MD-715 – Part J · 2019-10-22 · EEOC FORM U.S. Equal Employment Opportunity Commission ALCOHOL...

EEOC FORM

U.S. Equal Employment Opportunity Commission

ALCOHOL AND TOBACCO TAX AND TRADE BUREAU (TTB)

ANNUAL EEO PROGRAM STATUS REPORT (FY 2018)

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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 plan will improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities. All agencies, regardless of size, must complete this Part of the MD-715 report. (According to EEOC, the goal is measured only including permanent, non-Seasonal employees. This primarily effects IRS and Treasury’s overall analysis. Previously, Treasury indicated that since we have resurveyed our workforce using the revised SF-256, those employees who select I do not wish to disclose my disability or sever health condition (01 Code) should be included in the overall disability count/percentage. However, EEOC now states that is on hold until further notice.)

Section I: Efforts to Reach Regulatory Goals EEOC regulations (29 C.F.R. § 1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation of persons with reportable and targeted disabilities in the federal government.

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving 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) Yes 0 No X b. Cluster GS-11 to SES (PWD) Yes 0 No X

Only if the answer is “yes”, provide a brief comment (in the below box) describing the triggers noted above. New/Old data table B4-1 from Workforce Analytics (WA).

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) Yes X No 0 b. Cluster GS-11 to SES (PWTD) Yes 0 No X

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Only if the answer is “yes”, provide a brief comment (in the below box) describing the triggers noted above. New/Old data table B4-1 from WA. • The percentage of PWTD in the GS-1 to GS-10 cluster was 0% in FY18, which falls below

the federal goal of 2%.

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

• TTB conducts biennial training for its workforce, including hiring managers/supervisors, in EEO, Diversity & Inclusion. Training includes workforce diversity (e.g., PWD/PWTDs, veterans/disabled veterans).

• TTB requests that the Treasury’s Office of Civil Rights and Diversity (OCRD) conduct training on special hiring authorities. For example, OCRD conducted a presentation entitled “Recruiting and Employing Persons with Disabilities and Veterans” for TTB hiring managers and supervisors. It included “Be a Champion” video, provided information on the benefits of hiring under the special hiring authorities for veterans and people with disabilities,

• TTB conducts state of the agency briefings to senior leaders on the Bureau’s progress of establishing/maintaining a model EEO program, which includes discussions of the Bureau’s progress of meeting the hiring and on-board goals for PWD/PWTD and veterans/disabled veterans.

• TTB provides ad hoc, informal, refresher training to managers and supervisors on the Bureau’s workforce participation rates of veterans/disabled veterans; special hiring authorities, including Schedule A, 30% or More Disabled Veteran, and Veterans Recruitment Appointment (VRA).

• TTB periodically provides managers/supervisors updates of the hiring numerical goals for PWD/PWTD and veterans/disabled veterans.

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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.

Yes X No 0

Only if the answer is “no”, provide a brief comment (in the below box) describing the plan to improve staffing.

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2. Identify all staff responsible for implementing the agency’s disability employment program by the office, staff employment status, and responsible official. (Should include the number of all personnel, to include those who are assigned to support the bureau via FS ARC.)

Disability Program Task

# of FTE Staff by Employment Status Responsible Official

(Name, Title, Office, Email) Full Time

Part Time

Collateral Duty

Processing applications from PWD and PWTD

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2 HR Specialists from BFS ARC are assigned to support TTB in processing applications for regular & special hiring authorities; no specific staff member is assigned to process only PWD/PWTD applications. TTB’s HR Director provides oversight of BFS: Name: Harinder Jaiswal Title: HR Director Office: Human Resources Division Email: [email protected]

Answering questions from the public about hiring authorities that take disability into account

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2 HR Specialists from BFS are assigned to support TTB in answering questions about hiring authorities. TTB’s HR Director provides oversight of BFS: Name: Harinder Jaiswal Title: HR Director Office: Human Resources Division Email: [email protected]

Processing reasonable accommodation requests from applicants and employees

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Harinder Jaiswal, TTB HR Director [email protected]

mailto:[email protected]



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Ryan Collins, BFS HR Specialist [email protected] Greg Friedland, TTB Office of the Chief Counsel [email protected] Tram-Tiara Ngo, TTB EEO Director [email protected]

Section 508 Compliance

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Tram-Tiara Ngo, EEO Director [email protected] Cassandra Williams, Special Emphasis Program Manager for Persons with Disabilities Employment Program & Veterans Employment Program [email protected]

Architectural Barriers Act Compliance

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Patrick Waller Director, Acquisition and Facilities Management Division [email protected]

Special Emphasis Program for PWD and PWTD

1 Cassandra Williams, Special Emphasis Program Manager for Persons with Disabilities Employment Program & Veterans Employment Program [email protected]

3. Has the agency provided disability program staff with sufficient training to carry out their responsibilities during the reporting period? If “yes”, describe the training that disability program staff have received. If “no”, describe the training planned for the upcoming year.

Yes X No 0

• Annually, TTB managers/supervisors are required to complete online courses related to veteran’s employment, which include disability components. This training, provided by the Department of the Treasury, is mandated by Executive Order (EO) 13518.

• Biennially, TTB’s EEO and Counsel Offices jointly conduct reasonable accommodation (RA) training to TTB workforce, including all individuals responsible for providing assistance with reasonable accommodation. Training topics include:

– ADA Act of 1990








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– Rehabilitation Act of 1973 – “Qualified Employee” – “Disability” – “Accommodation” – “Undue Hardship” – Are You Entitled to a Reasonable Accommodation? – Requesting an Accommodation & Interactive Process – TTB’s RA Process – Examples – Other Options outside of RA (Family Medical Leave Act; Advanced Sick Leave;

Donated Leave The last RA training was conducted in FY18.

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM

Has the agency provided sufficient funding and other resources to successfully implement the disability program during the reporting period? If “no”, describe the agency’s plan to ensure all aspects of the disability program have sufficient funding and other resources.

Yes X No 0

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.

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A. PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES 1. Describe the programs and resources the agency uses to identify job applicants

with disabilities, including individuals with targeted disabilities. • BFS supports TTB in identifying job applicants with disabilities and targeted disabilities.

TTB’s HR Director, Harinder Jaiswal, provides oversight of these services that BFS provides

• TTB’s HR Specialist serves as the Bureau’s Selective Placement Program Coordinator (SPPC) and is included in OPM’s Disability Employment SPPC Directory at https://www.opm.gov/policy-data-oversight/disability-employment/selective-placement-program-coordinator-directory/search.aspx?t=ag&q=dfdf62d0-6090-43ae-bef7-f59fdd0a3051. The SPPC receives applications and refers them to the Bureau’s hiring officials. The HR Director has designated __________ to replace TTB’s former SPPC, Paula Bailey. (TTB HR Director will designate a replacement.)

• TTB sends copies of the position descriptions and any special requirements of job vacancies to Ms. Lisa Jones, [email protected] and Ms. Griselda Wallace, [email protected] at the Treasury’s Office of Civil Rights and Diversity (OCRD). ORD provides TTB with applications of qualified PWD and PWTD individuals to include seabed veterans to non-competitively hire using Schedule A hiring authority.

• TTB uses OPM’s Share List of People with Disabilities at https://community.max.gov/pages/viewpage.action?pageId=555323722.

• TTB reaches out to the Virginia Department for Aging and Rehabilitative Services at https://www.vadars.org/services.htm.

• TTB participates in recruitment events, job fairs, such as: Operation Warfighter (OWF) Intern Fair and Fort Meade Community Job Fair.

• TTB uses the Pathways Intern Program to hire interns with targeted disabilities. • TTB continues outreach efforts with organizations that assist persons with disabilities and

veterans/disabled veterans in obtaining employment.

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.

TTB uses Schedule A and Veteran Appointment Authorities to non-competitively appoint PWD and PWTD and veterans with service-connected disability rating of 30% or more.

https://www.opm.gov/policy-data-oversight/disability-employment/selective-placement-program-coordinator-directory/search.aspx?t=ag&q=dfdf62d0-6090-43ae-bef7-f59fdd0a3051





https://community.max.gov/pages/viewpage.action?pageId=555323722

https://www.vadars.org/services.htm

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3. When individuals apply for a position under a hiring authority that takes disability into account (e.g., Schedule A), explain how the agency (1) determines if the individual is eligible for appointment under such authority and (2) forwards the individual's application to the relevant hiring officials with an explanation of how and when the individual may be appointed.

• When individuals apply using the Schedule A Hiring Authority, their applications are reviewed by the designated BFS HR Specialist who confirms that the applicants meet the qualification requirements of the announced position and have provided required proof of disability. Applicants applying under the Schedule A Hiring Authority who are deemed qualified are referred to the hiring manager on a Schedule A certificate of eligibility with guidance on selection procedures including the application of veterans’ preference, when applicable. Managers have the option to interview and/or hire from the Schedule A certificate or to consider other candidates from other issued certificates (Merit Promotion, Non-Competitive, VRA, etc.).

• Alternatively, when individuals submit their resumes directly to the Treasury or TTB Special Placement Program Coordinator (SPPC) for vacant positions, the SPPC refers the resumes to the designated BFS HR Specialist. The HR Specialist reviews the resumes to determine qualifications. If qualifications and Schedule A eligibility are met, the resumes are then forwarded to the hiring manager for consideration, with guidance on selection procedures, including the application of veterans’ preference, when applicable.

4. Has the agency provided training to all hiring managers on the use of hiring authorities that take disability into account (e.g., Schedule A)? If “yes”, describe the type(s) of training and frequency. If “no”, describe the agency’s plan to provide this training.

Yes X No 0 N/A 0

• Annually, TTB managers/supervisors are required to complete online training through the (former) Treasury Learning Management System (TLMS) related to veteran’s employment, which contain disability components. Courses include: Schedule A Hiring Made Simple; Uniformed Services Employment and Reemployment Rights Act; Veteran Employment Training for Federal Hiring Managers; and Veteran Employment and Uniform

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Services Employment. This training, provided by the Department of the Treasury, is mandated by Executive Order (EO) 13518.

• TTB hiring managers/supervisors participated in Treasury’s Be a Champion Road Show training focusing on employing PWD, PWTD and veterans under the available special hiring authorities, such as Schedule A. The presentation, entitled “Recruiting and Employing Persons with Disabilities and Veterans”, included “Be a Champion” video, providing information on the benefits of hiring under the special hiring authorities for veterans and people with disabilities,

• TTB provides ad hoc, informal, refresher training to managers and supervisors on the Bureau’s workforce participation rates of veterans/disabled veterans; special hiring authorities, including Schedule A, 30% or More Disabled Veteran, and Veterans Recruitment Appointment (VRA).

• TTB periodically provides managers/supervisors updates of the hiring numerical goals for PWD/PWTD and veterans/disabled veterans.

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.

• TTB continues to establish and strengthen relationships, networking opportunities, and partnerships with veterans’ organizations, such as the Department of Veterans Affairs (VA), VA hospitals, Department of Labor Employment Service, state and local employment agencies, and private veterans’ assistance centers in respective geographic areas.

• TTB continues to develop partnerships with organizations that support individuals with disabilities in areas such as rehabilitation assistance, training, skills assessment, assistive devices, and job resources.

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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 (external) in the permanent workforce? If “yes”, please describe the triggers below.

a. New Hires for Permanent Workforce (PWD) Yes 0 No X b. New Hires for Permanent Workforce (PWTD) Yes X No 0

Only if the answer is “yes”, provide a brief comment (in the below box) describing the triggers noted above. Old data table B8 from WA. • In FY18 TTB had 0 PWTD hires, which is below the federal goal of 2%.

2. Using the qualified applicant pool as the benchmark, do triggers exist for PWD

and/or PWTD among the new hires (external) for any of the mission-critical occupations (MCO)? If “yes”, please describe the triggers below.

a. New Hires for MCO (PWD) Yes X No 0 b. New Hires for MCO (PWTD) Yes X No 0

Only if the answer is “yes”, provide a brief comment (in the below box) describing the triggers noted above. New data table B6 in WA and new B6-1 in Monster Analytics (MA).

FY 2018 Hires PWD Qualified vs. New Hires

PWTD Qualified vs. New Hires

0511 Auditing: 0 ----- ----- 0905 General Attorney: 0 ----- ----- 1320 Chemistry: 2 2.36% vs. 0.00% 0.68% vs. 0.00% 1801 Specialists*: 9 13.86% vs. 33.00% 6.37% vs. 0.00% 1810 Investigation: 4 8.20% vs. 25.00% 4.92% vs. 0.00% *TTB’s Specialist positions within the 1801 series include: Alcohol and Tobacco Tax and Trade Specialist; Industry Specialist; Market Compliance Specialist; Regulations Specialist; International Trade Specialist; Formulation Specialist; Labeling Specialist.

There are triggers when comparing the qualified applicant flow data with the new hires for PWD in the occupational series 1320. For PWTD, triggers exist within series 1320, 1801, and 1810. Note: In FY18, one individual hired through Schedule A was incorrectly coded as “01 – I do not wish to identify my disability or serious health condition.” BFS has requested their

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Processing Unit to look into this matter to determine the potential source(s) of this type of error and develop a solution to ensure all future Schedule A new hires correctly self-identify their disability rather than select code as “01” or “05 – I do not have a disability or serious health condition.” If this particular Schedule A new hire has a targeted disability, then TTB’s PWTD new hires for FY18 would increase from 0.00% to 6.25%, exceeding the federal goal of 2.0%. As required, TTB will develop a plan to improve the hiring (eliminate any identified barriers) of PWD/PWTD within the identified major occupations.

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.

a. Qualified Applicants for MCO (PWD) Yes 0 No 0 b. Qualified Applicants for MCO (PWTD) Yes 0 No 0

Only if the answer is “yes”, provide a brief comment (in the below box) describing the triggers noted above. New data table B6 in WA, B6-1 in MA, B8S in WA. There is no applicant data for internal selections/promotions.

4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD

and/or PWTD among employees promoted (internal selections) to any of the mission-critical occupations (MCO)? If “yes”, please describe the triggers below.

a. Promotions for MCO (PWD) Yes 0 No 0 b. Promotions for MCO (PWTD) Yes 0 No 0

Only if the answer is “yes”, provide a brief comment (in the below box) describing the triggers noted above.

New data table B6 in WA and new B6-1 in MA. There is no applicant data for internal selections/promotions.

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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.

• TTB offers career development opportunities to its workforce including PWD and PWTD, such as training, career-ladder positions, and merit promotions.

• TTB vacancy announcements are sent TTB-wide via email Broadcast. • TTB has a Mentoring Program. (This program was not active for FY18. As part of the

Bureau's balanced scorecard annual business plan, the review and reactivation of the program has been identified as a potential Tier 2 Priority Initiative. The decision to activate the initiative is pending for midyear FY19.)

• TTB encourages its employees to write their Individual Development Plan for discussion with their supervisor.

• TTB also has other career development programs, which are internal developmental training for employees in their specific occupations. Some of these training courses are conducted annually or biannually. The programs are generally advertised through the Bureau to employees who are working in the specific occupational series. In addition, TTB has Skillsoft on-line training, including training in leadership, supervision, and other related areas, which are available to all employees. TTB’s Training and Professional Development Division notifies all employees via email through the intranet and broadcasts to all employees.

B. CAREER DEVELOPMENT OPPORTUNITIES 1. Please describe the career development opportunities that the agency provides

to its employees. TTB’s primary career development program (CDP) is the Emerging Leaders Program (ELP) – a three year centralized training program that is competitive with selections made at the Assistant Administrator level. During the 4th quarter of each fiscal year, TTB broadcasts an ELP annual

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opportunity announcement to request applicants for the Program. The announcement provides general information about the ELP and its three programs, identifies the three year curriculum for each program, and explains how employees may apply. The TTB ELP framework consists of three separate and distinct programs:

- Program for non-supervisory employees - Program for 1st level supervisors - Program for 2nd level supervisors and senior leaders

All TTB employees, including disabled veterans, are eligible for consideration for the ELP and may apply during the annual announcement period. Selections are made through a competitive process. TTB’s Training and Professional Development Division chairs a meeting with senior leaders and provides its recommendations for selection. Senior leaders make the final selections. Note: The ELP is TTB’s primary leadership CDP. However, it is not considered a formal CDP in accordance with Treasury’s definition:

– Must be announced via USA JOBS – Announcement must include a statement indicating that this is a CDP – Program must be competitive and individuals must apply – Upon completion of the program, the employee would be considered qualified for a

promotion to the next higher grade

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(%)

Internship Programs

TTB uses the Pathway Internship Program. However, the Bureau did not post any Pathways announcements in FY 2018. Therefore, there

N/A N/A N/A N/A N/A N/A

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were not any Pathways hires.

Fellowship Programs

TTB uses the Presidential Management Fellows (PMF) Program.

Note:

TTB (& other agencies) generally reviews resumes for the PMF selectees and sends BFS the selection to hire. In FY 2018, TTB forwarded several PMF resumes to BFS for review. TTB cancelled this request without making a selection.

The PMF who was selected this past year was sent as a selection from TTB earlier in the year and not part of the package of resumes TTB had asked BFS to review.

4 1 0 0 0 0

Mentoring Programs

TTB’s Mentoring Program was not active for FY18. As part of the Bureau's balanced scorecard annual business plan, the review and reactivation of the program has been identified as a potential Tier 2 Priority Initiative. The decision to activate the initiative is pending for midyear FY19.

N/A N/A N/A N/A N/A N/A

Coaching Programs N/A N/A N/A N/A N/A N/A

(Other) Training Programs N/A N/A N/A N/A N/A N/A

Detail Programs N/A N/A N/A N/A N/A N/A

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Other Career Development Programs

TTB Emerging Leaders Program (ELP)

17 10 5.9% 0% 5.9% 10%

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.

a. Applicants (PWD) Yes 0 No 0 N/A b. Selections (PWD) Yes 0 No 0 N/A

Note: As indicated by Treasury, a formal CDP is one which must be advertised via USA JOBS, employees must apply and be identified as qualified and selected through a competitive process and upon completion would be considered qualified for a promotion to the next higher grade. Only bureaus with formal CDP are required to collect and report applicant pool data. This information is not reportable at the Treasury-wide level. TTB does not have a formal CDP as defined by Treasury.

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

career development programs identified? (The appropriate benchmarks are the relevant applicant pool for applicants and the applicant pool for selectees.) If “yes”, describe the trigger(s) in the text box.

a. Applicants (PWTD) Yes 0 No 0 N/A b. Selections (PWTD) Yes 0 No 0 N/A

(See comment above)

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) Yes X No 0 b. Awards, Bonuses, & Incentives (PWTD) Yes X No 0

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Participation Rates vs. Inclusion Rates Participation rates are obtained by calculating a ratio of how many employees with targeted disabilities are in the total or permanent workforce. In the workforce data tables, the participation rates are calculated by dividing across a row so that each EEO group is a percentage of the workforce indicator (total workforce, permanent workforce, etc.). In Table B1, the participation rate of employees with targeted disabilities in the total workforce is calculated by dividing the number of that EEO group by the number of employees in the agency’s total workforce, and then multiplying by 100. To determine whether a trigger exists, the agency would compare the participation rates of either persons with reportable disabilities or persons with targeted disabilities to EEOC’s goal of 12% or 2%, respectively. Inclusion rates, however, calculate the proportion of employees with reportable or targeted disabilities in the permanent workforce who fall within a particular occupational category, mission-critical occupation, grade level, or other type of workforce indicator. Inclusion rates are calculated by dividing down a column to show the distribution of one EEO group in a particular workforce indicator. For example, the inclusion rate of employees with targeted disabilities who received a particular award is calculated by dividing the number of that EEO group who received a quality step increase by their number in the permanent workforce, and then multiplying by 100. In Table B9, the inclusion rate shows that of the employees with targeted disabilities in the permanent workforce, 2% received a quality step increase. Next, the agency should compare the inclusion rate of employees with targeted disabilities who received the award to the corresponding inclusion rate of employees without disabilities who received the same award. The inclusion rate can assist agencies in determining whether a glass ceiling (a barrier preventing career advancement for qualified members of a group), or a glass wall (a barrier preventing a group from moving to an occupation with a promotional ladder) exists. New data table B9-2 from WA.

• The inclusion rate (IR) for PWD (5.88%) and PWTD (0.00%) are below the IR of persons with no disability (PWND) (12.17%) for time off hours 1-10.

• The IR for PWD (0.00%) and PWTD (0.00%) are below the IR of PWND (7.30%) for time off hours 11-20.

• The IR for PWD (0.00%) and PWTD (0.00%) are below the IR of PWND (2.92%) for time off hours 21-30.

• The IR for PWD (0.00%) and PWTD (0.00%) are below the IR of PWND (1.22%) for time off hours 31-40. However, only 5 of awards were given, therefore, this would not be considered a trigger.

• The IR for PWTD (0.00%) is below the IR of PWND (17.27%) for cash awards $500 and under. However, the IR for PWD (17.65%) is equal to the IR of PWND (17.27%).

• The IR for PWD (2.94%) and PWTD (0.00%) are below the IR of PWND (11.68%) for cash awards $501-$999.

• The IR for PWD (67.65%) is slightly below the IR of PWND (72.75%) for cash awards $1,000-$1,999. However, the IR for PWTD (72.73%) is equal to the IR of PWND (72.75%).

• The IR for PWD (4.41%) and PWTD (0.00%) are below the IR of PWND (9.005) for cash awards $2,000 - $2,999.

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2. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for quality step increases or performance-based pay increases? If “yes”, please describe the trigger(s) in the text box.

a. Pay Increases (PWD) Yes 0 No X b. Pay Increases (PWTD) Yes X No 0

Only if the answer is “Yes” describe (in the below box) the triggers noted above. New data table B9-2 from WA.

The IR for PWTD (0.00%) is below the IR for PWND (1.95%). However, the IR for PWD (1.47%) is equal to the PWND (1.95%).

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) Yes 0 No 0 N/A X b. Other Types of Recognition (PWTD) Yes 0 No 0 N/A X

Only if the answer is “Yes” describe (in the below box) the triggers noted above.

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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.

a. SES

i. Qualified Internal Applicants (PWD) Yes 0 No 0

ii. Internal Selections (PWD) Yes 0 No 0

b. Grade GS-15



c. Grade GS-14



d. Grade GS-13



New B7-1 from WA and new B7-1 from MA. There is no applicant data for internal selections/promotions.

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2. Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions to the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants and the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If “yes”, describe the trigger(s) in the text box.

a. SES

i. Qualified Internal Applicants (PWTD) Yes 0 No 0

ii. Internal Selections (PWTD) Yes 0 No 0

b. Grade GS-15



c. Grade GS-14



d. Grade GS-13




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.

a. New Hires to SES (PWD) Yes 0 No 0 N/A X

b. New Hires to GS-15 (PWD) Yes 0 No 0 N/A X

c. New Hires to GS-14 (PWD) Yes X No 0

d. New Hires to GS-13 (PWD) Yes 0 No 0 N/A X

Only if the answer is “Yes” describe (in the below box) the triggers noted above. New B7-1 from WA; new B7-1 from MA; new B6-1 from MA.

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Qualified Applicants - New Hires: GS-14 PWD: 5.08% - 0.00%


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.

a. New Hires to SES (PWTD) Yes 0 No 0 N/A X

b. New Hires to GS-15 (PWTD) Yes 0 No 0 N/A X

c. New Hires to GS-14 (PWTD) Yes X No 0

d. New Hires to GS-13 (PWTD) Yes 0 No 0 N/A X

Only if the answer is “Yes” describe (in the below box) the triggers noted above. New B7-1 from WA; new B7-1 from MA; new B6-1 from MA. Qualified Applicants - New Hires: GS-14 PWD: 1.69% - 0.00%

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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.

a. Executives



b. Managers



c. Supervisors




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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.

a. Executives



b. Managers



c. Supervisors



Only if the answer is “Yes” describe (in the box below) the triggers noted above.



trigger involving PWD among the selectees for new hires to supervisory positions? If “yes”, describe the trigger(s) in the text box.

a. New Hires for Executives (PWD) Yes 0 No 0 N/A X b. New Hires for Managers (PWD) Yes X No 0

c. New Hires for Supervisors (PWD) Yes 0 No 0 N/A X

Only if the answer is “Yes” describe (in the below box) the triggers noted above. New B8-1 from WA; new B8-1 from MA; new B6-1 from MA. Qualified Applicants - New Hires: Mangers PWD: 9.09% - 0.00%

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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.

a. New Hires for Executives (PWTD) Yes 0 No 0 N/A X

b. New Hires for Managers (PWTD) Yes 0 No X

c. New Hires for Supervisors (PWTD) Yes 0 No 0 N/A X

Only if the answer is “Yes” describe (in the below box) the triggers noted above. New B8-1 from WA; new B8-1 from MA; new B6-1 from MA.

Section V: Plan to Improve Retention of Persons with Disabilities To be a model employer for persons with disabilities, agencies must have policies and programs in place to retain employees with disabilities. In this section, agencies should: (1) analyze workforce separation data to identify barriers retaining employees with disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) provide information on the reasonable accommodation program and workplace personal assistance services.

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS 1. In this reporting period, did the agency convert all eligible Schedule A employees

with a disability into the competitive service after two years of satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If “no”, please explain why the agency did not convert all eligible Schedule A employees.

Yes 0 No X Only if the answer is “No” explain (in the below box) why the bureau did not convert all eligible Schedule A employees. TTB had one Schedule A employee who was not converted per the employee’s supervisor’s request to not convert.

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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) Yes X No 0 b. Involuntary Separations (PWD) Yes 0 No X

Note/Example: The “inclusion rate” for this purpose is determined by dividing the number of permanent employees with disabilities who voluntarily separated (129) by the total number of employees with disabilities 12,664. That rate, 1.01%, exceeds the 0.69% “inclusion rate” for permanent employees without disabilities who voluntarily separated (570 divided by 82,087).

Only if the answer is “Yes” describe (in the below box) the triggers noted above. Old data table B14 from WA.

• The inclusion rate for PWD (7.35%) exceeds the inclusion rate for persons with no disability (3.4%) for voluntary separations.

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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) Yes 0 No X b. Involuntary Separations (PWTD) Yes 0 No X

Only if the answer is “Yes” describe (in the box below) the triggers noted above. Old data table B14 from WA.

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.

Only if a trigger exists describe (in the below box) explain why the majority of employees left the agency (other than retirement). TTB had 18 permanent voluntary separations. Of these 18, 12 responded to the exit survey. Of the 12 respondents, 1 (8%) self-identified as having a disability, and 11 (92%) indicated they do not have a disability. Reasons for separation:

• Retirement (68%) • Accept a position in a state or local government (8%) • Continue education (8%) • Personal circumstance2 (8%) • Transfer to another federal agency (8%)

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform applicants and employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b), concerning the accessibility of agency technology, and the Architectural Barriers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to inform individuals where to file complaints if other agencies are responsible for a violation.

1. Please provide the internet address on the agency’s public website for its notice explaining employees’ and applicants’ rights under Section 508 of the Rehabilitation Act, including a description of how to file a complaint.

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Reasonable Accommodation: https://www.ttb.gov/eeo/reasonable_accomodation.shtml

Personal Assistance Services: https://www.ttb.gov/eeo/personal-assistance-services.shtml

EEO Complaint Process: https://www.ttb.gov/eeo/discrimination.shtml

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.

N/A

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.

TTB along with GSA review the Bureau’s facilities and work out the necessary adjustment. The most recent work occurred at the Bureau’s National Revenue Center (NRC) when they installed handicapped piping covers on exposed plumbing in the break area.

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.)

Average time: 12.25 days.

2. Describe the effectiveness of the policies, procedures, or practices to implement

the agency’s reasonable accommodation program. Some examples of an effective program include timely processing requests, timely providing approved accommodations, conducting training for managers and supervisors, and monitoring accommodation requests for trends.

All of TTB’s requests were processed timely.

https://www.ttb.gov/eeo/reasonable_accomodation.shtml

https://www.ttb.gov/eeo/personal-assistance-services.shtml

https://www.ttb.gov/eeo/discrimination.shtml

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D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE WORKPLACE

Pursuant to 29 C.F.R. § 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.

OPM established the requirement for Personal Assistance Services (PAS). During FY18, Treasury established a PAS Working Group of which TTB was a participant. The initial purpose of this working group was to establish and finalize a Statement of Work (SOW) for procuring a Treasury-wide PAS contact. This contract will allow TTB to establish a purchase order against the Treasury-wide base contract. While the PAS contract is being established, the PAS working group will create the PAS policy and procedures. In the interim, the TTB will follow Treasury’s existing reasonable accommodation policy and procedures to provide PAS.

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?

Yes 0 No 0 N/A X 2. During the last fiscal year, did any complaints alleging harassment based on

disability status result in a finding of discrimination or a settlement agreement? Yes 0 No 0 N/A X

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.

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Only provide comment (in the below box) if there were one or more findings of discrimination alleging harassment based on disability in the last FY.

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?

Yes 0 No 0 N/A X 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?

Yes 0 No 0 N/A X 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.

Only provide comment (in the below box) if there were one or more findings of discrimination involving the failure to provide a RA in the last FY.

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Part I: Barrier Analysis and Plan to Removed Identified Barriers 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. (Ensure when evaluating triggers that you associate all like trigger data.) Note: For each trigger or group of associated triggers you will be required to complete the portion contained in Question 3 below.

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect employment opportunities for PWD and/or PWTD?

Yes X No 0

2. Has the agency established a plan to correct the barrier(s) involving PWD and/or PWTD?

Yes X No 0

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. Ensure your analysis consolidates associated triggers, rather than reporting on each one separately. For example: A lower than expected participation rate for PWD is too broad. It would be better to identify where in the workforce the lower than expected participation rate is such as in a major occupation. However, keep in mind that a lower than expected participation rate in a mission critical occupation which leads to the feeder pools for your senior Executive Service positions may also be the reason for the lower than expected participation in the feeder pools and SES for PWD. Pull your triggers from the analysis in previous sections of the PART J.

Trigger 1 In FY18 TTB had 0.00% PWTD new hires compared to the Federal goal of 2.00%.

Barrier(s)

• Lack of consistent use of Schedule A hiring authority. • There is a flaw in BFS’ current procedures for processing new hires,

causing some Schedule A employees to have an incorrect disability code in the system. If these individuals have a targeted disability, then being incorrectly coded negatively affects TTB’s PWTD hiring numbers.

Objective(s)

• Ensure consistent use of Schedule A hiring authority. • Identify and remove source(s) of BFS’ processing procedures. • Develop and implement an improved process.

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Responsible Official(s) Performance Standards Address

the Plan? (Yes or No)

Tiara Ngo, TTB EEO Director Yes

Harinder Jaiswal, TTB HR Director ? (HRD will confirm)

TTB Selective Placement Program Coordinator ? (HRD will confirm)

TTB Hiring Officials ? (HRD will confirm) Barrier Analysis Process Completed?

(Yes or No) Barrier(s) Identified?

(Yes or No) Yes Yes

Sources of Data Sources

Reviewed? (Yes or No)

Identify Information Collected

Workforce Data Tables Yes Complaint Data (Trends) Yes Grievance Data (Trends) Findings from Decisions (e.g., EEO, Grievance, MSPB, Anti-Harassment Processes)

Yes

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

Exit Interview Data Yes Focus Groups Yes Interviews Reports (e.g., Congress, EEOC, MSPB, GAO, OPM) Yes

Other (Please Describe) Target Date

(mm/dd/yyyy) Planned Activities

(Each planned activity should be entered in separately, not in the same box and numbered)

Sufficient Staffing & Funding (Yes or No)

Modified Date

(mm/dd/yyyy)

Completion Date

(mm/dd/yyyy)

03/31/2019 The HR Director will designate a replacement for TTB’s former Selective Placement Program Coordinator (SPPC), who retired in FY 2018. (The SPPC provides ad hoc briefings/informal training to TTB

Yes

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hiring supervisors on special hiring authorities, including Schedule A.)

03/31/2019 BFS will determine source(s) of disability coding errors, and develop and implement an improved process to prevent future errors.

Yes

04/30/2019 and on-going, as needed

The SPPC will provide ad hoc briefings/informal training to TTB hiring supervisors on special hiring authorities, including Schedule A.

Yes

On-going TTB EEO and HR Directors will continue to request PDs from hiring officials for vacancy announcements, which will be forwarded to Treasury’s OCRD to request resume packages from potentially qualified applicants for hiring officials’ review.

Yes

Fiscal Year Accomplishments

Trigger 2

TTB’s PWTD workforce in the following mission-critical occupations is 0.00%, compared to the Federal goal of 2.00%:

• 0511 Auditing • 0905 General Attorney • 1320 Chemistry

Barrier(s) • Lack of use of Schedule A hiring authority.

Objective(s)

Increase the use of Schedule A to increase PWTD new hires in these mission-critical occupations to meet the Federal goal of 2.00%:


Responsible Official(s) Performance Standards Address

the Plan? (Yes or No)

Tiara Ngo, TTB EEO Director Yes

Harinder Jaiswal, TTB HR Director ? (HRD will confirm)

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TTB Selective Placement Program Coordinator ? (HRD will confirm) TTB Hiring Officials for the following mission-critical occupations:


? (HRD will confirm)

Barrier Analysis Process Completed? (Yes or No)

Barrier(s) Identified? (Yes or No)

Yes Yes

Sources of Data Sources

Reviewed? (Yes or No)

Identify Information Collected

Workforce Data Tables Yes Complaint Data (Trends) Yes Grievance Data (Trends) Findings from Decisions (e.g., EEO, Grievance, MSPB, Anti-Harassment Processes)

Yes

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

Exit Interview Data Yes Focus Groups Yes Interviews Reports (e.g., Congress, EEOC, MSPB, GAO, OPM) Yes

Other (Please Describe) Target Date

(mm/dd/yyyy) Planned Activities

(Each planned activity should be entered in separately, not in the same box and numbered)

Sufficient Staffing & Funding (Yes or No)

Modified Date

(mm/dd/yyyy)

Completion Date

(mm/dd/yyyy)

02/28/2019 TTB EEO and HR Directors will provide the Directorates’ Administrator/Deputy Administrator with a summary of results of TTB’s FY 2018 PWTD on-board workforce and new hires and encourage the use of Schedule A hiring authority.

03/31/2019 The HR Director will designate a replacement for TTB’s former Selective Placement Program

Yes

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Coordinator (SPPC), who retired in FY 2018. (The SPPC provides ad hoc briefings/informal training to TTB hiring supervisors on special hiring authorities, including Schedule A.)

04/30/2019 and on-going, as needed

The SPPC will provide ad hoc briefings/informal training to TTB hiring supervisors overseeing these mission-critical occupations on special hiring authorities, including Schedule A:


Yes

On-going TTB EEO and HR Directors will continue to request PDs from hiring officials for vacancy announcements, which will be forwarded to Treasury’s OCRD to request resume packages from potentially qualified applicants for hiring officials’ review.

Yes

Fiscal Year Accomplishments

4. Please explain the factor(s) that prevented the agency from timely completing any of the planned activities.

5. For the planned activities that were completed, please describe the actual impact of those activities toward eliminating the barrier(s). (quantify and qualify the effect of the implemented plans)

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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.

MD-715 – Part J · 2019-10-22 · EEOC FORM U.S. Equal Employment Opportunity Commission ALCOHOL...

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Transcript of MD-715 – Part J · 2019-10-22 · EEOC FORM U.S. Equal Employment Opportunity Commission ALCOHOL...