Disability Employment: Further Action Needed to Oversee Efforts to Meet Federal Government Hiring Goals
Released: 2012-05-25T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: In July 2010, the president signed Executive Order 13548 committing the federal government to become a model employer of individuals with disabilities and assigned primary oversight responsibilities to OPM and Labor. According to OPM, the federal government is not on track to meet the goals of the executive order, which committed the federal government to hire 100,000 workers with disabilities over the next 5 years. GAO was asked to examine the efforts that (1) OPM and Labor have made in overseeing federal efforts to implement the executive order; and (2) selected agencies have taken to implement the executive order and to adopt leading practices for hiring and retaining employees with disabilities. To conduct this work, GAO reviewed relevant agency documents and interviewed appropriate agency officials. GAO conducted case studies at Education, SSA, VA, and OMB.

section_title: What GAO Found
paragraphs: The Office of Personnel Management (OPM) and the Department of Labor (Labor) have taken steps to implement the executive order and help agencies recruit, hire, and retain more employees with disabilities. OPM provided guidance to help agencies develop disability hiring plans and reviewed the 66 plans submitted. OPM identified deficiencies in most of the plans. For example, though 40 of 66 agencies included a process for increasing the use of a special hiring authority to increase the hiring of people with disabilities, 59 agencies did not meet all of OPM’s review criteria, and 32 agencies had not addressed plan deficiencies as of April 2012. In response to executive order reporting requirements, OPM officials said they had briefed the White House on issues related to implementation, but they did not provide information on deficiencies in all plans. While the order does not specify what information these reports should include beyond addressing progress, providing information on deficiencies would enable the White House to hold agencies accountable. OPM is still developing the mandatory training programs for officials on the employment of individuals with disabilities, as required by the executive order. Several elective training efforts exist to help agencies hire and retain employees with disabilities, but agency officials said that more information would help them better use available tools. To track and measure progress towards meeting the executive order’s goals, OPM relies on employees to voluntarily disclose a disability. Yet, agency officials, including OPM’s, are concerned about the quality of the data. For example, agency officials noted that people may not disclose their disability due to concerns about how the information may be used. Without quality data, agencies may be challenged to effectively implement and assess the impact of their disability hiring plans.

The Department of Education (Education), Social Security Administration (SSA), Office of Management and Budget (OMB), and Department of Veterans Affairs (VA) submitted disability hiring plans, and have taken steps to implement leading practices for increasing employment of individuals with disabilities, such as demonstrating top leadership commitment. The executive order provided SSA, VA, and Education an opportunity to further develop existing written plans. However, officials at these agencies cited funding constraints as a potential obstacle to hiring more employees with disabilities. In terms of leading practices, all four agencies have communicated their commitment to hiring and retaining individuals with disabilities and coordinated within or across other agencies to improve their recruitment and retention efforts. For example, each agency has a single point of contact to help ensure that employees with disabilities have access to information that is comparable to that provided to those without disabilities, and for overseeing activities related to hiring and retaining employees with disabilities. In addition, VA holds senior managers accountable for meeting hiring goals by including targets in their contracts. Each agency requires training for managers and supervisors on procedures for hiring individuals with disabilities, and VA further requires that all employees receive training on the legal rights of individuals with disabilities. Education, SSA, and VA rely on centralized funding accounts to pay for reasonable accommodations.

section_title: What GAO Recommends
paragraphs: GAO recommends that OPM: (1) incorporate information about plan deficiencies into its required regular reporting to the president on implementing the executive order and inform agencies about this process; (2) expedite the development of the mandatory training programs required by the executive order; and (3) assess the accuracy of the data used to measure progress toward the executive order’s goals and, if needed, explore options for improving its ability to measure the population of federal employees with disabilities, including strategies for encouraging employees to voluntarily disclose disability status. OPM agreed with GAO’s recommendations.

section_title: Letter
paragraphs: Section 501 of the Rehabilitation Act of 1973, as amended (Rehabilitation  Act), requires federal agencies to develop affirmative action program  plans for hiring, placement, and advancement of people with disabilities,  as well as to ensure employment nondiscrimination and reasonable  accommodation. To encourage the federal government to become a  model employer of individuals with disabilities through effective  recruitment, hiring, and retention efforts, Executive Order 13548 was  issued in July 2010. This executive order called for increasing the  number of individuals with disabilities in the federal government through  the hiring of 100,000 individuals with disabilities over the next 5 years and  through greater efforts to retain federal workers with disabilities, including  ensuring the return to work of individuals injured on the job. According to  draft data from the Office of Personnel Management (OPM), the  government is not on track to meet the goals of the executive order,  having hired approximately 20,000 employees with disabilities during  fiscal years 2010 and 2011; however, as discussed later in this report, we  were unable to verify these data.

Because of concerns about the federal government’s ability to meet the  goals set out by Executive Order 13548, you asked us to assess the  efforts that (1) OPM and the Department of Labor (Labor) have made in  overseeing the implementation of the executive order across the federal  government, and (2) selected agencies have taken to implement the  executive order and to adopt leading practices for hiring and retaining  employees with disabilities. To assess OPM and Labor’s oversight efforts,  we examined relevant documents from OPM and Labor, including OPM’s  guidance to federal agencies for implementing the executive order,  agency plans for hiring and employing people with disabilities, and OPM’s  review of these plans. We also interviewed key agency officials at OPM,  Labor, and other agencies cited in the executive order such as the Equal  Employment Opportunity Commission (EEOC) and the Office of  Management and Budget (OMB). We also interviewed advocates for  individuals with disabilities from the American Association of People with  Disabilities, the National Council on Disabilities, and the National  Disability Rights Network to obtain their opinions on the executive order.  To determine how selected agencies are implementing the executive  order and leading practices, we focused our review on four federal  agencies: (1) the Department of Education (Education), (2) the Social  Security Administration (SSA), (3) the Department of Veterans Affairs  (VA), and (4) OMB. We selected this nongeneralizable sample among  many agencies within the federal government to provide a cross section  for review. Education, SSA, and VA have programs with missions and  goals related to assisting people with disabilities and OMB is specifically  cited in the executive order. We developed and administered a structured  questionnaire, and conducted follow-up interviews with agency officials.  We also reviewed agency specific disability hiring plans and other  documents related to hiring, reasonable accommodation policies, and  strategic planning efforts to better understand their experiences with  hiring and retaining employees with disabilities.

We conducted this performance audit from January 2011 to May 2012 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Under the Rehabilitation Act, a person is considered to have a disability if  the individual has a physical or mental impairment that substantially limits  one or more major life activities. Existing federal efforts are intended to  promote the employment of individuals with disabilities in the federal  workforce and help agencies carry out their responsibilities under the  Rehabilitation Act. For example, federal statutes and regulations provide  special hiring authorities for people with disabilities. These include  Schedule A excepted service hiring authority—which permits the  noncompetitive appointment of qualified individuals with intellectual,  severe physical, or psychiatric disabilities without posting and publicizing  the position—and appointments and noncompetitive conversion for  veterans who are 30 percent or more disabled. To qualify for a Schedule  A appointment, an applicant must generally provide proof of disability and  a certification of job readiness. Proof of disability can come from a  number of sources, including a licensed medical professional, or a state  agency that issues or provides disability benefits. The proof of disability  document does not need to detail the applicant’s medical history or need  for an accommodation.

Executive Order 13548 committed the federal government to many of the  goals of an executive order issued a decade earlier, but went further by  requiring federal agencies to take certain actions. For example, Executive  Order 13548 requires federal agencies to develop plans for hiring and  retaining employees with disabilities and to designate a senior-level  official to be accountable for meeting the goals of the order and to  develop and implement the agency’s plan. In addition, OPM and Labor  have oversight responsibilities to ensure the successful implementation of  the executive order (see table 1).

For the purposes of determining agency progress in the employment of  people with disabilities and setting targeted goals, the federal government  tracks the number of individuals with disabilities in the workforce through  OPM’s Standard Form 256, Self-Disclosure of Disability (SF-256).  Federal employees voluntarily submit this form to disclose that they have  a disability, as defined by the Rehabilitation Act. For reporting purposes,  disabilities are separated into two major categories: Targeted and Other  Disabilities. Targeted disabilities, generally considered to be more severe,  include such conditions as total deafness, complete paralysis, and  psychiatric disabilities. Other disabilities include such conditions as partial  hearing or vision loss, gastrointestinal disorders, and learning disabilities.

Further, Labor is given responsibilities in the executive order to improve  efforts to help employees who sustain work-related injuries and illnesses  return to work. In July 2010, the Protecting Our Workers and Ensuring  Reemployment (POWER) Initiative was established, led by Labor. This  initiative aims to improve agency return-to-work outcomes by setting  performance targets, collecting and analyzing injury and illness data, and  prioritizing safety and health management programs that have proven  effective in the past.

5 U.S.C. §8101, et seq.

Workers’ Compensation Programs (OWCP) reviews FECA claims and  makes decisions on eligibility and payments.

We have completed a number of reviews that have identified steps that  agencies could take to provide equal employment opportunity to qualified  individuals with disabilities in the federal workforce. In July 2010, we held  a forum that identified barriers to the federal employment of people with  disabilities and leading practices to overcome these barriers. Participants said that the most significant barrier keeping people with  disabilities from the workplace is attitudinal and identified eight leading  practices that agencies could implement to help the federal government  become a model employer:  (1)  top leadership commitment;  (2)  accountability, including goals to help guide and sustain efforts;  (3)  regular surveying of the workforce on disability issues;  (4)  better coordination within and across agencies;  (5)  training for staff at all levels to disseminate leading practices  (6)  career development opportunities inclusive of people with  (7)  a flexible work environment; and  (8)  centralized funding at the agency level for reasonable  accommodations.

GAO, Highlights of a Forum: Participant-Identified Leading Practices that Could Increase  the Employment of Individuals with Disabilities in the Federal Workforce, GAO-11-81SP  (Washington, D.C.: Oct. 5, 2010).

section_title: OPM and Labor Have Taken Steps to Implement the Executive Order, but Further Action Is Needed to Meet Hiring Goals
subsections: section_title: OPM Helped Agencies Develop Plans to Employ More Individuals with Disabilities, Yet Many Plans Lacked Required Elements and Have Not Been Corrected
paragraphs: OPM, in consultation with EEOC, OMB, and Labor, issued a  memorandum in November 2010 to heads of executive departments and  agencies outlining the key requirements of the executive order and what  elements must be included in agency disability hiring plans. These  elements include listing the name of the senior-level official to be held  accountable for meeting the goals of the executive order and describing  how the agency will hire individuals with disabilities at all grade levels and  in various job occupations. The memorandum also described strategies  that agencies could take to become model employers of people with  disabilities, such as reviewing all recruitment materials to ensure  accessibility for people with disabilities. To help implement the strategies,  OPM contracted in December 2010 with a private firm to recruit and to  manage a list of Schedule A-certified individuals from which federal  agencies can hire.

OPM received 66 agency plans for promoting the employment of  individuals with disabilities, representing over 99 percent of the federal  civilian executive branch workforce. OPM officials reviewed all the plans, recording whether they met criteria developed by OPM based on  the executive order and its model strategies memorandum. OPM also  identified and informed agencies about innovative ideas included in plans.

In reviewing the plans, OPM found that many agency plans did not meet  one or more of its review criteria (see fig. 1). For example, OPM’s review  found that 29 of the 66 agency plans did not include numerical goals for  the hiring of people with disabilities. OPM also found that 9 of the 66  agency plans did not identify a senior-level official responsible for the  development and implementation of the plan. Finally, only 7 of the 66  plans met all of the criteria; over half of the plans met 8 or fewer of the 13  criteria. However, OPM expected agencies to begin implementing their  plans immediately, regardless of any unaddressed deficiencies.

Agencies met some criteria more successfully than others. For example,  OPM found that 40 of the 66 agency plans included a process for  increasing the use of Schedule A to increase the hiring of people with  disabilities. In contrast, 29 of the 66 agency plans provided for the  quarterly monitoring of the rate at which employees injured on the job  successfully return to work.

OPM provided agencies with written feedback on plan deficiencies and  strongly encouraged agencies to address them numerous times  beginning in June 2011. However, 32 out of the 59 agencies with  deficiencies in their plans had not addressed them as of April 2012.  Specifically, in June 2011, OPM provided agencies with access to  reviews of their plans, which identified deficiencies, through OMB’s Max  Information System (MAX). According to OPM, in July 2011, a White  House official told agency senior executives that they were required to  address deficiencies in their plans. In October and November 2011, OPM  provided agencies with a list of the deficiencies identified in their plans,  and asked agencies to determine how their plans could be improved. In  December 2011, OPM again told agencies they were strongly  encouraged to review and address plan deficiencies and provided  agencies with several examples of plans that met all of the criteria.

Though the executive order does not specifically authorize OPM to  require agencies to address plan deficiencies, it calls for OPM to regularly  report on agencies’ progress in implementing their plans to the White  House and others. In response to the executive order’s reporting  requirement, OPM officials told us that they had briefed White House  officials on issues related to agencies’ implementation of the executive  order, but did not provide information on the deficiencies in all of the  agency plans. In addition, OPM does not think that the federal  government is on target to achieve the goals set in the executive order.  While the executive order did not provide additional detail as to what  information should be reported, providing information on the extent to  which agencies’ plans have met OPM’s criteria would better enable the  White House to hold agencies accountable for addressing plan  deficiencies.

section_title: OPM Has Yet to Fully Develop the Required Mandatory Training Programs
paragraphs: In addition to reviewing agency plans, the executive order required OPM  to develop mandatory training programs on the employment of people  with disabilities for both human resources personnel and hiring managers,  within 60 days of the executive order date. We have previously reported  that training at all staff levels, in particular training on hiring, reasonable  accommodations, and diversity awareness, can help disseminate leading  practices throughout an agency and communicate expectations for  implementation of policies and procedures related to improving  employment of people with disabilities. Such policies and procedures  could be communicated across the federal government with training on  topics such as how to access and efficiently use the list of Schedule A- certified individuals, the availability of internships and fellowships, such as  Labor’s Workforce Recruitment Program, and online communities of  practice established to help officials share best practices on hiring people  with disabilities, such as eFedlink.

In its November 2010 model strategies memorandum to heads of  executive agencies, OPM stated that, in consultation with Labor, EEOC,  and OMB, it was developing the mandatory training programs required by  the executive order and that further information would be forthcoming.  OPM officials told us in March 2012 that they are working with federal  Chief Human Capital Officers (CHCO) to develop modules on topics such  as using special hiring authority that will be available through HR  University. Officials explained that they need to ensure that the training is uniform to ensure all personnel receive consistent information, and they  expect the training modules to be ready by August 2012.

Although it has yet to fully develop mandatory training programs, OPM  has taken steps to train and inform federal officials about tools available  to them. For example, OPM partnered with Labor, EEOC, and other  agencies to provide elective training courses for federal officials involved  in implementing the executive order on topics including: the executive  order, model recruitment strategies, guidance on developing disability  hiring plans, and return-to-work strategies. OPM also conducted training  on implementation of the executive order in July 2011 specifically for  senior executives accountable for their agencies’ plans. It also offers  short online videos for hiring managers on topics such as Schedule A  hiring authority. Further, other governmentwide training on employing  people with disabilities exists. For example, Labor’s Job Accommodation  Network offers online training on relevant issues like applying the  Americans with Disabilities Amendments Act and providing reasonable  accommodations. Moreover, the Department of Defense’s  Computer/Electronic Accommodations Program offers online training  modules to help federal employees understand the benefits of hiring  people with disabilities.

Nevertheless, agency officials we interviewed told us that they would like  to have more comprehensive training on strategies for hiring and retaining  individuals with disabilities, confirming the need for OPM to complete the  development of the training programs required by the executive order. For  example, officials from one agency said that more training on the  relationship between return-to-work efforts and providing reasonable  accommodations is needed, while officials from another agency identified  a need for increased awareness of the Schedule A hiring process.

section_title: OPM Tracks the Hiring of People with Disabilities, but Concerns about Data Quality Exist
paragraphs: Executive Order 13548 requires OPM to implement a system for reporting  regularly to the president, heads of agencies, and the public on agencies’  progress in implementing the objectives of the executive order. OPM is  also to compile, and post on its website, governmentwide statistics on the  hiring of individuals with disabilities. This is important because effectively  measuring workforce demographics requires reliable data to inform  decisions and to allow for individual and agencywide accountability.

To measure and assess their progress towards achieving the goals of the  executive order, agencies and OPM use data about disability status that  employees voluntarily self-report on the SF-256. OPM’s guidance to  agencies for implementing the executive order explained that the data  gathered from the SF-256 is crucial for agencies to determine whether  they are achieving their disability hiring goals. Agencies also report these  data to EEOC in an effort to identify and develop strategies to eliminate  potential barriers to equal employment opportunities. According to the  form, the data are used to develop reports to bring to light agency specific  or governmentwide deficiencies in the hiring, placement, and  advancement of individuals with disabilities. The information is  confidential and cannot be used to affect an employee in any way. Only  staff who record the data in an agency’s or OPM’s personnel systems  have access to the information. According to draft data from OPM, as  stated earlier, the government hired approximately 20,000 employees  with disabilities during fiscal years 2010 and 2011.

However, according to officials at OPM, EEOC, VA, Education, and SSA,  accurately measuring the number of current and newly hired employees  with disabilities is an ongoing challenge. While the accuracy of the SF- 256 data is unknown, agency officials and advocates for people with  disabilities believe there is an undercount of employees with disabilities.  For example, despite the safeguards in place explaining the  confidentiality of the data, agency officials and advocates for people with  disabilities told us that some individuals with disabilities may not disclose  their disability status out of concern that they will be subjected to  discrimination. Similarly, EEOC reported that some persons with  disabilities are reluctant to self-identify because they are concerned that  such disclosure will preclude them from advancement.

Additionally, some individuals may develop disabilities during federal  employment and may not know how to or why they should update their  disability status. We have reported that regularly encouraging employees  to update their disability status allows agencies to be aware of any  changes in their workforce. EEOC guidance recommends that agencies  request that employees update their disability status every 2 to 4 years.

As previously noted, disabled veterans with a compensable service-connected disability  of 30 percent or more may be noncompetitively appointed and converted to a career  appointment under 5 U.S.C. § 3112. agency’s ability to establish appropriate policies and goals, and assess  progress towards those goals.

section_title: Labor Has Taken Steps to Develop Return-to-Work Strategies
paragraphs: Labor has taken several steps toward meeting the requirements of the  executive order to improve return-to-work outcomes for employees  injured on the job, including pursuing overall reform of the FECA system.  Specifically, Labor developed new measures and targets to hold federal  agencies accountable for improving their return-to-work outcomes within  a 2-year period. Agencies were expected to improve return-to-work  outcomes by 1 percent for fiscal year 2011 and an additional 2 percent in  each of the following 3 years over the 2009 baseline. In fiscal year 2011,  the federal government had a cumulative return-to-work rate of 91.6  percent, almost 5 percent better than the target rate of 86.7 percent.  Goals such as these are useful tools to help agencies improve  performance. Labor is also researching strategies that agencies can use  to increase the successful return-to-work of employees who have  sustained disabilities as a result of workplace injuries or illnesses. The  results of this study are expected to be released in September 2012.

Another Labor initiative is aimed at helping the federal government rehire  injured federal workers who are not able to return to the job at which they  were injured. OWCP initiated a 6-month pilot project in May 2011 to  explore how Schedule A noncompetitive hiring authority might be used to  rehire injured federal workers under FECA. As part of the project, OWCP  provided guidance to claims staff, rehabilitation specialists, rehabilitation  counselors, and employing agencies on the process of Schedule A  certification and the steps it will take to facilitate Schedule A placements.  According to Labor, the pilot identified obstacles to reemployment and  provided input needed to determine whether such an effort can be  expanded to other federal agencies. Identified obstacles included  unanticipated questions from potential workers, such as if acceptance of  a Schedule A designation would require a “probationary” period, and what  impact acceptance of a Schedule A position would have on their  retirement benefits. Of the 48 individuals Labor screened for Schedule A  certification, 45 obtained certification, of whom 5 have been placed into  federal employment.

section_title: Selected Agencies Have Plans in Place to Hire and Retain Employees with Disabilities and Have Adopted Many Leading Practices
subsections: section_title: Agencies Are Implementing Plans to Improve Hiring and Retention of Employees with Disabilities
paragraphs: Each of the four agencies we reviewed submitted a plan for implementing  the executive order as required. Only VA’s plan, as initially submitted, met  all of OPM’s criteria for satisfying the requirements of the executive order  (see table 2). Education and SSA revised their plans based on feedback  from OPM. Specifically, Education’s revised plan states that Education  will hire individuals with disabilities in all occupations and across all job  series and grades. Education also clarified its commitment to coordinate  with Labor to improve return-to-work outcomes through the POWER  Initiative, and to engage and train managers on Schedule A hiring  authority. Further, Education increased its goals for the percentage of job  opportunity announcements that include information related to individuals  with disabilities. SSA revised its plan to include goals and planned  activities under the POWER Initiative, including quarterly monitoring of  return-to-work successes under the program and a strategy for identifying  injured employees who would benefit from reasonable accommodations  and reassignment. OMB submitted its plan in March 2012 but, according  to OMB officials, the agency has not received feedback from OPM.

Agencies had positive views about the executive order’s requirement that  they develop written plans to increase the number of federal employees  with disabilities. In particular, Education, SSA, and VA said that the  executive order provided an opportunity to further develop the written  plans they already had in place for hiring and retaining employees with  disabilities.

Agencies were supportive of the goal of increasing the hiring and  retention of federal employees with disabilities, and reported few  challenges in implementing their plans to achieve this goal. Officials at all  of the agencies we interviewed cited funding constraints as a potential  obstacle to hiring more employees with disabilities. OMB officials also  said that it was a challenge to identify individuals with the right skills and  experience to fill their positions. For example, officials said that many of  the candidates on OPM’s list of Schedule A-certified individuals have  entry level skills and not the more advanced skills and experience that are  required for positions at OMB. Agency officials cited no special  challenges with respect to retaining employees with disabilities at their  agencies.

section_title: Agencies Have Taken Steps to Implement Leading Practices for Increasing Employment of Individuals with Disabilities
paragraphs: In October 2010, we reported on eight leading practices that could help  the federal government become a model employer for individuals with  disabilities. These practices, which are consistent with the executive  order’s goal of increasing the number of individuals with disabilities in the  federal government, have been implemented to varying degrees by the  four agencies we contacted for this review.

Top leadership commitment: Involvement of top agency leadership is  necessary to overcome the resistance to change that agencies could face  when trying to address attitudinal barriers to hiring individuals with  disabilities. When leaders communicate their commitment throughout the  organization, they send a clear message about the seriousness and  business relevance of diversity management. Leaders at the agencies we  talked with have, to varying degrees, communicated their commitment to  hiring and retaining individuals with disabilities to their employees.  Education has issued annual policy statements to its employees ensuring  equal employment opportunity for all applicants and employees, including  those with targeted disabilities, and officials told us that they routinely  host events that address issues related to hiring and promoting equal  employment opportunity. For example, in October 2008, Education  hosted an event to encourage hiring individuals with disabilities and  distributed a written guide about using Schedule A hiring authority to  facilitate hiring individuals with targeted or severe disabilities, as well as  disabled veterans. OMB officials said that it is briefing managers on the  requirements of the executive order and that it planned to communicate  the agency’s commitment to implementing the executive order to all staff  in May 2012. SSA’s Commissioner announced his support for employing  individuals with disabilities and encouraged employees to continue efforts  to hire and promote these individuals in a March 2009 broadcast to all  employees. VA said that the Secretary regularly communicates his  commitment to hiring and retaining employees with disabilities through  memorandums to all employees. In a September 2010 memorandum, the  Secretary announced the agency’s goal of increasing the percentage of  individuals with targeted disabilities that it hires and employs to 2 percent  in fiscal year 2011.

Accountability: Accountability is critical to ensuring the success of an  agency’s efforts to implement leading practices and improve the  employment of individuals with disabilities. To ensure accountability,  agencies should set goals, determine measures to assess progress  toward goals, evaluate staff and agency success in helping meet goals,  and report results publicly. Education, SSA and VA’s disability hiring  plans all include goals that will allow them to measure their progress  toward meeting the goals of the executive order. Prior to the executive  order, Education issued a Disability Employment Program Strategic Plan  for fiscal years 2011-2013 that established goals related to reasonable  accommodations, and recruitment and retention, and offered strategies  for meeting these goals, as well as ways to track and measure agency  progress. At SSA, accountability for results related to the executive order  is included in the performance plan of the senior-level official responsible  for implementing it. VA specifically holds senior executives accountable  for meeting agency numerical goals by including these goals in their  contracts. Additionally, VA senior executives’ contracts include a  performance element for meeting hiring goals for individuals with targeted  disabilities. OMB has not yet developed such goals.

Regular surveying of the workforce on disability issues: Regularly  surveying their workforces allows agencies to have more information  about potential barriers to employment for people with disabilities, the  effectiveness of their reasonable accommodation practices, and the  extent to which employees with disabilities find the work environment  friendly. To collect this information, agencies should survey their  workforces at all stages of their employment, including asking employees  to complete the SF-256 when they are hired, and asking relevant  questions on employee feedback surveys and in exit interviews. VA  officials said that they encourage new employees to complete the SF- 256, and SSA reminds all employees to annually review their human  resource records and update or correct information, including disability  data. In addition, all of the agencies we contacted survey employees to  solicit feedback on a range of topics. However, only SSA and VA include  a question on disability status or reasonable accommodations on these  surveys. In addition, Education and SSA said that they routinely conduct  exit surveys to solicit information from employees who separate from  service about their reasons for leaving. While VA has an exit survey,  officials said it is not consistently administered to all employees who  separate. Education officials said that they have additional means of  obtaining information about barriers for employees with disabilities. For  example, senior managers hold open forums with staff, and employees  can submit feedback to management through the agency’s Intranet.  Education officials also reported that employees with disabilities have  formed their own group to address access to assistive technology, which  has helped Education to obtain improved technology, such as  videophones. OMB officials said that their Diversity Council and  Personnel Advisory Board provide forums for employees to discuss  diversity issues, including those related to disabilities, and share them  with senior leadership.

Better coordination of roles and responsibilities: Often the  responsibilities related to employment of people with disabilities are  dispersed, which can create barriers to hiring if agency staff defer taking  action, thinking that it is someone else’s responsibility. Coordination  across agencies can encourage agencies with special expertise in  addressing employment obstacles for individuals with disabilities to share  their knowledge with agencies that have not yet developed this expertise.  All of the agencies we interviewed had, to some extent, coordinated  within and across agencies to improve their recruitment and retention  efforts. Specifically, each agency has a designated section 508  coordinator who assists the agency in ensuring that, as required by  section 508 of the Rehabilitation Act, employees with disabilities have  access to information and data that are comparable to that provided to  those without disabilities. In addition, each agency has a single office or  primary point of contact that is responsible for overseeing activities  related to hiring and retaining employees with disabilities.

Officials at all of the agencies we talked to said their agencies engaged in  one or more interagency efforts to address disability issues. All of these  agencies participate in the CHCO Council, which facilitates sharing of  best practices and challenges related to human capital issues, including  those related to employees with disabilities. In addition, Education, OMB  and SSA officials said that they work with state vocational rehabilitation  agencies, which can help them identify accommodations that may be  needed for new hires with disabilities. Education and SSA also participate  in the Federal Disability Workforce Consortium, an interagency  partnership working to improve recruitment, hiring, retention, and  advancement of individuals with disabilities by sharing information on  disability employment issues across government. SSA and VA have also  participated in the Workforce Recruitment Program for College Students   VA and Education have also worked together to assist  with Disabilities; disabled veterans by providing unpaid work experience at Education,  which may lead to permanent employment.

Managed by Labor’s Office of Disability Employment Policy and the Department of  Defense’s Office of Diversity Management and Equal Opportunity, this program is a  recruitment and referral effort that connects federal sector employers nationwide with  highly motivated college students and recent graduates with disabilities. said that the site is useful for seeing what other agencies are doing, and  that they have also shared their own practices on the site.

Training for staff at all levels: Agencies can leverage training to  communicate expectations about implementation of policies and  procedures related to improving employment of people with disabilities,  and help disseminate leading practices that can help improve outcomes.  All of the selected agencies provide some training for staff at all levels on  the importance of workforce diversity. They also require managers and  supervisors to take training on hiring procedures related to individuals  with disabilities, and the use of Schedule A hiring authority. In addition,  VA requires employees at all levels to take training specifically devoted to  the legal rights of individuals with disabilities. At Education, this training is  required for managers and supervisors, while at SSA it is available but  optional for all employees.

Career development opportunities: Opportunities for employees with  disabilities to participate in work details, rotational assignments, and  mentoring programs can lead to increased retention and improved  employee satisfaction, and improve employment outcomes by helping  managers identify employees with high potential. All of the agencies we  interviewed provided special work details or rotational assignments for all  employees; one reported having a program exclusively for those with  disabilities. Specifically, Education uses Project SEARCH to provide  internships for students with disabilities to help them become ready to  work through on-the-job training. Education officials reported that some of  these internships have led to permanent employment at Education.

A flexible work environment: Flexible work schedules, telework, and  other types of reasonable accommodations are valuable tools for the  recruitment and retention of employees, regardless of disability status.  Such arrangements can make it easier for employees with health  impairments to successfully function in the work environment or facilitate  an injured employee’s return to work. All of the agencies we interviewed  provide flexible work arrangements, including flexible work schedules and  teleworking. These agencies also make assistive technologies, such as  screen reader software, available for employees with disabilities, which  can facilitate their ability to take advantage of flexible work arrangements.  Education, OMB, and SSA also offer all employees opportunities for job  sharing.

Centralized funding for reasonable accommodations: Having a  central budget at the highest level of the agency can help ensure that  employees with disabilities have access to reasonable accommodations  by removing these expenses from local operational budgets and thus  reducing managers’ concerns about their costs. Education, SSA, and VA  use centralized funding accounts to pay for reasonable accommodations  for employees with disabilities. At Education, a centralized fund is usually  used to cover expenses related to providing readers, interpreters, and  personal attendants. However, in cases where these services are needed  on a daily basis, Education may require the operating unit to hire  someone full-time and pay for this from their unit budget. OMB provides  funding from its own budget to pay for reasonable accommodations,  rather than receiving funding from the Executive Office of the President.  OMB officials also told us that they also have been able to rely on the  Department of Defense’s Computer/Electronic Accommodations Program  to help provide reasonable accommodations for some of the employees.  This program facilitates access to assistive technology and services to  people with disabilities, federal managers, supervisors, and information  technology professionals by providing a single point of access for  executive branch agencies.

section_title: Conclusions
paragraphs: As the nation’s largest employer, the federal government has the  opportunity to be a model for the employment of people with disabilities.  Consistent with the July 2010 executive order, OPM, Labor, and other  agencies have helped provide the framework for federal agencies to take  proactive steps to improve the hiring and retention of persons with  disabilities.

However, nearly 2 years after the executive order was signed, the federal  government is not on track to achieve the executive order’s goals.  Although federal agencies have taken the first step by submitting action  plans to OPM for review, many agency plans do not meet the criteria  identified by OPM as essential to becoming a model employer of people  with disabilities. Though the executive order does not specifically  authorize OPM to require agencies to address deficiencies, regularly  reporting to the president and others on agency progress in addressing  these deficiencies may compel agencies to address them and better  position the federal government to reach the goals of the executive order.

Further, officials responsible for hiring at federal agencies need to acquire  the necessary knowledge and skills to proactively recruit, hire, and retain  individuals with disabilities. Agency officials we spoke with said more  comprehensive training on the tools available to them, including the  requirements of Schedule A hiring authority, is needed. While the  mandatory training program remains in development, until it is fully  developed and communicated to agencies, opportunities to better inform  relevant agency officials on how to increase the employment of  individuals with disabilities may be missed.

Finally, concerns have been raised by stakeholders, including EEOC,  OPM, and advocates for people with disabilities, about the reliability of  government statistics on the number of individuals with disabilities in the  federal government. Most of the concerns focus on the likelihood of  underreporting given the reliance on voluntary disclosure, but the extent  of the underreporting is unknown. Unreliable data hinder OPM’s ability to  measure the population of federal workers with disabilities and may  prevent the federal government from developing needed policies and  procedures that support efforts to become a model employer of people  with disabilities. Determining the accuracy of SF-256 data, for example,  by examining the extent to which employees voluntarily disclose their  disability status and reasons for nondisclosure, is an essential step for  ensuring that OPM can measure progress towards the executive order’s  goals.

section_title: Recommendations for Executive Action
paragraphs: To ensure that the federal government is well positioned to become a  model employer of individuals with disabilities, we recommend that the  Director of OPM take the following three actions:  1.  Incorporate information about plan deficiencies into its regular  reporting to the president on agencies’ progress in implementing their  plans, and inform agencies about this process to better ensure that  the plan deficiencies are addressed.  2.  Expedite the development of the mandatory training programs for  hiring managers and human resource personnel on the employment  of individuals with disabilities, as required by the executive order.  3.  Assess the extent to which the SF-256 accurately measures progress  toward the executive order’s goal and explore options for improving  the accuracy of SF-256 reporting, if needed, including strategies for  encouraging employees to voluntarily disclose their disability status.  Any such strategies must comply with legal standards governing  disability-related inquiries, including ensuring that employee rights to  voluntarily disclose a disability are not infringed upon.

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to Education, EEOC, Labor, OMB,  OPM, SSA, and VA for review and comment. In written comments, OPM  agreed with findings and recommendations identified in the report, and  described actions being implemented in an effort to address them. To  better ensure agencies address deficiencies identified in their disability  hiring plans, OPM has begun notifying agencies that it plans to report  remaining deficiencies to the president and on the OPM website by  August 2012. With regard to the need to expedite the development of the  mandatory training program, OPM, in coordination with partner agencies  has identified training for hiring managers and supervisors, and Human  Resource personnel. Finally, OPM stated that it is engaged in discussions  with the White House and stakeholder agencies to better define questions  on the SF-256 to increase response rates. OPM also said it plans to work  with EEOC and Labor to develop guidance for agencies to encourage  voluntary self-disclosure through annual re-surveying of the workforce  and providing employees with the option to complete the SF-256 when  they request a reasonable accommodation. OPM expects to complete  these efforts by January 2013. While these actions may help improve the  accuracy of the SF-256 data, we think taking steps to assess the  accuracy of the data will enhance OPM’s efforts. For example,  understanding the extent to which employees do not voluntarily self- disclose their disability status and the reasons why may help target the  messages agencies can use to encourage voluntary self-disclosure.  Without such an understanding, OPM and agencies may miss  opportunities to increase the accuracy of the data collected on the SF- 256.

Education, EEOC, OMB, OPM, and SSA provided technical comments,  which have been incorporated into the report as appropriate. Labor and  VA had no comments.

We are sending copies of this report to Education, EEOC, Labor, OMB,  OPM, SSA, and VA and to the appropriate congressional committees and  other interested parties. In addition, the report will be available at no  charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  Yvonne Jones at (202) 512-2717 or JonesY@gao.gov, or Daniel Bertoni  at (202) 512-7215 or BertoniD@gao.gov. Contact information for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Key contributors to this report are listed in  appendix II.

section_title: Appendix I: Comments from the Office of Personnel Management

section_title: Appendix II: GAO Contacts and Staff Acknowledgments
subsections: section_title: Contacts
paragraphs: Daniel Bertoni, (202) 512-7215, bertonid@gao.gov.   Yvonne D. Jones, (202) 512-2717, jonesy@gao.gov.

section_title: Acknowledgments
paragraphs: In addition to the contacts named above, Neil Pinney, Assistant Director;  Debra Prescott, Assistant Director; Charlesetta Bailey; Benjamin  Crawford; Catherine Croake; Karin Fangman; David Forgosh; Robert  Gebhart; Michele Grgich; Amy Radovich; Terry Richardson; and Regina  Santucci made key contributions to this report.

section_title: Related GAO Products
paragraphs: Federal Employees’ Compensation Act: Preliminary Observations on  Fraud-Prevention Controls. GAO-12-402. Washington, D.C.: January 25,  2012.

Coast Guard: Continued Improvements Needed to Address Potential  Barriers to Equal Employment Opportunity. GAO-12-135. Washington,  D.C.: December 6, 2011.

Federal Workforce: Practices to Increase the Employment of Individuals  with Disabilities. GAO-11-351T. Washington, D.C.: February 16, 2011.

Highlights of a Forum: Participant-Identified Leading Practices That Could  Increase the Employment of Individuals with Disabilities in the Federal  Workforce. GAO-11-81SP. Washington, D.C.: October 5, 2010.

Highlights of a Forum: Actions that Could Increase Work Participation for  Adults with Disabilities. GAO-10-812SP. Washington, D.C.: July 29, 2010.

Federal Disability Programs: Coordination Could Facilitate Better Data  Collection to Assess the Status of People with Disabilities. GAO-08-872T.  Washington, D.C.: June 4, 2008.

Federal Disability Programs: More Strategic Coordination Could Help  Overcome Challenges to Needed Transformation. GAO-08-635.  Washington, D.C.: May 20, 2008.

Highlights of a Forum: Modernizing Federal Disability Policy.  GAO-07-934SP. Washington, D.C.: August 3, 2007.

Equal Employment Opportunity: Improved Coordination Needed between  EEOC and OPM in Leading Federal Workplace EEO. GAO-06-214.  Washington, D.C.: June 16, 2006.

Results-Oriented Government: Practices That Can Help Enhance and  Sustain Collaboration among Federal Agencies. GAO-06-15. Washington,  D.C.: October 21, 2005.


Question-summary annotations: questions: question: How has the executive order propelled agencies to help employees with disabilities?
answer: The Office of Personnel Management (OPM) and the Department of Labor (Labor) have taken steps to implement the executive order and help agencies recruit, hire, and retain more employees with disabilities.

question: How has the OPM operated to address disability hiring?
answer: OPM provided guidance to help agencies develop disability hiring plans and reviewed the 66 plans submitted.
child_questions: question: How has the OPM identified problems in plans to address disability hiring?
answer: For example, though 40 of 66 agencies included a process for increasing the use of a special hiring authority to increase the hiring of people with disabilities, 59 agencies did not meet all of OPM’s review criteria, and 32 agencies had not addressed plan deficiencies as of April 2012.

question: How has the OPM worked with the White House to address flaws in the plans to address disability hiring?
answer: In response to executive order reporting requirements, OPM officials said they had briefed the White House on issues related to implementation, but they did not provide information on deficiencies in all plans.
child_questions: question: Why would providing information on deficiencies be beneficial for the White House?
answer: While the order does not specify what information these reports should include beyond addressing progress, providing information on deficiencies would enable the White House to hold agencies accountable.

question: What is OPM still developing in terms of its mandatory training programs?
answer: OPM is still developing the mandatory training programs for officials on the employment of individuals with disabilities, as required by the executive order.
child_questions: question: What did agency officials say would be helpful in their efforts?
answer: Several elective training efforts exist to help agencies hire and retain employees with disabilities, but agency officials said that more information would help them better use available tools.

question: How does OPM rely on employees as it is working to track and measure progress towards meeting the executive order’s goals?
answer: To track and measure progress towards meeting the executive order’s goals, OPM relies on employees to voluntarily disclose a disability.
child_questions: question: What are the concerns with needing voluntary disclosure?
answer: Yet, agency officials, including OPM’s, are concerned about the quality of the data. For example, agency officials noted that people may not disclose their disability due to concerns about how the information may be used. Without quality data, agencies may be challenged to effectively implement and assess the impact of their disability hiring plans.

questions: question: How have federal agencies addressed individuals with disabilities?
answer: The Department of Education (Education), Social Security Administration (SSA), Office of Management and Budget (OMB), and Department of Veterans Affairs (VA) submitted disability hiring plans, and have taken steps to implement leading practices for increasing employment of individuals with disabilities, such as demonstrating top leadership commitment.
child_questions: question: What roadblocks hinder agencies plans for individuals with disabilities?
answer: However, officials at these agencies cited funding constraints as a potential obstacle to hiring more employees with disabilities.

question: How have the agencies vocalized their plans for individuals with disabilities?
answer: In terms of leading practices, all four agencies have communicated their commitment to hiring and retaining individuals with disabilities and coordinated within or across other agencies to improve their recruitment and retention efforts.
child_questions: question: What does each agency have to ensure accessible information for employees with disabilities?
answer: For example, each agency has a single point of contact to help ensure that employees with disabilities have access to information that is comparable to that provided to those without disabilities, and for overseeing activities related to hiring and retaining employees with disabilities.

question: What does VA hold senior managers accountable for?
answer: In addition, VA holds senior managers accountable for meeting hiring goals by including targets in their contracts.

question: How has the federal government supported federal agencies concerning individuals with disabilities?
answer: The executive order provided SSA, VA, and Education an opportunity to further develop existing written plans.

question: What sort of training does each agency require?
answer: Each agency requires training for managers and supervisors on procedures for hiring individuals with disabilities, and VA further requires that all employees receive training on the legal rights of individuals with disabilities.

question: For what do centralized funding accounts pay?
answer: Education, SSA, and VA rely on centralized funding accounts to pay for reasonable accommodations.

questions: question: How did the federal government stance on employees with disabilities change in July 2010?
answer: In July 2010, the president signed Executive Order 13548 committing the federal government to become a model employer of individuals with disabilities and assigned primary oversight responsibilities to OPM and Labor.

question: What is the OPM's critique on the federal government and the executive order?
answer: According to OPM, the federal government is not on track to meet the goals of the executive order, which committed the federal government to hire 100,000 workers with disabilities over the next 5 years.

question: How is the GAO asked to evaluate the implementation of the executive order?
answer: GAO was asked to examine the efforts that (1) OPM and Labor have made in overseeing federal efforts to implement the executive order; and (2) selected agencies have taken to implement the executive order and to adopt leading practices for hiring and retaining employees with disabilities.
child_questions: question: How is the GAO carrying out its evaluation of the implementation of the executive order?
answer: To conduct this work, GAO reviewed relevant agency documents and interviewed appropriate agency officials. GAO conducted case studies at Education, SSA, VA, and OMB.