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, 2019 to September 30, 2020 

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 John Bragg Labor Member of the Board 

Head of Agency Erhard Chorle Chairman of the Board 

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

Principal EEO Director/Official Pamela Tate Director of Equal Opportunity 

Other EEO Staff Kathy Robinson EEO Specialist 

17 

1. 826 

2. 16 

4. 842 

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, 2019 to September 30, 2020 

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 

Agency Strategic Plan Y Y 

Anti-Harassment Policy and 

Procedures 

Y Y 

EEO Policy Statement Y Y 

Organization Chart Y Y 

Alternative Dispute Resolution 

Procedures 

Y Y 

Reasonable Accommodation 

Procedure 

Y Y 

Personal Assistance Services 

Procedures 

Y Y 

EEO Strategic Plan N 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 

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: MISSION 

The Railroad Retirment Board (RRB) is an independent agency in the Executive Branch of the Federal Government.  It's 

mission is to administer retirement/survivor and unemployment/sickness insurance benefit programs for the railroad workers 

and their families under the Railroad Retirmenet Act and the Railroad Unemployment Insurance Act.  These programs provide 

income protection during old 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 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 itsef 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) provides leadership, direction and guidance in carrying out the RRB's equal opportunity 

and civil rights responsiblities. 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 Orfers 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 their annual self-assessment which includes comparing the 

RRB program against benchmark elements. 

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

1. Essential Element A: Demonstrated Commitment from Agency Leadership: The Agency's EEO Program meets the 

requirements of Essential Element A. 

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

• The agency issued the EEO Policy Statement in September 2020 declaring the agency's position against discrimination on 

all protected basis.  The statement was signed by the three Presidential Appointed Board Memebers 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. 

• 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 EEO is listed on the agency's website and the names of the EEO Specialist (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 materals 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. 

• OEO provided EEO language to be include on all manager's performance appraisals so that they can be recognized for 

their accomplishments in equal employment opportunity.  And, EEO sub-element is being included in all manager's 

performace appraisals beginning October 2020. 

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

commitment is reiterated in the Agency's Strategic Plan which states in part that the agency will recruit and hire a highperforming workforce that reflects the diversity of all segments of the American society.  The OEO Strategic Plan includes 

the following objectives: 1) identify and remove barriers to allow the building of a diverse workforce; 2) develop programs 

and activities to educate RRB personnel on disability and diversity issues; 3) assist in succession planning for the agency; 

and 4) encourage mentoring.. 

• The EEO 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 EEO 

Director ensures timely compliance with EEOC orders and evaluates the EEO program and recommends improvements to 

the Agency Head. The EEO Director also ensures that complaint counselings, investigations and final agency actions are 

completed timely. 

• The EEO Director does not currently participate in senior-level staff meetings concerning personnel, budget, technology 

and other workforce issues, but during FY2020 she met with the Executive Committee (EC) about this concern and 

was provided with the opportunity to review and offer comments on the EC policy revisions regarding workforce issues 

prior to final implementation. 

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• The agency has sufficient budget and staffing  to support the success of the EEO program. OEO is staffed by the EEO 

Director and the EEO Specialist who is the complaints manager and oversees all sepcial 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 apects 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. 

• EEO is an independent organization reporting directily to the Board and is responsible for it's own budget. 

• We have two experienced Adhoc EEO Counselors and they did receive the 8-hour annual refresher training in FY2020. 

We did not recruit any new Counselors during FY2020. 

• 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. 

• The special emphasis programs were implemented with the assistance of the senior managers.  The managers must 

provide employees with time to attend these programs and the senior managers attend as well to show their committment 

to the EEO program. 

3. Element C: Management and Program Accountability.  The agency's EEO program meets the requirements of 

Essential Element C: 

• OEO reviewed reports reflecting activity for peronnel 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. 

• The agency has established procedures, including the Anti-Harassment Procedure and the EEO Complaint Process, to 

assist in preventing all forms of EEO discrimination in the workplace. OEO requested input of other organizations to create 

a new anti-harassment policy to establish a firewall between the EEO Director and the Anti-Harassment Coordinator to 

avoid a conflict of interest. The new anti-harassment policy and procedure was forwarded to EEOC in FY2020. OEO is no 

longer involved in the decision-making process on complaints of harassment per EEOC guidance. 

• The Agency's Reasonable Accommodation Procedure, which includes the Personal Assistance Services Procedures, 

comply with EEOC regulations.  The Reasonable Accommodation Coordinator works within the Department of Human 

Resources.  Language was added to all job announcements indicating how an applicant could request a reasonable 

accommodation, if needed. The Reasonable Accommodation Procedures, the EEO Complaint procedure, the Notification 

and Federal Employee Anti-discrimination and Retaliation Notice (No FEAR Act) are among several documents pertaining 

to EEO that are posted on the agency's website, the RRB intranet and bulletin boads located at headquarters and field 

offices.  The EEO Handbook, which was updated in FY2020, also includes all of the agency's EEO policies, procedures 

and programs.  During orientation, all new employees receive an EEO packet of materials which includes the handbook, 

the reasonable accommodation procedure and the No FEAR Act information. 

• A performance standard is included in all Senior Executive Service employee's performance appraisal.  During FY2019 

and again in FY2020, OEO and HR met and established language to be included as a sub-element on all manager's 

performance appaisals for FY2020. This sub-element was included on all manager's performance appraisals with 

an effective date of October 2020.  Now we can establish an EEO award program or some type of recognition to those 

who support the EEO program. 

• The agency's Table of Penalty's include penalities that pertain to those who violate EEO laws and regulations. The Table 

of Penalty was removed by HR, without notification to EEO, but we are working to reestablish it. 

• Intermittent reviews of agency policies and procedures are conducted without a formal timetable. 

4. Essential Element D: Proactive Prevention of Unlawful Discrimination. The agency's EEO program meets the 

requirements fo Essential Element D. 

• The agency no longer conducts exit interviews.  This was in HR's department and OEO was informed that they do not 

have the manpower to conduct the surveys any longer. 

• OEO reviwes agency policies, procedures and practices and have identified no barriers in the workplace.  As stated 

earlier, the RRB is a small agency.and discriminatory policies or practices would easily come to light. 

• Complaints of discriminaton during FY2020 involved non-selection and reasonable accommodation issues.  In review, we 

found no practice of the agency promoting certain races of people, people of a particular age, certain genders or people 

with or without a disability. The panel material was reviewed and the selections were based on the employees knowledge, 

skills and abilities.  

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: ESSENTIAL ELEMENT A-F 

• The EDAC has worked with HR to establish organizations that assist people with disabilities in returning to the workforce. 

EDAC found a number of organizations and forwarded the information to HR in order to establish a point of contact for the 

posting of our vacancy announcements. 

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

• 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 Responsiblities 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 throgh the Federal Sector EEO Portal (FedSEP). 

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

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

law department reviews the report in advance of the complainant requesting a hearing before EEOC  The law department 

is not included in the counseling or the investigation stage.  The law department does prepare the final agency decision for 

the agency. 

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

complaint.  Managers and supervisors have a duty to participate in the ADR process once it is elected.  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 FY2020. 

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

employees and applicants for emloyment were posted quarterly on the agency's website.  The annual No FEAR Act was 

timely submitted to the required congressional entitities 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. When a Final Agency Decision (FAD) is requested, the OGC 

in consultation with the 3-Member Board, is responsible for the FAD. To preserve the fairness in the processing of 

complaints, in the event of litigation the attorney responsible for the hearing proceedings would not handle any later 

litigations on that particular complaint. 

6. Essential Element F: Responsiveness and legal compliance.  The agency's EEO program meets the requirements 

of  Essential Element F. 

• During FY2020, the agency revised the language in the Reasonable Accommodation Policy and created a Power Point 

training that was uploaded to RRB University as a mandatory training for all managers. The policy was approved by EEOC. 

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

• 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. 

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: WORKFORCE ANALYSES 

For the purpose of this report, the benchmark used for examining our workforce demographics is the 2010 Civilian Labor Force 

(CLF) data.  The CLF represents the employment availability of classes of people by race, ethnicity and sex.  Due to the 

application of percentages for the various reporting categories, small employment fluctuations become amplified and the 

"underrepresentation" is often misleading.  As a result, the data may appear to signal that an employment barrier may exist 

when it does not. 

In addition to the headquarters office located in Chicago, the RRB has 53 district offices thoroughout the United States, with 

staff ranging from two (2) to eight (8) employees.  Therefore, the RRB hires from all regions of the United States.  Vacancies 

are posted nationwide.  During FY2020, a total of fifty-nine (59) individuals were hired.  A total of twenty-one (21) of those new 

hires represents 35% that indicated they had a disability. Of the new hires 2 individuals (3%) had a targeted 

disability.  Although, it was our goal to hire more individuals in FY2020, the total permanent workforce decreased from 851 in 

FY2019 to 842 in FY2020. 

In terms of how the workforce representation compares to the CLF, the percentage of Hispanic males is 4.75% compared to 

the CLF which is 5.17 %, However,the RRB employed 40 Hispanic males in FY2020 which is an increase from 36 in FY2019. 

Total Hispanic females slightly decreased from 44 in FY2019 to 42 in FY2020, however the RRB workforce percentage of 

Hispanic Females of 5% remained higher than the CLF of 4.79%. White males represent 24.70% of RRB workforce which is a 

slight decrease from 25.38% in FY2019 but still lower than the CLF of 38.33%,  During FY2020, white females 

represented 20.43% of the workforce (172) which  is a slight decrease from  21.87% (187) in FY2019 and lower than the CLF 

of 34.03%.  The RRB employed a total ot 92 Black males which represents 11% of the workforce in FY2020 which slighly 

increased from 10.41% in FY2019 and higher than the CLF of 5.49%. Black females totaled 238 or 28% of the workforce which 

was a slight increased from 27.60% in FY2019 and is higher than the CLF of 6.53%. Black females represent the largest 

percentage of the workforce. A total of 23 Asian males represented 2.73% of the FY2020 workforce which increased from 

2.69% in FY2019 and higher than the CLF of 1.97%. Asian females totaled 14 or 1.66% of the workforce which slightly 

increased from 1.29% of the workforce in FY2019 and lower than the CLF of 1.93%. Native American, Pacific Islanders and 

employees who showed 2 or more races represent less than 1% of the workforce which remained the same from FY2019 and 

relatively the same as compared to the CLF. 

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: ACCOMPLISHMENTS 

The following highlights many of the RRB's FY2020 program activities: 

• Issued the Agency's EEO Policy Statement 

• Conducted EEO training for new supervisors 

• Sponsored four diversity programs throughout the year including Native American, Disability Awareness, Black History, 

and Hispanic Heritage Month programs. 

• Processed all complaints in accordance with EEOC's regulatory timeframes; 

• Created and presented an 8-hour refresher training for EEO Counselors. 

• Prepared and submitted all required reports to oversight agencies; 

• 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 pocess, (4) AFGE officials who requested 

assistance and (5) external customers who requested assistance with an EEO or non-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. 

• Revised the Anti-Harassment Policy and created a Power-Point training for all employees; 

• Worked with HR to include an EEO sub-element on all manager's performance appraisals; 

• Updated the Sexual Harassment Policy.  All 3 Board Members signed it and it is posted on every floor at headquarters and 

in every field office. 

• Updated and renamed the Policy on Hiring Individuals with Disabilites to Plan For Increasing and Maintaining The 

Employment of Individuals with Disabilities. 

• Updated the EEO Handbook to include the revised Anti-Harassment Policy procedure. 

• Provided State of the Agency to the Board Members and their designees 

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, 2019 to September 30, 2020 

EXECUTIVE SUMMARY: PLANNED ACTIVITIES 

The planned activities for FY2021 include the following" 

• Update the EEO Handbook for compliance with EO 13988. 

• Update the in-house No FEAR Act training video for release for FY2021. 

• Promote on-line Diversity programs for Black History month, Women's History month, Asian Pacific Heritage month, 

Hispanic Heritage month, Native American History month and a Disability awareness in Employment month due to 

COVID-19 restrictions. 

• Re-establish award for manager's who show support for EEO activities 

• Analyze internal selections by requesting all panel information whether or not a complaint is filed 

• Conduct EEO training for new supervisors 

• Offer Refresher training to all EEO Counselors 

• Revise the power point training on the Reasonable Accommodation policy 

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

• Re-establish the Exit Survey and mail it to all employees who separated from service in the previous fiscal year to 

determine whether their departure was prompted by any form of discrimination at the RRB. 

• Provide a "State of the Agency" to the agency Board Members and/or their designees. 

Page 7 

 

 

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, 2019 to September 30, 2020 

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. 

9/4/2020 

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, 2019 to September 30, 2020 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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

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 

Counselor's are 

not listed because 

employees must 

contact the EEO 

Director. 

A.2.b.2. Written materials concerning the EEO program, laws, policy statements, and the operation of the EEO X Yes, we created a 

complaint process? [see 29 CFR §1614.102(b)(5)] 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, 2019 to September 30, 2020 

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 

Booklets 

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, 2019 to September 30, 2020 

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, 2019 to September 30, 2020 

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 The Office of 

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

one or two examples in the comments section. . Opportunity 

(OEO) 

collaborated with 

HR to have EEO 

language be 

included as a subelement on all 

managers 

performance 

appraisal for 

FY2020. This was 

not put on 

appraisals until 

FY2021. This can 

be used as a tool 

to notate 

accomplishments 

in EEO. We can 

then ask to 

forward any and 

all "write-ups" 

about 

performance to us 

for recognition. 

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, 2019 to September 30, 2020 

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, 2019 to September 30, 2020 

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. The EEO 

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 EEO Director 

agency head designee as the mission-related programmatic offices? If “yes,” please provide the title of the reports to the 3 

agency head designee in the comments. 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. The EEO 

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

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

with the 3 

member board. 

The Board or 

their assistants are 

always open to 

meeting with the 

EEO Director on 

issues about the 

efficiency and 

legal compliance 

of the agency's 

EEO program. 

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

management officials, the "State of the agency" briefing covering the six essential elements of the model EEO provided a "State 

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

the date of the briefing in the comments column. report to the 

Board Members 

and their 

assistants in 

FY2020. 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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

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

X No. However, 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 during 

FY2020. 

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, 2019 to September 30, 2020 

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 EEO 

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 EEO 

§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 EEO 

[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. We work 

CFR §1614.102(c)(5)] [This question may not be applicable for certain subordinate level components.] 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, 2019 to September 30, 2020 

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 

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

Director is 

included. 

Sometimes it may 

be a review of the 

recruitment 

strategies, 

vacancy 

projections, 

succession 

planning, etc., 

prior to 

implementation 

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, 2019 to September 30, 2020 

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, Federal 

Women's 

Program and 

Employee 

Disability 

Advisory 

Council); as well 

as 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 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. 

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

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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. 

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 

downloaded 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. 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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

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

prints our EEO 

literature and/or 

materials for 

various programs. 

Policies are 

posted throughout 

the agency in 

plain view as well 

as in every Field 

office. We also 

have an internal 

and external 

website where we 

post our various 

policies and 

information on 

our EEO 

programs. 

B.4.a.7. to maintain accurate data collection and tracking systems for the following types of data: complaint X 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. We 

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

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

programs during 

fiscal year 2020 

prior to the office 

closure due to 

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)] 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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. 

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 23 
 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

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 Anti-harassment 

policy was 

revised in 

FY2020. 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. 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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. 

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] manages 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 Senior 

management must 

participate in the 

barrier analysis 

process to get 

their buy-in. 

However, we 

have not had a 

barrier analysis 

because no trigger 

has been spotted. 

B.6.c. When barriers are identified, do senior managers assist in developing agency EEO action plans (Part I, X No barriers have 

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

But if and when 

they are, senior 

managers will be 

included. 

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

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

removed from the 

agency strategic 

plan. I brought 

this to the senior 

executive 

manager's 

attention and he 

assured me when 

the strategic plan 

is revised (2022), 

the EEO language 

would be in there. 

Page 25 
 

 

 

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, 2019 to September 30, 2020 

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 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, 2019 to September 30, 2020 

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 policy 

Supervisors (Enforcement Guidance), EEOC No. 915.002, § V.C.1 (June 18, 1999)] 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 27 
 

 

 

 

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, 2019 to September 30, 2020 

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 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 

is needed. The 

revised policy 

includes language 

that the inquiry 

begins within 10 

days. We did not 

have any 

harassment 

complaints in 

FY20. 

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. 

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 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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

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

Accommodation 

Coordinator in 

Human Resources 

to assist with 

processing 

requests 

throughout the 

agency and keep 

information as to 

what 

accommodation 

was approved or 

denied. 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. 

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. 

Page 29 
 

 

 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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

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

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

column. 

X Yes, we process 

all 

accommodations 

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 

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

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

X Yes, we have 

established 

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 

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

column. 

X Yes, it is included 

in the Reasonable 

Accommodation 

Policy which is 

posted on rrb.gov. 

To date, we have 

had no requests. 

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, 2019 to September 30, 2020 

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 senior 

performance appraisal that evaluates their commitment to agency EEO policies and principles and their executives (SES) 

participation in the EEO program? has language in 

their performance 

appraisal and an 

EEO sub-element 

was sent to all 

Directors in 

September 2020 

to be include on 

all managers 

performance 

appraisal 

beginning 

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 sub-element, 

managers will be 

appraised on this 

beginning in 

FY2021. 

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 sub-element, 

all manages will 

be appraised on 

this beginning 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 sub-element, 

managers will be 

appraised on this 

beginning in 

FY2021. 

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 sub-element, 

all managers will 

be appraised on 

this beginning 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 sub-element, 

managers will be 

appraised on this 

beginning in 

FY2021. 

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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 sub-element, 

managers will be 

appraised on this 

beginning in 

FY2021. 

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 sub-element, 

managers will be 

appraised on this 

beginning 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 sub-element, 

managers will be 

appraised on this 

beginning in 

FY2021. 

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

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

MD-715, II(C)] managers will be 

appraised on this 

beginning in 

FY2021. 

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

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

§1614.102(c)(2)] always 

recommend. 

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 

FY20. 

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, 2019 to September 30, 2020 

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. 

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

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. 

OEO downloads 

applicant data 

annually from 

Applicant Flow 

Data provided by 

OPM and OEO is 

provided 

information on 

training programs 

annually. 

C.4.d. Does the HR office timely provide the EEO office with access to other data (e.g., exit interview data, X Yes, HR no 

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

interviews. 

Climate 

assessment survey 

information is 

shared with OEO. 

Grievance data is 

not normally 

shared because 

we have not asked 

for it. 

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

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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

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 

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

the Status and 

Dynamics files 

for the MD-715. 

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, 2019 to September 30, 2020 

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 Yes, a guide to 

[see 29 CFR §1614.102(a)(6); see also Douglas v. Veterans Administration, 5 MSPR 280 (1981)] disciplinary 

actions for 

discriminatory 

conduct was 

included in the 

RRB Table of 

Penalty's included 

in the Employee 

Handbook. HR 

decided to 

remove the table 

of penalties 

covering 

discriminatory 

conduct during 

FY2020. 

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 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, 2019 to September 30, 2020 

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 36 
 

 

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, 2019 to September 30, 2020 

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 RMO's 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, 

complaint data 

and special 

emphasis 

programs. 

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 HR used to 

conduct exit 

interviews but 

removed this 

process due to 

low staff. 

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, 2019 to September 30, 2020 

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 

which did not 

impact a certain 

group of 

employees. 

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, exit survey, 

MD-715 Instructions, Sec. I]] If “yes”, please identify the data sources in the comments column. program 

evaluations and 

special emphasis 

programs for 

barriers. 

Page 38 
 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

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 FY2020. 

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 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, 2019 to September 30, 2020 

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 40 
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, 2019 to September 30, 2020 

Agency Self-Assessment Checklist 

Essential Element: E Efficiency 

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, 2019 to September 30, 2020 

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 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, 2019 to September 30, 2020 

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. We advise 

them on the onset 

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 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, 2019 to September 30, 2020 

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 yes, the OGC 

function? [see MD-110, Ch. 1(IV)(D)] If “yes”, please explain. handles the 

defensive 

function and there 

is a clear 

separation 

between OEO and 

OGC. OGC is not 

involved in the 

process until the 

Complainant 

requests a hearing 

or Final Agency 

Decision. 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. 

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 

or a Final Agency 

Decision is 

required. If 

Complainant 

request a final 

agency decision, 

OGC writes the 

decision. 

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 44 
 

 

 

 

 

 

EEOC FORM U.S. Equal Employment Opportunity Commission 

715-02 FEDERAL AGENCY ANNUAL 

PART G EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

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 RMO 

settlement authority? [see MD-110, Ch. 3(I)] 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 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, 2019 to September 30, 2020 

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 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, 2019 to September 30, 2020 

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 

Human 

Resources. 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. This Office 

Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), § V.C.2] of Administration 

processes 

complaints of 

harassments 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 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, 2019 to September 30, 2020 

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, I am a 

effectiveness of its EEO program? [see MD-715, II(E)] If “yes”, provide an example in the comments. 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 48 
 

 

 

 

 

EEOC FORM 

715-02 

PART G 

U.S. Equal Employment Opportunity Commission 

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

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 49 
 

 

 

 

 

 

 

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, 2019 to September 30, 2020 

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 50 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

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 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 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 sub-element was added to all managers performance appraisals for FY21. 

Page 51 
 

 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

Plan to Attain Essential Elements 

PART H.2 

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 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 Pamela M. Tate Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

05/01/2020 For the EEO Director to be apart of Senior Level meetings on hiring workforce, technology, Yes 10/01/2021 

etc. 

Accomplishments 

Fiscal Accomplishment 

Year 

2020 The 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 EEO Director was sent policies to review prior to implementation. 

Page 52 
 

EEOC FORM U.S. Equal Employment Opportunity Commission

715-02 FEDERAL AGENCY ANNUAL

PART H EEO PROGRAM STATUS REPORT 

Railroad Retirement Board For period covering October 1, 2019 to September 30, 2020 

Plan to Attain Essential Elements 

PART H.3 

Brief Description of Program C.4.b. Has the agency established timetables/schedules to review at regular intervals its merit promotion program, employee 

Deficiency: recognition awards program, employee development/training programs, and management/personnel policies, procedures, and 

practices for systemic barriers that may be impeding full participation in the program by all EEO groups? [see MD-715 Instructions, 

Sec. I] 

Establishment of timetables/schedules to review the merit promotion program,, employee recognition awards program, employment development/training programs, 

personnel policies, procedures and practices for systemic barriers that may impede full participation in the program by all EEO groups. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2020 10/01/2023 To establish schedules to review the agency's merit promotion program, employee recognition 

awards program, employee development /training programs and management personnel 

policies, procedures and practices for systemic barriers that may be impeding full participation 

in the program b all EEO groups? 

Responsible Officials 

Title Name Standards Address the Plan? 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

Page 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, 2019 to September 30, 2020 

Plan to Attain Essential Elements 

PART H.4 

Brief Description of Program 

Deficiency: 

D.1.c. Does the agency conduct exit interviews or surveys that include questions on how the agency could improve the recruitment, 

hiring, inclusion, retention and advancement of individuals with disabilities? [see 29 CFR §1614.203(d)(1)(iii)(C)] 

Does the agency conduct exit surveys. 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2021 10/01/2022 Meet with the Director of HR about re-establishing Exit Surveys. 

Responsible Officials 

Title Name Standards Address the Plan? 

EEO Director Pamela M. Tate Yes 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

04/01/2021 Contacted the Director of HR to discuss the re-establishment of Exit Surveys and was Yes 

informed that they (HR) has already begun the process to re-establish it. Will follow-up. 

Accomplishments 

Fiscal Accomplishment 

Year 

Objectives for EEO Plan 

Date Initiated Target Date Date Modified Date Completed Objective Description 

10/01/2021 10/01/0022 Meet with the Director of HR about re-establishing exit surveys 

Responsible Officials 

Title Name Standards Address the Plan? 

Planned Activities 

Target Date Planned Activity Sufficient Modified Date Completion 

Staffing & Date 

Funding? 

Accomplishments 

Fiscal Accomplishment 

Year 

Page 54 
EEOC FORM 

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, 2019 to September 30, 2020 

Plan to Eliminate Identified Barriers 

Page 55 
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 FY2020, the Workforce Table, B4P, shows we have a total of total of 

819 permanent employees of which 128 (16%) were employees with a 

disability. There are 275 permanent employees in grades GS-1 through 10 

positions. Of the 275 employees 54 (20%) stated they have a disability. Of the 

544 permanent employees in grades GS-11 through SES, a total of 74 (14%) 

indicated they have 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 No 

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

During FY2020, the Workforce Table, B4P shows we have a total of 819 

permanent employees of which 128 (16%) listed a disability. A total of 21 (3%) 

listed a targeted disability. Of the 21, a total of 13 employees with a targeted 

disability worked in GS-1 through GS10 positions and a total of 8 employees 

with a targeted disability worked in GS-11 through SES positions. 

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. 

Section II: Model Disability Program 

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

persons with disabilities and persons with targeted disabilities, administer the reasonable accommodation program and 

special emphasis program, and oversee any other disability hiring and advancement program the agency has in place. 

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR THE DISABILITY 

PROGRAM 

1.  Has the agency designated sufficient qualified personnel to implement its disability program during the reporting period? If “no”, describe the 

agency’s plan to improve the staffing for the upcoming year. 

Answer Yes 

Page 56 
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 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 

# of FTE Staff By Employment Status 

Responsible Official (Name, Title, 

Full Time Part Time Collateral Duty Office Email) 

Processing applications from PWD and PWTD 0 0 0 

N/A 

Architectural Barriers Act Compliance 0 0 1 Scott Rush 

Supvy Facility Operations Specialist 

scott.rush@rrb.gov 

Answering questions from the public about 

hiring authorities that take disability into 

account 

0 0 1 Melissa T Welch 

Lead HR Specialist/Selective Placement 

Coordinator 

melissa.welch@rrb.gov 

Special Emphasis Program for PWD and PWTD 0 0 1 Kathy Robinson 

EEO Specialist 

kathy.robinson@rrb.gov 

Section 508 Compliance 0 0 1 Robert LaBerry 

Supvy IT Specialist 

robert.laberry@rrb.gov 

Processing reasonable accommodation requests 

from applicants and employees 

0 0 1 Regina Block 

HR Specialist/Labor Relations 

regina.block@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 

All managers and supervisors, and HR personnel, completed "A Roadmap to 

Success: Hiring, Retaining, and Including People with Disabilities" course in 

RRB University in March of FY2020. 

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. 

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. 

We do not identify job applicants with disabilities. All positions are filled based 

on the applicants knowledge, skills and abilities and not on their disability. 

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 

Page 57 
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 

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. 

B.  PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS 

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

in securing and maintaining employment. 

During FY2020, OEO worked with HR to establish and maintain contacts with 

eleven organizations that assist PWD and PWTD. These organizations include 

the Chicago Lighthouse, Aspire Non-Profit, Trinity Services, Inc., Search, Inc., 

Goodwill Chicago, America Works, the City of Chicago, the Department of 

Human Services, Independent Living and Transition Advocate Progress 

Center, and Southwest American Job Center. We secured a contact person at 

each organization with their email addresse and telephone number. We send 

our vacancy notices to them and in turn they disburse 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 

The RRB hired a total of 60 new employees during FY2020. A total of six (6) 

new employees (10%) listed a disability and 15 or (25%) did not want to identify 

their disability. I believe these individuals have a disability and they should be 

included. So together, that accounts for twenty-one (21) employees or 35% of 

our new hires. Of the 60 new employees, two (2) or 3% identified their disability 

as a targeted 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 

Page 58 
The RRB has two mission critical occupations (MCO): 2210 and 0993. Only 

two (2) individuals were hired in the 2210 MCO. We only know this from our 

accession report. We believe they are not shown on the AFD Table A7/B7 

because they omitted their demographics and did not provide their race, sex 

nor disability status on usajobs.gov. A total of eighteen (18) individuals were 

hired in the 0993 MCO. One (1) new employee (5%) said their disability was 

not listed (code 06) however,four (4) new employees (22%) did not want to 

disclose their disability (01). Together, that represents 27%. Since code 01 and 

code 06 does not tell us the nature of the disability, we can not make a well 

informed decision as to whether any new hire had a targeted 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 

A total of only twenty-six (26) internal applicants applied for promotion in the 

MCO 0993. A total of two (2) or 8% of the employees identified a disability and 

two (2) or 8% identified a targeted disability. A total of seven (7) or 27% 

applicants did not identify a disability and seventeen (17) or 65% stated they 

did not have a disability. There were eight (8) or 13% applicants selected and 

one applicant did not identify their disability, code (01). This may or may not be 

a trigger, but will continue to monitor the statistics. There were no internal 

applicants for MCO 2210. 

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 

For MCO 0993, nineteen (19) employees were promoted into 0993 positions. 

Of the nineteen (19) two (2) employees or 11% of the employees listed a 

disability and they were both targeted disabilities. There were seven (7) 

employees selected for promotion and they all cited having no disability. This 

may or may not trigger a barrier analysis because the selection is so small. We 

will continue to monitor the statistics. We also want to state that one of the 

employees with a disability withdrew her application. There were no promotions 

for MCO 2210. 

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 employees have advancement opportunities based on their knowledge, 

skills and abilities. Reasonable accommodations are provided to those in need 

but advancement is based on the individuals skills and abilities and not 

because they have a disability. 

B.  CAREER DEVELOPMENT OPPORTUNITES 

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

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All employees can complete an Individual Development Plan (IPD) to assist 

them in moving ahead in the agency. They share their plan with their 

supervisor and they set short term and long term goals as to what they would 

like to achieve at the RRB. We have online courses that they can take to help 

them with their goals. By writing it down and sharing it with supervisor, they are 

reminded of their goals and their supervisors are tasks with encouraging and 

assisting them reach their goals and/or positions they aspire to. 

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 

The RRB did not offer any other career development programs other than the 

IDP in 2020. As stated above, all employees are encouraged to participate in 

the IDP. There were 60 employees who participated in the IDP and eight (8) or 

13% reported having a disability. There were no employees who identified 

themselves as having a targeted disability. Out of the sixty (60) participants in 

the program seven (7) or 12% did not identify a disability, (code 01). And as 

always, all managers and supervisors took required supervisory/management 

training. 

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 

The RRB did not offer career development programs in FY2020. 

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 FY2020 the RRB issued fifty-seven (57) time-off awards and one 

hundred and thirty-eight (138) non performance based awards (includes 

suggestion awards, group awards, cash award not based on performance) 

totaling 196 awards. A total of twenty-six (26) employees (13%) listed a 

disability and three (3) or 2% listed a targeted disability. Again, I believe we 

should include the employees who did not identify their disability. A total of 

eleven (11) employees or 6% did not identify their disability. Added with the 26 

who listed their disability, we total 19%. 

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. 

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a. Pay Increases (PWD) Answer No 

b. Pay Increases (PWTD) Answer No 

During FY2020, a total of one hundred and forty-eight (148) employees 

received a quality step increase and five hundred and fourteen (514) 

employees received a performance based incentive award for a total of six 

hundred and sixty-two (662) employees. A total of ninety-five (95) or 14% of 

these employees listed a disability. Of the 662 employees, seven-teen (17) 

or3% listed a targeted disability. 

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 

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 

During FY2020, no employee was promoted into a SES position. A total of two 

(2) employees applied and qualified for a GS-15 position. Both reported no 

disability. There were twenty-nine (29) employees who applied for a GS-14 

position and ten (10) were qualified. Of those who qualified, four (4) applicants 

reported no disability; and six (6) employees (24%) did not identify their 

disability (code 06). There were four (4) applicants who applied for the GS-13 

positions, and all four reported having no disability. All four applicants qualified 

and one was selected. 

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 

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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 FY2020 there was one internal applicant who applied for a GS-14 

position who reported having a targeted disability (code 40). No other 

applicants reported a targeted 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 N/A 

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 No 

During FY2020, the RRB did not hire any new employees into a SES position. 

The RRB hired two (2) individuals for a GS-15 position (external posting). 

Neither one stated a disability. The RRB hired one (1) individuals for a GS-14 

position (external posting). The selectee reported no disability. The RRB hired 

one (1) individual for a GS-13 position (external posting). The selectee did not 

want to identify his disability. 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 N/A 

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 No 

During FY2020, the RRB did not hire any new employees into an SES position. 

The RRB hired two (2) individuals for a GS-15 position. Neither stated a 

disability. Therefore, there were no targeted disabilities The RRB hired one (1) 

individuals for a GS-14 position. The applicant flow data did not show any 

GS-14 data on new hires. The only data we had was the RRB accessions 

report where one new employee was hired. The selectee reported no disability. 

Therefore, there no targeted disabilities. And, the RRB hired one (1) individual 

for a GS-13 position. The selectee did not want to identify his disability. So we 

do not know if he had a targeted disability. Since the 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 N/A 

ii. Internal Selections (PWD) Answer N/A 

b.  Managers 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

c. Supervisors 

i. Qualified Internal Applicants (PWD) Answer No 

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ii. Internal Selections (PWD) Answer No 

During FY2020, no employee applied or was selected for a SES or Executive 

position. A total of thirty-seven (37) applied and twenty (20) qualified for a 

supervisory/management position at the GS-13 through GS-15 level. A total of 

three (3) applicants had a disability but only 1 applicant with a disability was 

qualified for the position. That disability was not listed (code 06). The Applicant 

Flow Data program could not separate the supervisors from the managers, 

therefore all management positions were included together under supervisors 

on the relevant A19 and B19 tables. 

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 

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 FY2020, no employee applied or was selected for an SES or Executive 

position. A total of thirty-seven (37) applied and twenty (20) qualified for a 

supervisory/management position at the GS-13 through GS-15 level. A total of 

three (3) applicants had a disability and two had a target disability. Both 

applicants with a targeted disability were rated not qualified. Therefore, no 

applicant with a targeted disability could be selected. 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 FY2020, one (1) external applicant was hired to fill a supervisory 

position. This applicant stated no disability. Most applicants either reported 

having no disability or did not identify the disability. These new hires are so 

small in number that we do not see this as a trigger. 

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, 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 

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To be model employer for persons with disabilities, agencies must have policies and programs in place to retain 

employees with disabilities. In this section, agencies should: (1) analyze workforce separation data to identify barriers 

retaining employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) 

provide information on the reasonable accommodation program and workplace assistance services. 

A.  VOLUNTARY AND INVOLUNTARY SEPARATIONS 

1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability into the competitive service after two years of 

satisfactory service (5 CFR § 213.3102(u)(6)(i))? If “no”, please explain why the agency did not convert all eligible Schedule A employees. 

Answer N/A 

The agency is restricted from using Schedule A. 

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and involuntary separations exceed that of persons without 

disabilities? If “yes”, describe the trigger below. 

a.Voluntary Separations (PWD) Answer No 

b.Involuntary Separations (PWD) Answer No 

During F2020, a total of eighty-nine (89) employees separated from the RRB. 

Two employees (2) were involuntary separated from the RRB. One employee 

(1) had no disability (code 05) and the other employee did not wish to identify 

their disability (code 01). No trigger with only 2 employees to analyze whether 

trigger exists. A total of eighty-seven (87) employees voluntarily separated from 

the RRB. Sixty-four employees (64) stated they had no disability. Three (3) 

employees did not wish to identify their disability (code 01), three employees 

(3) stated that their disability was not listed on the form and seventeen 

employees (17) or 20% stated they had a disability. 

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 FY2020, a total of eighty-nine employees separated from the RRB. Two 

employees (2) were involuntary separated from the RRB. One employee (1) 

had no disability (code 05) and the other employee did not wish to identify their 

disability (code 01). No trigger with only 2 employees to analyze whether 

trigger exists. Although one listed a disability but they did not want to say what 

it was, the sample is to small. A total of eighty-seven (87) employees voluntarily 

separated from the RRB. Sixty-four employees (64) stated they had no 

disability. Three (3) employees did not wish to identify their disability (code 01), 

three, employees (3) stated that their disability was not listed on the form and 

seventeen employees (17) stated they had a disability . Of the seventeen, a 

total of four (4) stated a targeted disability (5%). 

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. 

No trigger existed. 

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. 

https://www.rrb.gov/Resources/OfficeOfEqualOpportunity/Nondiscrimination. 

2. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ rights under the Architectural 

Barriers Act, including a description of how to file a complaint. 

https://www.rrb.gov/Policy#aba 

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. 

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The IT department is still in the process of revising/changing some of the RRB 

systems so that they are compatible with each other and pull data from each 

other so claims are paid quicker and more efficiently. These program updates 

will take a couple of years to complete. 

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.) 

The average time frame for processing initial requests was 23.5 work days. 

The lowest time was 8 workdays for an ergonomic desk and the longest time 

as 67 workdays for a sit/stand workdesk. All others were 30 work days or less. 

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. 

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. The RRB had 

eleven (11) requests for a reasonable accommodations and four of the 

requests involved a sit/stand desk. 

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. 

We included the PAS procedure in the Reasonable Accommodation Policy. 

During FY2020, no one requested PAS so no data is available on this. 

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 FY2020. 

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 

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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 FY2020. 

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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