphasis programs (such as, Federal Women’s Program, Hispanic X All Special 

Employment Program, and People with Disabilities Program Manager)? [5 USC § 7201; 38 USC § 4214; 5 CFR Emphasis 

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

and activities 

were virtual 

during fiscal year 

2022 since the 

agency was 

operating in a 

maximum 

telework posture 

due to the 

Covid-19 

pandemic. 

B.4.a.9. to effectively manage its anti-harassment program? [see MD-715 Instructions, Sec. I; EEOC X The Agency's antiEnforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), § V.C. harassment 

1] program is 

handled by the 

Office of 

Administration, 

hence there is a 

firewall with the 

Office of Equal 

Opportunity. 

B.4.b. Does the EEO office have a budget that is separate from other offices within the agency? [see 29 CFR § X 

1614.102(a)(1)] 

B.4.c. Are the duties and responsibilities of EEO officials clearly defined? [see MD-110, Ch. 1(III)(A), 2(III), & X 

6(III)] 

B.4.d. Does the agency ensure that all new counselors and investigators, including contractors and collateral X The Director of 

duty employees, receive the required 32 hours of training, pursuant to Ch. 2(II) (A) of MD-110? Equal 

Opportunity 

ensures all 

training is 

completed by 

requiring 

attendees to 

provide a copy of 

the certificate of 

completion. 

B.4.e. Does the agency ensure that all experienced counselors and investigators, including contractors and X The Director of 

collateral duty employees, receive the required 8 hours of annual refresher training, pursuant to Ch. 2(II)(C) of Equal 

MD-110? Opportunity 

ensures that all 

annual refresher 

training is 

completed by 

requiring 

attendees to 

provide a copy of 

the certificate of 

completion. 

Page 21 
 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or B.5. The agency recruits, hires, develops, and retains supervisors and managers complete and who have effective managerial, communications, and interpersonal skills attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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

and advice on their responsibilities under the following areas under the agency EEO program: 

B.5.a.1. EEO complaint process? [see MD-715(II)(B)] X All new 

supervisors 

receive training 

on the EEO 

complaint process. 

B.5.a.2. Reasonable Accommodation Procedures? [see 29 CFR § 1614.102(d)(3)] X The Reasonable 

Accommodation 

procedure is 

included in the 

new supervisor 

training. 

B.5.a.3. Anti-harassment policy? [see MD-715(II)(B)] X 

B.5.a.4. Supervisory, managerial, communication and interpersonal skills in order to supervise most effectively X The agency 

in a workplace with diverse employees and avoid disputes arising from ineffective communications? [see provides 

MD-715, II(B)] numerous on-line 

soft skill 

management 

courses to help 

them with 

interpersonal 

skills and 

communication 

with employees. 

We believe our 

diversity and 

inclusion 

programs helps 

everyone 

understand each 

other better and 

creates an 

atmosphere of 

inclusion. 

B.5.a.5. ADR, with emphasis on the federal government’s interest in encouraging mutual resolution of disputes X We offer ADR to 

and the benefits associated with utilizing ADR? [see MD-715(II)(E)] all complainants 

except sexual 

harassment 

complaints. We 

also created an 

ADR video 

explaining how 

ADR works 

(optional 

viewing). 

Page 22 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

B.6. The agency involves managers in the implementation of its EEO program. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

B.6.a. Are senior managers involved in the implementation of Special Emphasis Programs? [see MD-715 X Senior managers 

Instructions, Sec. I] approve the time 

for their 

employees to 

attend and/or 

participate in 

commemorative 

events. Board 

members also 

attend and 

provide opening 

and closing 

remarks during 

commemorative 

events. 

B.6.b. Do senior managers participate in the barrier analysis process? [see MD-715 Instructions, Sec. I] X The Director of 

Equal 

Opportunity has 

established a 

barrier analysis 

workgroup and 

has started to 

review data 

(grievance, antiharassment 

program 

complaints, exit 

survey results, 

etc.) on a monthly 

basis. 

B.6.c. When barriers are identified, do senior managers assist in developing agency EEO action plans (Part I, X The agency is 

Part J, or the Executive Summary)? [see MD-715 Instructions, Sec. I] currently 

developing an 

action plan to 

remedy this 

deficiency based 

on EEOC 

Technical 

Assistance review 

and findings of 

our FY 2019 and 

FY 2020 MD-715 

reports. All 

corrective plans 

are reviewed and 

vetted by the 

Board. 

Page 23 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

B.6.d. Do senior managers successfully implement EEO Action Plans and incorporate the EEO Action Plan X During FY 2022 

Objectives into agency strategic plans? [29 CFR §1614.102(a)(5)] and FY 2023, 

action plans were 

developed and 

continued to be 

implemented. We 

will continue to 

make progress, 

monitor and 

measure results in 

2023. 

Page 24 
 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Essential Element: C Management and Program Accountability 

Compliance 

Indicator 

C.1. The agency conducts regular internal audits of its component and field offices. 

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.1.a. Does the agency regularly assess its component and field offices for possible EEO program deficiencies? 

[see 29 CFR §1614.102(c)(2)] If ”yes”, please provide the schedule for conducting audits in the comments 

section. 

X RRB has a 

centrally managed 

and operated EEO 

program; there 

are no separate 

programs run by 

components or at 

the field level. 

C.1.b. Does the agency regularly assess its component and field offices on their efforts to remove barriers from X RRB has a 

the workplace? [see 29 CFR §1614.102(c)(2)] If ”yes”, please provide the schedule for conducting audits in the centrally managed 

comments section. and operated EEO 

program; there 

are no separate 

programs run by 

components or at 

the field level. As 

of FY 2022, 

component data is 

generated and 

analyzed for 

triggers annually. 

C.1.c. Do the component and field offices make reasonable efforts to comply with the recommendations of the X RRB has a 

field audit? [see MD-715, II(C)] centrally managed 

and operated EEO 

program; there 

are no separate 

programs run by 

components or at 

the field level. As 

of FY 2022, 

component data is 

generated and 

analyzed for 

triggers annually. 

Page 25 
 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.2. The agency has established procedures to prevent all forms of EEO complete and discrimination. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.2.a. Has the agency established comprehensive anti-harassment policy and procedures that comply with X 

EEOC’s enforcement guidance? [see MD-715, II(C); Enforcement Guidance on Vicarious Employer Liability 

for Unlawful Harassment by Supervisors (Enforcement Guidance), EEOC No. 915.002, § V.C.1 (June 18, 1999)] 

C.2.a.1. Does the anti-harassment policy require corrective action to prevent or eliminate conduct before it rises X 

to the level of unlawful harassment? [see EEOC Enforcement Guidance on Vicarious Employer Liability for 

Unlawful Harassment by Supervisors (1999), § V.C.1] 

C.2.a.2. Has the agency established a firewall between the Anti-Harassment Coordinator and the EEO Director? X 

[see EEOC Report, Model EEO Program Must Have an Effective Anti-Harassment Program (2006)] 

C.2.a.3. Does the agency have a separate procedure (outside the EEO complaint process) to address harassment X 

allegations? [see Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by 

Supervisors (Enforcement Guidance), EEOC No. 915.002, § V.C.1 (June 18, 1999)] 

C.2.a.4. Does the agency ensure that the EEO office informs the anti-harassment program of all EEO counseling X The Director of 

activity alleging harassment? [See Enforcement Guidance, V.C.] Equal 

Opportunity 

provides the 

required notice to 

the Agency's AntiHarassment 

Coordinator and 

Director of 

Administration in 

accordance with 

RRB's AntiHarassment 

policy. 

C.2.a.5. Does the agency conduct a prompt inquiry (beginning within 10 days of notification) of all harassment X 

allegations, including those initially raised in the EEO complaint process? [see 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 (May 29, 2015)] If “no”, please provide the percentage 

of timely-processed inquiries in the comments column. 

C.2.a.6. Do the agency’s training materials on its anti-harassment policy include examples of disability-based X 

harassment? [see 29 CFR §1614.203(d)(2)] 

C.2.b. Has the agency established disability reasonable accommodation procedures that comply with EEOC’s X 

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

Page 26 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

C.2.b.1. Is there a designated agency official or other mechanism in place to coordinate or assist with processing X RRB has a 

requests for disability accommodations throughout the agency? [see 29 CFR §1614.203(d)(3)(D)] designated 

Reasonable 

Accommodation 

Coordinator in the 

Bureau of Human 

Resources who 

coordinates and 

assists with 

reasonable 

accommodation 

processing 

requests 

throughout the 

agency and also 

tracks information 

on 

accommodation 

approvals and 

denials. The 

Office of the 

Inspector General 

processes their 

reasonable 

accommodation 

requests and has 

their own RA 

Coordinator. 

C.2.b.2. Has the agency established a firewall between the Reasonable Accommodation Program Manager and X The Agency's 

the EEO Director? [see MD-110, Ch. 1(IV)(A)] Reasonable 

Accommodation 

Coordinators are 

in the Bureau of 

Human Resources 

and the Office of 

the Inspector 

General. 

C.2.b.3. Does the agency ensure that job applicants can request and receive reasonable accommodations during X Every vacancy 

the application and placement processes? [see 29 CFR §1614.203(d)(1)(ii)(B)] notice includes 

the language "The 

Railroad 

Retirement Board 

Provides 

reasonable 

accommodations 

to applicants. If 

you need a 

reasonable 

accommodation 

for any part of the 

application 

process, please 

notify the Bureau 

of Human 

Resources. The 

decision of 

granting a 

reasonable 

accommodation 

will be on a caseby-case basis." 

Page 27 
 

 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

C.2.b.4. Do the reasonable accommodation 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? [see 29 CFR §1614.203(d)(3)(i)(M)] 

X Our agency's 

Reasonable 

Accommodation 

policy provides 

for 15 workdays 

unless there are 

extenuating 

circumstances. 

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

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

provide the percentage of timely-processed requests, excluding ongoing interpretative services, in the comments 

column. 

X 

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? [see 29 CFR §1614.203(d)(6)] 

X 

C.2.c.1. Does the agency post its procedures for processing requests for Personal Assistance Services on its 

public website? [see 29 CFR §1614.203(d)(5)(v)] If “yes”, please provide the internet address in the comments 

column. 

X It is included in 

the Reasonable 

Accommodation 

Policy which is 

posted on rrb.gov. 

Page 28 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.3. The agency evaluates managers and supervisors on their efforts to ensure complete and equal employment opportunity. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.3.a. Pursuant to 29 CFR §1614.102(a)(5), do all managers and supervisors have an element in their X The performance 

performance appraisal that evaluates their commitment to agency EEO policies and principles and their appraisals for 

participation in the EEO program? senior executives 

(SES) contain an 

EEO element. An 

EEO sub-element 

was adopted in 

2020 and was 

fully implemented 

in the 

performance 

appraisals of all 

agency managers 

(GS 15 and 

below) during FY 

2023. 

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

on the following activities: 

C.3.b.1. Resolve EEO problems/disagreements/conflicts, including the participation in ADR proceedings? [see X This requirement 

MD-110, Ch. 3.I] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.2. Ensure full cooperation of employees under his/her supervision with EEO officials, such as counselors X This requirement 

and investigators? [see 29 CFR §1614.102(b)(6)] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.3. Ensure a workplace that is free from all forms of discrimination, including harassment and retaliation? X This requirement 

[see MD-715, II(C)] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

Page 29 
 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

C.3.b.4. Ensure that subordinate supervisors have effective managerial, communication, and interpersonal skills X This requirement 

to supervise in a workplace with diverse employees? [see MD-715 Instructions, Sec. I] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.5. Provide religious accommodations when such accommodations do not cause an undue hardship? [see X This requirement 

29 CFR §1614.102(a)(7)] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.6. Provide disability accommodations when such accommodations do not cause an undue hardship? [ see X This requirement 

29 CFR §1614.102(a)(8)] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.7. Support the EEO program in identifying and removing barriers to equal opportunity?. [see MD-715, X This requirement 

II(C)] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.8. Support the anti-harassment program in investigating and correcting harassing conduct?. [see X This requirement 

Enforcement Guidance, V.C.2] is included in the 

new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.b.9. Comply with settlement agreements and orders issued by the agency, EEOC, and EEO-related cases X This requirement 

from the Merit Systems Protection Board, labor arbitrators, and the Federal Labor Relations Authority? [see is included in the 

MD-715, II(C)] new EEO subelement 

implemented in 

FY 2023 for all 

agency managers 

(GS 15 and 

below). 

C.3.c. Does the EEO Director recommend to the agency head improvements or corrections, including remedial X There were no 

or disciplinary actions, for managers and supervisors who have failed in their EEO responsibilities? [see 29 CFR findings of 

§1614.102(c)(2)] discrimination in 

FY 2022. 

Page 30 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

C.3.d. When the EEO Director recommends remedial or disciplinary actions, are the recommendations regularly X There were no 

implemented by the agency? [see 29 CFR §1614.102(c)(2)] findings of 

discrimination in 

FY 2022. 

Page 31 
 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.4. The agency ensures effective coordination between its EEO program and complete and Human Resources (HR) program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.4.a. Do the HR Director and the EEO Director meet regularly to assess whether personnel programs, policies, X As of FY 2022, 

and procedures conform to EEOC laws, instructions, and management directives? [see 29 CFR §1614.102(a)(2)] the HR Director 

and OEO Director 

meet bi-weekly. 

C.4.b. Has the agency established timetables/schedules to review at regular intervals its merit promotion X Timetable/ 

program, employee recognition awards program, employee development/training programs, and management/ Schedule was 

personnel policies, procedures, and practices for systemic barriers that may be impeding full participation in the established in 

program by all EEO groups? [see MD-715 Instructions, Sec. I] September 2022 

by the OEO 

Director. 

C.4.c. Does the EEO office have timely access to accurate and complete data (e.g., demographic data for the X 

workforce, applicants, training programs, etc.) required to prepare the MD-715 workforce data tables? [see 29 

CFR §1614.601(a)] 

C.4.d. Does the HR office timely provide the EEO office with access to other data (e.g., exit interview data, X 

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

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? [see 29 CFR §1614.203(d); X This Plan is 

MD-715, II(C)] approved by the 

Director of 

Administration 

who is over HR. 

The Plan was 

shared with the 

Executive 

Committee. 

C.4.e.2. Develop and/or conduct outreach and recruiting initiatives? [see MD-715, II(C)] X These tasks are 

conducted by the 

Bureau of Human 

Resources. The 

OEO Director 

does not 

participate in 

outreach, 

recruitment 

strategies, 

recruitment 

initiatives, 

vacancy 

projections, 

succession 

planning, and 

selections for 

training/career 

development 

opportunities for 

the agency. 

C.4.e.3. Develop and/or provide training for managers and employees? [see MD-715, II(C)] X 

Page 32 
 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

C.4.e.4. Identify and remove barriers to equal opportunity in the workplace? [see MD-715, II(C)] X 

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

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or C.5. Following a finding of discrimination, the agency explores whether it should complete and take a disciplinary action. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.5.a. Does the agency have a disciplinary policy and/or table of penalties that covers discriminatory conduct? X 

[see 29 CFR §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 X Since the agency 

conduct? [see 29 CFR §1614.102(a)(6)] If “yes”, please state the number of disciplined/sanctioned individuals did not have a 

during this reporting period in the comments. finding of 

discrimination, no 

(zero) individuals 

were sanctioned/ 

disciplined during 

FY 2022. 

C.5.c. If the agency has a finding of discrimination (or settles cases in which a finding was likely), does the X The Responsible 

agency inform managers and supervisors about the discriminatory conduct (e.g., post mortem to discuss lessons Management 

learned)? [see MD-715, II(C)] Official (RMO) is 

advised if their 

actions were 

inappropriate, 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

C.6. The EEO office advises managers/supervisors on EEO matters. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

C.6.a. Does the EEO office provide management/supervisory officials with regular EEO updates on at least an X OEO provides 

annual basis, including EEO complaints, workforce demographics and data summaries, legal updates, barrier annual updates to 

analysis plans, and special emphasis updates? [see MD-715 Instructions, Sec. I] If “yes”, please identify the managers and 

frequency of the EEO updates in the comments column. supervisors. In 

addition, the 

Director of Equal 

Opportunity 

provides monthly 

updates and 

briefings to 

agency heads and 

executives. 

C.6.b. Are EEO officials readily available to answer managers’ and supervisors’ questions or concerns? [see X 

MD-715 Instructions, Sec. I] 

Page 33 
 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Essential Element: D Proactive Prevention 

Compliance 

Indicator 

Measures 

D.1. The agency conducts a reasonable assessment to monitor progress towards 

achieving equal employment opportunity throughout the year. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.1.a. Does the agency have a process for identifying triggers in the workplace? [see MD-715 Instructions, Sec. 

I] 

X As of September 

2022. 

D.1.b. Does the agency regularly use the following sources of information for trigger identification: workforce 

data; complaint/grievance data; exit surveys; employee climate surveys; focus groups; affinity groups; union; 

program evaluations; special emphasis programs; and/or external special interest groups? [see MD-715 

Instructions, Sec. I] 

X As of September 

2022. 

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? [see 29 

CFR §1614.203(d)(1)(iii)(C)] 

X As of January 

2022. 

Page 34 
 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or D.2. The agency identifies areas where barriers may exclude EEO groups complete and (reasonable basis to act.) attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.2.a. Does the agency have a process for analyzing the identified triggers to find possible barriers? [see X Yes, OEO 

MD-715, (II)(B)] analyzes the 

promotions, 

hiring and 

separation data 

for possible 

barriers that may 

impact minorities 

and/or people 

with disabilities, 

but have found 

none to date. 

D.2.b. Does the agency regularly examine the impact of management/personnel policies, procedures, and X 

practices by race, national origin, sex, and disability? [see 29 CFR §1614.102(a)(3)] 

D.2.c. Does the agency consider whether any group of employees or applicants might be negatively impacted X Yes, over the past 

prior to making human resource decisions, such as re-organizations and realignments? [see 29 CFR §1614.102(a) five years, we had 

(3)] one 

reorganization 

and no impact on 

any specific 

group was 

idenitified. 

D.2.d. Does the agency regularly review the following sources of information to find barriers: complaint/ X Yes, OEO 

grievance data, exit surveys, employee climate surveys, focus groups, affinity groups, union, program reviews complaint 

evaluations, anti-harassment program, special emphasis programs, and/or external special interest groups? [see data, antiMD-715 Instructions, Sec. I]] If “yes”, please identify the data sources in the comments column. harassment data, 

program 

evaluations and 

special emphasis 

programs for 

barriers. 

Beginning in FY 

2022, OEO plans 

to review exit 

survey and 

grievance data. 

Page 35 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

D.3. The agency establishes appropriate action plans to remove identified barriers. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.3.a. Does the agency effectively tailor action plans to address the identified barriers, in particular policies, X Yes, we have not 

procedures, or practices? [see 29 CFR §1614.102(a)(3)] identified any 

barriers in 

policies, 

procedures or 

practices. If we 

did, we would 

inform the Board 

members and 

their assistants 

and speak with 

the department 

head on the 

barrier the policy 

created and 

remove/revise the 

policy. 

D.3.b. If the agency identified one or more barriers during the reporting period, did the agency implement a plan X We did not 

in Part I, including meeting the target dates for the planned activities? [see MD-715, II(D)] identify a barrier 

during FY2021. 

D.3.c. Does the agency periodically review the effectiveness of the plans? [see MD-715, II(D)] X We have not had 

one to test. 

Page 36 
 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or D.4. The agency has an affirmative action plan for people with disabilities, complete and including those with targeted disabilities. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

D.4.a. Does the agency post its affirmative action plan on its public website? [see 29 CFR §1614.203(d)(4)] If X Yes, https:// 

yes, please provide the internet address in the comments. www.rrb.gov/ 

Resources/ 

OfficeOfEqualOpportunity/ 

EEOPolicies. 

D.4.b. Does the agency take specific steps to ensure qualified people with disabilities are aware of and X Yes. We send our 

encouraged to apply for job vacancies? [see 29 CFR §1614.203(d)(1)(i)] vacancy 

announcements to 

many 

organizations that 

assist people with 

disabilities get 

back into the 

workforce. Also, 

if an 

accommodation is 

needed, contact 

information is on 

the vacancy 

announcement. 

D.4.c. Does the agency ensure that disability-related questions from members of the public are answered X Yes, an HR 

promptly and correctly? [see 29 CFR §1614.203(d)(1)(ii)(A)] Specialist, the 

Selective 

Placement 

Coordinator, is 

assigned to this 

task. 

D.4.d. Has the agency taken specific steps that are reasonably designed to increase the number of persons with X Yes. We send our 

disabilities or targeted disabilities employed at the agency until it meets the goals? [see 29 CFR §1614.203(d)(7) vacancy 

(ii)] announcements to 

many 

organizations that 

assist people with 

disabilities get 

back into the 

workforce. Also, 

if an 

accommodation is 

needed, contact 

information is on 

the vacancy 

announcement. 

Page 37 
EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Essential Element: E Efficiency 

Page 38 
 

 

 

 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.1. The agency maintains an efficient, fair, and impartial complaint resolution complete and process. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.1.a. Does the agency timely provide EEO counseling, pursuant to 29 CFR §1614.105? X 

E.1.b. Does the agency provide written notification of rights and responsibilities in the EEO process during the X 

initial counseling session, pursuant to 29 CFR §1614.105(b)(1)? 

E.1.c. Does the agency issue acknowledgment letters immediately upon receipt of a formal complaint, pursuant X 

to MD-110, Ch. 5(I)? 

E.1.d. Does the agency issue acceptance letters/dismissal decisions within a reasonable time (e.g., 60 days) after X Yes, the Agency 

receipt of the written EEO Counselor report, pursuant to MD-110, Ch. 5(I)? If so, please provide the average issues acceptance 

processing time in the comments. letters/dismissal 

decisions within a 

reasonable time. 

The internal 

office policy is to 

issue within 15 

business days of 

receipt date of a 

formal complaint. 

E.1.e. Does the agency ensure that all employees fully cooperate with EEO counselors and EEO personnel in the X 

EEO process, including granting routine access to personnel records related to an investigation, pursuant to 29 

CFR §1614.102(b)(6)? 

E.1.f. Does the agency timely complete investigations, pursuant to 29 CFR §1614.108? X Yes, within 180 

days 

E.1.g. If the agency does not timely complete investigations, does the agency notify complainants of the date by X Yes. 

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)? 

E.1.h. When the complainant did not request a hearing, does the agency timely issue the final agency decision, X 

pursuant to 29 CFR §1614.110(b)? 

E.1.i. Does the agency timely issue final actions following receipt of the hearing file and the administrative X 

judge’s decision, pursuant to 29 CFR §1614.110(a)? 

Page 39 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

E.1.j. If the agency uses contractors to implement any stage of the EEO complaint process, does the agency hold X Yes, the Agency 

them accountable for poor work product and/or delays? [See MD-110, Ch. 5(V)(A)] If “yes”, please describe uses contract 

how in the comments column. investigators to 

conduct EEO 

discrimination 

investigations. As 

part of their 

contract 

expectations, we 

advise the 

contractors in 

writing that their 

fee may be 

reduced for a late 

or poor work 

product. As of FY 

2023, the OEO 

Director requires 

weekly progress 

reports from the 

contract 

investigators 

during the 

investigation. 

E.1.k. If the agency uses employees to implement any stage of the EEO complaint process, does the agency hold X Yes, we only use 

them accountable for poor work product and/or delays during performance review? [See MD-110, Ch. 5(V)(A)] employees as 

Collateral Duty 

EEO Counselors 

and OEO 

provides input on 

their performance 

appraisals as to 

how they handled 

their assignments. 

E.1.l. Does the agency submit complaint files and other documents in the proper format to EEOC through the X 

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

Page 40 
 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or 

E.2. The agency has a neutral EEO process. complete and 

attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.2.a. Has the agency established a clear separation between its EEO complaint program and its defensive X There is a firewall 

function? [see MD-110, Ch. 1(IV)(D)] If “yes”, please explain. between the EEO 

function and the 

agency's 

defensive 

function (OGC). 

OGC is not 

involved in the 

process until the 

Complainant 

requests a 

hearing. At that 

point, we provide 

OGC with the 

complaint file and 

post their name 

and contact info 

on FedSEP. 

E.2.b. When seeking legal sufficiency reviews, does the EEO office have access to sufficient legal resources X Yes, OEO 

separate from the agency representative? [see MD-110, Ch. 1(IV)(D)] If “yes”, please identify the source/ independently 

location of the attorney who conducts the legal sufficiency review in the comments column. conducts all 

sufficiency 

reviews. 

E.2.c. If the EEO office relies on the agency’s defensive function to conduct the legal sufficiency review, is X OEO conducts all 

there a firewall between the reviewing attorney and the agency representative? [see MD-110, Ch. 1(IV)(D)] sufficiency 

reviews. OEO 

does not rely on 

the agency's 

defensive 

function (OGC) 

for sufficiency 

reviews. 

E.2.d. Does the agency ensure that its agency representative does not intrude upon EEO counseling, X Yes, OGC is not 

investigations, and final agency decisions? [see MD-110, Ch. 1(IV)(D)] contacted until 

the Complainant 

requests a 

hearing. If 

Complainant 

request a final 

agency decision, 

OEO writes the 

decision. 

Page 41 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

E.2.e. If applicable, are processing time frames incorporated for the legal counsel’s sufficiency review for timely X OEO conducts 

processing of complaints? [see EEOC Report, Attaining a Model Agency Program: Efficiency (Dec. 1, 2004)] sufficiency 

reviews and 

completes them 

within 10 

business days to 

ensure timely 

processing of 

complaints. 

Page 42 
 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.3. The agency has established and encouraged the widespread use of a fair complete and alternative dispute resolution (ADR) program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.3.a. Has the agency established an ADR program for use during both the pre-complaint and formal complaint X Yes. 

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

advised they can 

request ADR 

(Mediation) 

during the 

informal and the 

formal complaint 

process. 

E.3.b. Does the agency require managers and supervisors to participate in ADR once it has been offered? [see X Yes, managers are 

MD-715, II(A)(1)] required to 

participate. 

E.3.c. Does the Agency encourage all employees to use ADR, where ADR is appropriate? [See MD-110, Ch. X Yes, the agency 

3(IV)(C)] encourages 

employees to use 

ADR for EEO 

and non-EEO 

complaints. 

E.3.d. Does the agency ensure a management official with settlement authority is accessible during the dispute X Yes. 

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

E.3.e. Does the agency prohibit the responsible management official named in the dispute from having X Yes. If the 

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

Management 

Official (RMO )is 

the Director of the 

Department, we 

try to have 

another Senior 

Executive sit in 

on the mediation 

with settlement 

authority. Of 

course, they still 

must consult with 

the director of 

that department. 

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

monitor how 

many resulted in 

settlements and/or 

ended in no 

agreements, 

where the 

Complainant did 

not pursue the 

complaint. 

Page 43 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.4. The agency has effective and accurate data collection systems in place to complete and evaluate its EEO program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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

E.4.a.1. Complaint activity, including the issues and bases of the complaints, the aggrieved individuals/ X Yes. OEO enters 

complainants, and the involved management official? [see MD-715, II(E)] all complaint 

information on an 

EXCEL 

worksheet to 

compare cases on 

their bases, issues 

and the RMO 

involved. 

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

entered on an 

EXCEL 

spreadsheet for 

comparability. 

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

monitors all 

accessions. 

Vacancy postings 

are listed on 

usajobs.gov. We 

also send vacancy 

announcements to 

organizations 

assisting people 

with disabilities 

and veterans 

trying to re-enter 

the workforce. 

E.4.a.4. External and internal applicant flow data concerning the applicants’ race, national origin, sex, and X Yes, we do this 

disability status? [see MD-715, II(E)] annually but will 

start reviewing 

data throughout 

the year. 

Page 44 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

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

the Reasonable 

Accommodation 

policy but the 

Reasonable 

Accommodation 

Coordinator 

(RAC) is in the 

Bureau of Human 

Resources. The 

RAC provides an 

annual report of 

approved, denied, 

changed 

reasonable 

accommodations 

and the cost to the 

agency. 

E.4.a.6. The processing of complaints for the anti-harassment program? [see EEOC Enforcement Guidance on X Yes. The Office 

Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), § V.C.2] of Administration 

processes 

complaints of 

harassment but 

provides a 

monthly report to 

OEO on whether 

a complaint was 

filed and when it 

was closed. The 

Anti-Harassment 

Coordinator and 

the OEO works 

together to ensure 

that the timeframes are met. 

E.4.b. Does the agency have a system in place to re-survey the workforce on a regular basis? [MD-715 X Yes, we use the 

Instructions, Sec. I] Federal Employee 

Viewpoint Survey. 

Page 45 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Measure Has For all unmet Compliance Been Met measures, provide Indicator a 

brief explanation 

in 

the space below or E.5. The agency identifies and disseminates significant trends and best practices in complete and its EEO program. attach Measures Yes No N/A an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

E.5.a. Does the agency monitor trends in its EEO program to determine whether the agency is meeting its X RRB monitors 

obligations under the statutes EEOC enforces? [see MD-715, II(E)] If “yes”, provide an example in the and assesses its 

comments. performance of 

the 156 Part G 

compliance 

measures, which 

are linked to 

various EEO 

laws, regulations 

and EEOC 

Management 

Directives, 

Instructions, and 

guidance. Several 

measures (e.g., 

complaints 

processing, 

reasonable 

accommodations 

processing, 

training 

compliance) use 

empirical data 

which is tracked 

over time to 

assess status, 

trends, and 

progress. 

E.5.b. Does the agency review other agencies’ best practices and adopt them, where appropriate, to improve the X Yes, the OEO 

effectiveness of its EEO program? [see MD-715, II(E)] If “yes”, provide an example in the comments. Director is a 

member of the 

small agency 

council and RRB 

has recently 

adopted data 

analysis practices 

and 

benchmarking 

tools from the 

Federal Finance 

Housing 

Authority (FHFA) 

and National 

Transportation 

Safety Board 

(NTSB) which 

are similarly sized 

agencies). 

Page 46 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

E.5.c. Does the agency compare its performance in the EEO process to other federal agencies of similar size? X Yes, we 

[see MD-715, II(E)] informally 

compare our EEO 

process and 

programs to other 

agencies within 

the small agency 

council. 

Page 47 
 

 

 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Essential Element: F Responsiveness and Legal Compliance 

Compliance 

Indicator 

Measures 

F.1. The agency has processes in place to ensure timely and full compliance with 

EEOC orders and settlement agreements. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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? [see 29 CFR §1614.102(e); MD-715, II(F)] 

X 

F.1.b. Does the agency have a system of management controls to ensure the timely, accurate, and complete 

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

X 

F.1.c. Are there procedures in place to ensure the timely and predictable processing of ordered monetary relief? 

[see MD-715, II(F)] 

X Yes, OGC 

approves any 

monetary 

settlements and 

OEO follows up 

to ensure HR 

processes 

payments timely. 

F.1.d. Are procedures in place to process other forms of ordered relief promptly? [see MD-715, II(F)] X Yes, OEO 

receives a copy of 

the settlement to 

ensure 

compliance. 

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? [see MD-110, Ch. 9(IX) 

(H)] 

X 

Page 48 
 

 

 

 

 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Agency Self-Assessment Checklist 

Compliance 

Indicator 

Measures 

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

directives, orders, and other written instructions. 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

F.2.a. Does the agency timely respond and fully comply with EEOC orders? [see 29 CFR §1614.502; MD-715, 

II(E)] 

X 

F.2.a.1. When a complainant requests a hearing, does the agency timely forward the investigative file to the 

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

X Yes, when OEO 

receives a request 

for a hearing 

notice, we 

immediately 

download the 

complaint file to 

FedSEP portal. 

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? [see 29 CFR §1614.501] 

X 

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? [see 29 CFR §1614.403(e)] 

X 

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

documentation for completing compliance? 

X 

Compliance 

Indicator 

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

Measures 

Measure Has 

Been Met 

Yes No N/A 

For all unmet 

measures, provide 

a 

brief explanation 

in 

the space below or 

complete and 

attach 

an EEOC FORM 

715-

01 PART H to the 

agency's status 

report 

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)] 

X Yes, by March 30 

every year. 

F.3.b. Does the agency timely post on its public webpage its quarterly No FEAR Act data? [see 29 CFR 

§1614.703(d)] 

X Yes, by the 15th 

of the month 

following the end 

of each quarter. 

Essential Element: O Other 

Page 49 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Attain Essential Elements 

PART H.1 

Brief Description of Program B.1.d. Does the EEO Director regularly participate in senior-level staff meetings concerning personnel, budget, technology, and 

Deficiency: other workforce issues? [see MD-715, II(B)] 

Does the EEO Director regularly participate in senior-level staff meetings concerning personnel, budget, technology and other workforce issues? 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

02/28/2020 01/31/2021 01/17/2022 To have the EEO Director participate in senior-level staff meetings concerning personnel, 

budget, technology and other workforce issues. 

Responsible Officials 

Title Name Standards Address the Plan? 

Director of Equal Opportuniry Shiri Ndang Yes 

Planned Activities 

Target Date Planned Activity 

10/01/2020 The EEO Director will participate in conference calls and meetings with the Senior 

Executive Members and be briefed on all Executive Committee discussions concerning 

personnel, budget, technology and other workforce issues. 

Sufficient 

Staffing & 

Funding? 

Modified Date Completion 

Date 

Yes 

Accomplishments 

Fiscal Accomplishment 

Year 

2022 RRB no longer views this as a deficiency. 

When this issue was first reported in 2020, the agency had not yet established regular and effective means for the OEO Director to advise agency heads 

(Board Members) and other senior management officials of the effectiveness, efficiency, and legal compliance of the agency’s EEO program. As of FY 

2022, the OEO director meets monthly with Board offices and Executive Committee members. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

02/28/2020 01/31/2021 01/18/2022 Does the EEO Director regularly participate in senior-level staff meetings concerning 

personnel, budget, technology and other workforce issues? 

Responsible Officials 

Title Name Standards Address the Plan? 

Director Equal Opportunity Shiri Ndang Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

05/01/2020 For the EEO Director to be apart of Senior Level meetings on hiring workforce, technology, Yes 10/01/2021 

etc. 

Accomplishments 

Fiscal Accomplishment 

Year 

2021 The previous Director of EEO met with the Executive Committee (EC) during FY2019 and expressed the need to be included on policies effecting 

personnel, budget, technology and other workforce issues. The EC agreed and said that they would contact the EEO Director in the future. During 

COVID-19 pandemic in FY2020, the previous EEO Director was sent policies to review prior to implementation. 

In FY 2021, the Senior Executive Committee Members had weekly conference call meetings with the Director of EEO to keep her updated on all senior 

level meetings concerning personnel, budget, technology and other workforce issues . 

However in FY 2022, the new EEO Director begun attending board meetings and has recurring bi-weekly meetings with the agency's Senior Executive 

Officer (SEO). 

Page 50 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Attain Essential Elements 

PART H.2 

Brief Description of Program C.4.e.2. Develop and/or conduct outreach and recruiting initiatives? [see MD-715, II(C)] Deficiency: 

Pursuant to Section II(C) of MD-715, the agency does not currently have in place a program for the EEO office to collaborate and conduct outreach and recruiting 

activities with Human Resources staff. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2022 10/01/2024 To determine the feasibility of a process for OEO and HR staff to jointly conduct recruiting 

and outreach activities. 

Responsible Officials 

Title Name Standards Address the Plan? 

Director of Equal Opportunity Shiri Ndang Yes 

Director of Human Resources Nancy Bitzer Yes 

Planned Activities 

Target Date Planned Activity 

09/30/2023 Establish and implement an outreach and recruitment initiative outlining the agency's 

planned participation in job fairs and/or federal-specific events that target students and recent 

graduates. 

07/30/2023 Evaluate the sufficiency of RRB's recruitment and outreach activities to support the agency's 

succession planning and diversity initiatives. 

Sufficient 

Staffing & 

Funding? 

Modified Date Completion 

Date 

Yes 

Yes 

Accomplishments 

Fiscal Accomplishment 

Year 

Page 51 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Attain Essential Elements 

PART H.3 

Brief Description of Program C.4.b. Has the agency established timetables/schedules to review at regular intervals its merit promotion program, employee 

Deficiency: 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? [see MD-715 Instructions, 

Sec. I] 

Establishment of timetables/schedules to review the merit promotion program,, employee recognition awards program, employment development/training programs, 

personnel policies, procedures and practices for systemic barriers that may impede full participation in the program by all EEO groups. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2020 10/01/2023 To establish schedules to review the agency's 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? 

Responsible Officials 

Title Name Standards Address the Plan? 

Director, Office of Equal Opportunity (OEO) Shiri Ndang Yes 

Human Resources Director Nancy Bitzer Yes 

Target Date 

09/30/2023 

Planned Activities 

Planned Activity 

June/July 2022 - Barrier analysis training for RRB OEO staff with MD-715 and data 

collection/analysis responsibilities. 

Sept 2022 - Establishment of a Barrier Analysis Workgroup to investigate barriers to EEO 

(hiring, retention & career development/advancement). Purpose of the workgroup is to 

leverage EEO data RRB-wide to conduct a comprehensive trigger analysis. 

Oct 2022 – Barrier Analysis Workgroup conducts its 1st quarter FY 2023 meeting to identify 

its priorities. 

Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Yes 

Accomplishments 

Fiscal Accomplishment 

Year 

2022 In September 2022, the Director of Equal Opportunity established a Barrier Analysis Workgroup which meets regularly to review data for trigger 

identification and trends. 

The HR Director and OEO Director also have bi-weekly meetings to discuss and follow up on pending matters and activities related to workforce and 

applicant data. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

08/03/2022 12/01/2022 09/01/2022 Evaluate agency needs and provide a project plan to Board staff and Executive Committee 

Chair. 

Responsible Officials 

Title Name Standards Address the Plan? 

Director of Equal Opportunity Shiri Ndang Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Page 52 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Attain Essential Elements 

Accomplishments 

Fiscal Accomplishment 

Year 

2022 The OEO Director briefed and reviewed EEOC Technical Assistance Review (TAR) letter with Board staff and Agency leadership. 

The OEO Director also provided a suggested plan of action to Board staff and Agency leadership. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

09/01/2022 09/30/2023 Hire a consulting firm to assist the agency with barrier analysis. 

Responsible Officials 

Title Name Standards Address the Plan? 

Director of Equal Opportunity Shiri Ndang Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

2022 On 09/26/2022, RRB contracted with a management consulting firm (EconSys, Inc.) to assist with barrier analysis. A comprehensive analysis of RRB's 

workforce and applicant data is ongoing at the time this report was drafted. The purpose of the comprehensive analysis is to both identify any data 

shortfalls or issues and to identify relevant triggers. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

09/01/2022 09/30/2022 Identify and establish a barrier analysis workgroup to facilitate barrier analysis projects 

Responsible Officials 

Title Name Standards Address the Plan? 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

02/17/2023 09/30/2024 When barriers are identified, working groups will incorporate the EEO Action plans into the 

agency's strategic plan. 

Responsible Officials 

Title Name Standards Address the Plan? 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Page 53 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Attain Essential Elements 

Accomplishments 

Fiscal Accomplishment 

Year 

2023 -Barrier Analysis Project Teams 

A project team in OEO was initiated to review barriers for persons with disabilities. There is an ongoing review of workforce demographics, complaints, 

and various HR program data to identify potential triggers and/or potential barriers. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

02/17/2023 09/30/2023 For ongoing barrier analysis projects, identify managers and subject matter experts to work on 

barrier analysis projects. 

Responsible Officials 

Title Name Standards Address the Plan? 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

02/17/2023 09/30/2024 For barriers identified, working groups will develop action plans to remove barriers. 

Responsible Officials 

Title Name Standards Address the Plan? 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

Page 54 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Attain Essential Elements 

PART H.4 

Brief Description of Program 

Deficiency: 

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? [see 29 CFR §1614.203(d)(1)(iii)(C)] 

Does the agency conduct exit surveys. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2021 10/01/2022 Meet with the Director of HR about re-establishing Exit Surveys. 

Responsible Officials 

Title Name Standards Address the Plan? 

EEO Director Pamela M. Tate Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

04/01/2021 Contacted the Director of HR to discuss the re-establishment of Exit Surveys and was Yes 

informed that they (HR) has already begun the process to re-establish it. Will follow-up. 

Accomplishments 

Fiscal Accomplishment 

Year 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2021 10/01/2022 08/22/2022 Meet with the Director of HR about re-establishing exit surveys 

Responsible Officials 

Title Name Standards Address the Plan? 

EEO Director Shiri Ndang Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

2022 RRB no longer considers this as a deficiency. In August 2022, the Director of Human Resources modified RRB’s exit survey to include disability-related 

questions as a result of EEOC Technical Assistance Review recommendations. 

2022 As part of RRB’s IT Modernization rollout plan, the agency has re-established its exit survey which went live in mid-January 2022 via Microsoft Forms. 

Page 55 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART I EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Eliminate Identified Barriers 

PART I.1 

Source of the Trigger: Other 

Specific Workforce Data 

Table: 

A/B1, A/B7, A/B8 

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? 

During EEOC's Technical Assistance Review in 2022, they identified several triggers for PWD and 

PWTD involving the 2210 series, the senior grade levels, and possibly separations. RRB was 

instructed to establish a schedule for investigating the triggers and conduct barrier analysis.. 

STATEMENT OF 

BARRIER GROUPS: 

Barrier Group 

All Men 

All Women 

Hispanic or Latino Males 

Hispanic or Latino Females 

Black or African American Males 

Black or African American Females 

Asian Males 

Asian Females 

Barrier Analysis Process 

Completed?: 

N 

Barrier(s) Identified?: N 

STATEMENT OF 

IDENTIFIED BARRIER: 

Provide a succinct statement 

of the agency policy, 

procedure 

or practice that has been 

determined to be the barrier 

of the 

undesired condition. 

Barrier Name Description of Policy, Procedure, or Practice 

N/A EEOC Technical Assistance Review instruction to study PWD and PWTD 

participation rate in the 2210 series, senior grade levels and separations.. 

Objective(s) and Dates for EEO Plan 

Date 

Initiated 

Target Date Sufficient 

Funding / 

Staffing? 

Date 

Modified 

Date 

Completed 

Objective Description 

01/31/2023 02/27/2024 Yes Continued evaluation and investigation of this trigger 

involving PWDs and PWTDs in the 2210 series, senior 

grades and separations, as well as to determine 

appropriate recommendations and action(s). 

Responsible Official(s) 

Title Name Standards Address The Plan? 

Director of Equal Opportunity Shiri Ndang Yes 

Page 56 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART I EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Eliminate Identified Barriers 

Responsible Official(s) 

Title Name Standards Address The Plan? 

Director of Human Resources Nancy Bitzer Yes 

Planned Activities Toward Completion of Objective 

Target Date Planned Activities Sufficient 

Staffing & 

Funding? 

Modified 

Date 

Completion 

Date 

02/27/2024 The Office of Equal Opportunity (OEO) will establish an 

analysis workgroup in partnership with Human Resources, to 

further evaluate and 

determine the root cause of the lower-than-expected 

participation rate. 

Yes 

Report of Accomplishments 

Fiscal Year Accomplishments 

2023 In process of determination of existence of barrier(s). 

Page 57 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART I EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Eliminate Identified Barriers 

PART I.2 

Source of the Trigger: Workforce Data (if so identify the table) 

Specific Workforce Data 

Table: 

Workforce Data Table - A7 

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? 

Low participation rate of PWDs and PWTDS in new hires and promotions in the GS 13 to SES 

cluster. Trigger was identified through the review of HR data on accessions and promotions. 

STATEMENT OF 

BARRIER GROUPS: 

Barrier Group 

All Women 

Hispanic or Latino Males 

Hispanic or Latino Females 

Black or African American Males 

Asian Males 

Asian Females 

Barrier Analysis Process 

Completed?: 

N 

Barrier(s) Identified?: N 

STATEMENT OF 

IDENTIFIED BARRIER: 

Provide a succinct statement 

of the agency policy, 

procedure 

or practice that has been 

determined to be the barrier 

of the 

undesired condition. 

Barrier Name Description of Policy, Procedure, or Practice 

Objective(s) and Dates for EEO Plan 

Date 

Initiated 

Target Date Sufficient 

Funding / 

Staffing? 

Date 

Modified 

Date 

Completed 

Objective Description 

Responsible Official(s) 

Title Name Standards Address The Plan? 

Director of Equal Opportunity Shiri Ndang Yes 

Director of Human Resources Nancy Bitzer Yes 

Planned Activities Toward Completion of Objective 

Target Date Planned Activities Sufficient 

Staffing & 

Funding? 

Modified 

Date 

Completion 

Date 

Page 58 
EEOC FORM 

715-02 

PART I 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Eliminate Identified Barriers 

Report of Accomplishments 

Fiscal Year Accomplishments 

Page 59 
EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART I EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2021 to September 30, 2022 

Plan to Eliminate Identified Barriers 

PART I.3 

Source of the Trigger: Workforce Data (if so identify the table) 

Specific Workforce Data 

Table: 

Workforce Data Table - A1 

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? 

High rate of separation by PWDs and PWTDs from the agency. Trigger was identified through the 

review of HR data on separations. 

STATEMENT OF 

BARRIER GROUPS: 

Barrier Group 

All Men 

All Women 

Black or African American Males 

Black or African American Females 

Barrier Analysis Process 

Completed?: 

N 

Barrier(s) Identified?: N 

STATEMENT OF 

IDENTIFIED BARRIER: 

Provide a succinct statement 

of the agency policy, 

procedure 

or practice that has been 

determined to be the barrier 

of the 

undesired condition. 

Barrier Name Description of Policy, Procedure, or Practice 

Objective(s) and Dates for EEO Plan 

Date 

Initiated 

Target Date Sufficient 

Funding / 

Staffing? 

Date 

Modified 

Date 

Completed 

Objective Description 

Responsible Official(s) 

Title Name Standards Address The Plan? 

Director of Equal Opportunity Shiri Ndang Yes 

Planned Activities Toward Completion of Objective 

Target Date Planned Activities Sufficient 

Staffing & 

Funding? 

Modified 

Date 

Completion 

Date 

Report of Accomplishments 

Fiscal Year Accomplishments 

Page 60 
ppppppp 

MD-715 – Part J 

Special Program Plan 

for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities 

To capture agencies’ affirmative action plan for persons with disabilities (PWD) and 

persons with targeted disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e)) 

and MD-715 require agencies to describe how their affirmative action plan will improve the 

recruitment, hiring, advancement, and retention of applicants and employees with 

disabilities. 

Section I: Efforts to Reach Regulatory Goals 

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

participation of persons with disabilities and persons with targeted disabilities in the federal government 

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving PWD by grade level cluster in the permanent workforce? If “yes”, 

describe the trigger(s) in the text box. 

a.Cluster GS-1 to GS-10 (PWD) Answer Yes 

b.Cluster GS-11 to SES (PWD) Answer No 

During FY 2022, RRB had a total of 745 employees in the permanent 

workforce of which 146 (or 19.2 percent) were employees with a disability 

(PWD). 59 employees in the GS-01 to GS-10 cluster and 87 employees in the 

GS-11 to SES cluster stated that they have a disability. The participation rate 

for PWD in the GS-01 to 10 cluster was 7.9 percent, which is below the target 

of 12%. RRB has a trigger for PWD in the GS-1 through GS-10 cluster. The 

participation rate for PWD in the GS-11 to SES cluster was 12 percent, which 

meets the target. Disability workforce data is employees who self-identify as 

having a disability. 

*For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, as set forth in 29 C.F.R. § 1614.203(d) 

(7). For all other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the 

Washington, DC metropolitan region. 

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by grade level cluster in the permanent workforce? If “yes”, 

describe the trigger(s) in the text box. 

a.Cluster GS-1 to GS-10 (PWTD) Answer Yes 

b.Cluster GS-11 to SES (PWTD) Answer Yes 

During FY 2022, RRB had a total of 745 employees in the permanent 

workforce of which 27 (or 3.6 percent) were employees with a targeted 

disability (PWTD). 13 employees in the GS-01 to GS-10 cluster and 14 

employees in the GS-11 to SES cluster stated that they have a targeted 

disability. The participation rate for PWTD in the GS-01 to 10 cluster was 1.7 

percent, which is below the target of 2%. RRB has a trigger for PWTD in the 

GS-1 through GS-10 cluster. The participation rate for PWTD in the GS-11 to 

SES cluster was 1.9 percent, which is also below the target of 2%. RRB has a 

trigger for PWTD in the GS-11 to SES cluster. Disability workforce data is 

employees who self-identify as having a disability. 

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

During FY 2022, the OEO Director raised the awareness of the Model Disability 

Program goals through briefings and an EEOC Technical Assistance Outreach 

visit for Board and Executive Committee members. OEO continues to provide 

the Board and agency leadership with monthly hiring and separations 

summaries. Additional OEO outreach activities include, but are not limited to, 

working with the Employees with Disabilities Council (EDAC) and RRB's 

American Legion group. In FY 2022, the OEO Director participated in quarterly 

Equal Employment Opportunity Commission Federal Exchange on 

Employment and Disability (FEED) meetings. To assist with recruitment, the 

Director of Equal Opportunity in FY 2022 also has shared leads on career and 

job fair leads with HR staff. 

Page 61 
Section II: Model Disability Program 

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

persons with disabilities and persons with targeted disabilities, administer the reasonable accommodation program and 

special emphasis program, and oversee any other disability hiring and advancement program the agency has in place. 

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR THE DISABILITY 

PROGRAM 

1.  Has the agency designated sufficient qualified personnel to implement its disability program during the reporting period? If “no”, describe the 

agency’s plan to improve the staffing for the upcoming year. 

Answer Yes 

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 

Architectural Barriers Act Compliance 

Special Emphasis Program for PWD and PWTD 

Section 508 Compliance 

Processing reasonable accommodation requests 

from applicants and employees 

Processing applications from PWD and PWTD 

Answering questions from the public about 

hiring authorities that take disability into 

account 

# of FTE Staff By Employment Status 

Full Time Part Time Collateral Duty 

0 0 1 

0 0 1 

0 0 1 

0 0 1 

0 0 1 

0 0 1 

Responsible Official (Name, Title, 

Office Email) 

Scott Rush 

Supvy Facility Operations Specialist 

Scott.Rush@rrb.gov 

Kathy Robinson 

EEO Specialist 

Kathy.Robinson@rrb.gov 

Robert LaBerry 

Supvy IT Specialist 

Robert.Laberry@rrb.gov 

Regina Block 

HR Specialist/Labor Relations 

Regina.Block@rrb.gov 

Meghan O'Connor 

Lead HR Specialist/SPC 

Meghan.O'Connor@rrb.gov 

Meghan O'Connor 

Lead HR Specialist/SPC 

Meghan.O'Connor@rrb.gov 

3. Has the agency provided disability program staff with sufficient training to carry out their responsibilities during the reporting period? If “yes”, describe 

the training that disability program staff have received. If “no”, describe the training planned for the upcoming year. 

Answer Yes 

During FY 2022, disability program staff received training on the following 

topics: reasonable accommodation, EEO updates, and accessibility (ABA) in 

the workplace. 

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM 

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

during the reporting period? If “no”, describe the agency’s plan to ensure all aspects of the disability program have 

sufficient funding and other resources 

Answer Yes 

Section III: Plan to Recruit and Hire Individuals with Disabilities 

Pursuant to 29 C.F.R. §1614.203(d)(1)(i) and (ii), agencies must establish a plan to increase the recruitment and hiring 

of individuals with disabilities. The questions below are designed to identify outcomes of the agency’s recruitment 

program plan for PWD and PWTD 

A.  PLAN TO IDENTIFY JOB APPLICATIONS WITH DISABILITIES 

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

Page 62 
Selective Placement Program Coordinator (SPPC) in the Bureau of Human 

Resources receives inquiries from job applicants with disabilities, including 

individuals with targeted disabilities via email. Staffing Specialists in the 

Staffing and Classification Unit in the Bureau of Human Resources receive 

applications from applicants with disabilities, including individuals with targeted 

disabilities, through the application process. The specialists review the 

provided documentation and make a determination as to whether the applicant 

is eligible for veterans’ preference. The specialists collaborate with the SPPC 

as necessary. 

2. Pursuant to 29 C.F.R. §1614.203(a)(3), describe the agency’s use of hiring authorities that take disability into account (e.g., Schedule A) to recruit PWD 

and PWTD for positions in the permanent workforce 

The RRB is restricted in its use of special appointment authorities based on the 

Railroad Retirement Act (RRA) and the Railroad Unemployment and Insurance 

Act (RUIA). Both the RRA and the RUIA mandate that all positions within the 

RRB must be in the competitive service with the exception of only 3 positions 

(assistant to Board Members). The agency is therefore restricted in its use of 

special appointment authorities and is limited to authorities that permit noncompetitive hiring into competitive service positions. The RRB does not have 

the ability to use Schedule A hiring authority (non-competitive hiring) as it is an 

excepted service authority and our establishing legislation prohibits the use of 

most excepted service authorities, including Schedule A. This response stems 

from the Powers and Duties of the Board section of the RRA of 1974. The 

specific language is located in 45 USC 231f(b)(9). Nevertheless, our agency 

has created work-arounds for this limitation to comply with other OMB rules, 

such as hiring attorneys, students, and recent graduates as excepted service. 

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. 

Individuals do not apply for a position under a hiring authority that takes 

disability into account because we do not have authority to hire under these 

special authorities as stated above. 

4.  Has the agency provided training to all hiring managers on the use of hiring authorities that take disability into account (e.g., Schedule A)? If “yes”, 

describe the type(s) of training and frequency. If “no”, describe the agency’s plan to provide this training. 

Answer N/A 

We do not have hiring authority under Schedule A and therefore, no training is 

provided on Schedule A. The RRB does not have the ability to use Schedule A 

hiring authority (non-competitive hiring) as it is an excepted service authority 

and our establishing legislation prohibits the use of most excepted service 

authorities, including Schedule A. This response stems from the Powers and 

Duties of the Board section of the RRA of 1974. The specific language is 

located in 45 USC 231f(b)(9). Nevertheless, our agency has created workarounds for this limitation to comply with other OMB rules, such as hiring 

attorneys, students, and recent graduates as excepted service. 

B.  PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS 

Describe the agency’s efforts to establish and maintain contacts with organizations that assist PWD, including PWTD, 

in securing and maintaining employment. 

Page 63 
Internally, RRB has an Employees with Disabilities Advisory Council (EDAC), 

which serves as an advocate and catalyst for change and also helps to provide 

strategic direction. Externally, RRB engages with various related Affinity 

Groups. Since FY2020, the Bureau of Human Resources has established and 

maintained contacts with eleven organizations that assist PWDs and PWTDs. 

These organizations include the Chicago Lighthouse, Aspire Non-Profit, Trinity 

Services, Inc., Search, Inc., Goodwill Chicago, America Works, the City of 

Chicago, the Department of Human Services, Independent Living and 

Transition Advocate Progress Center, and Southwest American Job Center. 

HR has secured a designated contact person including their email address and 

telephone number at each of these organizations. HR sends our vacancy 

notices to them and in turn they disseminate the information to clients being 

serviced by their organization. Continuing throughout FY 2022, HR staff was 

not able to attend in-person career fairs due to COVID-19. 

C.  PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) 

1.  Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do triggers exist for PWD and/or PWTD among the new hires in the 

permanent workforce? If “yes”, please describe the triggers below. 

a. New Hires for Permanent Workforce (PWD) Answer Yes 

b. New Hires for Permanent Workforce (PWTD) Answer Yes 

The hiring rate for PWD in FY 2022 was 15 or 2% which is below the EEOC 

target of 12%. The hiring rate for PWTD in FY 2022 was non-existent (0). None 

of RRB’s new hires in FY 2022 was a PWTD, which is also below the EEOC 

target of 2%. 

2.  Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among the new hires for any of the mission-critical 

occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data is not available for your agency, and describe your plan 

to provide the data in the text box. 

a. New Hires for MCO (PWD) Answer Yes 

b. New Hires for MCO (PWTD) Answer Yes 

2 (or 0.3 percent) PWDs were hired in FY 2022 for MCO 2210 (Information 

Technology). 8 (or 1.1 percent) PWDs were hired in FY 2022 for MCO 0993 

(Railroad Retirement Claims Examining). No PWDs was hired in FY 2022 in 

the following MCO series: 0301 (Miscellaneous Administration & Program). No 

PWTDs were hired in FY 2022 for the following MCO series: 2210 (Information 

Technology), 0993 (Railroad Retirement Claims Examining) and 0301 

(Miscellaneous Administration & Program) 

3.  Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among the qualified internal applicants for any of the 

mission-critical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data is not available for your agency, and 

describe your plan to provide the data in the text box. 

a. Qualified Applicants for MCO (PWD) Answer N/A 

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

RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround USA Staffing limitations. 

4.  Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among employees promoted to any of the missioncritical occupations (MCO)? If “yes”, please describe the triggers below. Select “n/a” if the applicant data is not available for your agency, and describe 

your plan to provide the data in the text box. 

a. Promotions for MCO (PWD) Answer No 

b. Promotions for MCO (PWTD) Answer No 

Disability Promotion in FY 2022 (TOTAL PROMOTIONS – 102), Number # of 

Promotions who were PWD = 18 or 17.6 percent, Number # of Promotions who 

were PWTDs = 2 or 2 percent, Due to applicant flow data limitations during FY 

2022, RRB is still working on drill down promotion data for MCOs. 

Page 64 
Section IV: Plan to Ensure Advancement Opportunities for Employees with Disabilities 

Pursuant to 29 C.F.R. §1614.203(d)(1)(iii), agencies are required to provide sufficient advancement opportunities for 

employees with disabilities. Such activities might include specialized training and mentoring programs, career 

development opportunities, awards programs, promotions, and similar programs that address advancement. In this 

section, agencies should identify, and provide data on programs designed to ensure advancement opportunities for 

employees with disabilities. 

A.  ADVANCEMENT PROGRAM PLAN 

Describe the agency’s plan to ensure PWD, including PWTD, have sufficient opportunities for advancement. 

All managers and supervisors are encouraged to promote the career 

development of all employees, including individuals with disabilities and 

individuals with targeted disabilities. OEO continues to promote workplace 

diversity goals and opportunities through the Employees with Disabilities 

Advisory Council (EDAC). 

B.  CAREER DEVELOPMENT OPPORTUNITES 

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

RRB has a variety of career development programs that require supervisory 

approval but not competition, including: (1) Executive coaching; (2) Pathways 

internships as of FY 2023; (3) multiple training opportunities for employees at 

all grade levels; and (4) training program for new supervisors. RRB continues 

to use career ladder promotions as a recruitment strategy to hire at the entry 

level with development, growth, and promotion potential. In addition, RRB 

employees also have access to training/career development courses through 

the following means: • RRB University is the agency’s learning management 

system (LMS) and the official system of record for all training and development 

records. The system delivers both mandatory and developmental training 

assignments and opportunities. RRB University’s learning resources can also 

be used as quick references, as practical job aids to gain in-depth knowledge, 

or to practice skills. • Treasury Executive Institute (TEI) – In partnership with 

the Department of Treasury, RRB routinely promotes the use of the TEI for 

leadership development for GS 14s, GS 15 and SES. TEI’s leadership 

development programs align with the Office of Personnel Management (OPM) 

Executive Core Qualifications (ECQ) and their supporting competencies. In 

addition, TEI provides coaching, a powerful tool for any RRB manager seeking 

to develop others and maximize employee performance and engagement. • On 

a yearly basis, the RRB also encourages all employees to complete and submit 

to their supervisor an Individual Development Plan (IDP). The RRB hosts 

workshops and opportunities for any employee interested in participating in the 

IDP process. 

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

to participate. 

Total Participants PWD PWTD 

Career Development Opportunities 

Applicants (#) Selectees (#) Applicants (#) Selectees (#) Applicants (#) Selectees (#) 

Internship Programs N/A N/A N/A N/A N/A N/A 

Mentoring Programs N/A N/A N/A N/A N/A N/A 

Coaching Programs N/A N/A N/A N/A N/A N/A 

Training Programs N/A N/A N/A N/A N/A N/A 

Detail Programs N/A N/A N/A N/A N/A N/A 

Other Career Development N/A N/A N/A N/A N/A N/A 

Programs 

Fellowship Programs N/A N/A N/A N/A N/A N/A 

3.  Do triggers exist for PWD among the applicants and/or selectees for any of the career development programs? (The appropriate benchmarks are the 

relevant applicant pool for the applicants and the applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant 

data is not available for your agency, and describe your plan to provide the data in the text box. 

a. Applicants (PWD) Answer N/A 

b. Selections (PWD) Answer N/A 

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Not applicable. The Agency does not have career development programs that 

require competition. 

4.  Do triggers exist for PWTD among the applicants and/or selectees for any of the career development programs? (The appropriate benchmarks are the 

relevant applicant pool for the applicants and the applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant 

data is not available for your agency, and describe your plan to provide the data in the text box. 

a. Applicants (PWTD) Answer N/A 

b. Selections (PWTD) Answer N/A 

Not applicable. The Agency does not have career development programs that 

require competition. 

C.  AWARDS 

1.  Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for any level of the time-off awards, 

bonuses, or other incentives? If “yes”, please describe the trigger(s) in the text box. 

a. Awards, Bonuses, & Incentives (PWD) Answer No 

b. Awards, Bonuses, & Incentives (PWTD) Answer No 

2.  Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for quality step increases or performancebased pay increases? If “yes”, please describe the trigger(s) in the text box. 

a. Pay Increases (PWD) Answer No 

b. Pay Increases (PWTD) Answer No 

3.  If the agency has other types of employee recognition programs, are PWD and/or PWTD recognized disproportionately less than employees without 

disabilities? (The appropriate benchmark is the inclusion rate.) If “yes”, describe the employee recognition program and relevant data in the text box. 

a. Other Types of Recognition (PWD) Answer N/A 

b. Other Types of Recognition (PWTD) Answer N/A 

D.  PROMOTIONS 

1.  Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to the senior grade levels? 

(The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS 

pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available 

for your agency, and describe your plan to provide the data in the text box. 

a.  SES 

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

ii. Internal Selections (PWD) Answer N/A 

b. Grade GS-15 

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

ii. Internal Selections (PWD) Answer N/A 

c.  Grade GS-14 

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

ii. Internal Selections (PWD) Answer N/A 

d.  Grade GS-13 

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

ii. Internal Selections (PWD) Answer N/A 

RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround USA Staffing limitations. 

However, our current FY 2022 show that there were 20 promotions (internal 

and external) in the GS 13 to SES cluster. Of the 20 promotions, PWDs 

accounted for 5 or 20 percent. No PWTDs were promoted. 

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2.  Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions to the senior grade levels? 

(The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS 

pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available 

for your agency, and describe your plan to provide the data in the text box. 

a.  SES 

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

ii. Internal Selections (PWTD) Answer N/A 

b. Grade GS-15 

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

ii. Internal Selections (PWTD) Answer N/A 

c.  Grade GS-14 

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

ii. Internal Selections (PWTD) Answer N/A 

d.  Grade GS-13 

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

ii. Internal Selections (PWTD) Answer N/A 

RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround for USA Staffing limitations. 

However, our current FY 2022 data shows that there were 20 promotions 

(internal and external) in the GS 13 to SES cluster. Of the 20 promotions, 

PWDs accounted for 5 or 25 percent. Of the 5 promotions, 1 PWD or 5 percent 

was selected for an internal promotion and 4 PWDs or 20 percent were 

external selection. No PWTDs or 0 percent were promoted. 

3.  Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD among the new hires to the senior grade levels? 

For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is 

not available for your agency, and describe your plan to provide the data in the text box. 

a. New Hires to SES (PWD) Answer N/A 

b. New Hires to GS-15 (PWD) Answer N/A 

c. New Hires to GS-14 (PWD) Answer N/A 

d. New Hires to GS-13 (PWD) Answer N/A 

RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround for USA Staffing limitations. 

However, our current FY 2022 data shows that there were 20 promotions 

(internal and external) in the GS 13 to SES cluster. Of the 20 promotions, 4 

PWDs or 20 percent were new hires (external). No PWTDs were promoted. 

4.  Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the new hires to the senior grade 

levels? For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant 

data is not available for your agency, and describe your plan to provide the data in the text box. 

a. New Hires to SES (PWTD) Answer N/A 

b. New Hires to GS-15 (PWTD) Answer N/A 

c. New Hires to GS-14 (PWTD) Answer N/A 

d. New Hires to GS-13 (PWTD) Answer N/A 

Page 67 
RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround USA Staffing limitations. 

However, our current FY 2022 data show that there were 20 promotions 

(internal and external) in the GS 13 to SES cluster. Of the 20 promotions, no 

PWTDs was selected. 

5.  Does your agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to supervisory positions? 

(The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If “yes”, 

describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your plan to provide the data in the 

text box. 

a.  Executives 

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

ii. Internal Selections (PWD) Answer N/A 

b.  Managers 

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

ii. Internal Selections (PWD) Answer N/A 

c. Supervisors 

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

ii. Internal Selections (PWD) Answer N/A 

RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround for USA Staffing limitations. 

However, our current FY 2022 data shows that there were 20 promotions 

(internal and external) in the GS 13 to SES cluster. Of the 20 promotions, 

PWDs accounted for 5 or 20 percent. No PWTDs were promoted. 

6.  Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions to supervisory positions? 

(The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) If “yes”, 

describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your plan to provide the data in the 

text box. 

a.  Executives 

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

ii. Internal Selections (PWTD) Answer N/A 

b.  Managers 

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

ii. Internal Selections (PWTD) Answer N/A 

c. Supervisors 

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

ii. Internal Selections (PWTD) Answer N/A 

RRB uses the services of OPM (USA Staffing) for the collection of applicant 

flow data (AFD). Currently, USA Staffing does not capture interview data 

(Tables A/B7 & A/B8). This limitation is a common challenge among all USA 

Staffing customers. RRB will explore short-term strategies using agency’s 

internal HR data as a temporary workaround USA Staffing limitations. 

However, our current FY 2022 show that there were 20 promotions (internal 

and external) in the GS 13 to SES cluster. Of the 20 promotions, PWDs 

accounted for 5 or 20 percent. No PWTDs were promoted. 

7.  Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD among the selectees for new hires to 

supervisory positions? If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box. 

a. New Hires for Executives (PWD) Answer N/A 

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b. New Hires for Managers (PWD) Answer N/A 

c. New Hires for Supervisors (PWD) Answer N/A 

Of the 20 promotions, no internal and external PWDs were selected. 

8.  Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the selectees for new hires to 

supervisory positions? If “yes”, describe the trigger(s) in the text box. Select “n/a” if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box. 

a. New Hires for Executives (PWTD) Answer N/A 

b. New Hires for Managers (PWTD) Answer N/A 

c. New Hires for Supervisors (PWTD) Answer N/A 

Of the 20 promotions, no internal and external PWTDs was selected. 

Section V: Plan to Improve Retention of Persons with Disabilities 

To be model employer for persons with disabilities, agencies must have policies and programs in place to retain 

employees with disabilities. In this section, agencies should: (1) analyze workforce separation data to identify barriers 

retaining employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) 

provide information on the reasonable accommodation program and workplace assistance services. 

A.  VOLUNTARY AND INVOLUNTARY SEPARATIONS 

1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability into the competitive service after two years of 

satisfactory service (5 CFR § 213.3102(u)(6)(i))? If “no”, please explain why the agency did not convert all eligible Schedule A employees. 

Answer N/A 

The agency is restricted from using Schedule A. 

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and involuntary separations exceed that of persons without 

disabilities? If “yes”, describe the trigger below. 

a.Voluntary Separations (PWD) Answer Yes 

b.Involuntary Separations (PWD) Answer Yes 

During FY 2022, RRB had 116 voluntary and 7 involuntary separations. PWDs 

accounted for 30 or 24.4 percent of total separations. 

3. Using the inclusion rate as the benchmark, did the percentage of PWTD among voluntary and involuntary separations exceed that of persons without 

targeted disabilities? If “yes”, describe the trigger below. 

a.Voluntary Separations (PWTD) Answer Yes 

b.Involuntary Separations (PWTD) Answer Yes 

During FY 2022, RRB had 116 voluntary and 7 involuntary separations. 

PWTDs accounted for 6 or 5 percent of total separations. 

4. If a trigger exists involving the separation rate of PWD and/or PWTD, please explain why they left the agency using exit interview results and other 

data sources. 

Exit interview results for FY 2022 are not reliable (incomplete) because RRB 

only added disability related questions to our exit survey in August 2022. 

Preliminary review of 2022 exit separations indicate that most employees 

transferred to another federal agency for a promotion or better opportunity. 

B.  ACCESSIBILITY OF TECHNOLOGY AND FACILITIES 

Pursuant to 29 CFR §1614.203(d)(4), federal agencies are required to inform applicants and employees of their rights 

under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), concerning the accessibility of agency 

technology, and the Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of 

agency facilities. In addition, agencies are required to inform individuals where to file complaints if other agencies are 

responsible for a violation. 

1. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ rights under Section 508 of the 

Rehabilitation Act, including a description of how to file a complaint. 

The RRB public facing website which explains how to file a formal complaint 

under Section 508 is (https://www.rrb.gov/Resources/OfficeOfEqualOpportunity/ 

Nondiscrimination). 

2. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ rights under the Architectural 

Barriers Act, including a description of how to file a complaint. 

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The address https://www.rrb.gov/Policy#aba contains information on rights 

associated with Section 508 of the Rehabilitation Act; however, the site does 

not include information on how to file a related complaint. 

3. Describe any programs, policies, or practices that the agency has undertaken, or plans on undertaking over the next fiscal year, designed to improve 

accessibility of agency facilities and/or technology. 

RRB continues to ensure access to our facilities for people with disabilities. 

RRB covers the 508 requirements as part of all new internally developed 

applications and Commercial Off-the-Shelf (COTS) purchases. Any information 

published on the agency's public website is checked and confirmed to be 508 

compliant prior to publication. Job applications are processed through 

USAJOBS. 

C.  REASONABLE ACCOMMODATION PROGRAM 

Pursuant to 29 C.F.R. § 1614.203(d)(3), agencies must adopt, post on their public website, and make available to all 

job applicants and employees, reasonable accommodation procedures. 

1. Please provide the average time frame for processing initial requests for reasonable accommodations during the reporting period. (Please do not include 

previously approved requests with repetitive accommodations, such as interpreting services.) 

30 days. 

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency’s reasonable accommodation program. Some examples of 

an effective program include timely processing requests, timely providing approved accommodations, conducting training for managers and supervisors, 

and monitoring accommodation requests for trends. 

RRB effectively operates a Reasonable Accommodation Program, including 

having a designated Reasonable Accommodation Coordinator. During FY 

2022, RRB received and timely processed 15 reasonable accommodation 

requests. RRB highlights disability topics through information and articles in the 

OEO newsletter. RRB includes information about Special Emphasis 

Observances and the Reasonable Accommodation Program on its intranet 

webpage; The RRB Reasonable Accommodation Coordinator provides a 

briefing to all new employees during orientation on reasonable accommodation 

procedures. In addition, the information is available on the intranet via the 

Bureau of Human Resources Employee link entitled “Accommodation for 

Individuals with Disabilities” at: http://boardwalk.intappsprod.usrrb.ad.local/ 

rrbintranet/default.asp?division=Office+of+Administration&group=Bureau+of 

+Human+Resources&subgroup=Accommodation+for+Individuals+with 

+Disabilities and on the agency’s public website at: https://www.rrb.gov/ 

Resources/OfficeOfEqualOpportunity/EEOPolicies 

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE 

Pursuant to 29 CFR §1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required to provide 

personal assistance services (PAS) to employees who need them because of a targeted disability, unless doing so 

would impose an undue hardship on the agency. 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. Some examples 

of an effective program include timely processing requests for PAS, timely providing approved services, conducting 

training for managers and supervisors, and monitoring PAS requests for trends. 

RRB's PAS procedure is included in the agency's Reasonable Accommodation 

Policy. RRB had no request for PAS in FY2022, thus no data is available on 

this. PAS training is incorporated into the mandatory RA training for supervisors. 

Section VI: EEO Complaint and Findings Data 

A. EEO COMPLAINT DATA INVOLVING HARASSMENT 

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging harassment, as compared to the government-wide 

average? 

Answer No 

2. During the last fiscal year, did any complaints alleging harassment based on disability status result in a finding of discrimination or a settlement 

agreement? 

Answer No 

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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. 

The agency had no findings of discrimination alleging harassment based on a 

disability during FY2022. 

B.  EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION 

1. During the last fiscal year, did a higher percentage of PWD file a formal EEO complaint alleging failure to provide a reasonable accommodation, as 

compared to the government-wide average? 

Answer No 

2. During the last fiscal year, did any complaints alleging failure to provide reasonable accommodation result in a finding of discrimination or a settlement 

agreement? 

Answer No 

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation during the last fiscal year, please 

describe the corrective measures taken by the agency. 

The RRB had no findings of discrimination involving the failure to provide a 

reasonable accommodation during FY2022. 

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 PWD and/or PWTD? 

Answer No 

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD? 

Answer N/A 

3. Identify each trigger and plan to remove the barrier(s), including the identified barrier(s), objective(s), responsible official(s), planned activities, and, 

where applicable, accomplishments 

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

While no barriers have yet been identified, PWD and PWTD-related triggers 

are the single highest priority of the trigger areas being investigated in FY 2023 

(as identified in Part I). The PWD/PWTD triggers related to low participation of 

PWD and PWTD in 3 MCOs (2210, 0993, 0301)and senior grades are 

described in Part J. The high separation rate of PWDs and PWTDS in FY 2022 

will also be investigated. One overarching factor that impacts the ability of the 

agency to conduct effective barrier analyses of PWD and PWTD is the 

accuracy of its disability status, recruitment and outreach data. 

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

While no barriers have yet been identified, PWD and PWTD-related triggers 

are the single highest priority of the trigger areas being investigated in FY 2023 

(as identified in Part I). The PWD/PWTD triggers related to low participation of 

PWD and PWTD in 3 MCOs (2210, 0993, 0301)and senior grades are 

described in Part J. The high separation rate of PWDs and PWTDS in FY 2022 

will also be investigated. One overarching factor that impacts the ability of the 

agency to conduct effective barrier analyses of PWD and PWTD is the 

accuracy of its disability status, recruitment and outreach data. 

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 

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