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Home >Policies & Resources >Resources >MD-715 >The Model EEO Program

Presentation - The Model EEO Program

The Model EEO Program

  • EEOC Management Directive 715 (MD-715)

Title VII - Section 717

  • Requires each federal agency to:
    • Make all personnel actions free from discrimination based on race, color, religion, sex or national origin
    • Maintain an "affirmative program of equal employment opportunity" for all employees and applicants
    • Submit annual plan and/or updates to EEOC for approval

Rehabilitation Act - Section 501

  • Make all personnel actions free from discrimination based on disability
  • Maintain an "affirmative action program plan for the hiring, placement and advancement of people with disabilities"
  • Submit annual plan and/or updates to EEOC for approval

Which Agencies are Covered?

  • All executive branch departments and agencies, including the U.S. Postal Service and the Postal Rate Commission

What Does MD-715 Require?

  • Develop and maintain model EEO program
  • Ensure all employment decisions are free from discrimination
  • Examine employment policies, procedures and practices to identify and remove barriers to equal opportunity
  • Develop plans to correct identified barriers
  • Report plans and progress to EEOC

Essential Elements of a Model EEO Program

  • Demonstrated commitment from agency leadership
  • Integration of EEO into the agency's strategic mission
  • Management and program accountability
  • Proactive prevention of unlawful discrimination
  • Efficiency
  • Responsiveness and legal compliance

I. Element One: Demonstrated commitment from agency leadership

  • Equal employment opportunity must be:
    • Embraced by agency leadership
    • Communicated through the ranks from the top down
  • EEO principles must be made a fundamental part of the agency's culture
  • Agency head must issue annual EEO and anti- harassment policy statements

II. Element Two: Integration of EEO into the agency's strategic mission

  • EEO Director has regular access to agency head and senior management
  • EEO professionals are involved in all major human resources decisions
  • EEO programs have sufficient resources
  • Managers and employees are involved in the implementation of the agency's Title VII and Rehabilitation Act programs

III. Element Three: Management and program accountability

  • Conduct regular internal EEO program audits
  • Establish procedures to prevent all forms of discrimination
  • Evaluate managers and supervisors on efforts to ensure equality of employment opportunity
  • Maintain effective reasonable accommodation procedures
  • Maintain clearly defined and fair personnel policies, selection and promotion procedures, evaluation procedures, rules of conduct and training systems

IV. Element Four: Proactive prevention of unlawful discrimination

  • Conduct a self-assessment on at least an annual basis to monitor progress and identify areas where barriers may operate to exclude certain groups
  • Develop strategic plans to eliminate identified barriers

V. Element Five: Efficiency

  • Maintain an efficient, fair and impartial complaint resolution process
  • Separate investigation and adjudication functions from the legal defense arm of the agency
  • Establish and encourage the widespread use of alternative dispute resolution (ADR)
  • Maintain effective data collection systems on workforce, applicant flow and complaint tracking

VI. Element Six: Responsiveness and legal compliance

  • Ensure full compliance with Title VII and Rehabilitation Act, including EEOC regulations, orders and other written instructions
  • Report agency program efforts and accomplishments to EEOC
  • Comply with final EEOC orders for corrective action and relief

Sources for Information to Identify Potential Barriers

  • Analyze workforce statistics
  • Review EEO complaints
  • Talk to EEO and human resources staff
  • Talk to unions and advocacy groups
  • Conduct surveys, focus groups and exit interviews
  • Review studies by outside agencies

Some Employment Policies, Procedures and Practices That Should Be Examined for Barriers

  • Hiring
  • Promotions and other internal selections
  • Attainment of supervisory and management positions
  • Training opportunities and developmental opportunities
  • Performance incentives and awards
  • Disciplinary actions
  • Separations

Plan to Eliminate Barriers

  • Design corrective plan to address the identified causes of barriers
  • Even if barrier is job-related, explore alternatives that serve the same purpose and that have less impact on a particular group of employees
  • Progress should be measurable and agency officials held accountable
  • Periodic reassessments should be done for need to adjust plan if necessary
  • Report plan and progress to EEOC annually

Additional Barrier Analyses Under the Rehabilitation Act

  • Compliance with Executive Order 13164 and EEOC guidance for reasonable accommodation procedures
  • Compliance with Architectural Barriers Act
  • Accessibility of electronic and information technology required by Section 508 of the Rehabilitation Act

Special Emphasis for Targeted Disabilities

  • MD-715 requires agencies with 1,000 or more employees to:
    • Establish goals for employment of individuals with targeted disabilities
    • Establish goals for the advancement of individuals with targeted disabilities
    • Show measurable progress each fiscal year

Further Information

Additional information will be available on this web site as MD-715 is implemented.

Contacting OEODM

Office of Equal Opportunity & Diversity Management
2 Center Drive, Third Floor
Bethesda MD 20892-0245
(301) 496-6301 tel.
(301) 496-9755 or 480-3122 tty
(301) 402-0994 fax