U.S. DEPARTMENT OF
AGRICULTURE
WASHINGTON, D.C. 20250
DEPARTMENTAL MANUAL |
Number: 4310-001 |
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SUBJECT: Instructions for Preparing AEP Plans, Accomplishment Reports, and Updates |
DATE: July 24, 1991 |
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DEPARTMENT OF AGRICULTURE
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20250
FOREWORD
This manual sets forth procedures for preparing and submitting
Multi-Year Affirmative Employment Program (AEP) Plans, Annual AEP
Accomplishment Reports, and Annual AEP Updates. The Affirmative
Employment Program supports the Department's Framework for Change
objective to build a diverse work force approximating the nation's labor
force at entry, mid, senior and executive levels by the year 2000. All
agencies will implement a strategic framework to achieve work force
diversity wherever underrepresentation exists in occupational
categories, series, grade levels and pay plans.
Since Departmental Notice 4310-3 expired on September 30, 1988, the
Department issued several memoranda of instruction for preparing AEP
plans; and reports. By issuing a single set of instructions, however,
we hope to increase the Department's reporting efficiency.
Agency heads, equal opportunity staffs, and personnel staffs of every
major operating component were invited to review and comment on this
manual during its development. Their comments were numerous and
thoughtful; each was considered and most were incorporated. Those who
must develop and implement the plans and reports, therefore, have shaped
this document to meet the needs of the Department's major operating
components, the needs of the Department, and the requirements of
legislative and other over- sight bodies.
Should you wish further information about the instructions or the plans
and reports referenced in this manual, please contact the Office of
Advocacy and Enterprise.
Charles R. Hilty
Associate Deputy Secretary
1 PURPOSE
This manual establishes U.S. Department of Agriculture (USDA)
reporting requirements and prescribes policies, procedures,
guidance, and formats for preparing Multi-Year Affirmative
Employment Program Plans, Annual AEP Accomplishment Reports, and
Annual AEP Plan Updates. These procedures apply to all USDA
components except those listed below which are exempted from the
provisions of EEO-MD-714 and this manual due to the size of their
work force.
Each exempted component must submit a statement signed by its head,
affirming its commitment to equal employment opportunity. Form
AD-1, "Commitment to Equal Employment Opportunity," will be used
for this purpose (See Figure 1).
Agricultural Cooperative Service
Board of Contract Appeals
Economic Analysis Staff
Office of Administrative Law Judges
Office of Energy
Office of the Consumer Advisor
Office of the Secretary
Office of Transportation
World Agricultural Outlook Board
2 SPECIAL INSTRUCTIONS
a Multi-Year AEP Plans, Annual AEP Accomplishment Reports, and
Annual AEP Plan Updates will be prepared in accordance with
EEOC Equal Employment Opportunity Management Directive 714
(EEO-MD-714, found at Appendix A) and this manual.
b Reporting levels will coordinate the development of these
plans and reports with EEO and Personnel Staffs.
c AEP Plan requirements not specifically addressed in this
manual shall be carried out in accordance with the provisions
of EEO-MD-714.
d Reporting levels will use specifically designed EEOC and AD
reporting forms.
e Reporting levels will refer to EEO-MD-714 for EEOC forms. AD
forms are found in figures 1-3.
f Reporting levels will submit AEP plans and reports to OAE
within 15 days following the end of the first quarter of each
fiscal year.
3 POLICY
It is the policy of the Department of Agriculture to develop
department-wide Multi-Year AEP Plans, Annual AEP Accomplishment
Reports and Annual AEP Plan Updates based on Major operating
component (MOC) plans and reports.
This manual supplements EEO-MD-714 and establishes a system for
reporting these plans and reports.
4 ABBREVIATIONS
AEP - Affirmative Employment Program
CLF - Civilian Labor Force
DM - Departmental Manual
EEO - Equal Employment Opportunity
EEOC - Equal Employment Opportunity Commission
FAA - Federal Affirmative Action
MICA - Manifest Imbalance or Conspicuous Absence
MOC - Major Operating Component
OAE - Office of Advocacy and Enterprise
OFM/NFC - Office of Finance and Management's National Finance
Center
SRL - Subordinate Reporting Level
PATCOB - Professional, Administrative, Technical, Clerical, and
Other White Collar occupational categories and the Blue
Collar occupational category.
5 FORMS
AEP Plan Forms. The following forms will be used in preparing and
submitting AEP plans and reports. The forms may be produced
locally or they may be obtained from the Landover Warehouse.
a Form AD-1, Commitment to Equal Employment Opportunity, must be
submitted by MOCs exempted from the provisions of EEO-MD-714
and this manual.
b Form AD-878, Numerical Objectives By PATCOB, will be used to
report established numerical objectives for the period the AEP
plans and reports cover.
c Form AD-855, Numerical Objectives by Major Occupation, will be
used to report established numerical objectives for the period
the AEP plans and reports cover.
6 DEFINITIONS
a Agency. The U.S. Department of Agriculture.
b Major Operating Components. All USDA program components and
staff offices, e.g., FmHA, FS, OP, OFM.
c Major Occupation. One which is central to the mission of the
agency or one in which there are 50 or more employees.
d Headquarters. Lead organizational component of a MOC with
primary management and administrative functions for developing
and coordinating MOC-wide policies, practices, and procedures.
e Subordinate Reporting Level. Organizational sub-unit below the
MOC level with 300 or more employees.
f Reporting Level. Each organizational level required to submit
plans and reports.
7 RESPONSIBILITIES
a OAE will:
(1) Provide technical assistance and guidance to MOCs;
(2) Review and approve MOC and Headquarters AEP plans and
reports prior to submission to EEOC;
(3) Coordinate the development of agency-wide plans and
reports;
(4) Monitor, evaluate, and aggregate MOC-wide AEP
accomplishments, goals, and objectives as a basis for
developing agency AEP plans and reports;
(5) Coordinate with EEOC, when appropriate, MOC requests for
variances from the mandatory use of national CLF data and
other requirements;
(6) Monitor timely and accurate delivery of OFM/NFC generated
work force data to MOCS; and
(7) Provide periodic status reports to the Secretary and MOC
heads.
b MOCs will:
(1) Provide technical assistance and guidance to SRLs
consistent with EEOC and USDA instructions;
(2) Review and approve SRL AEP plans and reports prior to
submission to the appropriate EEOC/FAA unit;
(3) Coordinate the development of MOC AEP plans and reports,
including headquarters plans and reports if applicable;
(4) Monitor, evaluate, and aggregate headquarters and SRI,
AEP accomplishments, goals, and objectives as a basis for
developing MOC AEP plans and reports;
(5) Submit MOC AEP plans and reports to OAE for review and
approval, including headquarters plans; and reports if
applicable; and
(6) Submit requests for variances from the mandatory use of
CLF data and other requirements to OAE.
c SRLs will:
(1) Coordinate the development of AEP plans and reports in
accordance with EEOC and USDA requirements;
(2) Submit AEP plans and reports to MOC headquarters for
review and approval prior to submission to the
appropriate EEOC/FAA unit; and
(3) Provide periodic status reports to MOC headquarters.
8 PROCEDURES
a Multi-Year Affirmative Employment Program Plan
(1) Management must actively participate in the development
of SRL, MOC, and headquarters AEP plans.
(2) MOC's with SRLs will submit MOC plans and headquarters
plans to OAE. MOCs with no SRLs will submit MOC plans
only (See Appendix B).
(3) MOC and headquarters AEP Plans are due to OAE within 15
days following the end of the first quarter of each
fiscal year.
(4) OAE will incorporate information contained in MOC plans
into an agency plan.
(5) All reporting levels will use OFM/NFC generated 4th
quarter work force data as the basis for work force
analyses. In addition, all reporting levels will use
EEO-MD-707, Appendix B, for national CLF data comparison
or other data approved by EEOC.
SRLs will compare administrative, technical, clerical,
and other white-collar occupations and blue-collar
occupations with appropriate geographical CLF data and
will compare the professional occupations with national
CLF data. Any variance from the use of these data must
be approved by EEOC. SRLs may use national CLF data to
compare administrative, technical, clerical, and other
white-collar occupations and blue-collar occupations if
they recruit nationally for these positions or if the
work force analysis justifies it.
(6) Each reporting level will submit an EEO policy statement
signed by the current MOC or SRL head.
(7) Each reporting level will provide a list, by title, of
all officials with designated EEO responsibilities; e.g.,
MOC or SRL heads, managers, supervisors, special emphasis
program managers etc., and a brief description of their
respective EEO duties.
(8) Each reporting level will prepare a Plan for the
Prevention of Sexual Harassment, identifying responsible
officials, specific action items, and target dates for
completing the action items.
(9) Each reporting level will address, in narrative form,
each item listed under the eight program elements in the
Program Analysis (Appendix A, pp. 8-12). The narratives
must accompany the plan at each reporting level. Appendix
C provides guidance for conducting the program analysis.
(10) Each reporting level will prepare a Report of objectives
and Action Items describing all problems/barriers and
associated actions identified in the program analysis.
Reporting levels must describe the same problems/barriers
and associated actions identified on the Problem/Barrier
Identification form.
(11) Reporting levels will establish numerical objectives for
each job category or major occupation where a comparison
of the work force and the CLF reveals MICA in that job
category or major occupation. Numerical objectives are
intended to serve as a strategy for achieving work force
diversity commensurate with the appropriate CLF or
approved Available Labor Force data. Further, they must
be:
(a) temporary and intended as a remedy for significant
imbalances of minorities and women in the affected
jobs;
(b) subject to change in relationship to changes in work
force composition;
(c) designed to eliminate existing imbalances without
trammeling the rights of non-minorities or
maintaining numerical proportionality; and
(d) based on candidate availability and the number of
projected vacancies.
(12) MOC's and SRLs will consult their personnel and budget
officers for assistance with vacancy projections when
establishing numerical objectives.
(13) Each reporting level will report numerical objectives on
Forms AD-878 (Figure 2) and AD-855 (Figure 3), or submit
DN Reports 714-6 and 7, described in section 9 d(l) of
this manual.
(14) Plan submissions for all reporting levels must include
pp. 1-10 from Exhibit 1 of EEO-MD-714; Form AD-878 or DN
Report 714-6, Numerical objectives by PATCOB; and Form AD
855 or DN Report 714-7, Numerical Objectives by Major
Occupation.
b Annual Affirmative Employment Program Accomplishment Report
(1) MOCs will submit annual MOC and headquarters AEP
Accomplishment Reports to OAE by the end of the first
quarter of each fiscal year.
(2) SRLs will submit Annual AEP Accomplishment: Reports to
their MOC Headquarters for review and approval prior to
submission to the appropriate EEOC/FAA unit.
(3) AEP accomplishment reports must be consistent with
objectives established in the Multi-Year Plan.
(4) All reporting levels will report accomplishments on EEOC
Form 568 (Appendix A, pp. 38-43).
(5) Annual submissions will contain the following:
(a) Statistical Analysis - Each reporting level will
conduct a statistical analysis of the work force
using NFC generated 4th quarter data. The analysis
should be reported in narrative form and cover the
work force by PATCOB, grade groupings, grade levels,
and major occupations. It must include an
identification of employment trends, a description
of changes in the work force, and a comparison of
the current work force with that of the previous
year.
(b) Objectives/Action Items - Each reporting level will
report progress made in achieving objectives and
action items, including numerical objectives. Where
there has been no progress, the unit must cite the
reason(s).
(c) Noteworthy Activities/Initiatives - All reporting
levels will report noteworthy activities or
initiatives implemented during the previous fiscal
year.
(6) Annual accomplishment reports for all reporting levels
must include pp. 1-6 from Exhibit 3 of EEO- MD-714.
c Annual Affirmative Employment Program Plan Update
(1) An Annual AEP Plan Update is necessary when there is a
major change in the organizational structure or work
force.
(2) The following are examples of some of the items and
circumstances under which an update is required:
(a) policy statements when MOC or SRL heads change;
(b) organizational charts when MOC or SRL structures
change;
(c) program analyses, problem/barrier identification
forms, reports of objectives/action items, and the
Plans for the Prevention of Sexual Harassment when
there are modifications to these areas of the plan.
(3) All reporting levels will use the appropriate pages of
EEOC Form 566. To assist in identifying updates, the
word "update" should be typed in the upper right hand
corner of all pages.
(4) Submissions, if appropriate, should accompany the Annual
AEP Accomplishment Report.
(5) An AEP Plan Update must address achieved and unachieved
action items.
9 EEO STATISTICAL DATA
a OFM/NFC will forward to designated reporting levels EEO
statistical reports containing information which meets
EEO-MD-714 requirements, assists in monitoring EEO
accomplishments, and facilitates report preparation.
b Current geographical breakouts for all EEO statistical reports
that are not reported by individual states are as follows:
Worldwide (excluding Hawaii, Guam, and Puerto Rico)
Hawaii only
Guam only
Puerto Rico only
c Requests for geographical breakouts other than those listed
above must be submitted in writing to OAE
d Accomplishment Reports for EEOC will include an "as of" date,
a "run" date, and numbered pages.
(1) The quarterly statistical reports generated by OFM/NFC
are as follows:
DN-714-1 - Change in Work force EEO Profile by Pay Level
DN-714-2 - Change in Work force EEO Profile by Series
with 50 or More
DN-714-3 - Change in Work force EEO Profile by Pay Level
DN-714-4 - Distribution of EEO Groups and
Underrepresentation Indices by, PATCOB and
Pay Level
DN-714-5 - Distribution of EEO Groups and
Underrepresentation Indices by, Series and
Pay Level
DN-714-6 - Numerical Objective Accomplishments by PATCOB
DN-714-7 - Numerical Objective Accomplishments by Series
with 50 or More
DN-714-8 - Internal Movement Goal Accomplishments by
PATCOB
DN-714-9 - Internal Movement Goal Accomplishments by
Series with 50 or More 10
DN-714-10 - Separations by PATCOB and Pay Level
DN-714-11 - Separations by PATCOB, Series, and Pay Level
DN-714-12 - Promotions by PATCOB and Pay Level
DN-714-13 - Promotions by PATCOB, Series, and Pay Level
DN-714-14 - Awards by PATCOB and Pay Level
DN-714-15 - Awards by PATCOB, Series, and Pay Level
DN-714-16 - Training Instances by PATCOB and Pay Level
DN-714-17 - Training Instances PATCOB, Series, and Pay
Level
(2) Reports DN-714-6 through 9 will satisfy the reporting
requirement of EEOC Forms 568.
(3) OFM/NFC will divide DN-714-10 and 11 reports into two
categories of voluntary and involuntary separation-type
nature of action codes which are furnished by the Office
of Personnel.
(4) OFM/NFC will divide DN-714-12 and 13 reports into two
categories of competitive and noncompetitive
promotion-type nature of action codes which are furnished
by the office of Personnel.
(5) OFM/NFC will divide DN-714-14 and 15 reports into the
following five categories:
(a) Quality Step Increases
(b) Cash Awards for Suggestions
(c) Cash Awards for Performance
(d) Cash Awards for Special Act or Service
(e) Cash Awards for Invention
(6) OFM/NFC will divide DN-714-16 and 17 reports by the
following types of training:
(a) Executive and Management
(b) Supervisory
(c) Legal, Medical, Scientific, or Engineering
(d) Administrative Analysis
(e) Specialty and Technical
(f) Clerical
(g) Trade or Craft
(h) Orientation
(i) Adult Basic Education
e EEO Tracking Reports
(1) Employment & Goals Summary and Employment & Goals Summary
by Occupational series
(2) Cumulative Gains & Losses Summary and Cumulative Gains &
Losses Summary by Occupational Series
(3) Grade Distribution Summary and Grade Distribution Summary
by Occupational series
(4) Occupational Series Summary - Percentages of
Representation
(5) Occupational Series Summary - Average Grade
f Other EEO Reports
(1) Employment & Representation Index of Most Populous PATCOB
Series
(2) Quarterly/Annual Reports of Gains & Losses
FIGURE 1
U.S. DEPARTMENT OF AGRICULTURE
COMMITMENT TO EQUAL EMPLOYMENT OPPORTUNITY
STATEMENT FOR MAJOR OPERATING COMPONENT (MOC) EXEMPTED FROM THE
PROVISIONS OF EEO-MD-714
POLICY STATEMENT
I AM AFFIRMING
(MOC NAME)
COMMITMENT TO TITLE VII OF THE CIVIL RIGHTS ACT OF 1964, AS AMENDED,
WHICH GUARANTEES EQUAL EMPLOYMENT OPPORTUNITY FOR ALL EMPLOYEES AND
APPLI
CANTS FOR EMPLOYMENT WITHOUT REGARD TO RACE, COLOR, RELIGION, SEX,
OR NATIONAL ORIGIN. OUR OBJECTIVE IS TO PROVIDE A WORK ENVIRONMENT FREE
FROM UNLAWFUL EMPLOYMENT DISCRIMINATION.
ALL MANAGERS AND SUPERVISORS ARE RESPONSIBLE FOR SUPPORTING USDA
AND ---------------------------------------- POLICY ON EQUAL
(MOC NAME)
EMPLOYMENT AND ARE HELD ACCOUNTABLE FOR ASSURING THAT THE WORK PLACE IS
RECRUITMENT, SELECTION, TRAINING, PROMOTION, TRANSFER, AND BENEFITS ARE
REQUIRED TO BE FREE FROM UNLAWFUL DISCRIMINATION.
____________________________________________
SIGNATURE OF MOC HEAD OR DESIGNATED OFFICIAL
____________________________________________
CONTACT OIRM, IMD on 202-720-8799 for the paper copy of the following
images: Figure 2, Numerical Objectives By PATCOB, Form AD-878 (11/87);
Figure 3, Numerical Objectives By Major Occupation, Form AD-855 (11/87).
APPENDIX A
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
EQUAL EMPLOYMENT OPPORTUNITY
MANAGEMENT DIRECTIVE
EEO-MD-714
DATE OCTOBER 6, 1967
TO THE HEADS OF FEDERAL AGENCIES:
1. SUBJECT. Instructions for the Development and Submission of Federal
Affirmative Employment Multi-Year Program Plans, Annual
Accomplishment Reports, and Annual Plan Updates for FY 1988 through
FY 1992.
2. PURPOSE. To prescribe to Federal agencies instructions, policies,
procedures, guidance, and formats for the development and
submission of:
a. Multi-!fear affirmative employment program plans,
b. Annual affirmative employment program accomplishment reports,
and
c. Annual affirmative employment program plan updates.
3. EFFECTIVE DATE. October 1, 1987.
4. ORIGINATOR. Federal Sector Programs, Office of Program Operations,
Equal Employment Opportunity Commission (EEOC).
5. OBSOLETE DATA. EEO-MD-707 and EEO-MD-707A are canceled as of
January 1, 1988.
6. AUTHORITY. These instructions are prepared pursuant to EEOC's
authority under Section 717 of the Civil Rights Act of 1964, as;
amended, 42 USC 20OOe-16; Reorganization Plan No. 1 of 1978, issued
pursuant to 5 USC 901 et. seq.; Executive Order 11748 (3 CFR,
1966-70 Comp., p. 803) as amended by Executive Order 12106 (3 CFR
1978 Comp., p. 263); and 29 CFR Part 1613. specific sources of
authority and guidance are further explained in Appendix E of this
document.
7. POLICY INTENT. The intent of the Commission in issuing this
Directive is to develop a systematic multifaceted methodology for
affirmative employment programs which require:
o Strong commitment by the Head of the Agency through a clear
delegation of authority to Senior Managers;
o Management accountability systems for holding Senior Managers
responsible for achieving Agency EEO objectives;
o Identification and removal of barriers at all levels of the
work force;
o Aggregation of the agency work force into agencywide, major
operating component (MOC) wide, commandwide, regionwide, and
installation program plans;
o The use of prescribed program elements to analyze program
needs and a reporting mechanism to monitor progress in
resolving problems;
o Annual reports, submitted in a timely manner, on program
accomplishments in addition to reports on statistical changes
in the agencies' work force profiles; and
o Objectives and actions that lead to positive meaningful
results.
Also, the intent of the Commission in issuing these program
instructions is to allow for:
o Flexibility in agency problem solving activities, by allowing
each agency to decide which objectives and actions will meet
their EEO program needs;
o Reduction of at least 40% of the paperwork burden placed on
agencies; and
o Numerical goal setting where there is a manifest imbalance or
conspicuous absence of minorities and women in the agency's
work force.
The Management Directive should substantially contribute to the
achievement of equal employment opportunity for all Federal
employees, not only when hired; but also as they advance within the
work force, by providing for a stronger, more effective, more
focused affirmative employment program. This will be accomplished
by:
o Shifting major responsibility and accountability to Agency
Heads and their designees;
o Focusing on specific problems within specific agencies rather
than general issues identified by generalized instructions;
o Eliminating unnecessary forms;
o Using Central Personnel Data File (CPDF) information, where
available and appropriate, in the work force analysis;
o Placing specific emphasis on identification and removal of
barriers so that elimination of problem areas are permanent
and not just the result of a short-term effort; and
o Requiring a five-year planning document with annual
accomplishment reports.
The Commission intends to strengthen evaluation and accountability
by:
o Conducting one or more onsite program reviews at each agency
during the five-year cycle;
o Placing more emphasis on onsite program audits to evaluate
agency programs;
o Continuing use of labor force data for comparison with agency
work force profiles;
o Requiring Federal agencies to have self evaluation programs;
o Mandating that additional program elements be addressed when
agencies fail to show progress; and
o Reporting on a yearly basis, findings as to the extent to
which agencies are in compliance with Title VII of the Civil
Rights Act of 1964, as amended, to the President, the
Congress, and the appropriate Committees of the Congress.
8. APPLICABILITY AND SCOPE.
These instructions apply to all executive agencies as defined in
section 102 of Title 5, U.S.C. (including those with employees and
applicants for employment who are paid from nonappropriated funds),
the United States Postal Service, the Postal Rate Commission, and
those units of the legislative and judicial branches of the Federal
Government having positions in the competitive service.
9. RESPONSIBILITIES.
a. Agency Heads are responsible for the following:
(1) Ensuring compliance with affirmative employment program
instructions issued by EEOC;
(2) Establishing agencywide objectives, consolidating and
submitting agencywide multi-year affirmative employment
program plans, providing current guidance for the
development of program plan to all components/field
installations, developing systems for evaluation of
program effectiveness, and preparing accomplishment
reports and plan updates for timely submission to the
EEOC;
(3) Ensuring that all managers under the Senior Executive
Service are held accountable for tile achievement of
affirmative employment objectives and the fulfillment of
equal employment opportunity requirements and objectives
established by the agency; and
(4) Ensuring the accuracy of work force data submitted to the
Office of Personnel Management's Central Personnel Data
File (CPDF).
b. Major Operating Components (MOCs). Commands, Regions, and
Designated Installations are responsible for preparing,
submitting, and implementing plans that fulfill agencywide
objectives.
c. EEOC is responsible for:
(1) Reviewing and evaluating the operation of all. agency
equal employment opportunity programs;
(2) Reviewing and approving agency plans and reports,
communicating the results of evaluations to each agency,
and directing agencies, as appropriate, to develop
additional program objectives;
(3) Providing technical assistance to agencies;
(4) Providing CPDF data to agencies annually; and
(5) Submitting an annual report to the Congress and the
appropriate committees of the Congress and the President
on the employment of minorities and women in the Federal
Government based upon agency reports of accomplishments
during the fiscal year, data from the Central Personnel
Data File, onsite program reviews, and audits.
10. DEFINITIONS.
a. Action Item. Clearly identified step to the attainment of an
objective.
b. Agency. All government entities including executive agencies
as defined in Section 102 of Title 5, U.S. Code (including
those with employees and applicants for employment who are
paid from nonappropriated funds), the United States Postal
Service, the Postal Rate commission, and those units of the
legislative and judicial branches of the Federal Government
having positions in the competitive service.
c. Audit. Enforcement tool to be used when there are sufficient
deficiencies in an agency's program operations.
d. Barrier. Personnel principle, policy, or practice which
restricts or tends to limit the representative employment of
applicants and employees, especially minorities, women and
individuals with handicaps.
e. Civilian Labor Force. Persons, 16 years of age or over,
excluding those in the Armed Forces, who are employed or
seeking employment.
f. Conspicuous Absence. Particular EEO group that is nearly or
totally nonexistent from a particular occupation or grade
level in the work force.
g. EEO Group. Black males, black females, Hispanic males,
Hispanic females, Asian American/Pacific Islander, males,
Asian American/Pacific Islander females, American
Indian/Alaskan Native males, American Indian/Alaskan Native
females, white males, and white females. 1/
h. Employee. Permanent, full or part-time, members of the agency
work force including those in excepted service positions.
Does not include temporary or intermittent individuals.
i. Employment Category. The major occupational Categories for
the White Collar pay system and wage board pay system
including: Professional, Administrative, Technical, Clerical,
and Other, and Blue-Collar (PATCOB).
j. Fiscal Year. Reporting period from October 1 of one year to
September 30th of the following year.
k. Major Occupation. Mission oriented occupations or other
occupations with 100 or more employees.
l. Major Operating Component (MOC). Organizational sub-unit
directly below the agency (department) level.
m. Manifest Imbalance. Representation of EEO groups in a
specific occupational grouping or grade level in the agency's
work force that is substantially below its representation in
the appropriate CLF.
________________________________
1/ Handicapped males and females are also considered EEO groups but are
covered by a separate Management Directive issued pursuant to Section
501 of the Rehabilitation Act of 1973, as amended. See EEO-MD-713.
n. Numerical Objectives (Goals). Quantifiable) objective
designed to eliminate a manifest imbalance or conspicuous
absence of EEO Groups.
o. Objective. Statement of a specific end product or condition
to be attained by a specific date. Accomplishment of an
objective will lead to the elimination of a barrier or other
problem.
p. Onsite Program Review. Visit by EEOC representatives to an
agency installation for the purpose of reviewing program areas
such as program management, data collection, monitoring and
evaluation, personnel practices, barrier analysis, prevention
of sexual harassment, training and recruitment.
q. Technical Assistance. Onsite visit to provide assistance and
training.
r. Problem. A situation that exists in which on or more EEO
groups do not have full equal employment opportunity.
s. PATCOB. Acronym for Professional, Administrative, Technical,
Clerical, and Other White-Collar occupational categories and
the Blue-Collar occupational category.
t. Program Analysis. Review of entire agency affirmative
employment program.
u. Program Element. Prescribed program area for assessing where
agencies should concentrate their affirmative employment
program analysis and plan development.
v. Responsible Official. Executive, Manager, or Supervisor who
is accountable for accomplishing an action item.
w. Small Agencies. Agencies with fewer than 500 employees.
x. Target Date. Date (month/year) for completion of an action
item.
11. POLICIES AND PROCEDURES.
The attached instructions contain requirements for Federal agency
affirmative employment program planning and reporting. The EEOC
will provide technical assistance and training necessary to assist
agencies in the development of comprehensive five-year programs to
accomplish EEO objectives. Plan elements and procedures for
submission and approval, and other requirements for Fiscal Years
1988 through 1992, are described below.
12. REPORTING LEVELS FOR PREPARATION AND SUBMISSION OF
MULTI-YEAR AFFIRMATIVE EMPLOYMENT PROGRAM-PLANS, ANNUAL
ACCOMPLISHMENTS, AND ANNUAL UPDATES.
Planning and Reporting Levels. These instructions require
development and submission of multi-year affirmative employment
program plans, annual accomplishment reports, and updates in a
timely manner, by agencies with 500 or more employees, departments,
major operating components (MOCs), commands, and regional offices.
Also, installations with 2000 or more employees are required to
develop and submit multi-year affirmative employment program plans
and annual accomplishment reports and updates.
All plans and reports must be approved and signed by the principal
official of the agency, department, MOC, command, regional office,
or installation. (See Figure 3 for chart of planning and reporting
levels.)
a. Agency. Agencies with 500 or more employees shall aggregate
multi-year affirmative employment program plans and annual
accomplishment reports and updates from subordinate units (if
any) and submit an agency-wide plan/report/update to EEOC's
Federal Sector Programs.
b. Region, Major Operating Component (MOC) or Command. Regions,
MOCS, and commands shall be responsible for developing and
submitting multi-year affirmative employment program plans and
annual accomplishment reports and updates. Plans, reports and
updates for regions, MOC'S, and commands shall include all
subordinate installations and be submitted first to the next
higher organizational level, and then to the appropriate EEOC
office.
c. Installations with 2000 or More Employees. Installations with
2000 or more employees shall be responsible for developing and
submitting multi-year affirmative employment program plans and
annual accomplishment reports and updates. Plans, reports,
and updates are to be submitted to the appropriate EEOC
distribution office and the agency's next higher
organizational level. The installation's plans, reports, and
updates shall be included in combined regional, MOC, or agency
plans, reports and updates. Agency Headquarters offices shall
be considered an installation for planning and reporting
purposes if it has 2000 or more employees (these
plans/reports/updates shall be submitted to EEOC's Federal
Sector Programs).
d. Small Agencies. Small agencies with fewer than 500 employees
are not required to develop plans or to submit an annual
report. Small agencies shell submit a statement, signed by
the agency head, affirming the agency's commitment to equal
employment opportunity. This statement shall be submitted
once at the beginning of the five-year reporting period. EEOC
will monitor agency work force profiles with CPDF reports
annually. (See Exhibit 2, EEOC Form 567).
13. MULTI-YEAR PLAN DEVELOPMENT.
Agencies with 500 or more employees are required to submit the
following to EEOC.
a. Program Analysis. The first step in the multi-year
affirmative employment program (AEP) plan is to conduct a
comprehensive program analysis of the current status of all
affirmative employment efforts within the agency. Subordinate
units shall conduct a program analysis for submission to the
next higher organization level. Each organizational level
shall aggregate analyses submitted by their respective
subordinate units. For program analysis and planning
purposes, the AEP is divided into eight program elements.
Agencies and their subordinate units must use all of these
program elements in conducting their analysis, but may use
some or all of these program elements in developing their
plans.
(1) Organization and Resources
(a) Does EEO staff office or director have direct access
to top management and lines of communication to
agency supervisors
(b) Are EEO program officials receiving adequate
training in EEO, personnel, administration, and
management to effectively resolve problems and
issues within their areas of responsibility?
(c) Are adequate management and fiscal controls
established to monitor all resources allocated to
the EEO program?
(d) Do special emphasis program managers devote
sufficient time to accomplish program objectives?
Do these managers have adequate delegations of
authority to promote programs and to accomplish
program objectives?
(e) Are EEO officials providing technical advice to
management officials and the personnel office?
(f) Have supervisory and management personnel attended
formal training including coverage of their equal
employment opportunity responsibilities?
(g) Has incentive awards system been used to recognize
supervisory and managerial personnel for their
understanding and support of, and accomplishments in
equal employment opportunity?
(h) Do performance evaluations of supervisory and
managerial personnel include specific factors for
evaluating understanding, support, and achievement
of equal employment opportunity?
(2) Work Force
(a) Analysis of the agency's work force by PATCOB
category, grade groupings, and major occupations.
(b) Comparison of the agency's work force with the
previous year's work force.
(c) Comparison of the agency's work force with the
appropriate civilian labor force (CLF). See
Appendix C for examples.
(3) Discrimination Complaints
Does an analysis of the bases, issues, and findings of
recent complaints suggest possible problem areas that may
need to be explored?
(4) Recruitment and Hiring
(a) Do present recruitment sources yield qualified
minority and female applicants who meet
organizational needs?
(b) Have qualification requirements and procedures for
hiring been examined to determine whether barriers
to EEO exist?
(c) Does recruitment literature reflect the agency's
desire to reach all segments of the potential work
force?
(d) Do EEO officials participate in the development of
vacancy projections?
(e) Are recruitment efforts coordinated within the
agency in order to obtain maximum effectiveness and
efficiency, where appropriate?
(f) Do EEO officials provide technical assistance to the
personnel office and monitor, as well as participate
in recruitment efforts?
(g) Is the selection process reviewed periodically to
ensure equal treatment regardless of race, color,
religion, sex, national origin, or age?
(h) When paid advertising is used for recruitment or
institutional purposes, is minority media included?
(i) Does management make itself available to community,
civic, and other groups interested in enhancing
equal employment opportunity?
(j) Does the agency participate in cooperative efforts
with Federal and other organizations to resolve
employment related problems in the community,
including needs for improved public transportation,
education, child day care, and community services?
(k) Does the agency provide opportunities and services
to the community such as cooperative education
programs and shared use of training facilities?
(l) Does the agency participate in community career
information programs, conferences, and occupational
study projects?
(m) Has the agency examined means for expanding
worker-trainee placement? Do current plans call for
maximum participation in the Worker- Trainee
Opportunities program, or other such programs, with
particular emphasis on the identification of
developmental positions?
(5) Employee Development Programs
(a) Are systems for tracking information on employee
skills and training in operation?
(b) Has a survey of current skills and training of the
agency's work force been conducted to determine the
availability of employees from the EEO Groups,
having skills required to meet agency staffing
needs?
(c) Have studies been conducted on time-in-grade to
determine the reasons for any differentials which
may exist by minority status and sex?
(d) Have studies been conducted to examine relative
upward movement of employees to full performance,
professional, supervisory, and highest grade levels?
(e) Is career counseling available to all employees?
(f) Are efforts being made to ensure that appropriate
training opportunities are available to employees at
all grade levels and in all occupational areas,
without regard to minority status and sex?
(g) Is the agency encouraging the use of programs that
emphasize outside educational opportunities?
(6) Promotions
(a) Are internal selection and promotion qualification
requirements and procedures valid and job-related,
and include no unnecessary barriers to full
utilization of skills and training?
(b) Are efforts being made to ensure that appropriate
promotional opportunities are available to employees
at all grade levels and in all occupational areas,
regardless of minority status and sex?
(7) Separations
(a) Are efforts made to ensure that separations are
conducted fairly and in a non-discriminatory manner?
(b) Are Reductions-in-Force conducted fairly in a
non-discriminatory manner?
(8) Program Evaluation
(a) Are findings from EEOC onsite Reviews and Agency
program evaluations being incorporated into the
annual AEP plan development process, if appropriate?
(b) Do EEO committees, where established, consult with
the EEO officer, personnel officer, and management
officials to ensure that each provides input to EEO
program evaluation?
(c) Are statistical data necessary for EEO program
evaluation accurate, timely, and accessible?
(d) Are staff responsible for EEO program evaluation
fully trained in EEO and merit system requirements
contained in EEOC and OPM regulations?
(e) Do EEO program evaluations include input from
special emphasis program managers and EEO
committees?
b. Problem and Barrier Identification, After conducting a program
analysis of the affirmative employment program within the
agency, then problems and barriers shall be identified. A
critical part of agency multi-year affirmative employment
program planning is an evaluation of agency personnel and
management policies, practices, systems, and procedures which
may serve as problems and barriers to employment for EEO
Group(s). Problems and barriers shall be examined in the
context of the entire employment process. (See Appendix D).
The following elements must be used as basic criteria
applicable to problem and barrier identification within each
agency:
(1) Agencies shall select problems and barriers within their
control (and only within their control).
(2) Agencies shall select problems and barriers that can be
eliminated within the five-year cycle.
(3) Agencies shall select problems and barriers affecting
PATCOB categories and major occupations and identify
specific actions to eliminate each problem and barrier.
c. Report of Objectives and Action Items. The next step in the
development of a multi-year affirmative employment program is
the preparation of a report containing the following:
(1) A clear statement of specific and measurable objectives
and supporting action items which will resolve problems
identified.
(2) Assignment of a responsible official for each objective
and action item listed.
(3) A target date for completion of each objective and action
item.
See Exhibit 1 for a sample. (EEOC Form 566, p.10).
After, review of an agency's Report of Objectives and Action
Items, the EEOC may direct, after discussion with the agency,
the development of additional objectives and action items.
d. Numerical Objectives (Goals). Agencies may establish
numerical objectives (goals) for each job category or major
occupation where there is a manifest imbalance or conspicuous
absence of EEO Group(s) in the work force. Numerical
objectives (goals) shall be used in accordance with the
following guidance.
(1) Agencies should review the Supreme Court decision,
Johnson v. Transportation Agency, Santa Clara County, 107
S. Ct. 1442 (1987).
(2) The agency must conduct an appropriate work force
analysis. Where the work force representation of EEO
Groups is below their corresponding civilian labor force
(CLF) representation so that a conspicuous absence or
manifest imbalance exists, the agency may develop
reasonable numerical objective (goals) to address the
absence or imbalance.
(3) Agencies should use Appendix B of EEO-MD-707 for Civilian
Labor Force (CLF) data comparisons. Any deviation from
this data base must be approved by EEOC, Federal Sector
Programs, Washington, D.C.
(4) Numerical objectives (goals) must be reasonable. They
must have a reasonable relation to the extent of manifest
imbalance or conspicuous absence, the availability of
candidates and the number of vacancies. The availability
of candidates is dependent on effective community
outreach, agency, recruitment, applicant flow, relevant
qualifications, training, and promotions.
(5) Agencies should consult with their personnel and budget
officers for assistance with their vacancy projections.
(6) Numerical objectives (goals) do not require or mandate
the selection of unqualified persons or preferential
treatment based on race, national origin or sex. The
purpose of numerical measures is to attain, rather than
maintain a balanced work force.
(7) Agencies should use the form in Exhibit 3 (EEOC Form 568,
p. 4) to monitor, measure, and evaluate progress made as
a result of the use of their numerical objectives
(goals). After a review of the agency's program plan,
EEOC may direct the development of additional numerical
objectives.
14. REPORTING REQUIREMENTS.
a. Multi-Year Requirements. Agencies shall submit multi- year
requirements on a staggered basis to the EEOC, beginning
February 15, 1988. Each agency will be notified of the due
date for its submission. All agencies with 500 or more
employees shall submit items 1 through 9 specified below.
These items are required only once during the five-year
reporting period. Once submitted to EEOC, they may be
referenced in subsequent years. Any update or change should
be submitted to EEOC. (See Exhibit 1, EEOC Form 566, pp.
1-10).
(1) Policy Statement. The head of each agency shall submit a
signed policy statement. This statement should affirm
that equal employment opportunity and affirmative
employment program requirements will be enforced by the
agency head and agency management. The policy statement
should include, but not be limited to the following:
(a) Equal employment opportunity for all employees and
applicants for employment, regardless of their race,
religion, color, sex, national origin, age or
handicap is an integral part of agency policy.
(b) Equal employment opportunity policy requires
affirmative employment program efforts throughout
the agency to overcome past employment practices
that have operated to restrict opportunities for
employment.
(c) Equal employment opportunity covers all employment
practices including, but not limited to,
recruitment, hiring, promotion, transfer,
reassignments, training, benefits, and separation.
(d) Managers, supervisors, EEO Officers, and
personnelists share responsibility for successful
implementation of the affirmative employment
program. Performance appraisals should include an
element based on meeting equal employment
opportunity objectives.
(2) Delegation of Authority. This provides a clear
delineation of the specific duties and responsibilities
of Affirmative Employment Program officials.
(3) Organizational Chart. Agencies shall submit an
organizational chart with MOC's/components/ installations
required to submit plans/reports by this directive.
(4) Certification of Qualifications. Agencies shall submit a
certification of qualifications for principal officials
responsible for implementing the EEO program.
(5) Plan for the Prevention of Sexual Harassment. Agencies
must develop a comprehensive plan of action to prevent
sexual harassment in the work place. Agencies must
submit the following information:
(a) Specific steps to inform employees that complaints
of sexual harassment are cognizable under Title VII.
Existing EEO Complaint System must be structured to
deal sensitively with sexual harassment issues.
(b) Training, directives, or other programs designed to
inform supervisors and other agency personnel of
their responsibilities to discourage explicit or
implicit unwelcome advances or physical conduct of a
sexual nature in order to maintain a work place free
of sexual harassment.
(c) Amendments to agency codes of conduct or other
policy directives/materials designed to curtail
inappropriate conduct.
(d) Method(s) to ensure accountability within the agency
for maintaining a work place free of sexual
harassment.
(e) Any other initiatives already undertaken to educate
employees of their rights and responsibilities.
(6) Statement of Monitoring and Evaluation System. Agencies
shall submit a narrative describing their agency's
monitoring and evaluation system. Internal monitoring
and evaluation systems must include, at a minimum:
(a) Information systems that will provide periodic
status reports on work force profile and affirmative
employment efforts.
(b) Capability to monitor employment trends through
review of personnel transactions and other
historical data.
(c) Integration of barrier analyses; elimination of
impediments; innovative staffing techniques and
concomitant revisions in agency selection
procedures.
(d) Capability to integrate comprehensive management,
personnel, and budget planning with affirmative
employment planning.
(e) Capability to review proposed personnel actions
which affect categories where objectives have been
established.
(7) Program Analysis. Agencies must conduct a program
analysis of the current status of affirmative employment
within the agency. Subordinate units shall conduct a
program analysis for submission to the next higher
organization level. Each organizational level shall
aggregate analyses submitted by their respective
subordinate units. For program analysis and planning
purposes, the AEP is divided into eight program elements:
(a) Organization and Resources
(b) Work Force
(c) Discrimination Complaints
(d) Recruitment and Hiring
(e) Employee Development Programs
(f) Promotions
(g) Separations, and
(h) Program Evaluation.
(8) Problem and Barrier Identification. Agencies shall
evaluate agency personnel and management policies,
practices, systems, and procedures which operate as
problems and barriers to employment for each EEO Group.
Problems and barriers shall be examined in the context of
the entire recruiting and staffing process.
The following elements must be used as basic criteria
applicable to problem and barrier identification within
each agency:
(a) Agencies shall select problems and barriers within
their control.
(b) Agencies shall select problems and barriers that can
be eliminated within the five-year cycle.
(c) Agencies shall select problems and barriers
affecting PATCOB categories and major occupations
and identify specific actions to eliminate each
problem and barrier.
(9) Report of Objectives and Action Items. Agencies shall
prepare a report containing the following:
(a) A clear statement of specific and measurable
objectives and supporting action items which will
solve problems identified.
(b) Assignment of a responsible official for each
objective and action item listed.
(c) A target date for completing each objective and
action item.
b. Annual Affirmative Employment Program Requirements. Annual
submissions will be submitted to EEOC on a staggered basis
beginning February 15, 1988, in a timely manner. Each agency
will be notified of the due date for its submission. Annual
submissions will contain the following (See Exhibit 3, EEOC
Form, 568):
(1) Statistical Analysis. Annually, the EEOC will transmit
to agencies copies of their CPDF data. Using CPDF data,
as of September 30, or substitute data, as of September
30, where appropriate, agencies shall provide EEOC with a
statistical analysis of their work force. This should
include an analysis of the agency's work force by PATCOB
category, grade groupings, and major occupations; and
analysis of the agency's work force for the current year
and previous year; identification of employment trends;
and a description of changes in the work force. (See
Appendix A and C for guidance on work force analysis and
reporting forms).
(2) Annual Accomplishment Reports and Updates. Agency
accomplishment reports shall reflect the progress made in
achieving objectives and action items. Agency updates
shall address achieved and unachieved action items.
(3) Noteworthy Activities/Initiatives. Agencies should
submit noteworthy activities or initiatives implemented
during the fiscal year for inclusion in EEOC's annual
report to the Congress and the President.
15. EVALUATION AND ENFORCEMENT
a. Evaluation.
Agencies will be evaluated on the effectiveness of their
affirmative employment program efforts. In reviewing changes
in the work force, EEOC will use the comparative analyses
provided by the agency.
EEOC will use the following criteria in evaluation of an
agency's progress:
(1) Positive change in the participation of EEO Groups in the
work force. With good faith efforts, the EEO Groups
should increase in major occupations and occupational
levels within the agency's work force.
(2) Successful hiring and internal movement activity.
(3) Successful completion of plan of action.
(4) Completeness and accuracy of required information.
(5) Effectiveness of an Agency's internal monitoring and
evaluation system.
In evaluating an agency's affirmative employment program plan,
EEOC shall carefully review all program elements, objectives
and action items to ensure that they adequately address the
problems identified. Where appropriate, after discussions
with the agency, the EEOC may and will recommend the use of
additional program elements, the development of additional
objectives (including numerical goals) and action items.
b. Enforcement.
(1) Program Audit. EEOC will conduct a full program audit of
any agency which fails to meet the requirements of this
directive in developing and implementing an affirmative
employment program or if its program efforts show
insufficient progress.
The program audits will include a thorough examination of
the agency's affirmative employment program objectives,
strategies, procedures, and accomplishments. The audit
will cover the following:
(a) The management of the agency program;
(b) The resources allocated to the program;
(c) the alternative strategies considered to bring about
positive change in the participation of each EEO
group in the work force; and
(d) The extent to which the agency was committed to the
objectives of the affirmative employment program.
EEOC will communicate its program audit findings to the
responsible agency official. The agency will be provided
an opportunity to respond to EEOC's findings.
(2) EEOC May Direct Additional Objectives and Strategies. If
the EEOC review of agency progress under the agency's
affirmative accomplishment program reveals a continuing
manifest imbalance, the EEOC may direct or require that
additional steps be taken to identify and remove barriers
to equal employment opportunity and may also direct or
require the development of numerical objectives (goals).
(3) Report to Congress and the President. EEOC will report
to Congress, the appropriate committees of the Congress,
and the President annually on each agency's affirmative
employment program efforts. The report will include
analysis of changes in the Agency's work force.
c. Onsite Reviews.
EEOC will continue to conduct onsite review of selected
agencies to evaluate their affirmative employment programs.
Affirmative Employment Program planning areas to be reviewed
are:
(1) program management;
(2) data collection;
(3) monitoring and evaluation;
(4) personnel practices;
(5) barrier analysis;
(6) prevention of sexual harassment;
(7) training; and
(8) recruitment.
EEOC will conduct an onsite review of each agency's
affirmative employment program at least once during the
multi-year cycle.
16. LIST OF FIGURES.
Figure Title
1 Affirmative Employment Program Schedule
2 Flow Chart for Affirmative Employment
Planning Process - FY 1988 through FY 1992
3 Planning and Reporting Levels
4 Map of EEOC Federal Affirmative Employment
Program Regions
5 EEOC Field Offices with Federal Affirmative
Employment Units
17. LIST OF EXHIBITS.
EEOC Forms 566 through 568 are to be used for agency reporting.
Exhibit Title
1 Multi-year Affirmative Employment Program Plan.
FORM 556 (pp. 1-10)
2 Commitment to Equal Employment Opportunity Statement
for Agencies with 500 or fewer Employees. FORM 567
3 Annual Affirmative Employment Program Report and
Update. FORM 568 (pp. 1-6)
18. LIST OF APPENDICES.
Appendix Title
A Analysis of CPDF Data
B Data Formats for Central Personnel Data File
Information
C Examples - Analysis of Work Force Data
D Examples of Problem and Barrier
Analysis/Identification
E Legal Authorities
19. SUPPLY OF FORMS.
If supplies of EEOC forms are needed, agencies may produce them
locally or if 50 or more copies are needed, agencies may contact:
Federal Sector Programs
Equal Employment Opportunity Commission
2401 E Street, N.W., Room 422
Washington, D.C. 20507
20. INQUIRIES.
Further information concerning this directive may be obtained by
contacting:
Director
Affirmative Employment Programs Division
Federal Sector Programs
2401 E Street, N.W., Room 422
Washington, D.C. 20507
Telephone: (202) 634-6753
Interagency Report Control Number: 0279-EEO-AN This reporting
requirement has been cleared in accordance with FIRMR 201-45.6 and
assigned Interagency Report Control Number: 0279-EEO-AN
Clarence Thomas
Chairman
Equal Employment Opportunity Commission
FIGURE 1
AFFIRMATIVE EMPLOYMENT PROGRAM SCHEDULE
Date Plan Elements and Activities
July 1987 EEOC forwards CPDF data to agencies.
July 1987 EEOC distributes draft directive to
agencies for Interagency Coordination.
August 1987 EEOC receives comments from agencies.
October 1987 Directive is issued to agencies for
implementation
Beginning Agencies submit multi-year requirements.
February 15, 1988
(staggered basis)
August 15, 1988, Annually, EEOC forwards CPDF data to
through 1992 agencies.
Beginning Agency submission of annual
accomplishment
February 15, 1989, report and plan update, statistical
through 1992 analysis of work force, and noteworthy
(staggered basis) activities/initiatives.
FIGURE 2
FLOW CHART
MULTI-YEAR AFFIRMATIVE EMPLOYMENT PROGRAM PLANNING PROCESS
FISCAL YEAR 1988 THROUGH FISCAL YEAR 1992
1. PROGRAM ANALYSIS Conduct a Program Analysis of the
current status of the affirmative
employment program within the agency.
2. IDENTIFICATION Evaluation of agency policies,
OF procedures, and systems which may
PROBLEM/BARRIERS affect the employment of minorities
and women.
3. DEVELOPMENT OF Statement of objectives which will
OBJECTIVES resolve each problem identified.
AND Each objective contains action items,
ACTION ITEMS an official responsible for
accomplishing the action item, and
target dates for action.
4. SUBMISSION Agency submits multi-year plan
OF requirements: Policy Statement,
MULTI-YEAR Delegation of Authority,
AFFIRMATIVE Organization Chart, Certification
EMPLOYMENT of Qualifications, Plan for the
PROGRAM PLANS Prevention of Sexual Harassment,
Statement of Monitoring and Evaluation
System, Program Analysis, Problem and
Barrier Identification, and Report of
Objectives and Action Items.
5. SUBMISSION Agency submits annual
OF accomplishment reports and
ANNUAL updates which include statistical
AFFIRMATIVE analysis of work force, and
EMPLOYMENT noteworthy activities/initiatives.
PROGRAM REPORTS
AND UPDATES
PLEASE SEE HARD COPY OR CONTACT OIRM,IMD ON 202-720-8755
FOR THE PAPER COPY OF THE FOLLOWING IMAGE(S):
FIGURE 3 - PLANNING AND REPORTING LEVELS
FIGURE 4 - EQUAL EMPLOYMENT OPPORTUNITY COMMISSION FEDERAL
AFFIRMATIVE ACTION REGIONS
FIGURE 5
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
FIELD OFFICE WITH
FEDERAL AFFIRMATIVE ACTION UNITS
NEW ENGLAND REGION MID-CONTINENT REGION
FEDERAL AFFIRMATIVE ACTION UNIT FEDERAL AFFIRMATIVE ACTION UNIT
90 CHURCH ST, ROOM 1501 625 NORTH EUCLID ST. 5TH FLOOR
NEW YORK, NY 10007 ST. LOUIS, MO 63108
EASTERN REGION SOUTHWEST REGION
FEDERAL AFFIRMATIVE ACTION UNIT FEDERAL AFFIRMATIVE ACTION UNIT
90 CHURCH ST, ROOM 1501 8303 ELMBROOK DRIVE, 2ND FLOOR
NEW YORK, NY 10007 DALLAS, TX 75247
MID-ATLANTIC REGION ROCKY MOUNTAIN REGION
FEDERAL AFFIRMATIVE ACTION UNIT FEDERAL AFFIRMATIVE ACTION UNIT
127 NORTH 4TH ST., 3RD FLOOR 1845 SHERMAN ST., 2ND FLOOR
PHILADELPHIA, PA 19106 DENVER, CO 80203
SOUTHEAST REGION NORTHWEST REGION
FEDERAL AFFIRMATIVE ACTION UNIT FEDERAL AFFIRMATIVE ACTION UNIT
75 PIEDMONT AVE, NE, RM. 1100 ARCADE PLAZA BUILDING
ATLANTA, GA 30335 1321 SECOND AVENUE
SEATTLE, WA 98104
GREAT LAKES REGION WESTERN REGION
FEDERAL AFFIRMATIVE ACTION UNIT FEDERAL AFFIRMATIVE ACTION UNIT
536 S. CLARK STREET, ROOM 930-A 901 MARKET ST., SUITE 500
CHICAGO, IL 60605 SAN FRANCISCO, CA 94103
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
MULTI-YEAR AFFIRMATIVE EMPLOYMENT PROGRAM PLAN
=================================================================
==
* POLICY STATEMENT * STATEMENT OF ADEQUATE
* DELEGATION OF AUTHORITY MONITORING/EVALUATION SYSTEM
* ORGANIZATIONAL CHART * PROGRAM ANALYSIS
* CERTIFICATION OF * PROBLEM/BARRIER
IDENTIFICATION
QUALIFICATIONS
* PLAN FOR THE PREVENTION * REPORT OF OBJECTIVES AND
OF SEXUAL HARASSMENT ACTION ITEMS
===================================================================
_________________________________________________________________
__
_________________________________________________________________
_
ADDRESS OF ORGANIZATION
______
COMMAND______ INSTALLATION_______ HEADQUARTERS_________
NUMBER OF EMPLOYEES COVERED BY PLAN: TOTAL __________
PROFESSIONAL_____ ADMINISTRATIVE ________
TECHNICAL________
CLERICAL _______ OTHER______ BLUE COLLAR________
_________________________________________________________________
__
_________________________________________________________________
__
_________________________________________________________________
__
SIGNATURE OF PRINCIPAL EEO OFFICIAL DATE
CERTIFIES THAT THIS PLAN IS IN COMPLIANCE WITH EEO-ME-714.
_________________________________________________________________
__
_________________________________________________________________
__
SIGNATURE OF HEAD OF ORGANIZATION OR DESIGNATED OFFICIAL
CERTIFIES THAT THIS PLAN IS IN COMPLIANCE WITH EEO-ME-714.
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
E E O P O L I C Y S T A T E M E N T
==============================================================
_______________________________________
SIGNATURE OF AGENCY HEAD DATE
_______________________________________
NAME AND TITLE OF AGENCY HEAD
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
D E L E G A T I O N OF A U T H O R I T Y
(EXPLANATION OF RESPONSIBILITIES OF EEO PROGRAM OFFICIALS)
=================================================================
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
O R G A N I Z A T I O N A L C H A R T
INCLUDE A LIST OF COMMANDS, MAJOR OPERATING COMPONENTS, REGIONAL
OFFICES, AND INSTALLATION.
=================================================================
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
CERTIFICATION OF QUALIFICATIONS OF EEO OFFICIALS
=================================================================
I CERTIFY THAT THE QUALIFICATIONS OF ALL STAFF OFFICIALS, FULL-
EQUAL EMPLOYMENT OPPORTUNITY PROGRAM AND AFFIRMATIVE EMPLOYMENT
PROGRAM HAVE BEEN REVIEWED BY COMPETENT AUTHORITY AND MEET THE
QUALIFICATION STANDARDS IN THE HANDBOOK X-118.
_________________________________
SIGNATURE
_________________________________
DATE
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
PLAN FOR THE PREVENTION OF SEXUAL HARASSMENT
=================================================================
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
STATEMENT OF ADEQUATE MONITORING/EVALUATION SYSTEM
=================================================================
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
PROGRAM ANALYSIS
=================================================================
PROVIDE A NARRATIVE ANALYSIS OF THE AFFIRMATIVE EMPLOYMENT
PROGRAM FOR THE FOLLOWING ELEMENTS:
1. ORGANIZATION AND RESOURCES
2. WORK FORCE
3. DISCRIMINATION COMPLAINTS
4. RECRUITMENT AND HIRING
5. EMPLOYEE DEVELOPMENT PROGRAMS
6. PROMOTIONS
7. SEPARATIONS
8. PROGRAM EVALUATION
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
PROBLEM/BARRIER IDENTIFICATION
=================================================================
PROVIDE A NARRATIVE DESCRIBING THE PROBLEMS/BARRIERS IDENTIFIED:
EXHIBIT 1
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
REPORT OF OBJECTIVES AND ACTION ITEMS
=================================================================
PROGRAM ELEMENT:
_________________________________________________________________
PROBLEM/BARRIER STATEMENT:
_________________________________________________________________
OBJECTIVE:
RESPONSIBLE OFFICIAL:
TARGET DATE:
_________________________________________________________________
ACTION ITEMS: RESPONSIBLE TARGET
DATE
OFFICIAL
EXHIBIT 2
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
COMMITMENT TO EQUAL EMPLOYMENT OPPORTUNITY
STATEMENT FOR AGENCIES WITH FEWER THAN 500 EMPLOYEES
POLICY STATEMENT FOR OCTOBER 1, 1987 THROUGH SEPTEMBER 30, 1992
=================================================================
ACT OF 1964, AS AMENDED, WHICH GUARANTEES EQUAL EMPLOYMENT OPPORTUNITY
FOR ALL EMPLOYEES AND APPLI
CANTS FOR EMPLOYMENT WITHOUT REGARD TO RACE,
COLOR, RELIGION, SEX, OR NATIONAL ORIGIN. OUR OBJECTIVE IS TO PROVIDE A
RESPONSIBLE FOR SUPPORTING OUR POLICY ON EQUAL EMPLOYMENT OPPORTUNITY
AND FOR ASSURING THAT THE WORK PLACE IS FREE FROM DISCRIMINATION. ALL
PERSONNEL PRACTICES INCLUDING RECRUITMENT, SELECTION, TRAINING,
PROMOTION, TRANSFER, AND BENEFITS ARE REQUIRED TO BE FREE OF UNLAWFUL
DISCRIMINATION.
______________________________________________
SIGNATURE OF AGENCY HEAD OR DESIGNATED
OFFICIAL
_______________________________________________
NAME AND TITLE DATE
EXHIBIT 3
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
ANNUAL AFFIRMATIVE EMPLOYMENT PROGRAM ACCOMPLISHMENT REPORT
FOR FISCAL YEAR 19___
=================================================================
==
* SUMMARY ANALYSIS OF WORK FORCE
* ACCOMPLISHMENT REPORT ON OBJECTIVES AND ACTION ITEMS
* NOTEWORTHY ACTIVITIES AND INITIATIVES
=================================================================
==
_________________________________________________________________
__
_________________________________________________________________
_
ADDRESS OF ORGANIZATION
COMMAND______ INSTALLATION_______ HEADQUARTERS_________
NUMBER OF EMPLOYEES COVERED BY PLAN: TOTAL __________
PROFESSIONAL_____ ADMINISTRATIVE ________
TECHNICAL________
CLERICAL _______ OTHER______ BLUE COLLAR________
_________________________________________________________________
__
_________________________________________________________________
__
_________________________________________________________________
__
SIGNATURE OF PRINCIPAL EEO OFFICIAL DATE
CERTIFIES THAT THIS PLAN IS IN COMPLIANCE WITH EEO-ME-714.
_________________________________________________________________
__
_________________________________________________________________
__
SIGNATURE OF HEAD OF ORGANIZATION OR DESIGNATED OFFICIAL CERTIFIES THAT
EXHIBIT 3
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
ANNUAL AFFIRMATIVE EMPLOYMENT PROGRAM ACCOMPLISHMENT REPORT
SUMMARY ANALYSIS OF WORK FORCE
PROVIDE A NARRATIVE WORK FORCE ANALYSIS USING THE RELEVANT CIVILIAN
LABOR FORCE. ANALYZE OCCUPATIONAL CATEGORIES, GRADE GROUPINGS, AND
MAJOR OCCUPATIONS.
=================================================================
EXHIBIT 3
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
ACCOMPLISHMENT REPORT OF OBJECTIVES AND ACTION ITEMS
=================================================================
PROGRAM ELEMENT:
_________________________________________________________________
PROBLEM/BARRIER STATEMENT:
_________________________________________________________________
OBJECTIVE:
RESPONSIBLE OFFICIAL:
TARGET DATE:
_________________________________________________________________
ACTION ITEMS: RESPONSIBLE TARGET
DATE
OFFICIAL
REPORT ON ACCOMPLISHMENT OF OBJECTIVE:
PLEASE SEE HARD COPY OR CONTACT OIRM,IMD ON 202-720-8755
FOR THE PAPER COPY OF THE FOLLOWING IMAGE(S):
EXHIBIT 3 - PAGE 4 NUMERICAL OBJECTIVE ACCOMPLISHMENTS
BY PATCOB
EXHIBIT 3 - PAGE 5 NUMERICAL OBJECTIVE ACCOMPLISHMENTS
BY MAJOR OCCUPATIONS
EXHIBIT 3
AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN
ANNUAL AFFIRMATIVE EMPLOYMENT PROGRAM ACCOMPLISHMENT REPORT
NOTEWORTHY ACTIVITIES/INITIATIVES
IMPROVING EMPLOYMENT AND PROMOTIONAL OPPORTUNITIES FOR MINORITIES AND
WOMEN.
=================================================================
APPENDIX A
ANALYSIS OF CPDF INFORMATION
1. WORK FORCE PROFILES
Annually, EEOC will provide Federal agencies with work force
information from the Office of Personnel Management's (OPM) Central
Personnel Data File (CPDF) for PATCOB categories and grade
groupings. This information should be used in evaluation of the
agency work force. All agencies, except the U.S. Postal Service,
Tennessee Valley Authority, Federal Reserve Board; and parts of a
few other agencies, are covered by the CPDF. Agencies not covered
by the CPDF must submit agency generated work force data.
This work force information is critical for evaluation of agency
progress and governmentwide trends for the annual report to the
Congress and to the President. Use of CPDF information will ensure
uniformity of data and facilitate data analysis. Each agency is
responsible for ensuring that its work force information is
accurate. Agencies should cooperate with the Office of Personnel
Management to develop the most accurate data possible.
a. PATCOB Categories by EEO Group
Data on PATCOB categories will be generated from OPM's CPDF and
transmitted by EEOC to each agency for verification. See
Appendix B for the data format.
b. Grade Groupings by EEO Group for White and Blue Collar
Positions
Data on PATCOB categories will be generated from OPM's CPDF and
transmitted by EEOC to each agency for verification. See
Appendix B for the data format.
c. Statistical Summary Analysis
Agencies should provide EEOC with its own summary analysis of
the CPDF data by PATCOB category, and by grade groupings.
Agencies must also submit to EEOC a work force analysis by
major occupational series. Agencies should analyze work force
data and identify employment trends for action and further
study. Agencies should use this element to select areas for
affirmative employment efforts.
Specific Actions to Achieve Progress. See Appendix C for examples.
1. Agencies should compare its work force for the current year
with its work force for the previous year. Agencies should
provide EEOC with a summary of its analysis describing changes
in its work force.
2. Agencies should compare its work force with the appropriate
civilian work force. The agency should provide EEOC with an
explanation of both geographic and Civilian Labor Force
percentages used in comparison with the agency's work force.
APPENDIX B
DATA FORMATS FOR CENTRAL PERSONNEL DATA FILE INFORMATION
The following formats will be provided to agencies on an annual basis:
1. FORM 505M - Change in White-Collar EEO Work Force Profile
by PATCO Occupational Category,
2. FORM 506L1 - Change in White-Collar EEO Work Force Profile
by GS Grade Equivalent Group,
3. FORM 506L2 - Change in Blue-Collar EEO Work Force Profile
Part I by WD/WD Grade Groups,
4. FORM 506L2 - Change in Blue-Collar EEO Work Force profile
Part II by WL/WN/WS Grade Groups,
5. FORM 506M - Average Grade and Average Salary EEO profile,
and
6. FORM 506N - Unspecified Data.
Information in the above forms covers all CPDF records, (Tenure Codes 1
and 2) full-time and part-time permanent employees in the Senior
Executive Service, FS and equivalent white-collar pay plans, and all
blue-collar pay plans. With the exception of Forms 506M and 506N, all
forms compare data at the beginning and ending of the fiscal year.
Forms 506M and 506N cover data as of the end of the fiscal year.
APPENDIX C
EXAMPLES - ANALYSIS OF WORK FORCE DATA
This Appendix provides examples of how an agency could analyze work
force data and identify employment trends for action and additional
study.
EXAMPLE 1.
Review of Form 505M:
Identify occupational categories and groups where EEO groups decrease or
increase. By focusing attention on areas where decreases occurred and
an EEO group is not fully represented, the agency might be able to
identify recruitment strategies for increasing the number of an EEO
group in the agency work force.
Conversely, by studying areas where an EEO group is making progress to
reduce the difference between its representation in the agency work
force in comparison to the CLF, the agency might uncover successful
recruitment strategies which could be adapted to other areas where
little or no progress is occurring. The agency could also highlight
increases in its report on significant accomplishments.
EXAMPLE 2.
Review of Form 506L1:
Identify grade groupings and EEO groups where EEO groups are
concentrated or lacking. This would assist an agency in identifying
strategies for upward mobility, training, and advancement of minorities
and women.
EXAMPLE 3.
Analysis of Form 505M:
1. For agency, copy percentages for each occupational category and EEO
group's 1986 data from Form 505M to Agency Row on Comparison Form.
2. Enter the corresponding Civilian Labor Force percentages for each
EEO group into the Civilian Labor Force ROW.
3. Compare the percentages for each EEO group and occupational
category as follows:
a. If the percentages for each occupational category and EEO
group on the top row (Agency Row) is greater than the
corresponding percentage on the bottom row (Civilian Work
Force), the agency may not need to initiate actions for this
EEO group.
b. If the percentages for each occupational category and EEO
group on the top for (Agency Row) is less than the
corresponding percentage on the bottom row (Civilian Work
Force), the agency may need to initiate actions for
recruitment and barrier analysis for this EEO group and
occupational category.
PLEASE SEE HARD COPY OR CONTACT OIRM,IMD ON
202-720-8755 FOR THE PAPER COPY OF THE FOLLOWING
IMAGE(S):
Appendix C - Distribution of EEO Groups and
Comparison by PATCOB - EEOC Form 569
(8/87) - MD-714
Appendix C - Distribution of EEO Groups and
Comparison for Major Occupations -
EEOC FORM 570 (8/87) - MD-714
APPENDIX D
EXAMPLES OF PROBLEM AND BARRIER ANALYSIS/IDENTIFICATION
In some cases, problems and barriers are interpreted to be the same.
However, for the AEP plan, problems are defined as the situations or
conditions which need to be corrected or changed. Barriers are defined
as the personnel or management policies, practices, or procedures that
cause the situations or conditions.
A management team, consisting of key management officials, EEO staff,
personnel staff, and heads of other pertinent offices should meet to
review and identify the agency policies, practices and procedures
(barriers) that cause manifest imbalance (undesired conditions or
problems) in the employment of various EEO groups.
Agencies should use the following process to identify and remove
systemic barriers:
a. State the undesired condition that exists.
b. State the desired condition or results to be achieved.
c. Analyze the data to determine what policy, procedure, practice
or person might be the cause of the existing undesirable
results.
d. Identify the probable barrier.
e. State that alternative policy, procedure or practice that will
be instituted to bring about the desired conditions or
results.
f. State the results expected from the change in policy,
procedure, or practice.
g. Follow-up action. Track progress to determine if:
(1) Barrier correctly identified; the desired change or
condition realized.
(2) Barrier incorrectly identified; the undesired conditions
remain unchanged; Re-analyze by repeating steps a
through g.
1. a. UNDESIRED CONDITION: Of the over two hundred doctors in a
Medical Center, there are no Black, Hispanic, or Women doctors
on staff.
b. DESIRED CONDITION: Ensure that the opportunity for employment
in the Medical Center be open to all applicants, including
Black, Hispanic and Women doctors.
c. ANALYSIS: Management analysis revealed that all the Medical
Center's doctors are members of the medical faculty of the
local University's School of Medicine. Further investigation
by the EEO Advisory Committee revealed that top management has
an unwritten/unannounced policy of screening out applicants
who are not members of the Medical School faculty, but who
would otherwise qualify to perform as doctors in the Medical
Center.
d. PROBABLE BARRIER: The unwritten, unspoken policy of requiring
doctor applicants to be members of the local Medical School
faculty to qualify.
e. ALTERNATIVE: Advise top management that the unwritten policy
of requiring the applicant to be a member of the local Medical
School faculty, while it lends prestige to the medical staff
of the Medical Center, is not a valid qualification
requirement, but has the effect of screening out
disproportionately more minorities and women doctors who would
otherwise qualify to be doctors in the Medical Center and
therefore should be discontinued; or
Discontinue the unwritten policy of requiring doctor
applicants to be members of the local Medical School faculty
to qualify.
f. EXPECTED RESULT: Result of the changed policy is that
minority and women doctor applicants who are not members of
the local Medical School faculty will be considered and
selected for medical doctor positions in the Medical Center.
g. FOLLOW-UP ACTION: Following the change in the policy, data of
subsequent recruitment actions show that minority and women
doctor applicants not on the University Medical faculty were
considered and selected. Barrier was correctly identified.
2. An analysis of an organization's personnel action history shows
that over a period of years, some managers and supervisors may have
had the practice of hiring another minority/female to fill low
graded jobs that were previously successfully occupied by other
persons of that same minority/female group. A history of such
actions may imply an attitude on the part of these supervisors and
managers of stereotyping the abilities or capabilities of certain
groups of minorities or women, which would have the result of
excluding them from consideration for other more responsible,
higher paying positions.
a. UNDESIRED CONDITION: The practice of not opening all job
opportunities to the affected minority or women groups.
b. DESIRED CONDITION: Ensure that all employment in all jobs are
available to all minorities and women who meet the
qualification requirements.
c. ANALYSIS: Follow up tracking data of the highly qualified
applicants indicated that minorities and women applying for
the more responsible positions in the organization experienced
exceedingly low selection rates, while the same groups'
selection rate for the positions traditionally occupied by
members of these groups remained exceedingly high.
d. PROBABLE BARRIER: The policy or practice of not giving equal
consideration for employment in certain positions to certain
minorities and women.
e. ALTERNATIVE: Bring the results of such practices to the
attention of top management, and the managers and supervisors
involved, and urge them to commit themselves to giving equal
consideration for employment to all minorities and women in
all the positions in the organization.
f. EXPECTED RESULT: Selection results of subsequent
announcements of higher graded positions should show higher
selection rates of members of these groups.
g. FOLLOW-UP ACTION: Track the applicant flow data, and report
the relative selection rates to management. Results should
show a better selection rate for the affected groups in the
employment area which previously showed low participation.
3. a. UNDESIRED CONDITION: The practice of requiring education
levels above those imposed by the qualification standards
issued by the Office of Personnel Management.
b. DESIRED CONDITION: Have positive staffing requirement only
where mandated by the appropriate qualification standard.
c. ANALYSIS: A review of several staffing actions revealed that
for some Administrative positions, a college degree was
required, even though the qualification standard issued by the
Office of Personnel Management did not require such a degree.
d. PROBABLE BARRIER: The practice of requiring a college degree
where not necessary.
e. ALTERNATIVE: Require a college degree only for those
positions where the Office of Personnel Management has found
it to be necessary.
f. EXPECTED RESULT: Selection rates for underrepresented group
members should increase as a result of the appropriate
qualification requirements.
g. FOLLOW-UP ACTION: Track the data on selection rates and
report the results to management team.
4. a. UNDESIRED CONDITION: Statistics indicate that minorities are
repeatedly inadequately represented in the applicant flow
data.
b. DESIRED CONDITION: Minorities are adequately represented on
the certificates of job announcements, especially those jobs
where minority goals have been set.
c. ANALYSIS: Shows that management, personnel, and the EEO staff
are not reacting to the poor recruitment results, and have not
adopted other recruitment efforts which have proven to be
successful with other better represented groups.
d. PROBABLE BARRIER: Management and personnel policy continue
recruitment practices that are adversely impacting on specific
minority groups.
e. ALTERNATIVE: Inform management of the poor recruitment
results, and urge the adoption of a new policy of pursuing
more successful recruitment methods and practices.
f. FOLLOW-UP ACTION: Gather data, track and evaluate the results
of the new recruitment efforts for effectiveness and desired
results. Continue pursuing different approaches such as
finding new sources where there is a larger representation of
minorities.
5. a. UNDESIRED CONDITION: Women represent only .5 percent of
agency's 300 Auditors.
b. DESIRED CONDITION: Ensure that Auditor positions are open to
all qualified applicants.
c. ANALYSIS: Analysis of applicant flow data for the past three
years reveals that women apply for auditor positions at a
higher rate than their representation in the CLF. Women also
represent 30 percent of applicants certified for positions.
However, the selection rate for females is considerably lower
than that of other EEO groups.
Further inquiry by way of interviews with selecting officials
reveal that the position of auditor requires about 30 to 50
percent travel time, and that selecting officials believe,
based on interview questions, that women would not be
available for heavy travel schedules (because of child care
and other family responsibilities.)
d. PROBABLE BARRIERS: Selecting officials stereotyped all
females in a traditional female role of being primarily
responsible for child care and running a household.
e. ALTERNATIVE: Advise selecting official that (1) their
attitudes toward women have a demonstrably adverse impact on
female applicants for Auditor positions; (2) no questions
should be asked during the interview which do not directly
relate to the applicant's ability to perform the job, and no
questions should be asked of female applicants that are not
asked of male applicants; and (3) all applicants should
receive equal consideration based on their qualifications,
and, based on their willingness of travel.
f. EXPECTED RESULTS: Applicants are given equal consideration,
which should result in an increase in representation of female
auditors.
g. FOLLOW-UP ACTION: Following the change in practice, the
representation of female auditors increased significantly
during the first fiscal year. There is every indication that
progress will continue for female auditors in agency's work
force. Barrier has been properly identified.
APPENDIX E
Legal Authorities
Section 717 of Title VII. In the 1972 amendments of Title VII of the
Civil Rights Act (Section 717, 42 USC 2000e-16), the Congress required
agencies to maintain affirmative employment programs to ensure
enforcement of Federal equal employment opportunity policy; to apply the
same legal standards to prohibited discrimination established for
private employers to the Federal Government; and to eliminate
discrimination that Congress found existing throughout the Federal
employment system.
In enacting these requirements, Congress cited the need to eliminate
discrimination in Federal employment. This discrimination was evidenced
(1) by serious underrepresentation and exclusion of minorities and women
in specific areas, agencies, regions, and grade levels; and (2) by
systemic institutional barriers operating through various civil service
rules and procedures, particularly non-job related selection and
promotion techniques.
Section 717(b) reads as follows:
"... The (EEOC) shall -- (1) be responsible for the annual review
and approval of a national and regional equal employment
opportunity plan which each department and agency and each
appropriate unit .
.
. shall submit in order to maintain an
affirmative program of equal employment opportunity for all such
employees and applicants for employment; .
.
.
"
Executive Order 11478. Requirements for Federal agency affirmative
employment programs were first established by Executive Order 11478 in
1969.
The Executive Order as amended by Executive Order 12106 reads as
follows:
"It is the policy of the Government of the United States to provide
equal opportunity in Federal employment for all persons, to
prohibit discrimination in employment because of race, color,
religion, sex, or national origin, and to promote the full
realization of equal employment opportunity through a continuing
program in each executive department and agency. This policy of
equal opportunity applies to and must be an integral part of every
aspect of personnel policy and practice in the employment,
development, advancement, and treatment of civilian employees of
the Federal Government .
.
.
The head of each executive department
and agency shall establish and maintain an affirmative program of
equal employment opportunity for all civilian employees and
applicants for employment within his jurisdiction.
.
.
"
Reorganization Plan No. 1 of 1978. This Presidential directive
transferred all Federal equal employment enforcement responsibilities
vested in the Civil Service Commission to the EEOC.
Executive Order 12067. This Presidential directive gave EEOC lead
coordinating responsibility for all Federal equal employment opportunity
programs and activities. Pursuant to this authority, EEOC consults
regularly with Federal agencies on Federal equal employment opportunity
policy.
Civil Service Reform Act. this legislation directed EEOC to develop
guidelines for a special recruitment program, designated the Federal
Equal Opportunity Recruitment Program (FEORP). The statutory authority
for program oversight was given to OPM (5 USC 7201) and required that
agencies conduct affirmative recruitment for those occupations and
grades within their work force in which there is underrepresentation of
minorities and women. Agency FEORP plans should result in more
representative applicant pools from which to select Federal employees.
Section 501 of the Rehabilitation Act of 1973, as amended (29 U.S.C
791). This legislation established within the Federal Government, an
Inter-agency Committee on Handicapped Employees comprised of such
members as the President may select, or their designees, whose positions
are Executive Level IV or higher.
APPENDIX B
ACCOMPLISHMENT REPORTS, AND ANNUAL AEP PLAN UPDATES:
Agricultural Marketing Service *
Animal and Plant Health Inspection Service *
Agricultural Research Service *
Agricultural Stabilization and Conservation Service *
Cooperative State Research Service
Economics Management Staff
Economics Research Service
Extension Service *
Foreign Agricultural Service
Farmers Home Administration *
Federal Crop Insurance Corporation
Federal Grain Inspection Service
Food and Nutrition Service *
Forest Service *
Food Safety and Inspection Service *
Human Nutrition Information Service
National Agricultural Library
National Agricultural Statistics Service
National Finance Center
Office of Advocacy and Enterprise
Office of Budget and Program Analysis
Office of Finance and Management
Office of the General Counsel
Office of International Cooperation and Development
Office of the Inspector General
Office of Information Resources Management
Office of Operations
Office of Personnel
Office of Public Affairs
Packers and Stockyards Administration
Rural Electrification Administration
Soil Conservation Service *
* Required to submit both MOC and headquarters plans and reports.
APPENDIX C
U.S. DEPARTMENT OF AGRICULTURE
PROGRAM ANALYSIS GUIDELINES
This manual requires that each reporting level conduct a comprehensive
program analysis of the current status of its affirmative employment
efforts. Reporting levels must use all of the eight program elements to
conduct their analyses.
Each reporting level must respond to a series of questions listed below
under each program element to complete the analysis. "Yes" or "no"
responses to the questions will not result in a comprehensive analysis;
therefore, submission must include an analysis of each program element
in narrative form.
The following guidelines are provided to assist in conducting the
required comprehensive program analysis.
Organization and Resources
a Does the Equal Employment Opportunity (EEO) officer have direct
access to top management and lines of communication to supervisors?
1 Review organizational chart for lines of authority.
2 Determine the number of "layers" of management between the EEO
officer and the reporting level head (Administrator, Chief,
etc.) and indicate if it facilitates or impedes the
accomplishment of specific EEO goals.
3 Indicate if the EEO officer attends staff meeting,s planning
sessions, etc., along with other management officials.
4 Determine the extent to which the EEO officer meets with the
reporting level head.
b Do EEO program officials receive adequate training in EEO,
personnel, administration, and management to effectively resolve
problems and issues within their areas of responsibility?
1 Define "adequate training."
2 Review the training record of all EEO program officials during
the most recent two years. Identify the training received and
the areas in which specific training is needed.
c Are there adequate management and fiscal controls to monitor all
resources allocated to the EEO program?
1 Identify the specific controls currently utilized and describe
how the monitoring process works.
2 Determine if the EEO officer maintains records which document
EEO program activities and accomplishments.
d Do special emphasis program managers (SEPMs) devote sufficient time
to accomplish program objectives? Do these managers have adequate
delegations of authority to promote programs and to accomplish
program objectives?
1 Compare the time allocated to each SEP with the time the
program manager actually devotes to the program.
2 Based on the above comparison, determine the amount of time
necessary to implement the SEPs. Refer to FPM Letter 713.37
for guidance on EEO collateral duty assignments.
3 Describe the delegations of authority issued to each SEPM.
e Are EEO officials providing technical advice to management
officials and the personnel office?
1 If so, indicate:
(a) How and when it is given.
(b) To whom it is given.
(c) The impact of the technical advice on the program and
development of plans and reports.
2 If not, state reason(s).
f Have supervisors and managers received training which includes
coverage of their EEO responsibilities?
1 Identify the training each supervisor and manager has received
during the past two years and indicate the following:
(a) Name of the course;
(b) Dates of attendance;
(c) Name of the provider; and
(d) Whether the training was mandatory or optional.
g If the incentive awards system used to recognize supervisors and
managers for their understanding and support of EEO and their
accomplishments in the EEO area?
1 Determine the number of supervisors and managers who received
EEO awards during the past two years. Cite the specific EEO
accomplishment(s) of each award recipient.
2 Describe methods used to encourage supervisors and managers to
excel in the area of EEO.
h Do performance evaluations of supervisors and managers include
specific factors for evaluating EEO performance?
1 Review performance standards for an EEO element.
2 Identify the criteria used to evaluate performance in EEO and
determine whether they are objective and realistic.
Work Force
a Has an analysis of the work force been conducted by PATCOB
category, grade groupings, grade levels, and major occupational
series?
1 Identify manifest imbalance or conspicuous absence (MICA) by
Professional, Administrative, Technical, Clerical and Other
White Collar occupational categories and the Blue Collar
occupational category (PATCOB), grade groupings, and major
occupational series.
2 Identify the individual grade levels within each grade
grouping where MICA exists.
3 Identify specific strategies to eliminate MICA.
4 Compare the current work force with that of the previous year,
and indicate significant changes in the status of EEO groups.
If possible, cite the reasons for the changes.
5 Compare the current work force with the appropriate CLF and
state what the comparison reveals about the work force.
Discrimination Complaints
a Does an analysis of the bases, issues, and findings of recent
complaints suggest the need to explore possible problem areas?
1 Identify the time period the complaint analysis covers.
2 Indicate the number of complaints included in the analysis.
3 Indicate the number of complaints filed during this period.
4 Show the most frequently cited bases and issues.
5 Indicate if the decisions are most often favorable or
unfavorable to the agency.
6 Identify the problem areas suggested by the analysis.
7 Identify actions planned or taken to eliminate the problem
areas.
8 Identify the official responsible for implementing,
evaluating, and monitoring actions to eliminate the problem
areas.
9 Describe systems established to provide periodic status
reports to management officials. Show how these systems are
utilized.
Recruitment and Hiring
a Do present recruitment sources yield qualified minority and female
applicants who meet organizational needs?
1 Identify the minority and female recruitment sources currently
being used.
2 Indicate the frequency of recruitment activities by type of
activity.
3 Identify the designated recruitment official(s).
4 Indicate the number of selections made for all positions
utilizing current recruitment strategies by race, sex, and
national origin (RSNO), series, and grade. Indicate the
number of minority and female applicants available for
selection by RSNO.
5 Identify the fiscal resources for recruitment activities and
determine if they are sufficient to implement plans.
b Have qualification requirements and procedures for hiring been
examined to determine whether barriers to EEO exist?
1 If so, indicate:
(a) When they were examined and by whom.
(b) The process used to identify barriers.
(c) The specific barriers identified.
(d) The actions selected to eliminate each barrier.
2 If not, state reason(s).
c Does the recruitment literature reflect a commitment to reach all
segments of the potential work force?
1 Identify minority, female, and community organizations which
receive recruitment literature.
2 Describe actions taken to reach all segments of the potential
work force.
3 Indicate if recruitment literature contains pictures of
minorities and women in non-traditional occupational settings.
d Do EEO officials participate in the development of vacancy
projections?
1 If so, describe:
(a) How they participate.
(b) How their involvement affects the process.
2 If not, state reason(s).
e Are recruitment efforts within the MOC coordinated to ensure
maximum effectiveness where appropriate?
1 If so, indicate:
(a) How they are coordinated.
(b) The official(s) responsible for coordinating recruitment
efforts.
(c) How coordinated recruitment efforts affect the
recruitment program.
2 If not, state reason(s).
f Do EEO officials provide technical assistance to the personnel
office and monitor, as well as participate in, recruitment efforts?
1 If so, indicate:
(a) Who the EEO officials are who provide technical
assistance and advice to the personnel office.
(b) How the personnel office accommodates the technical
assistance and advice with MOC personnel policies,
practices, and procedures.
(c) The extent to which EEO officials participate in
recruitment efforts.
(d) If the monitoring system is effective.
2 If not, state reason(s).
g Is the selection process reviewed periodically to ensure equal
treatment regardless of race, color, religion, sex, national
origin, age, or employee disability?
1 If so, indicate:
(a) Which official is responsible for conducting periodic
reviews.
(b) The frequency of the reviews.
(c) The deficiencies identified in the selection process and
specific actions selected to eliminate them.
2 If not, indicate plans to do so.
h When paid advertising is used for recruitment or institutional
purposes, are minority media included?
1 Identify advertising sources used and indicate which are
minority media.
2 Indicate the frequency with which minority media are used.
i Does management interact with the community, civic, and other
groups interested in enhancing equal employment opportunity?
1 If so, indicate:
(a) How management interacts with these groups.
(b) Which community, civic, and other groups are involved.
(c) What impact, if any, has this interaction on the size of
the applicant pool and representation of minorities and
women in the work force.
2 If not, state reason(s).
j Does the reporting level participate in cooperative efforts with
Federal and other organizations to resolve employment related
problems in the community; e.g., need for improved public
transportation, education, and child day care?
1 Identify the specific organizations and strategies used to
resolve employment related problems.
2 Describe the results of each cooperative effort.
3 Indicate whether or not such cooperative efforts are
continuous.
4 Identify the official(s) with major responsibility for these
efforts.
5 Describe the fiscal resources available for these efforts.
k Does the reporting level provide opportunities and services to the
community such as cooperative education programs and use of
training facilities?
1 Indicate the specific opportunities and services provided to
the community.
2 Describe to results of these activities.
3 Indicate if this initiative is continuous.
4 Identify official(s) with major responsibility for these
activities.
5 Describe how this activity has affected the size of applicant
pool and the representation of minorities and women in the
work force.
l Does the reporting level participate in community career
information programs, conferences, and occupational study projects?
1 Identify specific programs, conferences, and occupational
study projects.
2 Indicate the frequency of participation in these activities by
type.
3 Identify the official(sw) who participate in these activities
by type.
m Has the reporting level examined methods for expanding
worker-trainee placement? Do current plans call for maximum
participation in the Worker-Trainee Opportunities program, or other
such programs, with particular emphasis on the identification of
developmental positions?
1 Describe the examining process.
2 Describe methods to expand worker-trainee placement and
indicate if these methods are implemented.
3 Indicate the number of employees currently participating in
the Worker-Trainee Opportunities program or other such
programs by RSNO, series and grade.
4 Indicate methods used to identify developmental positions.
5 Indicate the number of developmental positions identified and
the current participants by RSNO, series, and grade.
Employee Development Programs
a Are systems for tracking information on employee skills and
training in operation?
1 Describe the extent to which the Training Information System
(TRAI) is used to track and analyze training.
2 If TRAI is not utilized, identify the system(s) currently in
use.
3 Identify deficiencies, if any, in the current system(s).
Indicate if they are updated as a result of periodic
assessments.
b Has a survey of current skills and training of work force been
conducted to determine the availability of employees with skills
required to meet staffing needs? If so,
1 Identify the date of the survey.
2 Identify the responsible official(s).
3 Describe the survey findings and the number of employees
affected by RSNO.
4 Describe specific plans to utilize these employees to meet
staffing needs.
5 If a survey has not been conducted, indicate plans to do so.
c Has the reporting level conducted time-in-grade studies to
determine the reasons for any differentials which may exist by
minority status and sex?
1 If so, indicate:
(a) When the studies were conducted.
(b) Who is responsible.
(c) The findings of each study.
(d) The specific actions taken as a result of the studies.
2 If not, indicate plans to do so.
d Has the reporting level conducted studies to examine upward
movement of employees to full performance, professional,
supervisory, and highest grade level?
1 If so, indicate:
(a) When the studies were conducted.
(b) Who is responsible.
(c) The findings of each study.
(d) The specific actions taken as a result of the studies.
2 If not, indicate plans to do so.
e Is career counseling available to all employees?
1 Identify the responsible official(s).
2 Determine the adequacy of the career counseling program.
f Are efforts made to ensure that appropriate training opportunities
are available to employees at all grade levels and in all
occupational areas, without regard to RSNO?
1 If so, indicate:
(a) Who is responsible.
(b) The specific efforts to ensure training opportunities.
(c) The impact of these efforts on training received by RSNO.
2 If not, state reason(s).
g Is the MOC encouraging the use of programs that emphasize outside
educational efforts? If so, list substantive results.
Promotions
a Are internal selection and promotion qualification requirements and
procedures valid, job-related, and free from unnecessary barriers
to the full utilization of skills and training?
1 Determine the number of promotions by RSNO.
2 Compare the number of promotions by RSNO with the number of
qualified candidates by RSNO.
3 Determine if disparities regarding internal selection and
promotion qualification requirements and procedures exist.
4 Indicate whether or not the personnel office has analyzed the
bases for any real or perceived inequities with regard to
internal selection procedures.
5 Describe the results of this analysis.
b Are efforts made to ensure that appropriate promotional
opportunities are available to employees at all grade levels and in
all occupational areas, regardless of minority status and sex?
1 If so, indicate:
(a) The specific efforts to ensure promotional opportunities.
(b) The impact of these efforts on the number of promotions
given to minorities and women.
(c) The responsible official(s).
2 If not, state reason(s).
Separations
a Are efforts made to ensure that separations (voluntary and
involuntary) are conducted fairly and in a nondiscriminatory
manner?
1 If so, indicate:
(a) The specific efforts to ensure fair and nondiscriminatory
separations.
(b) The impact of these efforts on separations.
(c) The responsible official(s).
2 If not, state reason(s)
b Are Reductions-in-Force (RIF) conducted fairly and in a
nondiscriminatory manner?
1 Indicate the number of reductions-in-force conducted within
the last two years.
2 Indicate the number of employees displaced as a result of each
RIF by RSNO.
3 Indicate by RSNO the number of discrimination complaints, if
any, filed by displaced employees.
4 Indicate whether the decisions rendered are most often
favorable or unfavorable to the reporting level.
5 Describe actions taken by management prior to and during the
RIF to minimize its effect on minorities and women.
Program Evaluation
a Are findings from EEOC on-site reviews and internal program
evaluations incorporated into the annual AEP plan development
process, if appropriate?
1 Indicate the number of EEOC on-site reviews and internal
program evaluations conducted in the last two years.
2 Describe the major findings of EEOC and internal review.
3 Describe the specific EEOC and internal review
recommendations.
4 Indicate how the findings have been or will be incorporated
into the annual AEP plan development process.
b Do EEO committee, where established, consult with the EEO officer,
personnel officer, and management officials to ensure that each
provides input to EEO program evaluation?
c Are statistical data for EEO program evaluations accurate, timely,
and accessible?
d Are officials responsible for EEO program evaluations fully trained
in EEO and merit system requirements contained in EEOC and OPM
manuals.
e Do EEO program evaluations include input from SEPMs and EEO
committees?