.
18
Department of Treasury FY 2017
Affirmative Action Plan
for the Recruitment, Hiring, Advancement, and
Retention of Persons with Disabilities
SECTION I: EFFORTS TO REACH REGULATORY GOALS .....................................
2
SECTION II: MODEL DISABILITY PROGRAM ...........................................................
2
A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR DISABILITY PROGRAM .....................................................................
3
B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM ........................................................................................ 3
SECTION III: PROGRAM DEFICIENCIES IN THE DISABILITY PROGRAM .............
4
SECTION IV: PLAN TO RECRUIT AND HIRE INDIVIDUALS
WITH DISABILITIES .....................................................................................................
4
A. PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES ..................................................................................................................... 4
B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS ......................................................................... 6
C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING) ....................................................................................................... 6
SECTION V: PLAN TO ENSURE ADVANCEMENT
OPPORTUNITIES FOR EMPLOYEES WITH DISABILITIES ......................................
7
A. ADVANCEMENT PROGRAM PLAN ...................................................................................................................................................... 8
B. CAREER DEVELOPMENT OPPORTUNITIES .......................................................................................................................................... 8
C. AWARDS ............................................................................................................................................................................................. 8
D. PROMOTIONS .................................................................................................................................................................................... 9
SECTION VI: PLAN TO IMPROVE RETENTION OF PERSONS
WITH DISABILITIES ....................................................................................................
14
A. VOLUNTARY AND INVOLUNTARY SEPARATIONS ............................................................................................................................... 14
B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES .............................................................................................................................. 15
C. REASONABLE ACCOMMODATION PROGRAM ................................................................................................................................... 16
D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE WORKPLACE .................................................. 17
SECTION VII: EEO COMPLAINT AND FINDINGS DATA ..........................................
17
A. EEO COMPLAINT DATA INVOLVING HARASSMENT ........................................................................................................................... 17
B. EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION ............................................................................................ 18
SECTION VIII: IDENTIFICATION AND REMOVAL OF BARRIERS ............................
Department of Treasury FY 2017
Affirmative Action Plan
for the Recruitment, Hiring, Advancement, and
Retention of Persons with Disabilities
To capture agencies’ affirmative action plan for persons with disabilities (PWD) and
persons with targeted disabilities (PWTD), EEOC regulations (29 C.F.R. § 1614.203(e))
and MD-715 require agencies to describe how their affirmative action plan will improve
the recruitment, hiring, advancement, and retention of applicants and employees with
disabilities.
Section I: Efforts to Reach Regulatory Goals
EEOC regulations (29 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) Answer: No
b. Cluster GS-11 to SES (PWD) Answer: Yes
PWD are participating at a rate (11.09%) slightly below the 12% bench mark at the
grade cluster GS-11 to SES.
* For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES,
as set forth in 29 C.F.R. § 1614.203(d)(7). For all other pay plans, please use the
approximate grade clusters that are above or below GS-11 Step 1 in the
Washington, DC metropolitan region.
2. Using the goal of 2% as the benchmark, does your agency have a trigger
involving PWTD by grade level cluster in the permanent workforce? If "yes",
describe the trigger(s) in the text box.
a. Cluster GS-1 to GS-10 (PWTD) Answer: No
b. Cluster GS-11 to SES (PWTD) Answer: No
3. Describe how the agency has communicated the numerical goals to the hiring
managers and/or recruiters.
Treasury has communicated the overall disability goals with its bureaus through the
quarterly HR Stat, HCAC meetings, OCRD Advisory Newsletter, EEO Officer
Meetings and the “Be a Champion” Roadshows. Treasury’s bureaus also have
communicated the disability goals to their leadership through various methods to
include new manager and supervisor training, newsletters, staff meetings, electronic
bulletin boards, and bureau/organization specific dashboards.
Section II: Model Disability Program
2
Department of Treasury FY 2017
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
DISABILITY PROGRAM
1. Has the agency designated sufficient qualified personnel to implement its
disability program during the reporting period? If “no”, describe the agency’s
plan to improve the staffing for the upcoming year.
Answer: Yes
2. Identify all staff responsible for implementing the agency’s disability
employment program by the office, staff employment status, and responsible
official.
Disability Program Task
# of FTE Staff by
Employment Status Responsible Official
(Name, Title, Office, Email)
Full Time Part Time Collateral Duty
Processing applications
from PWD and PWTD
59 1 10 See specific bureau PART J's.
Answering questions from
the public about hiring
authorities that take
disability into account
40 1 11 See specific bureau PART J's.
Processing reasonable
accommodation requests
from applicants and
employees
63 0 13 See specific bureau PART J's.
Section 508 Compliance 111 0 4 See specific bureau PART J's.
Architectural Barriers Act
Compliance
18 1 305 See specific bureau PART J's.
Special Emphasis Program
for PWD and PWTD
16 0 5 See specific bureau PART J's.
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(s) that disability program staff have received. If “no”, describe the
training(s) planned for the upcoming year.
Answer: Yes
Treasury’s Disability and Veteran Employment Program Managers have provided
training as needed through Treasury Learning Management System (TLMS),
Enterprise Learning Management System (ELMS), workshops and refresher training.
When needed, Treasury/bureaus coordinate training with external sources such as
EEOC.
B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY
PROGRAM
3
Department of Treasury FY 2017
Has the agency provided sufficient funding and other resources to successfully implement the
disability program during the reporting period? If “no”, describe the agency’s plan to ensure all
aspects of the disability program have sufficient funding and other resources.
Answer: Yes
Section III: Program Deficiencies in the Disability Program
In Part G of its FY 2017 MD-715 report, the agency identified the following program
deficiencies involving its disability program:
Program Deficiencies Agency Comments
Is there a central fund or other
mechanism for funding supplies,
equipment and services necessary to
provide disability accommodations?
Each bureau is responsible for funding disability
accommodations requests. However, OCC and
FinCEN have implemented a centralized fund for all
accommodations and DO has implemented a
centralized fund for providing interpreter services.
Are 90% of accommodation requests
processed within the frame set forth
in the agency procedures for
reasonable accommodation?
OCC and IRS both reported no. See Bureau PART
H’s outlining plans to correct untimely processing.
Section IV: Plan to Recruit and Hire Individuals with Disabilities
Pursuant to 29 C.F.R. § 1614.203(d)(1)(i) and (ii), agencies must establish a plan to increase
the recruitment and hiring of individuals with disabilities. The questions below are designed to
identify outcomes of the agency’s recruitment program plan for PWD and PWTD.
A. PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES
1. Describe the programs and resources the agency uses to identify job
applicants with disabilities, including individuals with targeted disabilities.
Treasury utilizes OPM’s Talent portal in USAJobs to identify qualified PWD, PWTD
and veterans and refer qualified applicants to hiring managers. Treasury’s Veterans
Program Coordinator provides all vacancies to veteran organizations that assist
transitioning veterans, including those with disabilities, in finding employment.
Treasury and Bureau Disability and Veterans Program Managers have also
established relationships with organizations that assist PWD, PWTD and Veterans
seeking employment.
Treasury’s Disability and Veterans Program Managers also maintain resumes of
qualified PWD and PWTD, including veterans with disabilities, who indicate they are
interested in seeking employment opportunities at Treasury. When a hiring manager
identifies an upcoming opening, the Disability and Veterans Program Managers send
the hiring manager resumes of those PWD, PWTD and veterans who may be
qualified.
Treasury and its bureaus also utilize the Workforce Recruitment Program (WRP) to
find and select college students and recent graduates with disabilities, including those
4
Department of Treasury FY 2017
with targeted disabilities.
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.
Schedule A is available for use along with Veteran Appointment Authorities to non-
competitively appoint PWD and PWTD and veterans with service-connected disability
rating of 30% or more. The Department’s Disability and Veterans Program Managers
work directly with bureau Disability Coordinators, Selective Placement Coordinators
and Program Managers to assist in finding qualified candidates for non-competitive
special hiring authorities. Additionally, through its Be a Champion Program, the
Disability and Veterans Program Managers have established relationships with bureau
hiring managers to identify resumes of qualified candidates who can be non-
competitively selected.
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 utilizing the Schedule A Hiring Authority, their applications are
reviewed by the servicing 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 bureau
Special Placement Program Coordinator (SPPC) for vacant positions within Treasury,
the SPPC refer the resumes to requesting hiring managers for consideration. The
hiring manager refers selected resumes to the HR Specialist who reviews the
resumes to determine qualifications. If qualifications and Schedule A eligibility are
met, the resumes are returned to the hiring manager 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.
Answer: Yes
Treasury includes the use of special hiring authorities (e.g. Schedule A, VRA, 30% or
more, etc.) in its mandatory training for new managers and supervisors. Also, through
Treasury’s Be a Champion Program, the Disability and Veterans Program Managers
provide training for bureau hiring managers, educating them on the benefits of using
special hiring authorities, and assist in identifying resumes of qualified candidates who
can be non-competitively selected and hired.
Additionally, Treasury’s Disability and Veterans Program Managers have provided
5
Department of Treasury FY 2017
bureau hiring managers with disability and veteran tool kits which highlight the use of
hiring authorities that take disability into account.
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.
• Partner, lecture, and attend on-site presentations, and classroom visits in order to
develop stronger relationships with college students and professors and with campus
clubs and groups focusing on students with disabilities on college campuses.
• Hold periodic meetings with professional organizations to share Treasury’s
process for providing vacancy announcements and information about opportunities.
• Attend specialty conferences and career/job fairs to share information about
Treasury’s mission, work environment and job opportunities.
• Host brown bag lunches and roundtable discussions between hiring
managers/senior management, and HC and organizations that assist PWD/PWTD.
C. PROGRESSION TOWARDS GOALS (RECRUITMENT AND HIRING)
1. Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do
triggers exist for PWD and/or PWTD among the new hires in the permanent
workforce? If “yes”, please describe the triggers below.
a. New Hires for Permanent Workforce (PWD) Answer: No
b. New Hires for Permanent Workforce (PWTD) Answer: No
2. Using the qualified applicant pool as the benchmark, do triggers exist for PWD
and/or PWTD among the new hires for any of the mission-critical occupations
(MCO)? If “yes”, please describe the triggers below.
a. New Hires for MCO (PWD) Answer: No
b. New Hires for MCO (PWTD) Answer: Yes
FY 2017 Hires Applicants vs. Hires Applicants vs. Hires
0110 (20) Hires: PWD: 4.59% - 5.00% PWTD: 2.75% - 0.00%
0340 (11) Hires: PWD: 4.37% - 9.09% PWTD: 1.73% - 9.09%
0343 (62) Hires: PWD: 4.52% - 11.29% PWTD: 1.94% - 3.23%
0501 (29) Hires: PWD: 4.94% - 20.99% PWTD: 1.83% - 0.00%
0511 (18) Hires: PWD: 3.52% - 5.56% PWTD: 1.69% - 0.00%
0570 (167) Hires: PWD: 2.77% - 4.19% PWTD: 1.19% - 0.00%
0905 (50) Hires: PWD: 3.20% - 4.00% PWTD: 1.14% - 0.00%
1169 (35) Hires: PWD: 1.94% - 17.14% PWTD: 0.88% - 2.86%
1811 (53) Hires: PWD: 3.32% - 1.89% PWTD: 1.42% - 0.00%
2210 (377) Hires: PWD: 5.26% - 22.55% PWTD: 2.43% - 3.89%
The 1811, Criminal Investigators occupation, limits the employment opportunities
available for PWD and PWTD based on OPM established medical requirements for
the position. Therefore, we would expect the hire of PWTD and PWD to be limited.
6
Department of Treasury FY 2017
However, we do note triggers when comparing the applicant flow data with the hires
for PWTD for the occupational series 0110, 0501, 0511, 0570, and 0905’s. Treasury
bureaus that noted the same triggers in their workforce evaluation have addressed
these triggers in the bureau PART J. For plans to improve hiring for PWD within the
major occupations listed see the specific bureau PART J’s.
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) Answer: No
b. Qualified Applicants for MCO (PWTD) Answer: No
This data is a new requirement to be implemented with the FY 2018 reporting and
revised MD-715 V2 data tables. Treasury is in the process of discussing the new MD-
715 V2 data tables with our data providers; Enterprise Data Management and
Monster/CareerConnector. We will work throughout FY 2018 to develop and release
the revised data tables for the FY 2018 reporting period.
4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD
and/or PWTD among employees promoted to any of the mission-critical
occupations (MCO)? If “yes”, please describe the triggers below.
a. Promotions for MCO (PWD) Answer: Yes
b. Promotions for MCO (PWTD) Answer: Yes
Applicants vs. Promotions Applicants vs. Promotions
0340 - PWD: 4.56% - 2.40% PWTD: 1.90% - 1.20%
0343 - PWD: 3.90% - 1.72% PWTD: 1.62% - 0.86%
0501 - PWD: 4.69% - 4.90% PWTD: 1.80% - 2.94%
0570 - PWD: 2.48% - 1.84% PWTD: 1.30% - 0.74%
0905 - PWD: 1.00% - 0.00% PWTD: 0.00% - 0.00%
1169 - PWD: 1.94% - 1.25% PWTD: 0.88% - 0.31%
2210 - PWD: 4.85% - 1.72% PWTD: 2.57% - 0.57%
We noted triggers when comparing the applicant flow data with the promotion data for
PWD in the following occupations: 0340, 0343, 0570, 0905, 1169 and 2210.
Additionally, triggers were noted when comparing the applicant flow data with the
promotion data for PWTD in the following occupations: 0340, 0343, 0570, 1169 and
2210.Treasury bureaus that noted the same triggers in their workforce evaluation
have addressed these triggers in their bureau PART J. For plans to improve
advancement opportunities for PWD and PWTD within the major occupations listed
see specific bureau PART J’s.
Section V: 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
7
Department of Treasury FY 2017
opportunities for employees with disabilities.
A. ADVANCEMENT PROGRAM PLAN
Describe the agency's plan to ensure PWD, including PWTD, have sufficient opportunities for
advancement.
Bureaus have established bureau specific programs for the advancement of PWDs
and PWTDs. For details see specific bureau Part J’s.
B. CAREER DEVELOPMENT OPPORTUNITIES
1. Please describe the career development opportunities that the agency provides
to its employees.
Treasury has three bureaus (IRS, OCC and TTB) with formal career development
programs. For details see specific bureau Part J’s.
2. 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 applicants and the applicant pool for selectees.) If "yes",
describe the trigger(s) in the text box.
a. Applicants (PWD) Answer: No
b. Selections (PWD) Answer: No
Treasury does not have a Treasury-wide career Development program, therefore
there is no data available.
3. 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) Answer: No
b. Selections (PWTD) Answer: No
Treasury does not have a Treasury-wide career Development program, therefore
there is no data available.
C. AWARDS
8
Department of Treasury FY 2017
1. Using the inclusion rate as the benchmark, does your agency have a trigger
involving PWD and/or PWTD for any level of the time-off awards, bonuses, or
other incentives? If "yes", please describe the trigger(s) in the text box.
a. Awards, Bonuses, & Incentives (PWD) Answer: Yes
b. Awards, Bonuses, & Incentives (PWTD) Answer: Yes
The inclusion rate for PWD (12.15%) and PWTD (12.78%) fell slightly below the
inclusion rate for employees with no disability (14.60%) for time off awards between 1
- 9 hours.
The inclusion rate for PWD (21.61%) for time off awards of more than 9 hours fell
slightly below the inclusion rate for employees with no disability (21.63%). However,
the inclusion rate for PWTD (22.89%) was above the inclusion rate for persons with no
disability.
The inclusion rate for PWD (15.56%) in cash awards $500 or less, was above the
inclusion rate for employees with no disability (14.13%). However the inclusion rate
for PWTD (12.43%) fell below the inclusion rate for employees with no disability.
The inclusion rate for PWD (40.84%) and PWTD (40.69%) was below the inclusion
rate for employees with no disability (54.35%) for cash awards of $501 and greater.
Treasury bureaus that noted the same triggers in their workforce evaluation are
required to address these triggers in their bureau PART J; see specific bureau PART
J’s.
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) Answer: Yes
b. Pay Increases (PWTD) Answer: Yes
The inclusion rate for PWD (2.43%) and PWTD (2.41%) was below the inclusion rate
for employees with no disability (3.64%) for QSI awards.
Treasury bureaus that noted the same triggers in their workforce evaluation are
required to address these triggers in their bureau PART J; see specific bureau PART
J’s.
3. If the agency has other types of employee recognition programs, are PWD
and/or PWTD recognized disproportionately less than employees without
disabilities? (The appropriate benchmark is the inclusion rate.) If "yes",
describe the employee recognition program and relevant data in the text box.
a. Other Types of Recognition (PWD) Answer: N/A
b. Other Types of Recognition (PWTD) Answer: N/A
D. PROMOTIONS
9
Department of Treasury FY 2017
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) Answer: No
ii. Internal Selections (PWD) Answer: No
b. Grade GS-15
i.Qualified Internal Applicants (PWD) Answer: No
ii. Internal Selections (PWD) Answer: No
c. Grade GS-14
i.Qualified Internal Applicants (PWD) Answer: No
ii. Internal Selections (PWD) Answer: No
d. Grade GS-13
i.Qualified Internal Applicants (PWD) Answer: No
ii. Internal Selections (PWD) Answer: No
Relevant pool/Applicants/Promotions Relevant Pool/Applicants/Promotions
GS-13 - PWD: 11.85% - 2.71% - 1.82% PWTD: 3.53% - 0.97% - 0.18%
GS-14 - PWD: 9.00% - 4.33% - 2.72% PWTD: 2.48% - 2.02% - 1.49%
GS-15 - PWD: 8.64% - 2.84% - 2.63% PWTD: 2.31% - 1.09% - 1.32%
SES Vacancy announcements are not posted internally to Treasury or its bureaus. All
SES vacancy announcements are required to be posted externally. Additionally,
Treasury’s systems do not have the capability to identify internal applicant from
external applicants on external vacancy announcements.
Treasury bureaus that noted the same triggers in their workforce evaluation are
required to address these triggers in their bureau PART J. For plans to improve
advancement opportunities for PWD and PWTD within the major occupations listed,
see specific bureau PART J’s.
10
Department of Treasury FY 2017
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) Answer: No
ii. Internal Selections (PWTD) Answer: No
b. Grade GS-15
i.Qualified Internal Applicants (PWTD) Answer: No
ii. Internal Selections (PWTD) Answer: No
c. Grade GS-14
i.Qualified Internal Applicants (PWTD) Answer: No
ii. Internal Selections (PWTD) Answer: No
d. Grade GS-13
i.Qualified Internal Applicants (PWTD) Answer: No
ii. Internal Selections (PWTD) Answer: No
Relevant Pool Applicants/Promotions
GS-13 - PWTD: 3.53% - 0.97% - 0.18%
GS-14 - PWTD: 2.48% - 2.02% - 1.49%
GS-15 - PWTD: 2.31% - 1.09% - 1.32%
SES Vacancy announcements are not posted internally to Treasury or its bureaus. All
SES vacancy announcements are required to be posted externally. Additionally,
Treasury’s bureaus do not have the capability to identify internal applicant from
external applicants on external vacancy announcements.
Treasury bureaus that noted triggers in their workforce evaluation are required to
address these triggers in their bureau PART J. For plans to improve advancement
opportunities for PWD and PWTD within the major occupations listed, see specific
bureau PART J’s.
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) Answer: No
b. New Hires to GS-15 (PWD) Answer: No
c. New Hires to GS-14 (PWD) Answer: No
11
Department of Treasury FY 2017
d. New Hires to GS-13 (PWD) Answer: No
This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking
appropriate steps to be able to report this information as part of the FY 2018 reporting
period.
4. Using the qualified applicant pool as the benchmark, does your agency have a
trigger involving PWTD among the new hires to the senior grade levels? For
non-GS pay plans, please use the approximate senior grade levels. If "yes",
describe the trigger(s) in the text box.
a. New Hires to SES (PWTD) Answer: No
b. New Hires to GS-15 (PWTD) Answer: No
c. New Hires to GS-14 (PWTD) Answer: No
d. New Hires to GS-13 (PWTD) Answer: No
This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking
appropriate steps to be able to report this information as part of the FY 2018 reporting
period.
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
i. Qualified Internal Applicants (PWD) Answer: No
ii. Internal Selections (PWD) Answer: No
b. Managers
i.Qualified Internal Applicants (PWD) Answer: No
ii. Internal Selections (PWD) Answer: No
c. Supervisors
i.Qualified Internal Applicants (PWD) Answer: No
ii. Internal Selections (PWD) Answer: No
This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking
appropriate steps to be able to report this information as part of the FY 2018 reporting
period.
12
Department of Treasury FY 2017
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
i. Qualified Internal Applicants (PWTD) Answer: No
ii. Internal Selections (PWTD) Answer: No
b. Managers
i.Qualified Internal Applicants (PWTD) Answer: No
ii. Internal Selections (PWTD) Answer: No
c. Supervisors
i.Qualified Internal Applicants (PWTD) Answer: No
ii. Internal Selections (PWTD) Answer: No
This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking
appropriate steps to be able to report this information as part of the FY 2018 reporting
period.
7. Using the qualified applicant pool as the benchmark, does your agency have a
trigger involving PWD among the selectees for new hires to supervisory
positions? If "yes", describe the trigger(s) in the text box.
a. New Hires for Executives (PWD) Answer: No
b. New Hires for Managers (PWD) Answer: No
c. New Hires for Supervisors (PWD) Answer: No
This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking
appropriate steps to be able to report this information as part of the FY 2018 reporting
period.
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) Answer: No
b. New Hires for Managers (PWTD) Answer: No
c. New Hires for Supervisors (PWTD) Answer: No
This is not an FY 2017 reporting requirement, Treasury and its bureaus will be taking
appropriate steps to be able to report this information as part of the FY 2018 reporting
period.
13
Department of Treasury FY 2017
Section VI: 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.
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.
A. VOLUNTARY AND INVOLUNTARY SEPARATIONS
Answer: No
In FY 2017, Treasury had 37 Schedule A employees who were eligible for conversion
to competitive service appointments. Of that:
• 31 were timely converted to career status
• 2 were untimely converted
• 2 were not converted based on unsatisfactory performance
2 were involuntarily separated based on FY 2017 budget cuts in the organization.
2. Using the inclusion rate as the benchmark, did the percentage of PWD among
voluntary and involuntary separations exceed that of persons without
disabilities? If "yes", describe the trigger below.
a. Voluntary Separations (PWD) Answer: Yes
b. Involuntary Separations (PWD) Answer: Yes
The inclusion rate for PWD (1.01%) exceeded the rate of persons with no disability
(0.69%) for involuntary separations. The inclusion rate for PWD (10.21%) also
exceeded the inclusion rate for persons with no disability (8.56%) for voluntary
separations.
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).
3. Using the inclusion rate as the benchmark, did the percentage of PWTD among
voluntary and involuntary separations exceed that of persons without targeted
disabilities? If "yes", describe the trigger below.
a. Voluntary Separations (PWTD) Answer: No
b. Involuntary Separations (PWTD) Answer: Yes
The (inclusion rate) for PWTD (0.94%) exceeded the rate of persons with no disability
(0.69%) for involuntary separations. The inclusion rate for PWTD (8.40%) did not
exceed the inclusion rate for persons with no disability (8.56) for voluntary
14
Department of Treasury FY 2017
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.
separations.
During the period of October 1, 2016 through September 30, 2017, 202
permanent/seasonal PWD responded to the Department’s Exit Survey. The overall
responses from PWD were similar to the overall permanent/seasonal employee
responses in that 48% (97) had more than 25 years of service and 76% (153) were
age 50 or older. Of the respondents with disabilities, 31% (63) were veterans. The
most frequently cited reason for separation of PWD was retirement (126 or 62%).
The factor most frequently cited as impacting a PWD’s decision to leave was job
stress (75%). Additional factors frequently cited include office morale (64%); office
organization and alignment with regard to effective and efficient service (51%),
resources to do the job (51%), ability to participate in decisions (48%), access to
developmental opportunities (48%), pay in relation to job responsibilities and
performance (47%), reasonableness of workload (46%), and job description in relation
to actual duties and responsibilities (46%).
71% of the respondents indicated their work experience was generally positive and
64% stated they would recommend Treasury as a good place to work. PWD (69%)
were slightly less likely to indicate that they would recommend Treasury as a good
place to work, as compared to the 72% of all respondents.
B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES
Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform job applicants
and employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. §
794(b)), concerning the accessibility of agency technology, and the Architectural Barriers Act of
1968 (42 U.S.C. § 4151 – 4157), concerning the accessibility of agency facilities. In addition,
agencies are required to inform individuals where to file complaints if other agencies are
responsible for a violation.
1. Please provide the internet address on the agency's public website for its
notice explaining employees' and applicants' rights under Section 508 of the
Rehabilitation Act, including a description of how to file a complaint.
The overall “Accessibility” page on the public Treasury.gov website,
https://www.treasury.gov/accessibility/Pages/default.aspx, provides three links with
resources for Persons with Disabilities.
Information on how to file a complaint can be found
The following address, located on the Treasury.gov public website, provides
information and explains employee and applicant rights under Section 508 of the
Rehabilitation Act: https://www.treasury.gov/accessibility/Pages/web.aspx.
Additionally, the following link (which is also located on the “Accessibility” page),
provides information regarding how to file a complaint of discrimination:
https://www.treasury.gov/about/organizational-
structure/offices/Mgt/Documents/Section508_Complaint_Processing.pdf.
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.
Regarding physical accessibility, the following address is located under the
15
Department of Treasury FY 2017
“Accessibility” page on the public Treasury.gov website:
https://www.treasury.gov/accessibility/Pages/physical.aspx.
Additionally, the following link (which is also located on the “Accessibility” page,
provides information regarding how to file a complaint of discrimination:
https://www.treasury.gov/accessibility/Pages/disability.aspx.
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.
n FY 2017, OCRD conducted two accessibility reviews of buildings occupied by DO
employees – 1750 Pennsylvania Avenue and Freedman’s Bank Building (Treasury
Annex).
For the Freedman’s Bank Building, the Treasury Library Area was under review.
Although the accessibility review indicated that the space is mostly accessible,
important requirements are not being met. OCRD identified ten (10) deficiencies
requiring a corrective action. The review was signed by Mariam Harvey, Director,
OCRD, and submitted to the Deputy Assistant Secretary for Operations on May 26,
2017.
For the Treasury Leased Space, 1750 Pennsylvania Avenue, the review also
indicated that the space was mostly accessible, but that there were important
requirements not met. OCRD identified twenty-eight (28) deficiencies that required a
corrective action. The review was signed by Mariam Harvey, Director, OCRD, and
submitted to the Deputy Assistant Secretary for Operations on May 12, 2017.
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.)
Each bureau is responsible for independently processing their request for reasonable
accommodations. See below:
Average Days by Bureau:
BEP 10
DO 20
FinCEN 15
FS 6
Mint 20
IRS 66
OCC 10
TIGTA 10
TTB 40
Overall average of 22 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
16
Department of Treasury FY 2017
approved accommodations, conducting training for managers and supervisors,
and monitoring accommodation requests for trends.
Overall, the Department has an effective Disability Program, supported by various
policies, procedures, and practices, as evidenced by timely processing requests for
accommodations. Mandatory new managers and supervisors training includes
responsibilities on providing reasonable accommodations. Throughout FY-2017
bureaus provided reasonable accommodations guidance via training courses,
newsletters and postings on its intranet websites (see specific bureau submission for
details). The Department established a Treasury-wide sign language interpreters
contract to provide an effective and efficient procedure for providing sign language
interpreters. Bureaus are responsible for monitoring reasonable accommodation data
for trends relating to the workforce. z
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,
timely providing approved services, conducting training for managers and supervisors, and
monitoring PAS requests for trends.
OPM established the requirement for Personal Assistance Services to be
implemented in January 2018. Therefore, for FY 2017, Treasury did not have a policy
or procedure in place to implement the PAS requirement. During FY 2018, first
quarter, Treasury EEO established a Personal Assistance Services (PAS) Working
Group. The initial purpose of this working group is to establish and finalize a
Statement of Work (SOW) for procuring a Treasury-wide PAS contact. This contract
will allow bureaus 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 Department will follow
existing reasonable accommodation policy and procedures to provide PAS.
Section VII: EEO Complaint and Findings Data
A. EEO COMPLAINT DATA INVOLVING HARASSMENT
1. During the last fiscal year, did a higher percentage of PWD file a formal EEO
complaint alleging harassment, as compared to the government-wide average?
Answer: No
2. During the last fiscal year, did any complaints alleging harassment based on
disability status result in a finding of discrimination or a settlement agreement?
Answer: Yes
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.
17
Department of Treasury FY 2017
Treasury had one FAD, hostile work environment based on disability and reprisal
when, among other things, complainant was denied reasonable accommodation and
issued a counseling memorandum; where training and consideration of disciplinary
action were ordered – In addition to appropriate relief for the complainant, the
following corrective action(s) were taken: training was provided and disciplinary action
was considered but found not to be warranted.
B. EEO COMPLAINT DATA INVOLVING REASONABLE
ACCOMMODATION
1. During the last fiscal year, did a higher percentage of PWD file a formal EEO
complaint alleging failure to provide a reasonable accommodation, as
compared to the government-wide average?
Answer: Yes
2. During the last fiscal year, did any complaints alleging failure to provide
reasonable accommodation result in a finding of discrimination or a settlement
agreement?
Answer: Yes
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.
Six FAD’s: (1) disability discrimination for failure to provide reasonable
accommodation; training was ordered for all responsible management officials in
office where complainant worked; training is pending; (2) disability discrimination for
denial of reasonable accommodation and termination for missing too much time from
work during probationary period; training and disciplinary action were ordered;
training was provided; disciplinary action is pending; (3) disability discrimination for
unnecessary delay in providing operable adaptive equipment, which had been
approved pursuant to request for reasonable accommodation; it was determined that
management acted in good faith in attempting to provide effective accommodation; (4)
disability discrimination for failure to provide reasonable accommodation in line with
complainant’s physician’s recommendation or even act on her request for reasonable
accommodation until the EEO complaint was filed; training on the responsibilities of
management under the Rehabilitation Act was ordered and was provided; disciplinary
action was not ordered because the individual who was primarily responsible for
processing the original reasonable accommodation request was no longer employed
with the Agency; (5) disability discrimination for delay in providing reasonable
accommodation; training and consideration of disciplinary action were ordered;
training was provided; decision on disciplinary action is pending; and (6) disability
discrimination for failure to provide reasonable accommodation and failure to maintain
confidential medical information in separate medical file; training and consideration of
disciplinary action were ordered; training was provided and oral counseling was
administered to four management officials.
Section VIII: Identification and Removal of Barriers
18
Department of Treasury FY 2017
Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests
that a policy, procedure, or practice may be impeding the employment opportunities of a
protected EEO group.
1. Has the agency identified any barriers (policies, procedures, and/or practices)
that affect employment opportunities for PWD and/or PWTD?
Answer: No
2. Has the agency established a plan to correct the barrier(s) involving PWD
and/or PWTD?
Answer: No
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.
Trigger
Barrier(s)
Objective(s)
Responsible Official(s)
Performance Standards Address
the Plan?
(Yes or No)
Barrier Analysis Process Completed?
(Yes or No)
Barrier(s) Identified?
(Yes or No)
Sources of Data
Sources
Reviewed?
(Yes or No)
Identify Information Collected
Workforce Data Tables
Complaint Data (Trends)
Grievance Data (Trends)
Findings from Decisions (e.g.,
EEO, Grievance, MSPB, Anti-
Harassment Processes)
Climate Assessment Survey (e.g.,
FEVS)
Exit Interview Data
Focus Groups
Interviews
Reports (e.g., Congress, EEOC,
MSPB, GAO, OPM)
Other (Please Describe)
19
Department of Treasury FY 2017
Target Date
(mm/dd/yyyy)
Planned Activities Sufficient
Staffing &
Funding
(Yes or No)
Modified
Date
(mm/dd/yyyy)
Completion
Date
(mm/dd/yyyy)
Fiscal Year Accomplishments
4. Please explain the factor(s) that prevented the agency from timely completing
any of the planned activities.
There were no planned activities to complete
5. For the planned activities that were completed, please describe the actual
impact of those activities toward eliminating the barrier(s).
There were no planned activities for 2017
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.
There were no planned activities for 2017
20