Board of Governors of the Federal Reserve System

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), Equal Employment Opportunity Commission (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.

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.

Using the goal of 12 percent 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.

	Yes	No
a. Cluster GS-1 to GS-10 (PWD)	X	0
b. Cluster GS-11 to SES (PWD)	X	0

Using the goal of 2 percent 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.

	Yes	No
a. Cluster GS-1 to GS-10 (PWTD)	X	0
b. Cluster GS-11 to SES (PWTD)	X	0

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

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

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	No
Designated sufficient qualified personnel	X	0

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	7	0	0	Tameika Pope, Chief Human Capital Officer, Management Division, Human Resources [email protected]
Answering questions from the public about hiring authorities that take disability into account	7	0	0	Tameika Pope, Chief Human Capital Officer, Management Division, Human Resources [email protected]
Processing reasonable accommodation requests from applicants and employees	7	0	0	Tameika Pope, Chief Human Capital Officer, Management Division, Human Resources [email protected]
Section 508 compliance	1	0	1	Melissa Lasbury, Manager, User Experience Services, Information Technology Division [email protected]
Architectural Barriers Act compliance	0	0	1	Stephen Pearson, Asst. Director, Facilities Management Division [email protected]
Special Emphasis Program for PWD and PWTD	3	0	0	Sheila Clark, Chief Diversity Officer, Office of Diversity & Inclusion [email protected]

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	No
Provided disability program staff with sufficient training	X	0

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	No
Provided sufficient funding and other resources	X	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.

A. Plan to Identify Job Applicants with Disabilities

Describe the programs and resources the agency uses to identify job applicants with disabilities, including individuals with targeted disabilities.

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.

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.

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	No	N/A
Provided training to all hiring managers	0	0	X

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.

C. Progression Towards Goals (Recruitment and Hiring)

1. Using the goals of 12 percent for PWD and 2 percent 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.

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

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.

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

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 MCO? If "yes," please describe the triggers below.

	Yes	No	N/A
a. Qualified Applicants for MCO (PWD)	0	0	X
b. Qualified Applicants for MCO (PWTD)	0	0	X

4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among employees promoted to any of the MCO? If "yes," please describe the triggers below.

	Yes	No	N/A
a. Promotions for MCO (PWD)	0	0	X
b. Promotions for MCO (PWTD)	0	0	X

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.

B. Career Development Opportunities

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

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
Fellowship programs
Mentoring programs
Coaching programs
Training programs
Detail programs
Other career development programs

In 2022, the Board's human resources information system does not capture the data requested in this table.

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.

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

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.

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

C. Awards

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.

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

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.

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

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.

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

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.

		Yes	No	N/A
a. SES	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X
b. Grade GS-15	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X
c. Grade GS-14	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X
d. Grade GS-13	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X

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.

		Yes	No	N/A
e. SES	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X
f. Grade GS-15	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X
g. Grade GS-14	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X
h. Grade GS-13	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X

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.

	Yes	No	N/A
i. New Hires to SES (PWD)	0	0	X
j. New Hires to GS-15 (PWD)	0	0	X
k. New Hires to GS-14 (PWD)	0	0	X
l. New Hires to GS-13 (PWD)	0	0	X

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.

	Yes	No	N/A
m. New Hires to SES (PWTD)	0	0	X
n. New Hires to GS-15 (PWTD)	0	0	X
o. New Hires to GS-14 (PWTD)	0	0	X
p. New Hires to GS-13 (PWTD)	0	0	X

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.

		Yes	No	N/A
a. Executives	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X
b. Managers	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X
c. Supervisors	i. Qualified Internal Applicants (PWD)	0	0	X
	ii. Internal Selections (PWD)	0	0	X

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.

		Yes	No	N/A
a. Executives	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X
b. Managers	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X
c. Supervisors	i. Qualified Internal Applicants (PWTD)	0	0	X
	ii. Internal Selections (PWTD)	0	0	X

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.

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

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.

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

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	No	N/A
Conversion of Schedule A employees to competitive service	0	0	X

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.

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

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.

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

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.

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.

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.

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.

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.)

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.

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.

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	No	N/A
Formal EEO complaint alleging harassment	0	X	0

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	No	N/A
Complaints alleging harassment based on disability status result in a finding of discrimination or a settlement agreement	0	X	0

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.

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	No	N/A
PWD file a formal EEO complaint alleging failure to provide a reasonable accommodation	0	X	0

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	No	N/A
Complaints alleging failure to provide reasonable accommodation result in a finding of discrimination or a settlement agreement	0	X	0

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.

Section VII: Identification and Removal of Barriers

Element D of MD-715 requires agencies to conduct a barrier analysis when a trigger suggests that a policy, procedure, or practice may be impeding the employment opportunities of a protected EEO group.

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

	Yes	No
Agency identified any barriers	X	0

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

	Yes	No	N/A
Established a plan to correct the barrier(s) involving PWD and/or PWTD	X	0	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.

Trigger 1	Participation of PWD and PWTD in the Board workforce is below each group's benchmark goals of 12 percent and 2 percent, respectively. In 2022, of the 2929 permanent Board employees, 7 percent were PWD and 0.85 percent were PWTD.
Barrier(s)	The identification of barriers is an ongoing process. However, the representation of PWD and especially PWTD improved among new hires in 2022, which suggest that the Board's current outreach and recruitment practices of PWTD are producing results.
Objective(s)	To steadily identify and eliminate barriers to the increased participation of PWD and PWTD in the Board workforce.

Responsible Official(s)	Performance Standards Address the Plan? (Yes or No)
Sheila Clark, Chief Diversity Officer, Office of Diversity, Equity, and Inclusion (ODEI)	No
Andre M. Smith, D&I/EEO Compliance Manager	No

Barrier Analysis Process Completed? (Yes or No)	Barrier(s) Identified? (Yes or No)
No	No

Sources of Data	Sources Reviewed? (Yes or No)	Identify Information Collected
Workforce data tables	Yes	Workforce data tables disability
Complaint data (trends)	Yes	The Board's No FEAR Act quarterly report on the Board's public website identifies complaint trends filed based on disability.
Grievance data (trends)	N/A	N/A
Findings from decisions (e.g., EEO, Grievance, MSPB, Anti-Harassment Processes)		The Board has had no disability or reasonable accommodation findings in 2022
Climate Assessment Survey (e.g., FEVS)	No	N/A
Exit interview data	No	Current exit interviews do not collect information about the specific reasons for PWD separations, so insufficient information is available to consider in the barrier analysis.
Focus groups	Yes	ODEI EEO Compliance staff regularly engages with ADVANCE ERG to hear and respond to disability-related issues and concern.
Interviews	No	N/A
Reports (e.g., Congress, EEOC, MSPB, GAO, OPM)	Yes	ODEI EEO Compliance staff regularly review EEOC disability reports.
Other (please describe)	N/A	N/A

Target Date (mm/dd/yyyy)	Planned Activities	Sufficient Staffing & Funding (Yes or No)	Modified Date (mm/dd/yyyy)	Completion Date (mm/dd/yyyy)
12/31/2023	Reinstitute its pilot program with local non-profit Seeking Employment, Equality, & Community (SEEC) to source PWD and PWTD for on-the-job training internships.	Yes
12/31/2023	Consult with People, Strategy & Operations (PSO) to identify feasible ways to capture the necessary applicant flow data to conduct effective recruitment/hiring trigger and barrier analyses.	Yes
09/30/2022	Participate in Bender Consulting virtual recruiting fairs in recruiting PWTD.		12/31/23
6/30/2024	Partner with PSO in developing a best practices guide for hiring managers in the recruiting and hiring of PWTD.
Ongoing	Train hiring managers on mitigating bias in the talent acquisition.	Yes
Ongoing	Continue ongoing strategic engagement with the ADVANCE ERG in the identification of barriers and effective strategies and actions to remove barriers, improve the work experience for individuals with disabilities.	Yes

Fiscal Year	Accomplishments
2020	ADVANCE, the Board's ERG for PWD and PWTD, issued a "Requesting a Reasonable Accommodation" guide at the Board and hosted webinars on dealing with pandemic-related stress.
2020	The Board Chair, Administrative Governor, and the Chief Operating Officer met with the leaders of ADVANCE in December 2020. The meeting enabled the ERG leaders to inform the Board's senior leadership about ADVANCE's mission, activities, and annual operating plans. The meeting also included discussion regarding diverse hiring, retention, development, promotion, and workforce and succession planning.
2020	Effective April 3, 2020, the Board adopted "Procedures for Providing Personal Assistance Services (PAS) for Employees with Targeted Disabilities."
2020	The Board updated its Reasonable Accommodation (RA) procedures to clarify how applicants should file a request for RA and/or PAS during the hiring process.
2021	In January 2021, ODI initiated Unity Month to encourage dialogue among and between focus groups. Unity Month included a presentation demonstrating the challenges and achievements of Board employees with targeted disabilities and a discussion of disability etiquette
2021	The Board identified additional recruiting avenues for PWD and especially PWTD, such as virtual career fairs during the COVID-19 pandemic and into the future.
2021	ODEI conducted a comprehensive analysis of EEO contacts by basis and issue to capture information about the unique benefits or barriers that PWD and PWTD experienced during the pandemic's full-time telework experience. Lessons learned will be used as best practices in the administration and provision of complex reasonable accommodation in the future.
2021	During National Disability Employment Awareness Month, the Board hosted a panel discussion event to highlight diversity within the disability experience.
2022	ODEI staff partnered with Board Talent Acquisition, the recruiting arm of Board Human Resources, to explore options for partnering with Bender Consulting to enhance recruiting of PWTD. An initial meeting was held on May 17, 2022, with action items and follow-ups planned.

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).

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.