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, 2020 to September 30, 2021 

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. 837 

2. 20 

4. 857 

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, 2020 to September 30, 2021 

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 

Personal Assistance Services 

Procedures 

Y Y 

Anti-Harassment Policy and 

Procedures 

Y Y 

EEO Policy Statement Y Y 

Organization Chart Y Y 

Agency Strategic Plan Y Y 

Alternative Dispute Resolution 

Procedures 

Y Y 

Reasonable Accommodation 

Procedure 

Y Y 

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 

Human Capital Strategic Plan N N 

EEO Strategic Plan N Y 

Disabled Veterans Affirmative 

Action Program (DVAAP) Report 

N Y 
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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: MISSION 

INTRODUCTION 

This Equal Employment Opportunity Program Status Report for Fiscal Year 2021 (FY 2021) outlines the status of the Railroad 

Retirement Board's (RRB or Agency) Equal Employment Opportunity (EEO) Program activities undertaken pursuant to its EEO 

program responsibilities under Title VII of the Civil Rights Act of 1964. This report also describes RRB activities undertaken 

pursuant to its affirmative action obligations under the Rehabilitation Act of 1973, and as required by the U.S. Equal 

Employment Opportunity Commission’s (EEOC) Management Directive (MD) 715. 

This report highlights RRB’s accomplishments in establishing and maintaining a model program by promoting equal 

employment opportunity for all employees and applicants for employment. The report also provides the FY 2022 plan to 

address any programmatic deficiencies that were identified during the year. 

THE RAILROAD RETIREMENT BOARD (RRB) 

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 800 plus employees, approximately 220 

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. 

THE OFFICE OF EQUAL OPPORTUNITY (OEO) 

The Office of Equal Opportunity (OEO) provides leadership, direction and guidance in carrying out the RRB's equal opportunity 

and civil rights responsibilities. OEO administers the agency-wide Equal Employment Opportunity (EEO) programs by initiating 

policy as well as by implementing and enforcing a variety of Federal Laws, Executive Orders and regulations that relate to 

EEO. The Equal Employment Opportunity Commission (EEOC) Management Directive 715 describes elements that are 

considered essential for a model EEO program. 

OEO conducted its fiscal year 2021 (FY21) Equal Employment Opportunity Commission (EEOC) Management Directive 715 

(MD-715) Self-Assessment in two iterations. The first iteration was completed prior to the hire of the new EEO Director. After 

onboarding in January 2022, the new EEO Director conducted a second iteration of targeted assessments, focusing on Parts G 

and J measures with objective criteria in order to validate key compliance measures in the limited time available before the 

deferred submission deadline for the FY21 Annual Agency EEO Program Status Report (a.k.a. MD-715 Report). The new EEO 

Director will conduct a comprehensive validation of all compliance measures as part of the FY 2022 reporting cycle. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

According to EEOC Management Directive 715, six essential elements serve as the foundation for a model EEO 

program: 

A. Demonstrated commitment from agency leadership; 

B. Integration of EEO into the agency’s strategic mission; 

C. Management and program accountability; 

D. Proactive prevention of unlawful discrimination; 

E. Efficiency; and 

F. Responsiveness and legal compliance 

1. Essential Element A: Demonstrated Commitment from Agency Leadership: 

RRB’s EEO Program meets the requirements of Essential Element A. 

The RRB is committed to the principles of EEO and maintaining a successful EEO Program. This commitment is 

demonstrated throughout the Agency’s hierarchy from senior executives, managers and supervisors to all employees. 

Efforts to demonstrate this commitment include the following: 

A. The agency issues an effective, up-to-date Policy Statement: 

• The agency issued the EEO Policy Statement in July 2021 declaring the agency's position against discrimination 

on all protected basis. The statement was signed by the three Presidential Appointed Board Members and is 

posted on every floor in the RRB headquarters building and in every RRB field office. 

B. The agency has communicated EEO policies and procedures to all employees. 

• Disseminated copies of RRB’s existing EEO policy statements to all new employees during orientation and 

onboarding activities. The majority of these offerings were provided virtually due to the pandemic. 

• Ensured that new managers and existing employees, when promoted to supervisory ranks, were provided EEO 

Training. 

• RRB managers and supervisors actively supported the agency’s EEO program and objectives by participating in 

a variety of EEO and Special Emphasis Program activities or presentations in which EEO or Diversity & 

Inclusion was discussed. 

• The agency has all EEO policies and procedures such as the anti-harassment policy, reasonable accommodation 

procedures and other EEO program information downloaded on the internal agency's intranet as well as on the 

public website. 

• The name of the Director of Equal Opportunity is listed on the agency's website and the names of the EEO 

Specialist (Special Emphasis Program Chair) and the special emphasis committee members are posted on the 

agency's internal intranet system for all employees to view. 

• The agency's reasonable accommodation procedure which includes the personal assistance services procedures, 

and other written materials concerning the EEO program is posted on the agency's internal intranet system. 

• OEO provides training on the EEO policies through the RRB on-line Learning Management System known as 

RRB University. This training is tracked to ensure everyone completes it. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• All RRB SES members’ performance plans include an EEO element. In addition, an EEO sub-element was 

implemented and included in all RRB manager/supervisor (GS 13-15) performance appraisals as of October 

2020 (FY 2021). 

2. Essential Element B: Integration of EEO into the Agency's Strategic Mission: 

The Agency's EEO Program meets the requirements of Essential Element B. 

The RRB values its workforce and is committed to having an agency that welcomes and thrives on diversity.  This 

commitment to human capital planning is reiterated in the RRB Strategic Plan for Fiscal Years (FY) 2020-2026 

Strategic Plan which is posted on the agency’s website: 

"While budgets and technology are important, the true foundation for the agency’s ongoing success is 

its dedicated employees. The RRB will continue to recruit and hire a high-performing workforce and 

foster a leadership environment that inspires, motivates and guides employees towards our strategic 

goals, allows them to link their responsibilities with the agency’s strategic vision, and results in a stable 

workforce that has the competencies needed to fulfill our mission and reflects the diversity of all 

segments of American society.” 

The RRB has instituted an Agency Equity Team (AET). The importance of Equity, Diversity and Inclusion at RRB 

is reflected by the inclusion of OEO staff on the team. 

RRB staff participated in various EEO/diversity training and conferences covering the following areas: EEO 

investigations; EEO counseling; gender stereotyping; disability program management/reasonable accommodation; 

EEO complaints process, including dismissal of EEO complaints, motions, hearings, and sanctions; Special 

Emphasis Program Management; employee engagement; and diversity and inclusion. 

The Office of Equal Opportunity (OEO) serves as a resource to RRB managers by providing direction, guidance and 

monitoring of key activities to achieve a diverse workplace free of barriers to equal opportunity. The agency's EEO 

program is organized and structured to maintain a workplace that is free from discrimination in management 

policies, practices and/or procedures. 

• The RRB does not have a traditional single person "Agency Head". The agency is headed by a three member 

Board appointed by the President of the United States. One Board Member is appointed upon the 

recommendation of the Rail Employers, one is appointed upon the recommendation of the Rail Labor 

Organizations and the third is appointed to represent the public interest. The Board Members' terms of office are 

5 years. The Director of Equal Opportunity reports to the Head of the Agency, who are the three Board 

Members. 

• The OEO Director controls all aspects of the EEO program and has direct access to the Head of the Agency, and 

their assistants to inform them of the effectiveness, efficiency and legal compliances of the agency's EEO 

program. The OEO Director ensures timely compliance with EEOC orders and evaluates the EEO program and 

recommends improvements to the Agency Head. The OEO Director also ensures that complaint counselings, 

investigations and final agency actions are completed timely. 

• During FY 2021, the previous OEO Director was provided with the opportunity to review and offer comments 

on the Executive Committee (EC) policy revisions regarding workforce issues prior to final implementation.  As 

of FY 2022, the new OEO Director now participates in board meetings and has a bi-weekly recurring meeting 

with the Senior Executive Officer (SEO) to discuss agency operations. All of the progress was made after the 

end of the fiscal year reporting cycle, resulting in resolution of this previously identified deficiency in FY 2022. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• OEO is staffed by the OEO Director and the EEO Specialist who is the complaints manager and oversees all 

special emphasis committees and programs. The RRB is a small agency and in lieu of personnel being assigned 

as special emphasis program managers, the RRB has three committees: (1) the Workplace Diversity Committee 

(WDC); (2) the Employees with Disabilities Advisory Council (EDAC); and (3) the Federal Women's Program 

Committee (FWPC). Each group assists in planning and carrying out traditional commemorative events and 

informational programs on various aspects of workplace diversity and disability issues. The EDAC also provides 

recruitment resources and input on issues that affect their co-workers who have a disability. 

• The Office of Equal Opportunity (OEO) is an independent organization reporting directly to the Board and is 

responsible for its own budget. 

• The Director of Equal Opportunity and the EEO Specialist provided training to new supervisors and managers 

regarding their responsibilities under the EEO program and civil rights laws. 

3. Element C: Management and Program Accountability. 

The Agency's EEO program meets the requirements of Essential Element C: 

• RRB staff participated on inter-agency councils and groups, including the EEOC’s Director’s Meetings, Small 

Agency Council EEO Diversity & Inclusion Committee (SAC EEODI), Small Agency Council 501 

Subcommittee, OPM’s USA Staffing Reporting and Analytics Workgroup meetings, Chicago Federal Executive 

Board’s Shared Neutrals Program, among others. 

• Provide input and assist in the coordination, development, and implementation of the following EEO and related 

plans, in collaboration with Bureau of Human Resources, Director of Administration, and other applicable 

officials: 

◦ The Annual Federal Equal Opportunity Recruitment Program (FEORP) Plan, which involved 

targeted recruitment efforts based on a determination of underrepresentation of minorities and/or 

women in the various occupational categories, both nationally and in specific geographic locations. 

◦ The Disabled Veterans Affirmative Action Program (DVAPP) Representation and Assessment 

and Action Plan, which focuses on methods used to recruit and employ disabled veterans, especially 

those who are 30 percent or more disabled. 

• Respond, in a timely manner, to compliance issues related to the EEOC and other applicable instructions (e.g. 

executive orders). 

• OEO reviewed reports reflecting activity for personnel actions such as promotions, awards, accessions and 

separations. Thus, changes in the workforce are monitored on a continuous basis. This information is transmitted 

to all bureau/office heads by means of the OEO monthly administrative report which contains statistical updates 

on the status of employment activity. 

• Continued the compilation and distribution of an RRB-wide public campaign of Special Emphasis Programs 

(SEPs) for each commemorative month, including but not limited to, African American History Month and 

National Disability Employment Awareness Month. 

• RRB continues to ensure that all EEO policies were prominently posted in all Headquarters and field offices, 

employee bulletin boards, and on the agency website. All policies related to anti-discrimination laws, civil 

rights, the eeo complaint process, reasonable accommodations policies and ADR have been posted on the 

agency website. 

4. Essential Element D: Proactive Prevention of Unlawful Discrimination. 

The Agency's EEO program meets the requirements of Essential Element D. 

• Encouraged the use of Alternate Dispute Resolution (ADR) to all employees via the EEO Complaints Program, 

inclusive of supervisors and managers. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• Conducted workforce analyses regarding race, ethnicity, sex, and disability in which the groups were evaluated 

via workforce profile, major occupations, grade level distribution, compensation and reward system, and 

management/personnel policies and procedures. The RRB is a small agency and discriminatory policies or 

practices would easily come to light. 

• The No FEAR Act training module was updated by OEO staff for a planned deployment in FY 2022 across 

RRB as mandatory training. 

• The Employees with Disabilities Advisory Council (EDAC) has continued to work with the Bureau of Human 

Resources to establish organizations that assist people with disabilities in returning to the workforce. 

5. Essential Element E: Efficiency. 

The agency's EEO program meets the requirements of Essential Element E. 

RRB met all measures under Essential Element E. Some highlights of accomplishments under this element include 

the following: 

• The agency maintains an efficient, fair, and impartial complaint resolution process. The agency has collateral 

duty EEO Counselors and we secure contracted investigators for formal complaints. All employees/applicants 

who file an informal complaint of discrimination receives a Rights and Responsibilities booklet when they first 

contact the OEO. Contracted investigators are held accountable for poor work product and/or delays of 

complaint report of investigation files. All files and required documents are downloaded in proper format to 

EEOC through the Federal Sector EEO Portal (FedSEP). 

• Continued to track and monitor all EEO complaint activity throughout an Excel program. 

• All RRB EEO Counselors received the required 8 hour refresher training. 

• Continued to identify and monitor trends in complaint processing to ensure the agency is meeting its obligation 

under applicable laws. 

• Sufficiency reviews are conducted within OEO by the Director and the EEO Specialist. No one in the RRB’s 

Office of General Counsel (OGC) reviews the report in advance of the complainant requesting a hearing before 

EEOC. OGC is not included in the counseling or the investigation stage. OEO is responsible for drafting the 

final agency decision for the agency. 

• ADR is offered to every complainant who files a complaint of discrimination/harassment except those who file a 

sexual harassment complaint. Once ADR is elected, managers and supervisors are required to participate. 

Participating managers are also required to have the applicable settlement authority. Those who elect ADR 

usually settle their complaint during the informal stage. 

• All complaints were processed within the required timeframes; from the counseling stage to the final action. 

• The RRB timely submitted its annual EEOC Form 462 report which details the agency's complaint activity 

during FY2021. 

• As required by the No FEAR Act, updates of the statistical data pertaining to the complaints of discrimination 

filed by employees and applicants for employment were posted quarterly on the agency's website. The annual 

No FEAR Act was timely submitted to the required congressional entities and government agencies including 

the EEOC. 

• The Office of General Counsel (OGC) represents the agency in EEO complaints at the hearing stage. The 

attorneys do not get involved during the counseling or investigation stage. OEO is responsible for the Final 

Agency Decision (FAD). 

6. Essential Element F: Responsiveness and legal compliance. 

The agency's EEO program meets the requirements of Essential Element F. 

RRB continues to maintain the goal of full compliance with all EEO statutes, regulations, policy guidance, and other 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

written instructions.  All Agency personnel are held accountable for timely compliance with orders issued by the 

EEOC. 

• Process all complaints in accordance with EEOC's regulatory timeframes 

• When a Complainant requested a hearing, their complaint file was timely submitted to EEOC. 

• Due to the COVID-19 pandemic, most agency work shifted to remote/telework execution. Measures were taken 

to ensure that virtual meetings were accessible to a wide range of employees with and without disabilities. 

• The agency timely and accurately submitted the No FEAR Act report to EEOC. 

• The agency timely posted its quarterly No FEAR Act data on its public webpage. This was completed by the 

15th of the month following the end of the quarter. 

Other Relevant Deficiencies, Potential Issues, and EEOC Requests: 

In addition to the deficiencies identified as part of the FY 2020 MD-715 Self-Assessment process, other deficiencies 

were identified by the EEOC during its technical assistance review (TAR) of RRB. In the EEOC’s TAR letter, it 

identified the following deficiencies (which had not yet been resolved at the time of the TAR), as well as new issues 

which collectively include: 

• The EEO Director does not participate in senior-level staff meetings; 

• RRB does not recognize employees, supervisors, managers and units demonstrating superior accomplishment in 

equal employment opportunity; 

• RRB does not collect exit interview data; 

• RRB has not established timetables to review its merit promotion, employee recognition/awards, and employee 

development/training programs for systemic barriers; 

• RRB does not have career development programs for persons with disabilities and persons with targeted 

disabilities; and 

• RRB has submitted incomplete applicant flow data, specifically A/B7 and A/B8, in its MD-715 report. 

After the EEOC TAR, RRB made progress on most of the identified issues: 

• The EEO Director has started to participate in senior-level staff including, Board meetings. 

• The agency’s incentive awards program was revised in October 2021 and it does include two EEO recognition 

awards, namely RRB’s EEO Achievement award & RRB’s EEO Special Performance award. In conjunction 

with RRB’s Human Resources Director, the OEO Director is currently working on a plan of action to implement 

and utilize these two incentive awards in FY 2022 to recognize employees, supervisors, managers and units for 

outstanding contributions to RRB’s EEO program. 

• As part of the agency’s IT Modernization rollout plan in FY 2022, RRB deployed an exit survey and also made 

revisions to it to fulfill relevant regulatory requirements. 

• The agency plans to have its OEO and Human Resources staff attend upcoming EEOC Institute training on 

MD-715 and Barrier Analysis, so that they can acquire the knowledge and skills needed to review data from our 

HR system & HR policies as well as identify systemic barriers. As of the writing of this report, all EEOC 

Training Institute classes are unavailable until further notice according to the EEOC Training registration page. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• 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. We however welcome any solutions and recommendations that EEOC may have 

to assist with RRB’s limitation on non-competitive hiring. When it comes to employee retention, supporting 

persons with disabilities through reasonable accommodations (RA) in compliance with laws and regulations 

governing Federal sector equal employment opportunity (EEO) and civil rights is a high priority of RRB. Our 

agency also works to ensure equal opportunity through policy development, workforce analyses, outreach, and 

education. All new employees are provided information about RRB’s reasonable accommodation services as a 

regular part of the onboarding process to ensure persons with disabilities know how to obtain an 

accommodation. These initiatives benefit RRB employees with disabilities, specifically, but also help RRB 

provide an open and inclusive environment for all employees. 

• OEO and the Bureau of Human Resources are collaborating to address the gaps in EEO data collection. As of 

FY 2022, HR staff have been given access to FedSEP and will assist in the uploading of EEO data required for 

the MD-715 report. 

Page 4 
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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

OEO staff conducted demographic review of RRB workforce. The review was conducted using data self-reported by RRB 

employees with regard to their racial and ethnic identity, gender, and disability status. The review is based on measurement 

areas as required by MD-715. These measurement areas comprise a significant portion of any organization's total human 

resource life cycle. 

USA Staffing data reflects that the RRB total workforce for FY 2021 was 857 employees (837 permanent and 20 temporary). 

During FY 2021, a total of sixty-nine (69) individuals were hired and a total of sixty-six (66) individuals separated from the 

agency. 

The FY 2021 total workforce represents an increase of 15 employees (or 1.75 percent) over FY 2020. RRB has three (3) 

Presidential appointed board members and seven (7) Executive Committee (EC) members to assist in managing its mission, 

responsibilities and goals. 

Gender Distribution 

RRB has a higher participation rate for females. In FY 2021, males comprised 364 or 43.5 percent of the permanent RRB 

workforce. Females comprised 473 or 56.5 percent of the permanent workforce. 

Ethnic and Race Indicators 

In FY 2021, the ethnic and race indicators were as follows: 

African American/Black males represented 11.2 percent (94) of the permanent RRB workforce. 

African American/Black females represented 28.9 percent (242) of the permanent RRB workforce. 

American Indian/Alaskan Native males (AIAN) represented 0.1 percent (1) of the permanent RRB workforce. 

American Indian/Alaskan Native (AIAN) females represented 0.1 percent (1) of the permanent RRB workforce. 

Asian American males represented 2.8 percent (23) of the permanent RRB workforce. This remained at the same levels from 

FY 2020. 

Asian American females 1.9 percent (16) of the permanent RRB workforce. This is a slight increase from 1.6 percent (14) 

Asian American females in FY 2020. 

Hispanic males represented 3.7 percent (31) of the permanent RRB workforce. This is a decrease from 40 Hispanic males 

(4.75 percent) in FY 2020. 

Hispanic females represented 4.5 percent (38) of the permanent RRB workforce. This is a slight decrease from 42 Hispanic 

females (5 percent) in FY 2020. 

Native Hawaiians/Pacific Islander (NHOPI) males represented 0.2 percent (2) of the permanent RRB workforce. 

Native Hawaiians/Pacific Islander (NHOPI) females represented 0 percent (0) of the permanent RRB workforce. 

White males represented 24.6 percent (206) of the permanent RRB workforce. 

White females represented 20.7 percent (173) of the permanent RRB workforce. 

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

I. FY 2021, men having “Two or more Races” comprised 0.8 percent (7) of the RRB permanent workforce. “Two or more 

Races” females comprised 0.4 percent (3) of the RRB permanent workforce. 

Whites comprised the majority of the RRB permanent workforce in fiscal year (FY) 2021 at 45.3 percent followed by Blacks at 

40.1%. Asians comprised 4.7 percent of the permanent workforce and Hispanics/Latinos comprised 8.2 percent of RRB’s 

permanent workforce in FY 2021. Other racial/ethnic groups (i.e., American Indian/Alaskan Native, Native Hawaiian/Other 

Pacific Islander, and Two or More Races/Ethnicity) comprised 1.6 percent of RRB’s permanent workforce in FY 2021. 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. 

In terms of workforce representation, African American/ Black females represent the largest percentage of the workforce at 

28.9 percent (242). 

Hispanic males and females, African American/Black males and females experienced small decreases in participation rates in 

the permanent workforce between FY 2020 and FY 2021. There was a slight increase in the percentage of Asian American 

females in FY 2021. 

Disability 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

In FY 2021, Persons with a disability (PWD) made up 22.93 percent (192) of RRB’s permanent workforce, exceeding EEOC’s 

goal of 12.00 percent. In addition, persons with a targeted disability (PWTD) made up 2.62 percent (22) of the permanent 

workforce, also exceeding EEOC’s goal of 2.00 percent. 

New Hires 

During FY 2021, RRB hired 69 new employees: 59 (85.5 percent) into permanent positions and 10 (14.5 percent) into 

temporary positions. This is an increase of 9 from the 60 new hires in FY 2020. 

• African American/Black males = 7 

• African American/Black females = 21 

• American Indian/Alaskan Native males = 1 

• American Indian/Alaskan Native females = 0 

• Asian American males = 1 

• Asian American females = 2 

• Hispanic males = 2 

• Hispanic females = 0 

• Native Hawaiians/Pacific Islander males = 0 

• Native Hawaiians/Pacific Islander females = 0 

• White males = 15 

• White females = 19 

• “Two or more Races” males = 0 

• “Two or more Races” females = 1 

The trend for at least the past two years has been the majority of new permanent hires went to African American/Black female 

applicants followed by White female applicants, while the least hired were Asian, Hispanic, American Indians/Alaskan Natives 

(AIAN), Hawaiian/Other Pacific Islanders (NHOPI) and persons of Two or More Race applicants. This pattern continued for FY 

2021. 

Workforce Participation by Grade Level 

In FY 2021, the majority of RRB’s permanent employees are in higher-graded professional and administrative positions. 

However, minority representation in higher grades (i.e., 13, 14, 15, and SES) is disparate compared to whites. For all grades 

13 through SES, White permanent employees had the highest levels in the workforce. 

In FY 2021, White permanent employees held 48 percent of GS-13 positions compared with 34 percent for African American/ 

Blacks, 6 percent for Asians, and 12 percent for Hispanics. Other race/ethnic groups held less than 1 percent of GS-13 

positions. 

White permanent employees held 65 percent of GS-14 positions compared to 19 percent for African Americans/Blacks, 11.5 

percent for Asians, and 4 percent for Hispanics. Again, other race/ethnic groups held less than 1 percent or were not 

represented in the grade. 

White permanent employees comprised 70 percent of GS-15 positions compared to 15 percent for African American/Blacks, 

7.5 percent for Asians and 7.5 percent for Hispanics. Other race/ethnic groups held less than 1 percent or were not 

represented in the grade. 

60 percent of SES positions were held by White permanent employees compared to 30 percent for African American/Blacks 

and 10 percent for Hispanics. Asians and Other race/ethnic groups were not represented in SES positions. 

Overall, the participation rate of African American/Blacks, Asians, Hispanics and Other race/ethnic groups decreased as the 

grades increased. 

Permanent employees in grades GS 1 through 10 positions = 295 

Permanent employees in GS-11 positions = 121 

Permanent employees in GS-12 positions = 186 

Permanent employees in GS-13 position = 107 

Permanent employees in GS-14 positions = 78 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

Permanent employees in GS-15 positions = 40 

Permanent SES employees = 10 

SES Participation by Race 

There were a total of 10 employees in SES positions, of which 

6 were White (60 percent), 

3 were African American/Black (30 percent) and 

1 was Hispanic (10 percent). 

GS-15 Participation by Race 

There were a total of 40 employees in GS-15 positions, of which 

28 were White (70 percent), 

6 were African American/Black (15 percent), 

3 were Asian (7.5 percent), 

3 were Hispanic (7.5 percent) 

GS-14 Participation by Race 

There were a total of 78 employees in GS-14 positions, of which 

51 were White (65 percent), 

15 were African American/Black (19 percent), 

9 were Asian (11.5 percent), and 

3 were Hispanic (4 percent) 

GS-13 Participation by Race 

There were 107 employees in GS-13 positions, of which 

51 were White (48 percent), 

36 were African American/Black (34 percent), 

7 were Asian (6 percent), 

13 were Hispanic (12 percent) 

In FY 2021, Persons with Disabilities (PWDs) had a participation rate of 22.93 percent in the permanent workforce and 

exceeded/met EEOC’s goal of 12 percent in both the GS 1-10 and GS 11-SES grade groupings. PWD comprised 11.23 

percent of GS 1-10 grades and 11.70 percent of GS 11-15 grades in the permanent workforce. Persons with Targeted 

Disabilities (PWTDs) had a participation rate of 2.6 percent in the permanent workforce and exceeded EEOC’s goal of 2.00 

percent for GS 1-10 and GS 11-SES. PWTD comprised 1.4 percent of GS 1-10 grades and 1.2 percent of GS 11-15 grades in 

the permanent workforce. 

The total number of Persons with Disabilities (PWDs) in RRB’s permanent workforce for FY 2021 was 192 (22.93 percent). 

There were 94 (11.23 percent) PWDs in the GS 1-10 grade cluster. 

There were 98 (11.70 percent) PWDs in the GS 11 – SES grade cluster. 

The total number of Persons with Targeted Disabilities (PWTDs) in RRB’s permanent workforce for FY 2021 was 

22 (2.6 percent). 

There were 12 (1.4 percent) in the GS 1-10 grade cluster. 

There were 10 (1.2 percent) in the GS 11-SES grade cluster. 

Net Change: Gains and Losses 

The net change between gains and losses for the total RRB employee workforce in FY 2021 was positive (+3 or 0.35 percent), 

with 69 new hires and 66 employee separations. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ACCOMPLISHMENTS 

In FY 2021, the RRB made some strides to address past deficiencies and to establish a model EEO program. The agency also 

sought to maintain engagement with managers and supervisors to increase awareness of EEO issues, policies and procedures 

despite the covid pandemic-related maximum telework posture. We also continued to support Special Emphasis Groups and 

Programs to foster an inclusive work environment for all employees. 

• EEO Policy Statement signed by the three Member Board was shared directly with staff and published on the RRB intranet 

for further reference. 

• RRB’s Office of Equal Opportunity (OEO) Director provided monthly administrative reports to the Board regarding EEO 

program activities. 

• RRB employees were assigned the mandatory No FEAR Act training in FY 2021. New employees are required to 

complete the No FEAR Act training course during orientation via RRB University within their first 30 days. 

• OEO staff updated and released an internal No FEAR Act training video. 

• In accordance with Executive Order 13988, Preventing and Combating Discrimination on the Basis of Gender Identity or 

Sexual Orientation, OEO reviewed all existing orders, regulations, guidance, policies and programs to ensure compliance 

with Section 1 of the Executive Order. This resulted in several revisions that included such items as the EEO Handbook, 

Sexual Harassment Policy, and the Alternative Dispute Resolution program. 

• Due to limitations on gatherings, OEO fully implemented utilization of its OEO SharePoint site to engage agency 

employees with honoring Special Emphasis Diversity programs. Video(s) were presented recognizing and highlighting 

Black History month, Women’s History month, Asian Pacific Heritage month, Hispanic Heritage month, Native American 

History month and Disability Awareness in Employment month. 

• Like most other federal agencies, the RRB remain affected by the covid pandemic for the second year in a row and most 

agency buildings were still closed to the public in FY 2021. Majority of our employees worked from home for their safety. 

All complaint forms and information was already on-line so we were able to process complaints over the telephone and online. Due to the continuing health & safety measures surrounding the pandemic, all employees were still provided a link to 

view civil rights programs on-line during their work-day just as if they were present at the agency. 

• The agency provided EEO training to new managers and supervisors. 

• The agency provided its annual refresher training to all EEO Counselors and recruited three (3) new EEO Counselors. 

• All EEO complaints were processed within the regulatory timeframes: Counselings were processed within the 30 day 

timeframe with no extension required; Acknowledgement Letters of receipt of formal complaints were process within 5 

business days; Investigation(s) completed within the 180 day timeframe. 

• Closely monitored the status of complaint investigations. The Statement of Work required contractors to be fully trained 

and described a penalty if the contractor failed to deliver a quality product within the prescribed timeframes. 

• Out of the five complaints processed in FY 2021, three Complainants filed based on non-selection for promotion, (this 

includes two that were filed in the previous year(s) and was continuing to be processed). The bases of complaints filed in 

FY 2021 included race (black), color, sex and/or age (over 40). This prompted a review of the analysis conducted in FY 

2020 due to the fact that only one Complainant filed in FY 2021 on non-selection. We noticed that there was no significant 

change. The criteria used to rate applicants seemed relevant and fair. The Selecting Official did not skip over any 

individual(s) to promote those rated lower and less qualified. Therefore, we have not found a practice of discrimination in 

the selections for promotions. 

• Provided guidance and assistance on a continuing basis to customers including 1) employees with EEO concerns; 2) 

employees with non-EEO issues who wanted guidance on how to handle a workplace dispute; 3) managers who had 

questions about how to deal with a situation or an inquiry about the EEO process; 4) AFGE officials who requested 

assistance and 5) railroad customers who requested assistance with an EEO related matter. Employees feel comfortable 

talking to OEO about their concerns because we provide a safe place where they can vent their frustrations and discuss 

possible solutions. Managers feel confident that they have received proper information and/or guidance. 

• Reviewed reports reflecting activity for personnel actions such as promotions, accessions, and separations in relation to 

race, sex, veteran’s preference and disability. Thus, changes in the workforce were monitored on a continual basis. 

• The agency received and processed eight (8) reasonable accommodation requests in FY 2021. The top three reasonable 

accommodation request were for ergonomic keyboard, sit/stand desk, and ergonomic mouse. 

• PHYSICAL ACCESSIBILITY: All RRB Headquarters facility spaces comply with all ADA requirements including 

handicapped accessible parking spaces, automated door openers, accessible bathrooms, physical access for employees 

and visitors with mobility and visual challenges. All automated door openers, and bathroom access, along with grab bars, 

and entrance doors are part of the overall preventive maintenance schedules performed by maintenance personnel under 

our facility maintenance contract. In addition, any new building construction performed at the headquarters facility must 

comply with the latest ADA standards. 

Page 6 
EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART E.4 EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: ACCOMPLISHMENTS 

• DIGITAL ACCESSIBILITY: The 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 dissemination. 

• HIRING ACCESSIBILITY: In its review of RRB’s FY 2020 MD-715 Report, EEOC noted that RRB did not provide 

information and list the staff who process employment applications for applicants/persons with disabilities and targeted 

disabilities. Although our agency is restricted from hiring under Schedule A hiring, we do have a Selective Placement 

Coordinator who handles any disability-related issues that arise during the application and selection processes.  All job 

applications are processed through USAJOBs. 

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, 2020 to September 30, 2021 

EXECUTIVE SUMMARY: PLANNED ACTIVITIES 

The planned activities for FY 2022 include the following: 

• RRB’s Office of Equal Opportunity (OEO) will continue to collaborate with the Bureau of Human Resources to address and 

correct deficiencies identified by EEOC in its review of our FY 2019 and FY 2020 MD-715 reports. 

• RRB will re-establish and include EEO awards as part of the incentive awards program to recognize employees, 

supervisors, managers and units demonstrating superior accomplishment in equal employment opportunity. 

• RRB will re-establish the collection of exit survey data. 

• RRB will ensure it has effective and accurate data collection systems in place to review external and internal applicant flow 

data concerning the applicant’s race, national origin, sex, and disability status. 

• RRB will establish timetables/schedules for the OEO and Human Resources Directors to review at regular intervals the 

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. 

• The OEO Director will provide a "State of the Agency" to the agency Board Members and/or their designees. 

CONCLUSION 

RRB leadership is proud of its accomplishments in the areas of attracting, developing, and retaining an increasingly diverse 

workforce. RRB’s overall representation of women, minorities, and persons with disabilities, is a significant accomplishment. 

This report identified accomplishments, but also identified some challenges requiring attention, including implementing an 

effective barrier analysis timetable/schedule, establishing a career development program, improving the retention strategy 

through the use of an exit survey, and increasing the participation of persons with disabilities and persons with targeted 

disabilities. The plans in Parts H and J address these issues. 

Page 7 
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. 

Shiri Ndang

Railroad Retirement Board (RRB)

05/10/2022

EEOC FORM 

U.S. Equal Employment Opportunity Commission 715-01 

PART F FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 

CERTIFICATION of ESTABLISHMENT of CONTINUING 

EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS

 I, , Director of the Office of Equal Opportunity (GS-0905-14)

Signature of Principal EEO Director/Official Date 

Certifies that this Federal Agency Annual EEO Program Status Report is in compliance with EEO MD-715. 

FOR THE BOARD 05/10/2022

 

Signature of Agency Head or Agency Head Designee Date 
 

 

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, 2020 to September 30, 2021 

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 in 

every field office. 

7/19/2021 

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

pregnancy, sexual orientation and gender identity), genetic information, national origin, race, religion, and status, marital 

reprisal) contained in the laws EEOC enforces? [see 29 CFR § 1614.101(a)] If the EEO policy statement covers status, political 

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

comments column. 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, 2020 to September 30, 2021 

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 Yes. 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 Yes. 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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

A.2.b.1. The business contact information for its EEO Counselors, EEO Officers, Special Emphasis Program X Yes. 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 Yes, 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 Yes. 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, 2020 to September 30, 2021 

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 Yes. Explanation 

how often and the means by which such training is delivered. of the EEO 

complaint process 

is given in the 

mandatory No 

FEAR Act biannual training. It 

is also posted on 

the internal 

intranet, the 

public website 

and on the poster 

board posted in 

every RRB office 

and each floor at 

headquarters. The 

Office of Equal 

Opportunity 

(OEO) has a 

Rights and 

Responsibilities 

Complaints 

Booklet 

explaining the 

complaint process 

in paper and 

online. 

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

of the ADR 

process is 

included in the 

mandatory No 

FEAR Act biannual training 

and is posted on 

the EEO 

Programs poster 

on every RRB 

floor and in every 

field office. The 

OEO has written 

materials and a 

video about ADR 

that is accessible 

to all employees 

on RRB Vision. 

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, 2020 to September 30, 2021 

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 Yes. An 

how often. explanation of the 

Reasonable 

Accommodation 

program is 

included in the 

mandatory No 

FEAR Act biannual training 

and is posted on 

the EEO Program 

poster that is 

posted on every 

RRB floor at 

headquarters and 

in every field 

office. The OEO 

has written 

materials for 

employees. 

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

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

program is 

included in the 

mandatory No 

FEAR Act biannual training 

and it is posted on 

the EEO 

Programs poster 

that is posted on 

every RRB floor 

in headquarters 

and in every field 

office. The policy 

is on the public 

website and the 

agency's internal 

intranet. It was 

revised in 2020 to 

remove the 

investigation from 

the OEO to the 

Office of 

Administration. 

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

§2635.101(b)] If “yes”, please provide how often. included in the 

Anti-Harassment 

policy and is 

explained in the 

No FEAR Act 

training provided 

to all RRB 

employees every 

2 years. 

Page 13 
 

 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

brief explanation 

in 

the space below or 

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

attach Measures Yes No N/A 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 X In FY 2020, the 

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

one or two examples in the comments section. . Opportunity 

(OEO) 

collaborated with 

HR to have EEO 

language included 

as a sub-element 

on all manager/ 

supervisor 

performance 

appraisals. As of 

FY 2021, EEO is 

an element that all 

RRB managers/ 

supervisors are 

appraised on. In 

addition, RRB's 

awards policy 

was revised in 

October 2021 to 

include 2 EEO 

recognition 

awards (slated for 

implementation in 

FY 2022). 

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

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

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, 2020 to September 30, 2021 

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, 2020 to September 30, 2021 

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 Yes. The head of 

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

member 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. to the 3 member 

Board. 

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

CFR §1614.102(b)(4)] organizational 

chart clearly 

defines the 

reporting 

structure for the 

EEO office. 

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

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

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

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, 2020 to September 30, 2021 

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 previous 

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

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

the date of the briefing in the comments column. administrative 

reports to the 

Board Members 

and their 

assistants in 

FY2021 as well 

as frequent 

ongoing briefings. 

B.1.d. Does the EEO Director regularly participate in senior-level staff meetings concerning personnel, budget, X In FY 2021, the 

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

Committee 

Members had 

weekly 

conference call 

meetings with the 

previous OEO 

Director to keep 

her updated on all 

senior level 

meetings 

concerning 

personnel, budget, 

technology and 

other workforce 

issues. In FY 

2022, the new 

OEO Director has 

begun attending 

board meetings 

and has recurring 

bi-weekly 

meetings with the 

agency's Senior 

Executive Officer 

(SEO). 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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 Yes. The OEO 

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

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

updates the 

affirmative 

employment 

program. 

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

§1614.102(c)(4)] Director and the 

EEO Specialist 

jointly oversee 

completion of 

EEO counselings. 

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

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

Office of the 

General Counsel 

to ensure timely 

issuance of all 

final agency 

decisions. 

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

1614.102(e); 1614.502]' 

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

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 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, 2020 to September 30, 2021 

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 If the meeting 

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

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

OEO Director is 

included. 

Sometimes it may 

be a review of the 

recruitment 

strategies, 

vacancy 

projections, 

succession 

planning, etc., 

prior to 

implementation. 

As of FY 2022, 

the OEO Director 

has bi-weekly 

recurring 

meetings with the 

Senior Executive 

Officer (SEO) to 

discuss agency 

operations. 

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

reflects the 

diversity of all 

segments of 

American society. 

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, 2020 to September 30, 2021 

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 We supplement 

the staffing with 

three EEO 

committees, 

(Workplace 

Diversity 

Committee, 

Federal Women's 

Program 

Committee and 

Employee 

Disability 

Advisory 

Council); as well 

as the use of 

collateral duty 

EEO counselors 

to assist with 

complaint 

processing. 

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

Reasonable 

Accommodation 

Coordinator 

within the Bureau 

of Human 

Resources that 

oversees the 

Reasonable 

Accommodation 

process. 

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

proper staffing 

that oversees the 

timely and 

complete 

compliance with 

EEOC orders. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

B.4.a.2. to enable the agency to conduct a thorough barrier analysis of its workforce? [see MD-715, II(B)] X During FY 2021, 

RRB's OEO 

program did not 

have the trained 

staff to perform 

trend and other 

data analyses, 

such as 

identifying 

triggers and 

barriers to EEO 

throughout the 

agency. Training 

of OEO and 

Bureau of Human 

Resources staff as 

well as qualified 

shared resources 

may be necessary 

to meet EEOC 

data collection, 

barrier analysis, 

trigger 

identification and 

reporting 

requirements. 

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

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

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

complaint 

processing and 

together we 

ensure timely, 

thorough and fair 

processing of 

EEO complaints, 

including 

overseeing EEO 

counseling, 

investigations and 

legal sufficiency 

reviews. The 

Bureau of Law 

completes all 

Final Agency 

Decisions but we 

ensure timeliness. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

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

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

the comments column. the annual New 

Supervisor's 

Training sessions 

and/or through 

the RRB 

University 

training portal. 

OEO created a 

PowerPoint 

presentation on 

the No FEAR Act 

that is uploaded to 

RRB University. 

It is then assigned 

to all employees 

and tracked for 

completion. 

B.4.a.5. to conduct thorough, accurate, and effective field audits of the EEO programs in components and the X There are no 

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

the RRB. We are 

one agency with 

offices in the field 

but these offices 

fall under the 

same EEO 

programs. 

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

accommodations procedures)? [see MD-715, II(B)] has a 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. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

B.4.a.7. to maintain accurate data collection and tracking systems for the following types of data: complaint X Yes, we used an 

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

systems with insufficient funding in the comments section. to track all 

complaint data 

and 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. 

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

2021 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 Yes. We have 

Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), § V.C. transferred all 

1] anti-harassment 

complaints to the 

Office of 

Administration to 

create 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 Yes. 

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 Yes. We 

6(III)] thoroughly 

explain our roles 

as EEO officials 

as it is defined in 

the MD-110. Our 

role is also 

mentioned in our 

EEO Complaints 

booklet as well. 

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

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

Opportunity 

ensures all 

training is 

completed by 

requiring a copy 

the certificate of 

completion. 

Page 23 
 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

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

MD-110? 

X Yes, The Director 

of Equal 

Opportunity 

ensures that all 

annual refresher 

training is 

completed by 

requiring a copy 

of the certificate 

of completion. 

Page 24 
 

 

 

 

 

 

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, 2020 to September 30, 2021 

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 Yes. 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 Yes. Reasonable 

Accommodation 

procedure is 

included in the 

new supervisor 

training. 

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

mandatory powerpoint training for 

all employees. 

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 Yes, we offer 

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

complainants 

except sexual 

harassment 

complaints. We 

also created an 

ADR video if 

they want to see 

how ADR works. 

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, 2020 to September 30, 2021 

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 Yes, the senior 

Instructions, Sec. I] managers approve 

the time for their 

employees to 

view on-line 

presentations of 

the various 

programs. 

B.6.b. Do senior managers participate in the barrier analysis process? [see MD-715 Instructions, Sec. I] X RRB has not 

completed barrier 

analysis. nor does 

the agency have a 

process for senior 

managers to 

participate in 

barrier analysis. 

The agency is 

currently working 

on 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. 

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. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

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

X RRB’s published 

Strategic Plan 

2022-2026 which 

is posted on our 

agency website 

incorporates 

EEO / diversity 

and inclusion 

principles. The 

RRB Strategic 

Plan states that 

"The RRB will 

continue to recruit 

and hire a highperforming 

workforce that 

reflects the 

diversity of all 

segments of 

American society. 

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, 2020 to September 30, 2021 

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 We do not have 

components of 

the RRB. 

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

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

comments section. 

X No components 

of the RRB. 

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

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

X No components 

of the RRB. 

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, 2020 to September 30, 2021 

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 Yes. The antiEEOC’s enforcement guidance? [see MD-715, II(C); Enforcement Guidance on Vicarious Employer Liability harassment policy 

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

during FY2020 to 

comply with 

EEOC's 

enforcement 

guidance. It was 

sent to EEOC and 

approved in 

FY2020. 

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

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 Yes. This was the 

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

revision to our 

anti-harassment 

policy in FY2020. 

C.2.a.3. Does the agency have a separate procedure (outside the EEO complaint process) to address harassment X Yes. The Antiallegations? [see Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Harassment 

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

that an 

employee's 

conduct be 

immediately 

addressed and/or 

corrected whereas 

the EEO 

complaint process 

is designed to 

make individuals 

whole for 

discrimination 

that already 

occurred through 

damage awards 

and equitable 

relief to prevent 

the recurrence of 

the unlawful 

discriminatory 

conduct. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

C.2.a.4. Does the agency ensure that the EEO office informs the anti-harassment program of all EEO counseling X Yes. The antiactivity alleging harassment? [See Enforcement Guidance, V.C.] harassment 

complaints 

program moved 

to the Office of 

Administration 

and the EEO 

office informs the 

anti-harassment 

coordinator if an 

EEO complaint 

alleges 

discrimination 

due to harassment 

or if the 

complainant 

wants to file a 

separate 

complaint so that 

action may be 

taken 

immediately. 

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

allegations, including those initially raised in the EEO complaint process? [see Complainant v. Dep’t of employees alleges 

Veterans Affairs, EEOC Appeal No. 0120123232 (May 21, 2015); Complainant v. Dep’t of Defense (Defense harassment 

Commissary Agency), EEOC Appeal No. 0120130331 (May 29, 2015)] If “no”, please provide the percentage (whether through 

of timely-processed inquiries in the comments column. the antiharassment 

program or 

through a 

complaint of 

discrimination), 

questions are 

asked to 

determine if 

immediate action 

(referral to the 

Anti-Harrasment 

Coordination, 

referral for 

investigation, etc) 

is needed within 

the 10 day 

timeframe in 

accordance with 

RRB's AntiHarassment 

policy. 

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

harassment? [see 29 CFR §1614.203(d)(2)] provides No 

FEAR Act 

training every 

other year which 

provides 

examples of 

harassment based 

on a disability. It 

is also covered 

during 

Reasonable 

Accommodation 

training. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

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

accommodation 

procedures 

comply with 

EEOC regulations 

and guidance 

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

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

Accommodation 

Coordinator in the 

Bureau of Human 

Resources who 

coordinates and 

assists managers 

and employees 

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 

Coordinator. 

C.2.b.2. Has the agency established a firewall between the Reasonable Accommodation Program Manager and X Yes, the 

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

Accommodation 

Manager is in the 

Bureau of Human 

Resources and/or 

the Office of the 

Inspector General. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

the application and placement processes? [see 29 CFR §1614.203(d)(1)(ii)(B)] vacancy 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." 

C.2.b.4. Do the reasonable accommodation procedures clearly state that the agency should process the request X Yes. Our policy 

within a maximum amount of time (e.g., 20 business days), as established by the agency in its affirmative action provides for 15 

plan? [see 29 CFR §1614.203(d)(3)(i)(M)] work days unless 

there are 

extenuating 

circumstances. 

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

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

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

column. requests within 

the time frame set 

forth in our 

reasonable 

accommodation 

procedure. 

C.2.c. Has the agency established procedures for processing requests for personal assistance services that X Yes, we have 

comply with EEOC’s regulations, enforcement guidance, and other applicable executive orders, guidance, and established 

standards? [see 29 CFR §1614.203(d)(6)] procedures for 

processing 

requests for 

personal 

assistance 

services that 

comply with 

EEOC's 

regulations, etc. 

in the Reasonable 

Accommodation 

Policy. 

C.2.c.1. Does the agency post its procedures for processing requests for Personal Assistance Services on its X Yes, it is included 

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

column. Accommodation 

Policy which is 

posted on rrb.gov. 

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, 2020 to September 30, 2021 

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 Yes, the 

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

participation in the EEO program? appraisals for 

senior executives 

(SES) contain an 

EEO element. An 

EEO sub-element 

was adopted in 

2020 and 

implemented in 

the performance 

appraisals of all 

agency managers 

during FY 2021 

(October 2020). 

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 Yes, under the 

MD-110, Ch. 3.I] new EEO subelement 

implemented in 

FY 2021. 

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

and investigators? [see 29 CFR §1614.102(b)(6)] new EEO subelement 

implemented in 

FY2021. 

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

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

implemented in 

FY 2021. 

C.3.b.4. Ensure that subordinate supervisors have effective managerial, communication, and interpersonal skills X Yes, under the 

to supervise in a workplace with diverse employees? [see MD-715 Instructions, Sec. I] new EEO subelement 

implemented in 

FY2021. 

C.3.b.5. Provide religious accommodations when such accommodations do not cause an undue hardship? [see X Yes, under the 

29 CFR §1614.102(a)(7)] new EEO subelement 

implemented in 

FY2021. 

C.3.b.6. Provide disability accommodations when such accommodations do not cause an undue hardship? [ see X Yes, under the 

29 CFR §1614.102(a)(8)] new EEO subelement 

implemented in 

FY2021. 

Page 33 
 

 

 

 

 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

II(C)] new EEO subelement 

implemented in 

FY2021. 

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

Enforcement Guidance, V.C.2] new EEO subelement 

implemented in 

FY2021. 

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

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

MD-715, II(C)] 

X Yes, under the 

new EEO subelement 

implemented in 

FY2021. 

C.3.c. Does the EEO Director recommend to the agency head improvements or corrections, including remedial 

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

§1614.102(c)(2)] 

X Yes, the OEO 

Director can 

always brief the 

Board and 

provide 

recommendations 

for its 

consideration. 

C.3.d. When the EEO Director recommends remedial or disciplinary actions, are the recommendations regularly X We did not 

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

remedial or 

disciplinary 

actions during 

FY2021. 

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, 2020 to September 30, 2021 

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 We meet to assess 

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

programs, 

policies and 

procedures to 

ensure conformity 

with EEOC laws, 

instructions and 

Management 

Directives. 

C.4.b. Has the agency established timetables/schedules to review at regular intervals its merit promotion X We do not have 

program, employee recognition awards program, employee development/training programs, and management/ established 

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

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

review those 

programs. 

However, the 

OEO Director and 

HR Director are 

working on a plan 

to formalize a 

schedule and 

procedures for 

trigger 

identification for 

implementation in 

FY 2022. 

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

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

CFR §1614.601(a)] annual 

spreadsheets of 

workforce 

demographics 

from the Bureau 

of Human 

resources,. OEO 

also downloads 

applicant data 

annually from 

Applicant Flow 

Data provided by 

OPM. OEO is 

also provided 

information on 

training programs 

annually by 

Human Resources. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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

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

information is 

shared with OEO. 

Grievance data is 

not normally 

shared because 

OEO has not 

asked for it. RRB 

did not collect 

exit interview 

data in FY 2021. 

As part of the 

agency's IT 

Modernization 

rollout plan, RRB 

now has an exit 

survey which 

went live via 

Microsoft Forms 

in FY 2022 and 

OEO plans to ask 

HR for this data 

to conduct 

workforce 

analysis. 

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 Yes, 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 

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

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

Director and HR 

Director are 

currently working 

on a plan of 

action to 

formalize 

procedures for 

barrier analysis 

and trigger 

identification. 

OEO and HR 

staff need training 

on barrier 

analysis in order 

to carry out this 

task. 

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

and uploaded the 

Status and 

Dynamics files 

for the MD-715 in 

FY 2021. 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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 The RRB does 

[see 29 CFR §1614.102(a)(6); see also Douglas v. Veterans Administration, 5 MSPR 280 (1981)] not have a standalone disciplinary 

policy or table of 

penalties. 

Douglas Factor 

considerations are 

taken into account 

by both our 

proposing and 

deciding officials 

when considering 

adverse actions 

for employee 

misconduct. 

C.5.b. When appropriate, does the agency discipline or sanction managers and employees for discriminatory X Yes, we have not 

conduct? [see 29 CFR §1614.102(a)(6)] If “yes”, please state the number of disciplined/sanctioned individuals had a finding of 

during this reporting period in the comments. discrimination but 

if we do, the 

agency supports 

discipline or 

sanction for 

managers and 

employees for 

discriminatory 

conduct. 

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

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

learned)? [see MD-715, II(C)] actions were 

inappropriate, 

Page 37 
 

 

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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

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 Yes, the Office of 

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

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

frequency of the EEO updates in the comments column. provides a 

monthly report 

outlining the 

number of 

complaints and 

special emphasis 

program updates. 

This report can be 

seen by all Senior 

management. 

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

MD-715 Instructions, Sec. I] trained and 

experienced EEO 

officials that are 

readily available 

to address EEO 

concerns from 

managers and 

supervisors. 

Page 38 
 

 

 

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, 2020 to September 30, 2021 

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. X Yes, we review 

I] all RMOs named 

in complaints as 

well as the 

basis(es) for a 

trend. We also 

review all races, 

disability status 

and ages of those 

promoted and 

hired every month. 

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 Yes, we use 

workforce data, 

harassment 

complaint data 

and special 

emphasis 

programs. The 

plan in FY 2022 

for OEO staff to 

start reviewing 

grievance data, 

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 RRB did not 

conduct exit 

interviews in FY 

2021. However as 

part of the 

agency's IT 

Modernization 

rollout plan, the 

agency now has 

an exit survey in 

use as of FY 2022. 

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, 2020 to September 30, 2021 

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 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, 2020 to September 30, 2021 

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 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, 2020 to September 30, 2021 

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 42 
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, 2020 to September 30, 2021 

Agency Self-Assessment Checklist 

Essential Element: E Efficiency 

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, 2020 to September 30, 2021 

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 Yes, we provide a 

initial counseling session, pursuant to 29 CFR §1614.105(b)(1)? Rights and 

Responsibilities 

Booklet to 

everyone who 

contacts us and is 

interested in filing 

a complaint of 

discrimination. 

E.1.c. Does the agency issue acknowledgment letters immediately upon receipt of a formal complaint, pursuant X Yes, we issue 

to MD-110, Ch. 5(I)? acknowledgement 

letters within 5 

work days. 

E.1.d. Does the agency issue acceptance letters/dismissal decisions within a reasonable time (e.g., 60 days) after X Yes, we issue 

receipt of the written EEO Counselor report, pursuant to MD-110, Ch. 5(I)? If so, please provide the average acceptance letters/ 

processing time in the comments. dismissal 

decisions within 

15 business days 

after the filing 

date of a formal 

complaint. The 

Counselor's report 

is sent to the 

Complainant if 

they file a formal 

complaint with 

the acceptance 

letter but prior to 

any dismissal 

decision. 

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 44 
 

 

 

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, 2020 to September 30, 2021 

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 

them accountable for poor work product and/or delays? [See MD-110, Ch. 5(V)(A)] If “yes”, please describe 

how in the comments column. 

X Yes. As part of 

their contract 

expectations, we 

advise contractors 

in writing that 

their fee may be 

reduced for a late 

or poor work 

product. 

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 we provide 

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 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, 2020 to September 30, 2021 

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 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, 2020 to September 30, 2021 

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 47 
 

 

 

 

 

 

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, 2020 to September 30, 2021 

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 48 
 

 

 

 

 

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, 2020 to September 30, 2021 

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 49 
 

 

 

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, 2020 to September 30, 2021 

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 50 
 

 

 

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, 2020 to September 30, 2021 

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 Yes, we 

obligations under the statutes EEOC enforces? [see MD-715, II(E)] If “yes”, provide an example in the constantly review 

comments. the EEO program 

to determine 

whether the 

agency is meeting 

its obligations. 

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 we 

regularly share 

best practices. 

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 51 
 

 

 

 

 

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, 2020 to September 30, 2021 

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 Yes, OEO ensures 

agency timely 

complies with any 

and all EEOC 

orders/directives 

and final agency 

actions. 

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 Yes, both 

management and 

the complainant 

are advised to 

contact OEO if an 

agreement is not 

followed. 

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 52 
 

 

 

 

 

 

 

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, 2020 to September 30, 2021 

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 Yes. 

F.2.a.1. When a complainant requests a hearing, does the agency timely forward the investigative file to the 

appropriate EEOC hearing office? [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 Yes. 

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

documentation for completing compliance? 

X Yes. 

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 the quarter 

Essential Element: O Other 

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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.1 

Brief Description of Program A.3.a. Does the agency provide recognition to employees, supervisors, managers and units demonstrating superior accomplishment 

Deficiency: in equal employment opportunity? [see 29 CFR § 1614.102(a)(9)] If “yes”, provide one or two examples in the comments section. . 

Does the agency provide recognition to employees, supervisors, managers and units who demonstrate superior accomplishment in equal opportunity. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2020 12/15/2022 10/01/2021 To recognize employee, supervisors, managers and units that demonstrate superior 

accomplishments in equal employment opportunity by including an EEO element in their 

performance appraisal. 

Responsible Officials 

Title Name Standards Address the Plan? 

Director of Human Resources Nancy Bitzer Yes 

Director of Equal Opportunity Pamela Tate Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

10/01/2020 The sub-element was added to all managers performance appraisals beginning 10.1.2020. Yes 09/30/2020 

Accomplishments 

Fiscal Accomplishment 

Year 

2021 The EEO sub-element was added to all managers performance appraisals for FY21. Thus, the performance expectations issued to RRB managers in 

October 2021 (FY 2022) contain an EEO sub-element 

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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.2 

Brief Description of Program 

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

Page 55 
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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.3 

Brief Description of Program 

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

Page 56 
 

 

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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.4 

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 05/01/2020 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 Opportunity Pamela Tate Yes 

Director of Equal Opportuniry Pamela Tate Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

10/01/2020 The EEO Director will participate in conference calls with the Senior Executive Member and Yes 

be briefed on all Executive Committee discussions concerning personnel, budget, technology 

and other workforce issues. 

Accomplishments 

Fiscal Accomplishment 

Year 

2020 The EEO Director met with the Executive Committee (EC) during FY2019 and expressed the need for her to be included on policies effecting personnel, 

budget, technology and other workforce issues. The EEO Director was not trying to be apart of the EC meetings but wanted the opportunity to review and 

provide input prior to policy changes, revisions, and/or implementations. The EC agreed and said that they would contact the EEO Director in the near 

future. 

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. 

Page 57 
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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

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 58 
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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.5 

Brief Description of Program 

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

Page 59 
 

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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.6 

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 b 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 by 

RRB employees (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 

Page 60 
 

 

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, 2020 to September 30, 2021 

Plan to Attain Essential Elements 

PART H.7 

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 01/25/2022 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 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 61 
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, 2020 to September 30, 2021 

Plan to Eliminate Identified Barriers 

Page 62 
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 No 

b.Cluster GS-11 to SES (PWD) Answer No 

During FY 2021, RRB had a total of 837 permanent employees of which 192 

(22.93 percent) were employees with a disability. There are 295 permanent 

employees in grades GS-1 through 10 positions. Of the 295 employees in 

grades GS-1 through 10 positions, 94 (11.23 percent) stated that they have a 

disability. Of the 542 employees in grades GS -11 through SES, a total of 98 

(11.70 percent) indicated that they had a disability. 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 

Based on the utilization analysis of the RRB workforce, our agency does not 

have triggers for in its overall permanent workforce when compared to the 2 

percent regulatory onboard goal. In FY 2021, the total number and percentage 

of Persons with Targeted Disabilities (PWTDs) in RRB’s permanent workforce 

is 22 (2.6 percent). However when calculated by grade, RRB does have 

triggers in both clusters in the permanent workforce when compared to the 2 

percent regulatory onboard goal. In FY 2021, PWTDS participated at a rate of 

1.4 percent (12) in the GS-1 to GS-10 cluster and 1.2 percent (10) in the GS-11 

to SES grade clusters nearly meeting the 2 percent regulatory goal. 

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

The agency communicated the numerical goals to the 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. In FY 2021, RRB hired a total 

of 69 new employees. A total of 35 (51 percent) listed a disability (PWD) and 

34 (49 percent) did not identify or listed as having a disability. Of the 35 new 

hires identifying that they have a disability, a total of 2 individuals (3 percent) 

identified their disability as a targeted disability (PWTD). 

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. 

Page 63 
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 

Human Resources has designated a HR Specialist to assist in improving the 

staffing of people with disabilities by contacting different organizations assisting 

people with disabilities to re-enter the workforce. We send all vacancy 

announcements to these organizations. We also have the Employees with 

Disabilities Advisory Council (EDAC) who assists in finding organizations that 

assist people with disabilities. 

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 

Processing reasonable accommodation requests 

from applicants and employees 

Answering questions from the public about 

hiring authorities that take disability into 

account 

Processing applications from PWD and PWTD 

Section 508 Compliance 

Architectural Barriers Act Compliance 

Special Emphasis Program for PWD and PWTD 

# 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) 

Regina Block 

HR Specialist/Labor Relations 

Regina.Block@rrb.gov 

Meghan O'Connor 

Lead HR Specialist/Selective Placement 

Coordinator 

Meghan.O'Connor@rrb.gov 

Meghan O'Connor 

Lead HR Specialist/Selective Placement 

Coordinator 

Meghan.O'Connor@rrb.gov 

Robert LaBerry 

Supvy IT Specialist 

Robert.Laberry@rrb.gov 

Scott Rush 

Supvy Facility Operations Specialist 

Scott.Rush@rrb.gov 

Kathy Robinson 

EEO Specialist 

Kathy.Robinson@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 2021, staff attended FDR training (virtual) which covered several 

EEO topics including reasonable accommodation and also completed “The 

Changing Reality of Disability in America" video training which re-examined the 

experience of disability in America by illuminating the stories of those who are 

all too often left behind in society and the workplace. The agency plans to 

provide Reasonable Accommodation training to all RBB managers and 

supervisors in FY 2022. 

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 

We have a Selective Placement Coordinator in Human Resources who 

ensures we have a contact person at various disability organizations so we can 

advise them of all vacancy announcements being posted to usajobs.gov. This 

will ensure that people with disabilities are advised of our job openings. The 

Selective Placement Coordinator also provides assistance to disabled 

applicants or applicants seeking an accommodation. 

Page 64 
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. 

RRB is committed to creating and maintaining a workplace culture that 

embraces inclusive diversity as a critical business imperative that cultivates a 

high-performing organization. Internally, RRB has three (3) Special Emphasis 

Programs (SEP) that are recognized to advance inclusive diversity and improve 

communication between employees and management across the agency. 

Externally, OEO since FY 2020 has worked with the Bureau of Human 

Resources office to establish and maintain 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. We send our vacancy notices to them and in 

turn they disseminate the information to clients being serviced by their 

organization. 

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 

Page 65 
Describe the agency’s efforts to establish and maintain contacts with organizations that assist PWD, including PWTD, 

in securing and maintaining employment. 

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, OEO has worked with our Human Resources office to 

establish and maintain contacts with eleven organizations that assist PWDs 

and PWTDs. These organizations include the Chicago Lighthouse, Aspire NonProfit, 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. We secured a designated contact person including their email address 

and telephone number at each of these organizations. We send our vacancy 

notices to them and in turn they disseminate the information to clients being 

serviced by their organization. 

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 No 

b. New Hires for Permanent Workforce (PWTD) Answer No 

RRB hired a total of 69 new employees in FY 2021. In FY 2021, RRB hired a 

total of 69 new employees. A total of 35 (51 percent) listed a disability (PWD) 

and 34 (49 percent) did not identify or listed as having a disability. Of the 35 

new hires identifying that they have a disability, 2 or 3 percent identified their 

disability as a targeted disability (PWTD). Disability workforce data includes 

employees who self-identify as having a disability. 

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 No 

b. New Hires for MCO (PWTD) Answer No 

Of the 69 new employees hired in FY 2021, 44 (64 percent) of the new hires 

were in the agency’s mission critical occupations (MCO). RRB has two mission 

critical occupations (MCO): 2210 and 0993. Three (3) individuals were hired in 

the 2210 MCO. A total of one (1) employee hired under MCO 2210 listed a 

disability but did not want to identify it (33 percent). A total of forty-one (41) 

individuals were hired in the 0993 MCO. A total of twenty-four (24) hired under 

MCO 0993 self-identified as having a disability (58.5 percent), 19 of the 24 did 

not want to identify their disability, one (1) indicated that their disability was not 

listed, two (2) were regular disabilities and one (1) new hire has a targeted 

disability (2.4 percent). Disability workforce data involves employees who selfidentify as having a disability. 

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 No 

b. Qualified Applicants for MCO (PWTD) Answer No 

Page 66 
In FY 2021, a total of seven (7) internal applicants applied for promotion in the 

MCO 0993. A total of six (6) applicants did not wish to identify as having a 

disability or targeted disability zero and a total of one (1) stated that they did 

not have a disability. In FY 2021, a total of fifteen (15) internal applicants 

applied for promotions in the MCO 2210. A total of eleven (11) applicants did 

not wish to identify as having a disability or targeted disability and a total of one 

(1) stated that they did not have a disability. Since RRB disability workforce 

data involves employees who self-identify as having a disability, this may or 

may not be a trigger, but OEO will continue to monitor the statistics and hiring 

trends. 

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 

In FY 2021, the agency had a total of 62 internal promotions for MCO 0993 and 

15 internal promotions for MCO 2210. Under MCO 0993, a total of 20 or 32.3 

percent of internal applicants who identified as having a disability (PWD) were 

promoted in FY 2021. Under MCO 0993, a total of 2 or 3.2 percent of internal 

applicants who identified as having a targeted disability (PWTD) were 

promoted in FY 2021. Under MCO 0993, a total of 40 or 64.5 percent of 

internal applicants stated that they did not have a disability were promoted in 

FY 2021. Under MCO 2210, a total of 3 or 20 percent of internal applicants who 

identified as having a disability (PWD) were promoted. Under MCO 2210, a 

total of 0 internal applicants who identified as having a targeted disability 

(PWTD) were promoted. Under MCO 2210, a total of 12 or 80 percent of 

internal applicants stated that they did not have a disability were promoted. 

Since RRB disability workforce data involves employees who self-identify as 

having a disability, this may or may not be a trigger, but OEO will continue to 

monitor the statistics and promotion trends. 

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. 

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In FY 2021, RRB offered various ways for employees to further their career 

goals. RRB employees 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 

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. 

Career Development Opportunities Total Participants PWD PWTD 

Applicants (#) Selectees (#) Applicants (#) Selectees (#) Applicants (#) Selectees (#) 

Fellowship Programs 0 0 0 0 0 0 

Other Career Development 

Programs 

0 0 0 0 0 0 

Training Programs 0 0 0 0 0 0 

Mentoring Programs 0 0 0 0 0 0 

Coaching Programs 0 0 0 0 0 0 

Internship Programs 0 0 0 0 0 0 

Detail Programs 0 0 0 0 0 0 

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 

RRB did not offer a formal career development program in FY 2021. However, 

RRB continued to encourage the use of the RRB University and Treasury 

Executive Institute (TEI) as career development tools and resources and these 

will be reflective in our FY2022 responses. Beginning in FY 2022, RRB will 

begin to collect data from our agency’s learning management system (RRB 

University) and TEI to identify qualifying career development course 

completion. Using data from our human resources system(s) to obtain 

personnel attributes, RRB will then identify and match the total number of 

employees who participated in those career development courses to produce a 

report that complies with the MD-715. Depending on FY 22 and FY 23 funding, 

RRB may expand to capture data that includes internships and mentoring, in 

order to facilitate analyses of usage and potential barriers. 

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 

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RRB did not offer a formal career development program in FY 2021. However, 

RRB continued to encourage the use of the RRB University and Treasury 

Executive Institute (TEI) as career development tools and resources. Beginning 

in FY 2022, RRB will begin to collect data from our agency’s learning 

management system (RRB University) and TEI to identify qualifying career 

development course completion. Using data from our human resources 

system(s) to obtain personnel attributes, RRB will then identify the total number 

of employees who participated in those career development courses to 

produce a report that complies with the MD-715. 

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 

During FY 2021, RRB issued seventy-five (75) time-off awards and twenty-nine 

(29) non-performance based awards (includes suggestion awards, group 

awards, cash awards not based on performance) totaling 104 awards. A total of 

twenty-one (21) employees (20.2 percent) listed a disability and zero (0) or 0 

percentlisted a targeted disability. Therefore, the inclusion rate for PWDs is 

20.2 percent and 0 percent for PWTDs. This may or may not be a trigger since 

the statistics are based on self-identification but the agency will continue to 

monitor. A total of 83 or 80 percent of the 104 recipients of time-off and nonperformance based awards stated that they did not have a disability. 

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 

During FY 2021, a total of one hundred and seven (107) employees received a 

quality step increase and five hundred and twenty-eight (528) received a 

performance based incentive award for a total of six hundred and thirty-five 

(635) employees. A total of one hundred twenty-one (121) or 19.1 percent of 

these employees listed a disability. Of the 635 employees receiving 

performance-based awards, seventeen (17) or 2.7 percent listed a targeted 

disability. Of the 635 employees receiving performance-based awards, a total 

of 514 or 80.9 percent of the recipients stated that they did not have a 

disability. Therefore, the inclusion rate for PWDs is 19.1 percent and PWTDs is 

2.7 percent. This may or may not be a trigger since the statistics are based on 

self-identification but the agency will continue to monitor. 

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 

The RRB does not have any additional recognition programs other than those 

listed above. 

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 

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i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

c.  Grade GS-14 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

d.  Grade GS-13 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

It should be noted that RRB generally announces job vacancies governmentwide to expand the applicant pool and recruit the best talent into the agency. 

As a result, the current RRB workforce or a subset of it (employees in an MCO, 

employees at next lower grade level, and so forth) might not be a relevant 

applicant pool. Identifying which current RRB employees would qualify for a job 

series they are not currently in is a difficult undertaking. The Bureau of Human 

Resources does not adjudicate applicant qualifications until an applicant 

applies for a specific position. The applicant may qualify based on experience 

obtained prior to entry into their current job series or RRB. During FY 2021, no 

employee was promoted into an SES position. A total of seven (7) employees 

applied and qualified for a GS-15 position. One (1) identified as having a 

disability and none (0) identified as having a targeted disability. A total of six (6) 

employees applied and qualified for a GS-14 position. One (1) identified as 

having a disability and none (0) identified as having a targeted disability. A total 

of four (4) employees applied and qualified for a GS-13 position. All reported no 

disability. 

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 

During FY2021, none of the internal applicants for GS-13, GS-14, GS-15 or 

SES positions reported a targeted disability. One internal applicant for GS-14 

position identified as having a disability. One internal applicant for a GS-15 

position also identified as having a disability. Many applicants did not want to 

identify their disability so we do not know if they had a targeted disability or not. 

The data does not trigger a barrier analysis. 

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 No 

b. New Hires to GS-15 (PWD) Answer No 

c. New Hires to GS-14 (PWD) Answer No 

d. New Hires to GS-13 (PWD) Answer N/A 

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During FY 2021, RRB hired four (4) new employees (external hires) into an 

SES position. A total of three (3) new SES hires identified as having a 

disability. None (0) identified as having a targeted disability. RRB hired one (1) 

individual for a GS-15 position. This employee identified as having a disability, 

but did not identified as having a targeted disability. RRB hired four (4) 

individuals for GS-14 positions. All reported no disability. During FY 2021, RRB 

did not hire any new employees into a GS-13 position. We do not believe the 

data is large enough to trigger a barrier analysis. 

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 No 

b. New Hires to GS-15 (PWTD) Answer No 

c. New Hires to GS-14 (PWTD) Answer No 

d. New Hires to GS-13 (PWTD) Answer N/A 

During FY 2021, RRB hired four (4) new employees into an SES position. A 

total of three (3) new SES hires identified as having a disability (PWD). None 

(0) identified as having a targeted disability (PWTD). RRB hired one (1) 

individual for a GS-15 position. This employee identified as having a disability 

(PWD), but did not identified as having a targeted disability (PWTD). RRB hired 

four (4) individuals for GS-14 positions. All reported no disability. During FY 

2021, RRB did not hire any new employees into a GS-13 position. Since RRB 

does not have hiring authority under Schedule A and the new hires are small in 

number, we do not see a trigger to support a barrier analysis. 

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 No 

ii. Internal Selections (PWD) Answer No 

b.  Managers 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

c. Supervisors 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

During FY 2021, RRB did not hire any internal applicants into a SES position. 

All four (4) hires in SES postions were external hires. Two (2 )internal 

applicants who applied for an SES position but were not selected. Of the ten 

(10) internal applicants who applied for a supervisory/management position at 

the GS-13 through GS-15 level, a total of 3 or 30 percent qualified and were 

selected during FY 2021. Two (2) of the internal applicants identified as having 

a disability (PWD) but zero (0) internal applicant(s) with a disability qualified 

and was selected for a GS-13 through GS-15 position. Zero (0) internal 

applicants for a GS-13 through GS-15 position reported having a targeted 

disability (PWTD). Please note that the Applicant Flow Data system could not 

separate the supervisors from the managers, therefore all management 

positions were included together under supervisors. 

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 No 

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ii. Internal Selections (PWTD) Answer No 

b.  Managers 

i. Qualified Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer No 

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer No 

During FY 2021, RRB did not hire any internal applicants into a SES position. 

All four (4) hires in SES postions were external hires. During FY 2021, a total of 

ten (10) internal applicants applied for a supervisory/management position at 

the GS-13 through GS-15 level. During FY 2021, a total of three (3 ) qualified 

and were selected for a supervisory/management position at the GS-13 

through GS-15 level. During FY 2021, a total of two (2 )internal applicants 

identified as having a disability (PWD) and zero (0) internal applicant(s) with a 

disability qualified and was selected for a GS-13 through GS-15 position. A 

total of zero (0) internal applicants reported having a targeted disability (PWTD) 

and zero (0) internal applicant(s) with a PWTD qualified and was selected for a 

GS-13 through GS-15 position. Please note that the Applicant Flow Data 

system could not separate the supervisors from the managers, therefore all 

management positions were included together under supervisors. 

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 No 

b. New Hires for Managers (PWD) Answer No 

c. New Hires for Supervisors (PWD) Answer No 

During FY 2021, RRB hired four (4) new employees into an SES position. A 

total of three (3) new SES hires identified as having a disability. None (0) 

identified as having a targeted disability. RRB hired one (1) individual for a 

GS-15 position. This employee identified as having a disability, but did not 

identified as having a targeted disability. RRB hired four (4) individuals for 

GS-14 positions. All reported no disability. During FY 2021, RRB did not hire 

any new employees into a GS-13 position. We do not believe the data is large 

enough to trigger a barrier analysis. Please also note that the Applicant Flow 

Data system could not separate the supervisors from the managers, therefore 

all management positions were included together under supervisors. 

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 No 

b. New Hires for Managers (PWTD) Answer No 

c. New Hires for Supervisors (PWTD) Answer No 

Of all the applicants who applied for the supervisory position in FY 2021, no 

one listed a targeted disability. Since the RRB cannot use Schedule A and our 

new hire numbers are so small, we do not see this as a trigger. 

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 

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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 No 

b.Involuntary Separations (PWD) Answer No 

During FY 2021, a total of sixty-six (66) separated from RRB. Of the 66 

separations, two employees were involuntarily separated and twelve 

employees' appointment(s) expired. Four (4) of the separated employees 

identified as having a disability (28.6 percent), none (0) as having a targeted 

disability and ten (10) did not identify as having a disability (71.4 percent). No 

trigger with only 4 employees to analyze whether trigger exists. Of the 66 

separations, a total of fifty-two (52) employees voluntarily separated from RRB. 

Nineteen (19) employees who voluntariily separated identified as having a 

disability (36.5 percent), none (0) as having a targeted disability and thirty-three 

(33) did not identify as having a disability (64.5 percent). 

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 No 

b.Involuntary Separations (PWTD) Answer No 

During FY 2021, a total of sixty-six (66) separated from RRB. Of the 66 

separations, two employees were involuntarily separated and twelve 

employees' appointment(s) expired. Four (4) of the separated employees 

identified as having a disability (28.6 percent), none (0) as having a targeted 

disability and ten (10) did not identify as having a disability (71.4 percent). No 

trigger with only 4 employees to analyze whether trigger exists. Of the 66 

separations, a total of fifty-two (52) employees voluntarily separated from RRB. 

Nineteen (19) employees who voluntariily separated identified as having a 

disability (36.5 percent), none (0) as having a targeted disability and thirty-three 

(33) did not identify as having a disability (64.5 percent). 

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. 

Based on available data, no trigger existed in FY 2021. During FY 2021, a total 

of sixty-six (66) separated from RRB. Of the 66 separations, two employees 

were involuntarily separated and twelve employees' appointment(s) expired. 

Four (4) of the separated employees identified as having a disability (28.6 

percent), none (0) as having a targeted disability and ten (10) did not identify as 

having a disability (71.4 percent). No trigger with only 4 employees to analyze 

whether trigger exists. Of the 66 separations, a total of fifty-two (52) employees 

voluntarily separated from RRB. Nineteen (19) employees who voluntariily 

separated identified as having a disability (36.5 percent), none (0) as having a 

targeted disability and thirty-three (33) did not identify as having a disability 

(64.5 percent). Analyses of the FY 2021 Statistical Report of Discrimination 

Complaints data and data on requests for Reasonable Accommodations were 

inconclusive. During FY 2021, RRB did not use or conduct exit interviews 

which may have helped explain why PWD and/or PWTD left the agency. As of 

FY 2022, the Bureau of Human Resources has reinstated the use of an exit 

survey. 

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. 

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The RRB public facing website (https://www.rrb.gov/Resources/ 

OfficeOfEqualOpportunity/Nondiscrimination) explains how to file a formal 

complaint under Section 508. Specifically, the website provides: EEO 

Complaint Procedure for RRB Customers A. If you are an employee of a 

railroad company and you believe you have been discriminated against by your 

employer, you must contact the Equal Employment Opportunity Commission 

(EEOC) in your area within 180 days of the alleged discrimination. The RRB 

does not have jurisdiction to process complaints against railroad employers. 

For information on how to file a complaint with EEOC, contact them at 

1-800-669-4000 or visit www.eeoc.gov to find the office in your geographic 

location. B.1 If you believe that the RRB has failed to make agency programs 

and activities accessible to all qualified individuals with a disability, you may file 

a complaint under Section 504 of the Rehabilitation Act of 1973. B.2 If you 

believe that the RRB failed to make electronic and information technology 

accessible to individuals with disabilities, you may file a complaint under 

Section 508 of the Rehabilitation Act of 1973. Complaints alleging 

noncompliance under Section 504 (which prohibits discrimination on the basis 

of disability in agency programs and activities) or Section 508 (which requires 

accessibility of electronic and information technology) must be in writing and 

include the complainant's name, address, telephone number and a description 

of how the agency violated Section 504 or Section 508. The complaint must be 

submitted within 90 calendar days of the alleged noncompliance or the date 

you became aware of the noncompliance to the address below. Director - 

Office of Administration Railroad Retirement Board 844 N. Rush Street 

Chicago, IL 60611-2092 

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. 

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 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.) 

RRB is committed to providing effective reasonable accommodations to 

employees and applicants with disabilities. The average time frame for 

processing initial requests was 30 work days or less. We received 8 reasonable 

accommodation requests in FY 2021. One employee submitted a request but 

decided to pursue disability retirement. One employee had the request 

approved but decided to retire. Five employees received their requested 

accommodations within the 60-day timeframe. One employee has not received 

their request to date. The top three requests: ergonomic keyboard, sit/stand 

desk, and ergonomic mouse. According to the Reasonable Accommodation 

Coordinator, the agency plans on implementing the following activities in FY 

2022 – developing and disseminating information on available Reasonable 

Accommodation resources, as well as tracking and reporting of Reasonable 

Accommodation requests in the annual Individuals with Disabilities Affirmative 

Action Program. 

Page 74 
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. 

As noted above, RRB is committed to providing effective reasonable 

accommodations to employees and applicants with disabilities. During FY 

2021, the agency's Reasonable Accommodation Coordinator continued to 

provide reasonable accommodation assistance, guidance and training to 

managers and supervisors regularly. The reasonable accommodation policy 

and procedure is very effective. Employees are able to come to the Office of 

Equal Opportunity (OEO) if they are not satisfied with their accommodation or 

they are denied an accommodation and wish to file a complaint or just talk 

about it. This policy is on OEO and HR internal website for all employees to 

read. OEO provides an annual new supervisors training. When revisions are 

made to the policy, a training PowerPoint is downloaded to our training module 

(RRB University) and we ensure all employees complete it by tracking their 

progress. During FY 2021, the RRB timely processed and provided approved 

accommodations. The Reasonable Accommodation Coordinator also continues 

to monitor accommodation requests for trends. 

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 FY2021, thus no data is available on 

this. The PAS requirement is understood by the cohort of OEO and HR staff 

(including the Reasonable Accommodation Coordinator). 

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 

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 FY2021. 

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 FY2021. 

Page 75 
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. 

N/A 

5. For the planned activities that were completed, please describe the actual impact of those activities toward eliminating the barrier(s). 

N/A 

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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