ML22026A208
| ML22026A208 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/2020 |
| From: | NRC/SBCR |
| To: | |
| Garland, Stephanie - 301-415-2729 | |
| Shared Package | |
| ML22026A185 | List: |
| References | |
| NRC-2022-000059 | |
| Download: ML22026A208 (66) | |
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EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency MD-715 Part G, C.4.a. Do the HR Director and the EEO Director meet Agency regularly to assess whether personnel programs, policies, and Assessment procedures conform to EEOC laws, instructions, and management directives? [see 29 CFR §1614.102(a).
On June 5, 2018 Catanya Chandler, EEOC representative contacted the EEO Director via email and requested a detailed progress status on deficiencies noted in the FY 2017 MD-715, which included, among other things, the following (which are applicable to both C.4.a and C.4.b):
- Timetables or schedules have not been established for review of Merit Promotion Program, Employee Recognition Awards Program or Employee Development Training program; and
- Management/personnel policies, procedures, and practices are not examined at regular intervals in accordance with C.4.a In following up on the above compliance items, the EEO office affirms attendance at the Human Capital Council Meetings, which are held quarterly, and the Agency Quarterly Performance Review Meetings.
However, there was no relevant information, data and/or documentation made available to support that the EEO office (including the Affirmative Employment Program) and OCHCO have engaged in the level of ongoing participation and review efforts set forth in MD 715 and 29 CFR 1614.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Type of Program Brief Description of Program Deficiency Deficiency The OCHCO and EEO office meet monthly to discuss personnel programs, policies, and procedures to identify barriers/triggers/issues and initiate necessary updates to agency practices ensure conformance to EEOC laws, instructions, and management directives. The Director and Deputy Director of OCHCO and the Director and Deputy EEO Office currently participate in these Human Capital Council monthly meetings.
MD-715 Part G, C.4.b. Has the agency established timetables/schedules to Agency review at regular intervals its merit promotion program, Assessment employee recognition awards program, employee development/training programs, and management/personnel policies, procedures, and practices for systemic barriers that may be impeding full participation in the program by all EEO groups? [see MD-715 Instructions, Sec. I].
Accordingly, MD-715 Instructions, Sec. I, Subsection 3.
Overall Accountability and EEO Programmatic Management states, the EEO office is required to ensure that personnel policies and procedures, rules of conduct, promotion, evaluation and training systems are routinely reviewed to ensure that they are clearly defined, well-communicated, consistently applied and fairly implemented.
Section 29 CFR §1614.101(a) states, It is the policy of the Government of the United States to provide equal opportunity in employment for all persons, to prohibit discrimination in employment because of race, color, religion, sex, national origin, age or [disability] and to promote the full realization of equal employment opportunity through a continuing affirmative program in each agency.
Section 29 CFR §1614.102(a) states, Each agency shall maintain a continuing affirmative program to promote equal
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Type of Program Deficiency Brief Description of Program Deficiency opportunity and to identify and eliminate discriminatory practices and policies. In support of this program, the agency shall under subsection (3) Conduct a continuing campaign to eradicate every form of prejudice or discrimination from the agencys personnel policies, practices and working conditions.
Currently, no relevant information, data and/or documentation has been provided, which supports that the EEO office (including the Affirmative Employment Program) and OCHCO have engaged in the level of ongoing participation and review efforts set forth in MD 715 and 29 CFR 1614.
The OCHCO and EEO office meet monthly to discuss potential systemic barriers, review management/personnel policies, procedures, and practices that may be impeding full participation in the program by all EEO groups, and initiate changes as necessary. This includes agency merit promotion programs, employee recognition awards programs, employee development/training programs.
The EEO office is an active participant on the agencys Strategic Workforce Oversight Utilization Panel (SWOUP) a subcommittee of the HCC. The SWOUP meets quarterly to provide direct guidance and recommendations on the agencys talent acquisition activities including recruitment, hiring and strategic direction. EEO Office representation on the HCC and SWOUP ensures that discussions and decisions are informed to ensure equal opportunity in employment for all persons, including prohibiting discrimination in employment because of race, color, religion, sex, national origin, age or [disability] and to promote the full realization of equal employment opportunity at the agency.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT B.3.a: Do EEO program officials participate in agency meetings regarding workforce changes that might impact EEO issues, including strategic planning, recruitment strategies, vacancy projections, succession planning, and selections for training/career development opportunities? [see MD-715, II(B)].
This subsection is being cited as deficient in FY 2020.
The EEO office (Affirmative Employment Program) will review relevant information, data, and support documentation to affirm that the level of ongoing review and participation by the EEO office and OCHCO is occurring consistent with the provisions set forth in MD 715 and 29 CFR 1614.
Objective(s) and Dates for EEO Plan Date Target Modified Date Initiated Objective Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy) 01/30/2018 The EEO office and OCHCO 09/30/21 Ongoing Directors meet regularly to assess Report whether personnel programs, annually policies, and procedures conform to MD-715 EEOC laws, instructions, and Report management directives The EEO office/AEDM Program 09/30/21 Ongoing Manager jointly brief the EEO and Report OCHCO Directors on policies, annually practices, and procedures that MD-715 adversely impact women, minorities, Report and individuals with disabilities.
The EEO office/AEDM Program 09/30/2021 Manager receives information/document to support corrective strategies for moving forward and to track progress, and report outcomes internally and externally (e.g., EEOC).
Responsible Official(s)
Performance Title Name Standards Address the Plan?
(Yes or No)
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Director, Office of Small Business Vonna Ordaz Yes and Civil Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Affirmative Employment and Tuwanda Smith Yes Diversity Management (AEDM)
Program Manager, SBCR AEDM Specialist Stephanie Garland Yes Program Manager, Special Dorothea Washington Yes Emphasis Program, SBCR Chief Human Capital Officer, Mary Lamary Yes Office of the Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Ashley Roberts Yes Officer, Office of the Chief Human Capital Officer (OCHCO)(Acting)
Associate Director for HR Susan Salter Yes Operations and Policy Planned Activities Toward Completion of Objective Sufficient Modified Completion Target Date Planned Activities Funding Date Date (mm/dd/yyyy) & (mm/dd/yyyy) (mm/dd/yyyy)
Staffing?
(Yes or No) 06/12/2018 Draft timetables/schedules for Yes Ongoing Drafted 2018.
conducting reviews of the Merit Agreed to by Promotion Program, Employee EEO Recognition Awards Program, office/OCHCO Employee Development/Training 1/20/2020 Program; and management/personnel policies, procedures, and practices. EEOC Approval 2020 Report annually via MD-715 Report 10/01/2018 Implement timetable/schedule and Yes Ongoing Report track reviews conducted, findings, annually actions, and outcomes over the fiscal via MD-year. 715
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Report Report of Accomplishments Fiscal Year Accomplishments NRC issued a separate Diversity and Inclusion Policy (on 5/18),
2020 which was distributed to all NRC employees through an agency yellow announcement.
2020 Continued to elicit support and promote the NRCs Inclusive Diversity Strategic Plan (IDSP), and Comprehensive Diversity Management Plan Reports.
2020 Implemented an Initiative on Civility, Awareness, Respect and Engagement known as iCARE to assist with Agency efforts in facilitating deeper understandings and appreciation of cultural and diversity and inclusion related issues amongst employees and promote individual personal and professional growth and effectiveness through the processes of listening, introspection, and building acceptance for differing perspectives.
2020 Continued implementation of DIALOGUEDiversity Inclusion Awareness Leading Organizational Growth, Understanding, and Engagementin which small groups of managers and employees participate in facilitated forums to discuss diversity topics in an open environment.
2020 Continued to facilitate the Speed of Trust initiative, consisting of workshops to provide opportunities for strengthening mutual trust among Agency leaders, supervisors, and employees.
2020 See additional agencywide accomplishments captured in MD-715 Part E3, Workforce Analysis.
2020 See additional agency accomplishments captured in MD-715 Part E2, Executive Summary: Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency The EEO office has been requesting required data from OCHCO as part of EEOCs MD-715 Model Agency MD-715 Reporting. In the MD-715, Part G Agency Self-Assessment, the EEO office Title VII and has responded to the compliance indicator related to OCHCO providing timely Rehabilitation Act accurate data by checking yes with comments referencing challenges Programs improvements. Additionally, OCHCO has indicated in the agencys annual FEORP Report submitted to OPM that the agency tracks career development demographics and MD-715 Part H and I are being put in place to help track, make available and produce the required affirmative employment information/data.
The data being requested should comply with the regulatory requirements set forth in the MD-715 Part G - Agency Self-Assessment, which are described in the following paragraphs:
B.4.a.7 - to maintain accurate data collection and tracking systems for the following types of data: complaint tracking, workforce demographics, and applicant flow data?
[see MD-715, II(E)]. If not, please identify the systems with insufficient funding in the comments section.
C.4.c - Does the EEO office have timely access to accurate and complete data (e.g.,
demographic data for workforce, applicants, training programs, etc.) required to prepare the MD-715 workforce data tables? [see 29 CFR §1614.601(a)]
D.1.b - Does the agency regularly use the following sources of information for trigger identification: workforce data; complaint/grievance data; exit surveys; employee climate surveys; focus groups; affinity groups; union; program evaluations; special emphasis programs; reasonable accommodation program; anti-harassment program; and/or external special interest groups? [see MD-715 Instructions, Sec. I]
E.4.a - Does the agency have systems in place to accurately collect, monitor, and analyze the following data:
E.4.a.2 - The race, national origin, sex, and disability status of agency employees?
[see 29 CFR §1614.601(a)]
E.4.a.3 - Recruitment activities? [see MD-715, II(E)]
E.4.a.4 - External and internal applicant flow data concerning the applicants race, national origin, sex, and disability status? [see MD-715, II(E)]
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Objective(s) and Dates for EEO Plan Date Target Modified Date Initiated Objective Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy)
To generate the information/data needed to 09/30/2021 Ongoing 04/01/2021 prepare the annual MD-715 report and monitor EEO activities throughout the year.
Responsible Official(s)
Title Name Performance Standards Address the Plan?
(Yes or No)
Deputy Chief Human Capital Officer, Office of Mary Lamary Yes the Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Officer, Ashley Roberts Yes OCHCO Chief, Human Capital Analysis Branch Terry Mintz Yes Yes Brendan Cain Human Capital Analysis Branch Director, Office of Small Business and Civil Yes Vonna Ordaz Rights (SBCR)
Deputy Director, SBCR Yes Jeanne Dempsey Program Manager, SBCR Affirmative Yes Tuwanda Smith Employment and Diversity Management (AEDM) Program AEDM Specialist Yes Stephanie Garland SBCR-Special Emphasis Program Yes Dorothea Washington
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Planned Activities Toward Completion of Objective Sufficient Modified Completion Target Date Planned Activities Funding &
Date Date (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No) 09/30/21 Continue to generate the information/data Yes Ongoing Ongoing needed to prepare the annual MD-715 report and monitor EEO activities throughout the year.
Report of Accomplishments Fiscal Year Accomplishments See recruitment efforts and agencywide performance results captured in 2020 MD-715 Report, Part E3, Workforce Analysis.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency Does the agency regularly use the following sources of information for trigger identification: workforce data: complain/grievance data; exit surveys; D.1.b.
employee climate surveys; focus groups; affinity groups; union; program evaluations; special emphasis programs; and/or external special interest groups? [see MD-715].
Objective(s) and Dates for EEO Plan Date Target Modified Date Objective Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy)
The OCHCO provides quarterly exit survey data to 04/06/20 09/30/21 Report 10/01/17 the EEO office/Affirmative Employment and On-going Annually via Diversity Management (AEDM) to: 1) conduct EEOC MD-09/30/19 routine reviews and assessments of Exit Survey 715 data; 2) coordinate efforts with OCHCO and other Report NRC offices around results; 3) improve, reduce, or eliminate unwarranted employee separations; 4) identify triggers and root causes of problems; and
- 5) implement plans to identify and eliminate any barriers to equality of opportunity for all NRC employees.
Responsible Official(s)
Performance Title Name Standards Address the Plan? (Yes or No)
Mary Lamary Chief Human Capital Officer, Office of the Chief Yes Human Capital Officer (OCHCO)
Ashley Roberts Deputy Chief Human Capital Officer, OCHCO Yes Associate Director for HR Susan Salter Yes Operations and Policy
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Branch Chief, Workforce Management and Tamla Ransford Yes Benefits Branch Director, Office of Small Business and Civil Vonna Ordaz Yes Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Yes Program Manager, Affirmative Employment Tuwanda M. Smith and Diversity Management (AEDM)
Program, SBCR Program Manager, Special Emphasis Dorothea Washington Yes Programs, SBCR Stephanie Garland Yes AEDM Specialist, SBCR Planned Activities Toward Completion of Objective Sufficient Target Modified Completion Planned Activities Funding &
Date Date Date (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No) 09/30/18 The AEDM Program Manager will meet with the Yes 03/30/21 Report EEO office and OCHCO Directors/Deputies to Annually via 04/20/20 discuss AEDMs review and examination of Exit Ongoing EEOC MD-Survey results for fiscal years 2018-2021. The EEO Activities 715 Report office and OCHCO will collaboratively devise a strategy plan for moving forward and working with NRC offices identified in the Exit Interview Survey as having unwarranted reasons for employee separations.
03/30/21 The AEDM will report suspected wrongdoing (e.g., Yes 03/30/21 Report incidences of abuse, misconduct, mismanagement Annually via of agency programs) cited by former and current EEOC MD-NRC employees in Exit Surveys to the EEO 715 Director, who is required to report these allegations Report in writing directly to the Office of the Inspector General consistent with the provisions set-forth in 28 U.S.C. 535 and NRCs Management Directive (MD) 7.4 Reporting Suspected Wrongdoing and Processing OIG Referrals. The Program Manager of AEDM also recognizes that MD 7.4 imposes a duty on NRC employees to report to the OIG suspect wrongdoing, as well.
03/30/21 The AEDM Program will coordinate efforts with the Yes Ongoing agencys Culture Improvement Initiative (CII) staff to Partnering include sharing exit survey results for the 2018-2021 periods and determine how the two groups can partner and work collaboratively with affected NRC offices identified as having unwarranted reasons for employee separations.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Sufficient Target Modified Completion Planned Activities Funding &
Date Date Date (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No) 09/30/18 The EEO office will elicit assistance from the DMIC Yes 04/20/20 Report to conduct a barrier analysis and focus groups to 04/30/21 Annually via identify issues/challenges confronting employees in Ongoing EEOC MD-the NRC workforce; determine underlying problems 715-Report and root causes related to employment conditions and potential unwarranted employee separations; and present findings and recommendations to the EEO office and OCHCO.
09/30/18 SBCR/AEDM will continue to coordinate efforts with Yes 10/15/20 Report OCHCO and others to incorporate within the EEO Ongoing Annually via and Diversity Management Training for managers EEOC MD-and supervisors, 5 CFR Part 412, Federal 715 Report supervisors and managers required triennial refresher training on performance management; and emergent training. Topics/focus include information on employee separations and causes, identifying and eliminating barriers, utilizing effective communication skills, recognizing and addressing bias, NRC culture and values, roles, responsibilities, and manager and supervisor accountability, drafting corrective action plans, etc.
04/20/20 The EEO office will elicit support from the EEO Yes 04/20/20 Report Advisory Committees to host lunch and learns, and Annually via other forums for employees around usage of ADR to 09/30/21 EEOC MD-resolve workplace disputes, the EEO complaints Ongoing 715 Report process, and other methods of communication that allows employees to bring attention on workplace environments and conditions.
07/01/20 The EEO Director/Deputy will continue to hold Yes Ongoing Report periodic meetings with NRC office Annually via Directors/Designees. The periodic meetings will EEOC MD-continue to include individualized Assessments 715 Report conducted by the EEO office Affirmative Employment and Diversity Management (AEDM) program and provide office specific information related to the following areas: Recruitment Outreach; Training/Development; Diversity and Inclusion (e.g., Employee Engagement Index, Employees Perception of diversity & inclusion specific to ranking for each office); and findings from Employee Exit Interviews (e.g., identify concerns raised regarding separations); and identifying supportive behaviors and recommendations.
09/30/18 The AEDM staff work directly with affected NRC Yes 04/20/20 Report offices to identify office level strategies, 09/30/21 Annually via interventions, and remedies specific to each Ongoing EEOC MD-affected office. 715 Report
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Report of Accomplishments Fiscal Year Accomplishments 2020 See MD -715, Part E3, Workforce Analysis.
2020 The EEO office Director/Deputy held individualized periodic briefing meetings with the following NRC offices (which included AEDM office specific Assessments related to affirmative employment and diversity management topics including employee separations and findings from Exit Interview Surveys): Office of Investigations and Region I (7/17); Office of Nuclear Material Safety and Safeguards, and Office of Nuclear Reactor Regulation (7/28); Office of the Chief Human Capital Officer, and Office of Enforcement (7/29); Office of the Chief Financial Officer (8/3); Office of Nuclear Security and Incident Response, and Office of Public Affairs (8/17); Office of International Programs (8/20); Office of Administration (8/24); Region II (8/31);
Office of the Advisory Committee on Reactor Safeguards (9/2); Region IV (9/3); Office of the Inspector General (9/29); and Office of the Chief Information Officer (9/30).
2020 See additional agencywide accomplishments captured in MD-715 Part E3, Workforce Analysis.
2020 See additional agency accomplishments captured in MD-715 Part E2, Executive Summary:
Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency Has the agency taken specific steps that are reasonably designed to increase the D.4.d. number of persons with disabilities or targeted disabilities employed at the agency until it meets the goals? [see 29 CFR § 1614.203(d)(7)(ii)].
Objective(s) and Dates for EEO Plan Date Modified Date Target Date Initiated Date Completed Objective (mm/dd/
(mm/dd/ (mm/dd/ (mm/dd/
yyyy) yyyy) yyyy) yyyy) 10/01/19 The OCHCO will make available to the EEO Ongoing Report office/AEDM program quarterly statistical tables, Outcomes demographics, and applicant flow data required to 04/06/20 Annually via prepare the agencys annual MD-715 Report and EEOC MD-needed to conduct periodic assessments during 715 Report the fiscal year.
10/01/19 Ongoing Report Increase the agencys use of hiring authorities that Outcomes take disability into account with respect to hiring; Ongoing Annually via promotion, and assignments to the extent EEOC MD-permitted by law.
715 Report 10/01/19 Ongoing Report Outcomes Increase representation of PWTD in NRCs senior Ongoing Annually via grade levels.
EEOC MD-715 Report 10/01/19 Ongoing Report Outcomes Achieve the 12 percent disability goals for persons Ongoing Annually via with disabilities (PWD).
EEOC MD-715 Report 10/01/19 Ongoing Report Outcomes Achieve the 2 percent disability goals for persons Ongoing Annually via with disabilities (PWTD).
EEOC MD-715 Report Create awareness, provide training, and Ongoing Report disseminate/post the agencys revised Reasonable Annually via 10/01/19 Ongoing Accommodations Procedures Plan (RAP), which EEOC MD-was approved by EEOC 09/27/19. 715 Report
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Provide (PAS) NRC has determined that requests Ongoing Report for Personal Assistance Services PAS procured Outcomes 10/01/19 using an independent PAS provider once needs Ongoing Annually via are identified. Payment would be made with EEOC MD-OCHCO purchase card. 715 Report Ongoing Report Outcomes Partner with organizations that specialize in the 10/01/18 Ongoing Annually via employment of individuals with disabilities.
EEOC MD-715 Report Ongoing Report Assurance that all hiring managers and supervisors Outcomes 10/01/18 are aware of NRC hiring authority equivalent to Ongoing Annually via Schedule A and other disability hiring authorities. EEOC MD-715 Report Remove barriers PWD and PWTD may encounter Ongoing Report in recruitment and/or selection processes related to Outcomes 10/01/18 new hires, promotions, training and career Ongoing Annually via development, and advancement; or distribution of EEOC MD-awards. 715 Report Ongoing Report Assurance that NRC policies, procedures, or Outcomes 10/01/19 practices are not the reason why PWD and PWTD Ongoing Annually via terminate their employment with the agency. EEOC MD-715 Report Assurance that the disability program staff possess Ongoing Report sufficient knowledge and skills to answer program Outcomes 10/01/18 and disability related questions; and provide Ongoing Annually via employees and job applicants with necessary EEOC MD-reasonable accommodations. 715 Report Assurance that managers and supervisors Ongoing Report demonstrate their commitment to equal Outcomes employment opportunity and diversity management 10/01/18 Ongoing Annually via principles, which includes among other things EEOC MD-recruiting, retaining, and developing a diverse 715 Report workforce.
Responsible Official(s)
Performance Standards Address Title Name the Plan?
(Yes or No)
Chief Human Capital Officer, Office of the Mary Lamary Yes Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Officer (Acting), Ashley Roberts Yes OCHCO Associate Director for HR Operations and Susan Salter Yes Policy
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Standards Address Title Name the Plan?
(Yes or No)
Chief, Workforce Management and Benefits Tamla Ransford Yes Branch Recruitment Program Manager, Special Kimberly English Yes Placement Program Coordinator (Individuals with Disabilities)
Reasonable Accommodations Coordinator, Anne Silk N/A Disability Program Manager Chief, Human Capital Analysis Branch Terry Mintz Yes Brendan Cain Yes Human Capital Analysis Branch Director, Office of Small Business and Civil Vonna Ordaz Yes Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Affirmative Employment Tuwanda M. Smith and Diversity Management (AEDM) Yes Program, SBCR Program Manager, Special Emphasis Dorothea Washington Yes Programs, SBCR AEDM Specialist, SBCR Stephanie Garland Yes Planned Activities Toward Completion of Objective Sufficient Funding & Modified Completion Target Date Planned Activities Staffing? Date Date (mm/dd/yyyy)
(Yes or (mm/dd/yyyy) (mm/dd/yyyy)
No)
Address inconsistences and provide MD-715 Yes Ongoing Report related workforce tables, demographics, and Annually via 10/01/18 applicant flow information/data. EEOC MD-715 Report Include a segment on disability hiring Yes Ongoing authorities in the annual mandatory EEO and Diversity & Inclusion Training for Supervisors Report and Managers; and encourage and support Annually via 10/01/18 fiscal year hiring efforts that take disability EEOC MD-715 into account (i.e., new hires; promotions, Report solicitations of interest, rotations, and assignments).
Conduct outreach and recruitment efforts for Yes Ongoing Report 09/3019 PWTD in the senior grade levels. Annually via
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Sufficient Funding & Modified Completion Target Date Planned Activities Staffing? Date Date (mm/dd/yyyy)
(Yes or (mm/dd/yyyy) (mm/dd/yyyy)
No)
EEOC MD-715 Report Increase the number of PWD hired, Yes Ongoing Report promoted, and reassigned (i.e., rotations, Annually via 10/01/18 details, reassignments). EEOC MD-715 Report Increase the number of PWTD hired, Yes Ongoing Report promoted, and reassigned (i.e., rotations, Annually via 10/01/18 details, reassignments). EEOC MD-715 Report Published the Disability Program Strategic Yes Ongoing Plan Project Plan for FY 2019 - FY 2024 and Activities completed/
posted on the agencys public Web site. Plan posted implementation ongoing. 04/14/2020 09/30/19 Status on implementation efforts - Report Annually via EEOC MD-715 Report Conduct a focus group in FY 2020, with NRC Yes employees, to Identify challenges and Report barriers for people with disabilities when Annually via 09/30/20 applying and interviewing for jobs at the 09/30/21 EEOC MD-715 NRC, receiving training and developmental Report opportunities, and applying for and being selected for promotions/new opportunities.
09/30/19 Post RAP on agencys public Web site. Yes 09/27/19 10/01/19 Provide RAP training to managers, Yes 02/27/18 09/27/19 10/01/19 supervisors, and employees.
Use a service provider to administer PAS to Yes Report disability status applicants and employees. Annually via 09/30/19 Ongoing EEOC MD-715 Report Establish and maintain contacts with Yes organizations that specialize in the Report employment of individuals with disabilities Annually via 9/30/19 and use program resources that identify Ongoing EEOC MD-715 applicants eligible to be appointed under Report NRC hiring authorities that take disabilities into account.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Conduct a barrier analysis to determine Yes 09/30/2021 whether PWD and PWTD have barriers in the recruitment and/or selection processes for Report via 09/30/19 new hires, promotions, training and career EEOC MD-715 development, advancement, distribution of Report awards and retention.
Conduct a barrier analysis to determine Yes 09/30/2021 Report via whether any policies, procedures, or 10/01/18 EEOC MD-715 practices are causing PWD and PWTD to Report leave the agency.
10/01/18 Conduct a focus group in FY 2020, with NRC Yes 09/30/2021 Report via employees, to Identify whether policies, EEOC MD-715 procedures, or practices for the reason PWD Report and PWTD terminate their employment with the agency.
10/01/18 Provide training to all hiring managers and Yes Ongoing Report supervisors on the use of NRC hiring Annually via authority equivalent to Schedule A and other EEOC MD-715 disability hiring authorities. One method will Report be to include a segment on disability hiring authorities in the annual mandatory EEO and Diversity & Inclusion Training for Supervisors and Managers.
10/01/18 Provide training to the disability program staff Yes Ongoing Report sufficient to increase their knowledge and Annually via skills regarding disability hiring programs; EEOC MD-715 answer disability related questions; provide Report job applicants with necessary reasonable accommodations; accept, validate, and forward applications for appointment under hiring authorities that take disability into account to the relevant hiring official and; oversee any other disability related hiring program.
10/01/18 Evaluate hiring managers on their support of Yes Report EEO and Diversity efforts including helping to Annually via Ongoing meet disability goals in their annual EEOC MD-715 performance appraisal. Report Report of Accomplishments Fiscal Year Accomplishments NRCs Disability Program Strategic Project Plan was published in FY 2020 and 2020 posted on NRCs internal and external Web sites on April 14, 2020. For more information click on Disability Program Strategic Project Plan 2019-2024.
NRCs OCHCO is continuing to work on developing a Career Development Tracking System. Efforts were initiated on January 23-28, 2020 to identify long-term requirements to track application and participation rates. OCHCO staff were able to generate an initial dataset of FY 2019 information and worked to produce 2020 summary reports. On January 31, 2020 staff started to get the training data connected with the PWD and PWTD data. On a high level, OCHCO begin exploring ways they could organize the data in TMS, connect to related HR data, and generate this type of reporting quicker in the future. To comply with MD-715
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT requirements that agencies track their career development opportunities to permit analyses of potential barriers to equality of opportunity for women, minorities, and individuals with disabilities, OCHCO created a Microsoft Excel spreadsheet of training for FY 2019 by Disability category. The spreadsheet tracks employees who applied for internal and external training and those selected (including PWD and PWTD), by numbers and percentages for the FY 2019 MD-715 Report. The same processes are being used to generate for FY 2020 information.
In 2020, the EEO office/ADEM, OCHCO, and OGC conducted four EEO and Diversity & Inclusion training courses for managers and supervisors, which covered 2020 disability regulations and requirements including the NRC procedures and processes, and manager/supervisor responsibilities related to reasonable accommodations.
NRC Disability program staff continued to implement the Disability Affirmative Action Plan. Promoted the use of our Schedule A equivalent hiring authority by 2020 providing training for supervisors on special hiring authorities and forwarding resumes of eligible applicants to hiring managers.
NRC hired 13 persons with disabilities, of which one person had a targeted 2020 disability, compared to eight hires and one hire with a targeted disability in FY 2019.
2020 NRC staff referred 14 resumes from the Workforce Recruitment Program (WRP) data base for consideration in the Temporary Summer Student Program and seven offers extended. Of the seven offers extended, four were accepted, two declined, and one withdrew from consideration. One student from the WRP accepted an offer to return for a second internship over winter break. Referred and subsequently hired a Wounded Warrior as an Intelligence Analyst.
2020 All NRC vacancy announcements include information on how to request a reasonable accommodation when applying to a vacancy posting; however, there were no requests for reasonable accommodations from job applicants in FY 2020.
There was one request for reasonable accommodations made during the new hire process for a deaf summer intern. There was also one request for reasonable accommodations during the promotional process for a GG-14 staffer who was promoted to a GG-15 Branch Chief position.
2020 NRC processed 115 requests for reasonable accommodations in FY20.
Approximately 68 of those requests were processed since mid-March 2020, when the agency began teleworking due to COVID-19. This is about a 17% increase in requests from the previous year.
2020 To improve career advancement opportunities for PWD and PWTD, the NRC offered training, internship, and mentoring programs.
2020 NRCs Advisory Committee for Employees with Disabilities (ACED) sponsored the Disability Employment Awareness Month Luncheon and a lunch and learn on Aphasia Awareness.
2020 As of 09/30/20, the NRC had partnered with the Department of Defense Operation Warfighter (OWF) Program, which provides Federal internship opportunities in a supportive work setting to recovering service members. The NRC also partnered with the Department of Labors Workforce Recruitment Program (WRP) by accessing their resume database to search for candidates for Administrative Assistant, Information Technology, and Temporary Summer Student positions.
The NRC strengthened its relationship with the Wounded Warrior Project (WWP),
and in June 2020 NRC staff conducted an informational session with WWP constituents on special hiring authorities. And, NRC participated in recruiting events and/or posted job vacancies on job boards with Equal Opportunity Publications (EOP), Ability Corps/Ability Magazine, MD Workforce Exchange job board, MD DORS, and GettingHired.com.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT In 2020, the OCHCO Disability program staff participated in training sessions such as: Building Understanding of Employment of People with Disabilities in Federal Agencies (FEED); Federal Equal Employment Opportunity Laws and the COVID-19 Pandemic (EEOC); Federal Agency Telework Considerations for Employees 2020 with Disabilities (FEED); 5 Tips for Disability Hiring(Disability Solutions);
Connecting Agency Practices to Federal Disability Discrimination Complaints (FEED); Resolving Complex Reasonable Accommodation Issues in the Federal Workplace (Federal Webinars-LRP Publications)
In 2020, NRC posted notices explaining employees and applicants rights under 2020 applicable regulations, including how to file a complaint.
See additional agencywide accomplishments captured in MD-715 Part E3, 2020 Workforce Analysis.
See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
See additional accomplishments captured in MD-715 Part J, Special Program 2020 Plan for the Recruitment, Hiring, Advancement, and Retention of Persons with Disabilities.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency E.1.d. Does the agency issue acceptance letters/dismissal decisions with a reasonable time (e.g., 60 days) after receipt of the written EEO Counselor report, pursuant to MD-110, Ch. 5(I)? If so, please provide the average processing time in the comments.
In 2020, the answer was, no and a MD-715 Part H plan was put into place.
PRIOR YEAR FINDINGS MD-715 Part G, Agency In FY 2018, the answer was, no. In FY 2019, the answer was yes. Mitigating and Assessment corrective strategies were put in-place, which included more efficient utilization of the iComplaint tracking system; and establishing 60 days as a reasonable time metric for issuing acceptance letters and dismissal decisions consist with MD-110 provisions. In FY 2020, the answer is no. A review of the 462 Report for the reporting period (10/01/2019-09/30/2020) reflects there were six complaints pending decision to accept/dismiss. The Summary of Pending Complaints by Category reflect that the number of days these cases were in pending status was 1,015, with the average number of days identified as 169, and pending time for the oldest case was 552 days.
Objective(s) and Dates for EEO Plan Date Target Modified Date Initiated Objective Date Date Completed (mm/dd/yyyy (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy)
)
In accordance with 29 CFR 1614 and EEOC Management Directive (MD) 715, make a Report on the 10/01/20 conscious effort to issue acceptance 9/30/21 Annual MD-letters/dismissal decisions within a thirty (30) day 715 Report timeframe.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
EEO Director Vonna Ordaz Yes
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Standards Title Name Address the Plan?
(Yes or No)
Deputy EEO Director Jeanne Dempsey Yes Program Manager Stephen Smith Yes Planned Activities Toward Completion of Objective Sufficient Target Modified Completion Planned Activities Funding &
Date Date Date (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
Hire additional staff to manage and oversee the 12/01/19 01/31/21 EEO complaint processing activities Continue to assess and implement process 10/01/20 improvement measures to increase program 09/30/21 efficiency and effectiveness Continue to optimize the use of the iComplaints Case Management System to 10/01/20 monitor the complaint activity to ensure that all 09/30/21 required timelines are being met (i.e.,
investigations)
Report of Accomplishments Fiscal Year Accomplishments A senior civil rights specialist was hired in June 2020 June 2020 Holds regularly scheduled team meetings and to discuss creative and innovated On-going ways to improve complaint processing activities by eliminating impediments CR has implemented new internal controls for complaint processing activities to October 2020 include a tracking spreadsheet which monitors a formal complaints life cycle Developed templates for standardizing all correspondence supporting the EEO October 2020 complaint process Reestablished clear internal complaint processing procedures by revising the acceptance/dismissal analysis stage to be completed within twenty (20) days December 2020 and provide legal sufficiency with the required ten (10) days for review and approval.
A senior EEO specialist was hired in January 2021 January 2021 See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency E.1.f - Does the agency timely complete investigations, pursuant to 29 CFR § 1614.108? No. This determination was made based on a review of the agencys EEOC SF462 Report for 2020.
Pursuant to 29 CFR § 1614.108 the agency is required to investigate a discrimination complaint in a timely manner. The investigation must be appropriate, impartial, and completed within 180 days of filing the complaint, or within the time period contained in an order from the Office of Federal Operations on an appeal from a dismissal pursuant to 29 CFR § 1614.107(a). The EEO Director or designee and the complainant may agree in writing, consistent with 29 CFR § 1614.108(e), to an extension of not more than ninety (90) days; or within the period of time set forth in 29 CFR §§ 1614.108(e) or 1614.606 if there are multiple complainants with similar allegations of discrimination or complainant has filed multiple complaints which the agency has consolidated. If the agency fails to complete the investigation in 180 days, it shall issue written notice to complainant informing the complainant that it was unable to complete the investigation, the estimated date of completion, and complainants right to file a civil action or request a hearing. See 29 CFR § 1614.108(g). Agencies are required to complete investigations within the earlier of 180 days after the filing of the last complaint or 360 days after the filing of the original complaint. Regardless of amendment or consolidation of complaints, the investigation shall be completed in not more than 360 days.
A review was conducted of NRCs EEOC SF 462 Report. In FY 2020, a total of 25 complaints were filed alleging discrimination. In FY 2020, contractors completed 11 EEO investigations. One investigation was completed in less than 180 days. Nine investigations were completed in 181-360 days (*3 were identified as timely, but reflect an average of 222.33 days, 6 were identified as untimely reflecting an average of 276.17 days) and 1 investigation was completed in 361 or more days. In 2020, the EEO office offered ADR to 37 counselees during the informal process, of whom 26 declined (70.27 percent). Eleven complaints were accepted into the ADR program (29.73 percent), of which there were no attempts to conduct ADR in six cases. Four mediations were conducted, which resulted in 3 ADR settlements. A total of 10 single complaints covering multiple statutes were closed during the reporting period, of which there were 10 final agency decisions (9 dismissals and 1 finding of no discrimination); and 1 final Agency merit decision. At the end of the fiscal year, there were 30 complaints pending. There were 2 Complaints pending written notification (Acknowledgement Letter), 6 complaints pending a decision to accept or dismiss, 11 complaints pending investigation, 9 complaints awaiting a hearing, and 2 complaints pending a final agency decision.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Objective(s) and Dates for EEO Plan Date Modified Date Objective Target Date Initiated (mm/dd/yyyy) Date Completed (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy)
In accordance with 29 CFR § 1614.108 and Ongoing Report EEOC Management Directive (MD) 715, its annually via 10/01/20 mandated that Federal agencies must have in 09/30/21 MD-715 place an effective EEO complaint processing Report measure to issue investigations within 180 days.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Director, Office of Small Business and Civil Rights Vonna Ordaz Yes (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Civil Rights Program Stephen Smith Yes Planned Activities Toward Completion of Objective Sufficient Completion Target Date Planned Activities Funding & Modified Date Date (mm/dd/yyyy) Staffing? (mm/dd/yyyy)
(mm/dd/yyyy)
(Yes or No)
Hire additional staff to manage and oversee the Yes 1/31/21 12/1/19 EEO complaint processing activities.
Continue to assess and implement process Yes Report improvement measures to increase program annually via 10/1/20 Ongoing efficiency and effectiveness. MD-715 Report Continue to optimize the use of Yes Report the iComplaints Case Management System to annually via 10/1/20 monitor the complaint activity to ensure that all Ongoing MD-715 required timelines are being met (i.e., Report investigations).
Report of Accomplishments Fiscal Year Accomplishments A senior civil rights specialist was hired in June 2020 June 2020 Holds regularly scheduled team meetings and to discuss creative and innovated Ongoing ways to improve complaint processing activities by eliminating impediments
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Developed templates for standardizing all correspondence supporting the EEO October 2020 complaint process CR has implemented new internal controls for complaint processing activities to October 2020 include a tracking spreadsheet which monitors a formal complaints life cycle Reestablished clear internal complaint processing procedures, on-going team trainings, revised processing timeframes for our contractors with established October 2020 penalties for untimely products, and certainly the hard work, passion, and commitment of the CR team A senior EEO specialist was hired in January 2021 January 2021 NRC issued its annual EEO Policy Statement reminder, which was distributed to all 2020 NRC employees through an agency Yellow Announcement.
In 2020, the EEO office, OCHCO, and OGC conducted four mandatory EEO and 2020 Diversity & Inclusion Training courses, which included a segment on EEO, legal updates, ADR, Harassment and a number of other topics.
Briefed the Commission biannually on the accomplishments and plans of the 2020 Agencys EEO affirmative employment and diversity management program at the Mid-Year Human Capital Briefing and end-of-the year EEO Briefing.
Timely submitted the No Fear Act Report to EEOC and posted information on 2020 NRCs public and internal Web sites.
NRC sent annual notification to all employees of their whistleblower protection rights, as required by the Office of Special Counsel, for Agency certification under 2020 5 U.S.C. Section 2302(c); In addition, NRC reviewed and updated its internal and external web pages to publicize these rights as well.
2020 See additional agencywide accomplishments captured in MD-715 Part E3, Workforce Analysis.
2020 See additional agency accomplishments captured in MD-715 Part E2, Executive Summary: Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency E.3.f. Does the agency annually evaluate the effectiveness of its ADR program?
MD-715 Part G, Agency [see MD-110, Ch.3(II)(D)]?
Assessment Low participation rate of employees in the ADR during the pre-complaint process.
Objective(s) and Dates for EEO Plan Target Modified Date Date Initiated Date Date Completed Objective (mm/dd/yyyy) (mm/dd/yy (mm/dd/ (mm/dd/
yy) yyyy) yyyy)
To increase employee participation for ADR to reflect 50 percent or more of the 10/01/2020 09/30/2021 aggregate amount of pre-complaints being processed for completion.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Director, Office of Small Vonna Ordaz Business and Civil Rights Yes (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, SBCR Stephen Smith Yes Civil Rights Program ADR Manager/Program Rhonda Dorsey Yes Coordinator
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Planned Activities Toward Completion of Objective Sufficient Modified Completion Funding &
Target Date Date Date Planned Activities Staffing?
(mm/dd/yyyy) (mm/dd/ (mm/dd/
(Yes or yyyy) yyyy)
No)
Heavily promote and market 10/01/2020 ADR (i.e., brochures, desk aids, FAQs, etc.)
Continue to assess and implement ADR process 10/01/2020 improvement measures to increase program efficiency and effectiveness Continue to optimize the use of the iComplaints Case Management System to monitor the complaint 10/01/2020 events/activities to ensure that all events/activities are accurately reflected as required (i.e., ADR)
Produce an outreach video on the benefits of the ADR program and post it on the 10/01/2020 SBCRs webpage to meet the outreach and training objective for the ADR program.
Report of Accomplishments Fiscal Year Accomplishments The Agency issued the Alternative Dispute Resolution (ADR) Program Manual for the purpose of making all NRC employees and stakeholders aware of the Agencys ADR October 2019 program and procedural processes and to assist individuals in better understanding how to resolve EEO complaints fast, confidentially, and effectively.
On April 26, 2017, the EEOC conducted a teleconference with NRC to review the status of its compliance and noted through its feedback that the Agency identified a program deficiency that involves a low ADR participation rate in the pre-complaint stage of the EEO process. After reviewing the Agencys 462 Reports, it was determined that the participation rate in the ADR program during the pre-complaint stage decreased from 44 percent in FY 2014 to 17 percent in FY 2016, which was below EEOCs goal of 50 percent.
May 2020 Although it was noted that the Agency did not establish a plan to address this deficiency in Part H of its FY 2016 MD-715 Report, the Agency has since established a Part H plan to address this deficiency in its FY 2017 MD-715 Report and in satisfying this compliance indicator, closed-out this program deficiency in Part H of its FY 2019 MD-715 Report by exceeding the 50 percent participation goal of employees in the ADR program during pre-complaint processing.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Moreover, and for its FY 2020 MD-715 Report, the Agency determined that its ADR participation rate in the pre-complaint stage of the EEO process dropped slightly to 39 percent. After reviewing the Agencys 462 Report, it was reported that there were 39 pre-complaints initiated during this reporting period and 8 pre-complaints on hand at the beginning of the reporting period for a total of 41 pre-complaints. Of the 41 pre-complaints, all participants were offered ADR (100 percent) and 39 pre-complaints were completed (95 percent) during this reporting period. Of the 39 pre-complaints that were completed, 11 were withdrawn (28 percent) now resulting in a total of 28 pre-complaints. Of the 28 pre-complaints, 11 were counseled where the employee participated in ADR resulting in 39 percent.
Therefore, the Agency has decided to establish a Part H plan to address this triggered deficiency of its FY 2020 MD-715 Report on the low participation rate of employees in the ADR during the pre-complaint process.
First time ever, the Agency issued the Chairmans Alternative Dispute Resolution May 2020 Program for Equal Employment Opportunity Complaints and Related Issues (Policy Statement).
Holds regularly scheduled team meetings and to discuss creative and innovated ways Ongoing to improve ADR processing activities and eliminate any impediments.
Annually conducts four (4) mandatory EEO and Diversity & Inclusion trainings for managers/supervisors which includes modules on EEO, legal case law updates, September 2020 ADR, harassment, reasonable accommodation, and a number of other topics. These training sessions were attended by 108 mid and senior level managers and supervisors.
CR has implemented a virtual platform to coordinate and administer the ADR process October 2020 supporting the pre-complaint and formal complaint process CR has implemented new internal controls for complaint processing activities to October 2020 include a tracking spreadsheet which monitors a complaints life cycle.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT 7MD-715 - Part H Agency EEO Plan to Attain the Essential Elements of a Model EEO Program Please describe the status of each plan that the agency has implemented to correct deficiencies in the EEO program.
If the agency did not address any deficiencies during the reporting period, please check the box.
Statement of Model Program Essential Element Deficiency Type of Program Brief Description of Program Deficiency Deficiency The overriding objective of MD-715 is to ensure that all employees and applicants MD-715 Model Agency for employment enjoy equality of opportunity in the Federal workplace regardless Title VII and of race/ethnicity, sex, disability, other protected groups, or reprisal for engaging in Rehabilitation Act prior protected activity. Federal agencies must position themselves to attract, Programs develop and retain a top-quality workforce that can deliver results and ensure our nation's continued growth and prosperity.
FY 2020 FINDINGS In 2020, the EEO office determined that there was some increase noted in representation of women, minorities and individuals with disabilities. However, this determination is not conclusive due to the limited information, data, and number of positions provided for review and analysis. The EEO office determined continued underrepresentation of women, minorities, and individuals with disabilities, based on a review of the workforce tables related to NRCs total workforce composition, permanent workforce complement, temporary workforce complement, executive and senior level grades, and participation rates of NRC mission critical and standard occupations. This determination is made based on review and analysis of the following information and data:
Total Workforce Composition - Workforce Tables a.1, a.2, b.1-1, b.1-2; Permanent Workforce Complement - Workforce Tables a.1, a.2, b.2; Temporary Workforce Complement - Workforce Tables a.1, b.1-1, b.1-2; Executives, Managers, Supervisors, SES, AD13/14, GG-15, and GG Workforce Tables a.3, a.4p, a.6 a.7, a.8, b.3 b.4 b.6, b.7, b.8 and other information contained in MD-715 Part E.3 Workforce Analysis.
FY 2019 PRIOR YEAR FINDINGS The NRCs policy is to have a workforce that reflects diversity in gender, ethnicity, education, occupation, age, and thought related to the working environment and safety culture. However, NRCs employment representation for women, minorities, and individuals with disabilities is below the civilian labor force (CLF) percentages and governmentwide statistics.
Based on a comparative review of NRCs demographic data and the FEORP published by OPM in October 2019 Federal Workforce and Civilian Labor Force (CLF) tables, the EEO office determined that triggers exist with regard to the representation of minority males (Hispanic, Black, Native Hawaiian or Pacific Islander; and individuals two or more races) and females (White, Hispanic, Native Hawaiian or Pacific Islander; American Indian or Alaska Native; and individuals two or more races) in NRCs permanent workforce. [see MD-715, Part E3, Workforce Analysis].
Based on a comparative review of the demographic data and the CLF, the EEO office determined that triggers exist with regard to the current representation of females, minorities, and PWD and PWTD in the following classifications: Senior Level Services (SLS) classification; mid-level officials and managers; team leaders; and Tech Managers and Supervisors. The EEO office was unable to make assessments at this time for GG-04 through GG-15, due to unavailability of workforce tables.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Based on a comparative review of NRCs demographic data and the Federal government statistics published by OPM in October 2019, the EEO office determined that triggers continue to exist with regard to the current representation of Senior Executive Services (SES) females (White; Black or African American; Hispanic or Latino; Asian; Native Hawaiian or Pacific Islander; and individuals two or more races) and minority (Hispanic; American Indian or Alaska Native; and individuals two or more races) at the NRC.
Objective(s) and Dates for EEO Plan Date Target Modified Date Initiated Objective Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy) (mm/dd/yyyy) 10/01/17 Increase representation of women, minorities, and Ongoing 09/30/21 This is an individuals with disabilities and targeted disabilities ongoing effort working at NRC in the above classifications. that will be reported annually via the MD-715 Report.
Responsible Official(s)
Performance Title Name Standards Address the Plan?
(Yes or No)
Deputy Chief Human Capital Officer, Office of Mary Lamary Yes the Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Officer, Ashley Roberts Yes OCHCO Associate Director for HR Operations and Susan Salter Yes Policy Yes Branch Chief, Workforce Management and Tamla Ransford Benefits Branch Special Placement Program Coordinator Kimberly English Yes (Individuals with Disabilities), OCHCO Reasonable Accommodation Specialist, Anne Silk N/A OCHCO
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Title Name Standards Address the Plan?
(Yes or No)
Director, Office of Small Business and Vonna Ordaz Yes Civil Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, SBCR Affirmative Tuwanda Smith Employment and Diversity Management Yes (AEDM) Program AEDM Specialist Stephanie Garland Yes SBCR-Special Emphasis Program Dorothea Washington Yes Managers and Supervisors All Yes Hiring & Selecting Officials All Yes Planned Activities Toward Completion of Objective Sufficient Modified Completion Target Date Planned Activities Funding &
Date Date (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No) 08/01/19 The EEO office and OCHCO will coordinate Yes 09/30/21 This is an efforts, and meet regularly to address concerns, ongoing effort review processes and procedures, hiring that will be selections, incorporated awareness training as reported part of the EEO and Diversity Management annually via training for managers and supervisors, and the MD-715 monitor progress. The EEO office will continue to Report.
coordinate efforts with OCHCO to target Minority Serving Institution grant recipients for entry level hiring.
This is an 10/01/17 Identify current and future employment gaps, Yes 09/30/21 ongoing effort establish strategic plans to fill those gaps, and offer that will be opportunities to attract diverse skilled individuals reported from all segments of society.
annually via the MD-715 Report.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT This is an 10/01/17 Increase participation of women and minorities in Yes 09/30/21 ongoing effort SES CDPs.
that will be reported annually via the MD-715 Report.
This is an 10/01/17 Continue to provide outreach and recruitment Yes 09/30/21 ongoing effort efforts that include all segments of the population.
that will be reported annually via the MD-715 Report.
Report of Accomplishments Fiscal Year Accomplishments See recruitment efforts and agencywide performance results captured in MD-715 2020 Report, Part E3, Workforce Analysis.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table The EEO office submitted to the EEOC a schedule of meetings with OCHCO to discuss EEO and HR related topics. Actions need to be in place to ensure measurable performance results and compliance with the following provisions:
B.3.a: Do EEO program officials participate in agency meetings regarding workforce changes that might impact EEO issues, including strategic planning, recruitment strategies, vacancy projections, succession planning, and selections for training/career development opportunities?
[see MD-715, II(B)].
C.4.a. Do the HR Director and the EEO Director meet regularly to assess whether personnel programs, policies, and procedures conform to EEOC laws, instructions, and management directives? [see 29 CFR§1614.102(a)(2).
C.4.b. Has the agency established timetables/schedules to review at regular intervals its merit promotion program, employee recognition award program, employee development/training programs, and management/personnel policies, procedures, and practices for systemic barriers that may be impeding full participation in the program by all EEO groups? [see MD-715 Instructions, Sec. I].
EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
MD-715 Part G - Self-Assessment Yes Regulatory Requirements
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice Although the timetable was established and approved by EEOC in accordance with C.4.b. provisions, performance factors have not been accomplished. This is also true of B.3.a and C.4.a provisions.
Objective(s) and Dates for EEO Plan Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
The EEO office and OCHCO Yes Report Directors meet regularly outcomes regarding to assess whether annually via personnel programs, policies, and 01/30/2018 09/30/2021 Ongoing EEOC MD-procedures conform to EEOC laws, 715 Report instructions, and management directives The EEO office/AEDM Program Yes Report Manager jointly brief the EEO and outcomes OCHCO Directors on policies, annually via practices, and procedures that 09/30/21 Ongoing EEOC MD-adversely impact women, 715 Report minorities, and individuals with disabilities The EEO office/AEDM Program Yes Report Manager receives outcomes information/document to support annually via corrective strategies for moving 10/1/2019 Ongoing Ongoing EEOC MD-forward and to track progress, and 715 Report report outcomes internally and externally (e.g., EEOC).
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Director, Office of Small Business and Civil Yes Vonna Ordaz Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Standards Title Name Address the Plan?
(Yes or No)
Program Manager, Affirmative Employment Yes and Diversity Management (AEDM) Tuwanda M. Smith Program, SBCR Program Manager, Special Emphasis Yes Dorothea Washington Programs, SBCR AEDM Specialist, SBCR Stephanie Garland Yes Chief Human Capital Officer, Office of the Yes Mary Lamary Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Officer Yes Ashley Roberts (Acting), OCHCO Associate Director for HR Operations and Yes Susan Salter Policy Planned Activities Toward Completion of Objective Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Drafted 2018.
Agreed to by EEO Draft time-tables/schedules for conducting reviews of the office/OCHCO Merit Promotion Program, Employee Recognition 1/20/2020.
Awards Program, Employee 06/12/2018 Ongoing Development/Training Program; and EEOC approval management/personnel policies, procedures, and 2020.
practices.
Report annually via MD-715 report.
Implement timetable/schedule and track reviews Report annually 10/01/2018 conducted, findings, actions, and outcomes over the Ongoing via MD-715 fiscal year. report.
Report of Accomplishments Fiscal Year Accomplishments NRC issued a separate Diversity and Inclusion Policy (on 5/18), which was 2020 distributed to all NRC employees through an agency yellow announcement.
Continued to elicit support and promote the NRCs Inclusive Diversity Strategic Plan 2020 (IDSP), and Comprehensive Diversity Management Plan Reports.
Implemented an Initiative on Civility, Awareness, Respect and Engagement known 2020 as iCARE to assist with Agency efforts in facilitating deeper understandings and appreciation of cultural and diversity and inclusion related issues amongst
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT employees and promote individual personal and professional growth and effectiveness through the processes of listening, introspection, and building acceptance for differing perspectives.
Continued implementation of DIALOGUEDiversity Inclusion Awareness Leading Organizational Growth, Understanding, and Engagementin which small groups of 2020 managers and employees participate in facilitated forums to discuss diversity topics in an open environment.
Continued to facilitate the Speed of Trust initiative, consisting of workshops to 2020 provide opportunities for strengthening mutual trust among Agency leaders, supervisors, and employees.
See additional agencywide accomplishments captured in MD-715 Part E3, 2020 Workforce Analysis.
See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table The EEO office has been requesting required data from OCHCO as part of EEOCs MD-715 Reporting. In the MD-715, Part G Agency Self-Assessment, the EEO office has responded to the compliance indicator related to OCHCO providing timely accurate data by checking yes with comments referencing challenges/improvements. Additionally, OCHCO has indicated in the agencys annual FEORP Report submitted to OPM that the agency tracks career development demographics and MD-715 Part H and I are being put in place to help track, make available and produce the required affirmative employment information/data.
The data being requested should comply with the regulatory requirements set forth in the MD-715 Part G - Agency Self-Assessment, which are described in the following paragraphs:
D.1.b - Does the agency regularly use the following sources of information for trigger identification: workforce data; complaint/grievance data; exit surveys; employee climate surveys; focus groups; affinity groups; union; program evaluations; special emphasis programs; reasonable accommodation program; anti-harassment program; and/or external special interest groups? [see MD-715 Instructions, Sec. I]
B.4.a.7 - to maintain accurate data collection and tracking systems for the following types of data: complaint tracking, workforce demographics, and applicant flow data? [see MD-715, II(E)]. If not, please identify the systems with insufficient funding in the comments section.
C.4.c - Does the EEO office have timely access to accurate and complete data (e.g., demographic data for workforce, applicants, training programs, etc.)
required to prepare the MD-715 workforce data tables? [see 29 CFR
§1614.601(a)]
E.4.a - Does the agency have systems in place to accurately collect, monitor, and analyze the following data:
E.4.a2 - The race, national origin, sex, and disability status of agency employees? [see 29 CFR §1614.601(a)]
E.4.a.3 - Recruitment activities? [see MD-715, II(E)]
E.4.a.4 - External and internal applicant flow data concerning the applicants race, national origin, sex, and disability status? [see MD-715, II(E)]
C.4.c - Does the EEO office have timely access to accurate and complete data (e.g., demographic data for workforce, applicants, training programs, etc.)
required to prepare the MD-715 workforce data tables? [see 29 CFR
§1614.601(a)]
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Data required to be made available in accordance with Regulations and Workforce Yes regulatory requirements has not been provided timely Tables and/or the information is inaccurate.
Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
We cant make assessments of information with regard to Yes representation or compliance with EEO policies and practices.
Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice D.1.b, B.4.a.7, C.4.c, E.4.a, E.4.a2, E.4.a.3, E.4.a.4, C.4.c Objective(s) and Dates for EEO Plan Sufficient Date Date Target Modified Funding & Complete Objective Initiated Date Date (mm/dd/yyyy (mm/dd/yyyy Staffing? d (Yes or No) (mm/dd/yyyy) (mm/dd/yyyy
) )
)
To generate the information/data Yes needed to prepare the annual MD-04/01/2021 09/30/2021 Ongoing 715 report and monitor EEO activities throughout the year.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Chief Human Capital Officer, Office of the Yes Mary Lamary Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Yes Ashley Roberts Officer (Acting), OCHCO
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Standards Title Name Address the Plan?
(Yes or No)
Chief, Human Capital Analysis Branch Terry Mintz Yes Human Capital Analysis Branch Brendan Cain Yes Director, Office of Small Business and Yes Vonna Ordaz Civil Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Affirmative Yes Employment and Diversity Management Tuwanda M. Smith (AEDM) Program, SBCR Program Manager, Special Emphasis Yes Dorothea Washington Programs, SBCR AEDM Specialist, SBCR Stephanie Garland Yes Planned Activities Toward Completion of Objective Modified Completion Target Date Planned Activities Date Date (mm/dd/yyyy)
(mm/dd/yyyy) (mm/dd/yyyy)
Continue to generate the information/data needed to prepare the annual MD-715 report 09/30/21 and monitor EEO activities throughout the Ongoing Ongoing year.
Report of Accomplishments Fiscal Year Accomplishments 2020 See recruitment efforts and agencywide performance results captured in MD-715 Report, Part E3, Workforce Analysis.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table In FY 2018, the EEO office determined, based on a review of NRC 2017-2018 Exit Interview Survey responses, that some separating employees provided reasons for leaving the agency which gave rise to triggers. The EEO offices review the NRCs 2019 and 2020 Exit Interview Survey responses also contain reasons that raise concerns, which are being addressed. Accordingly, the EEO office has initiated MD-715 Part H and Part I plans to take a closer look at issues such as underlying reasons for voluntary employee separations from NRC employment, as well as implementing the necessary corrective measures, where warranted. See MD-715 Part E.3 Workforce Analysis - Separations.
D.1.b - Does the agency regularly use the following sources of information for trigger identification: workforce data: complain/grievance data; exit surveys; employee climate surveys; focus groups; affinity groups; union; program evaluations; special emphasis programs; and/or external special interest groups?
[see MD-715]?
EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Workforce Data Tables A.1, B.1-1, B.1-2 Collected informational reasons for employee separations.
See the following provision: D.1.b - Does the agency regularly use the following sources of information for trigger MD-715 Part G-Agency Self- identification: workforce data: complain/grievance data; exit Assessment surveys; employee climate surveys; focus groups; affinity groups; union; program evaluations; special emphasis programs; and/or external special interest groups? [see MD-715]?
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Collected information and data on different types of MD-715 Part E.3 Workforce Yes separations, separation actions, and reasons given for Analysis - Separations separations.
Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice Separating employees (including EEO groups) are providing negative comments that contributed to their reason for leaving.
Objective(s) and Dates for EEO Plan Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
The OCHCO provides quarterly exit Yes Report survey data to the EEO outcomes office/Affirmative Employment and annually via Diversity Management (AEDM) to EEOC MD-
- 1) conduct routine reviews and 715 Report assessments of Exit Survey data;
- 2) coordinate efforts with OCHCO 10/01/2017 09/30/2021 and other NRC offices around 04/06/2020 results; 3) improve, reduce, or 09/30/2019 Ongoing eliminate unwarranted employee separations 4) identify triggers and root causes of problems; and
- 5) implement plans to identify and eliminate any barriers to equality of opportunity for all NRC employees.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Chief Human Capital Officer, Office of the Yes Mary Lamary Chief Human Capital Officer (OCHCO)
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Standards Title Name Address the Plan?
(Yes or No)
Deputy Chief Human Capital Yes Ashley Roberts Officer (Acting), OCHCO Associate Director for HR Operations and Yes Susan Salter Policy Branch Chief, Workforce Management and Yes Tamla Ransford Benefits Branch Director, Office of Small Business and Civil Yes Vonna Ordaz Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Affirmative Employment Yes and Diversity Management (AEDM) Tuwanda M. Smith Program, SBCR Program Manager, Special Emphasis Yes Dorothea Washington Programs, SBCR AEDM Specialist, SBCR Stephanie Garland Yes Planned Activities Toward Completion of Objective Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
The AEDM Program Manager will meet with the EEO Report annually office and OCHCO Directors/Deputies to discuss via MD-715 AEDMs review and examination of Exit Survey results Report 09/30/18 03/30/21 for fiscal years 2018-2021. The EEO office and OCHCO will collaboratively devise a strategy plan for moving 04/20/20 Ongoing forward and working with NRC offices identified in the Exit Interview Survey as having unwarranted reasons for employee separations.
The AEDM will report suspected wrongdoing (e.g., Report annually incidences of abuse, misconduct, mismanagement of via MD-715 agency programs) cited by former and Report current NRC employees in Exit Surveys to the EEO Director, who is required to report these allegations in writing directly to the Office of the Inspector General 03/30/21 03/30/21 consistent with the provisions set-forth in 28 U.S.C. 535 and NRCs Management Directive (MD) 7.4 Reporting Suspected Wrongdoing and Processing OIG Referrals.
The Program Manager of AEDM also recognizes that MD 7.4 imposes a duty on NRC employees to report to the OIG suspect wrongdoing, as well.
The AEDM Program will coordinate efforts with the Meeting to be Initial Meeting 03/30/21 agencys Culture Improvement Initiative (CII) staff to held with CII by XX/XX/21.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy) include sharing exit survey results for the 2018-2021 04/15/21 Ongoing periods and determine how the two groups can partner Partnering and work collaboratively with affected NRC offices identified as having unwarranted reasons for employee separations.
The EEO office will elicit assistance from the DMIC to Report annually conduct a barrier analysis and focus groups to identify 04/20/20 via MD-715 issues/challenges confronting employees in the NRC Report 09/30/18 workforce; determine underlying problems and root 04/30/21 causes related to employment conditions and potential unwarranted employee separations; and present findings Ongoing and recommendations to the EEO office and OCHCO.
SBCR/AEDM will continue to coordinate efforts with Report Annually OCHCO and others to incorporate within the EEO and via EEOC MD-Diversity Management Training for managers and 715 Report supervisors, 5 CFR Part 412, Federal supervisors and managers required triennial refresher training on performance management; and emergent training.
09/30/18 Topics/focus include information on employee separations and causes, identifying and eliminating barriers, utilizing effective communication skills, recognizing and addressing bias, NRC culture and values, roles, responsibilities, and manager and supervisor accountability, drafting corrective action plans, etc.
The EEO office will elicit support from the EEO Advisory Report annually Committees to host lunch and learns, and other forums 04/20/20 via MD-715 for employees around usage of ADR to resolve Report 04/20/20 workplace disputes, the EEO complaints process, and 09/30/21 other methods of communication that allows employees to bring attention on workplace environments and Ongoing conditions.
The EEO Director/Deputy will continue to hold periodic Report annually meetings with NRC office Directors/Designees. via MD-715 The periodic meetings will continue to include Report individualized Assessments conducted by the EEO office Affirmative Employment and Diversity Management (AEDM) program and provide office specific information related to the following areas: Recruitment Outreach; 07/01/20 Ongoing Training/Development; Diversity and Inclusion (e.g.,
Employee Engagement Index, Employees Perception of diversity & inclusion specific to ranking for each office); and findings from Employee Exit Interviews (e.g., identify concerns raised regarding separations); and identifying supportive behaviors and recommendations.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
The AEDM staff work directly with affected NRC offices 04/20/20 Report annually to identify office level strategies, interventions, and via MD-715 09/30/18 remedies specific to each affected office. 09/30/21 Report Ongoing Report of Accomplishments Fiscal Year Accomplishments 2020 See MD -715, Part E3, Workforce Analysis.
2020 The EEO office Director/Deputy held individualized periodic briefing meetings with the following NRC offices (which included AEDM office specific Assessments related to affirmative employment and diversity management topics including employee separations and findings from Exit Interview Surveys): Office of Investigations and Region I (7/17); Office of Nuclear Material Safety and Safeguards, and Office of Nuclear Reactor Regulation (7/28); Office of the Chief Human Capital Officer, and Office of Enforcement (7/29); Office of the Chief Financial Officer (8/3); Office of Nuclear Security and Incident Response, and Office of Public Affairs (8/17); Office of International Programs (8/20); Office of Administration (8/24); Region II (8/31); Office of the Advisory Committee on Reactor Safeguards (9/2); Region IV (9/3); Office of the Inspector General (9/29); and Office of the Chief Information Officer (9/30).
2020 See additional agencywide accomplishments captured in MD-715 Part E3, Workforce Analysis.
2020 See additional agency accomplishments captured in MD-715 Part E2, Executive Summary: Essential Element A-F.
2020 See MD -715, Part E3, Workforce Analysis.
2020 See MD -715, Part E3, Workforce Analysis.
2020 The EEO office Director/Deputy held individualized periodic briefing meetings with the following NRC offices (which included AEDM office specific Assessments related to affirmative employment and diversity management topics including employee separations and findings from Exit Interview Surveys): Office of Investigations and Region I (7/17); Office of Nuclear Material Safety and Safeguards, and Office of Nuclear Reactor Regulation (7/28); Office of the Chief Human Capital Officer, and Office of Enforcement (7/29); Office of the Chief Financial Officer (8/3); Office of Nuclear Security and Incident Response, and Office of Public Affairs (8/17); Office of International Programs (8/20); Office of Administration (8/24); Region II (8/31); Office of the Advisory Committee on Reactor Safeguards (9/2); Region IV (9/3); Office of the Inspector General (9/29); and Office of the Chief Information Officer (9/30).
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table In 2020, the NRC workforce continued to be beneath the employment benchmark goals of 12 percent for PWD and 2 percent for PWTD. A review of the agencys 2020 workforce data and related information did not include Schedule A hires (or NRC equivalent authority hires), which might be attributed to inaccurate recordkeeping or reporting. Second, NRC hiring (selecting) officials did not hire qualified PWTD or PWD for new hires and internal competitive promotions. It was further revealed that PWD and PWTD had lower than expected participation rates even in instances were selections occurred.
The EEO office determined that triggers exist using the goal of 12 percent and 2 percent as the benchmarks involving PWD and PWTD in NRCs permanent workforce. Based on a review of demographic data, the NRC has not achieved the required Section 501 workforce goals of employing 12 percent PWD and 2 percent PWTD within the agencys permanent workforce. Although, there have been PWD staff decreases, NRC is making meaningful progress towards reaching the Section 501 goals. The EEO office determined that triggers exist using the goal of 12 percent and 2 percent as the benchmarks involving PWD and PWTD by grade level cluster in the permanent workforce. This determination is supported by the information uncovered and described in the following documents:
Workforce Data Table B4.num (AD Permanent), Workforce Table B6P: Mission-Critical Occupations, Workforce Data Table B7: Senior Grade Levels-Distribution by Disability (Participation Rate), Workforce Data Table B8:
Management Positions (Participation Rate), and MD-715 Part E3. Workforce Analysis, Section 1. Introduction, Subsection 1.4 Workforce Composition, Subsection 1.4.2 Permanent Workforce Complement, Pp. 14-16, and Subsection 1.4.4 Analysis of Participation Rates for Women and Minorities in NRC Mission-Critical Occupations, Pp 16-29; Section 2. Analysis of Participation Rates for Women, Minorities, and Individuals with Disabilities in NRC Standard Occupations, Pp. 29-33; and Section 3. Analysis of Participation Rates for Women and Minorities in AD 13-14 Positions, Pp 33.
For more details see MD-715 E3 Workforce Analysis and Part J. Also see Part H for other areas of focus under compliance metric D.4.d.
EEO Group(s) Affected by Trigger EEO Group All Groups
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
D.4.d - Has the agency taken specific steps that are reasonably designed to increase the number of persons with disabilities or targeted disabilities employed at the agency until it meets the goals? [see 29 CFR
§1614.203(d)(7)(ii)].
Exit Interview Data Workforce Tables B.1-1, B.1-2, B.2, B.3, B.4, B.5, B.6, B.7, B.8, B.9 See MD-715 Part E.3 Workforce Analysis Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice The agency remains below the section 501 benchmark goals for 12 percent employment of PWD and 2 percent employment of PWTD. In instances where there have been qualified PWD and PWTD individuals, we have not complied with the agencys Disability Affirmative Action Plan, and Disability Program Strategic Project Plan for FY 2019 - FY 2024.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Objective(s) and Dates for EEO Plan Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
The OCHCO will make Yes Report available to the EEO office/AEDM outcomes program quarterly statistical tables, annually via demographics, and applicant flow 12/31/2021 EEOC MD-10/1/2019 4/6/2020 data required to prepare the Ongoing 715 Report agencys annual MD-715 Report and needed to conduct periodic assessments during the fiscal year.
Increase the agencys use of hiring Yes Report authorities that take disability into outcomes account with respect to hiring; 10/1/2019 Ongoing Ongoing annually via promotion, and assignments to the EEOC MD-extent permitted by law. 715 Report Yes Report outcomes Increase representation of PWTD in 10/1/2019 Ongoing Ongoing annually via NRCs senior grade levels.
EEOC MD-715 Report Yes Report Achieve the 12 percent disability outcomes goals for persons with disabilities 10/1/2019 Ongoing Ongoing annually via (PWD). EEOC MD-715 Report Yes Report Achieve the 2 percent disability outcomes goals for persons with disabilities 10/1/2019 Ongoing Ongoing annually via (PWTD). EEOC MD-715 Report Create awareness, provide training, Yes Report and disseminate/post the agencys outcomes revised Reasonable Accommodatio 10/1/2019 Ongoing N/A annually via ns Procedures Plan (RAP), which EEOC MD-was approved by EEOC 09/27/19. 715 Report Provide (PAS) NRC has Yes Report determined that requests for outcomes Personal Assistance Services PAS annually via procured using an independent 10/1/2019 Ongoing N/A EEOC MD-PAS provider once needs are 715 Report identified, and not through a formal long-term contract agreement.
Yes Report Partner with organizations that outcomes specialize in the employment of 10/1/2018 Ongoing N/A annually via individuals with disabilities. EEOC MD-715 Report
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
Assurance that all hiring managers Yes Report and supervisors are aware of NRC outcomes hiring authority equivalent to 10/1/2018 Ongoing N/A annually via Schedule A and other disability EEOC MD-hiring authorities. 715 Report Remove barriers PWD and PWTD Yes Report may encounter in recruitment outcomes and/or selection processes related annually via to new hires, promotions, training 10/1/2018 Ongoing N/A EEOC MD-and career development, and 715 Report advancement; or distribution of awards.
Assurance that NRC policies, Yes Report procedures, or practices are not the outcomes reason why PWD and PWTD 10/1/2019 Ongoing N/A annually via terminate their employment with the EEOC MD-agency. 715 Report Assurance that the disability Yes Report program staff possess sufficient outcomes knowledge and skills to answer annually via program and disability related 10/1/2018 Ongoing N/A EEOC MD-questions; and provide employees 715 Report and job applicants with necessary reasonable accommodations.
Assurance that managers and Yes Report supervisors demonstrate their outcomes commitment to equal employment annually via opportunity and diversity EEOC MD-10/1/2018 Ongoing N/A management principles, which 715 Report includes among other things recruiting, retaining, and developing a diverse workforce.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Chief Human Capital Officer, Office of the Yes Mary Lamary Chief Human Capital Officer (OCHCO)
Deputy Chief Human Capital Yes Ashley Roberts Officer (Acting), OCHCO Associate Director for HR Operations and Yes Susan Salter Policy
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Performance Standards Title Name Address the Plan?
(Yes or No)
Chief, Workforce Management and Benefits Yes Tamla Ransford Branch Recruitment Program Manager, Special Yes Placement Program Coordinator Kimberly English (Individuals with Disabilities)
Reasonable Accommodations N/A Anne Silk Coordinator, Disability Program Manager Chief, Human Capital Analysis Branch Terry Mintz Yes Human Capital Analysis Branch Brendan Cain Yes Director, Office of Small Business and Civil Yes Vonna Ordaz Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Affirmative Employment Yes and Diversity Management (AEDM) Tuwanda M. Smith Program, SBCR Program Manager, Special Emphasis Yes Dorothea Washington Programs, SBCR AEDM Specialist, SBCR Stephanie Garland Yes Planned Activities Toward Completion of Objective Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Address inconsistences and provide MD-715 related 10/01/2018 workforce tables, demographics, and applicant flow Ongoing information/data.
Include a segment on disability hiring authorities in the annual mandatory EEO and Diversity & Inclusion Training for Supervisors and Managers; and encourage 10/01/2018 Ongoing and support fiscal year hiring efforts that take disability into account (i.e., new hires; promotions, solicitations of interest, rotations, and assignments).
Conduct outreach and recruitment efforts for PWTD in 09/30/2019 Ongoing the senior grade levels.
Increase the number of PWD hired, promoted, and 10/01/2018 Ongoing reassigned (i.e., rotations, details, reassignments).
Increase the number of PWTD hired, promoted, and 10/01/2018 Ongoing reassigned (i.e., rotations, details, reassignments).
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Published the Disability Program Strategic Project Plan 09/30/2019 for FY 2019 - FY 2024 and posted on the agencys Ongoing public Web site. Plan implementation ongoing.
Conduct a focus group in FY 2020, with NRC employees, to Identify challenges and barriers for people with disabilities when applying and interviewing for jobs 09/30/2020 09/30/2021 at the NRC, receiving training and developmental opportunities, and applying for and being selected for promotions/new opportunities.
09/30/2019 Post RAP on agencys public Web site. 10/01/2019 Provide RAP training to managers, supervisors, and 02/27/2018 Ongoing employees.
Use a service provider to administer PAS to disability 09/30/2019 Ongoing status applicants and employees.
Establish and maintain contacts with organizations that specialize in the employment of individuals with 09/30/2019 disabilities and use program resources that identify Ongoing applicants eligible to be appointed under NRC hiring authorities that take disabilities into account.
Conduct a barrier analysis to determine whether PWD and PWTD have barriers in the recruitment and/or 09/30/2019 selection processes for new hires, promotions, training 09/30/2021 and career development, advancement, distribution of awards and retention.
Conduct a barrier analysis to determine whether any 10/01/2018 policies, procedures, or practices are causing PWD and 09/30/2021 PWTD to leave the agency.
Conduct a focus group in FY 2020, with NRC employees, to Identify whether policies, procedures, or 10/01/2018 09/30/2021 practices for the reason PWD and PWTD terminate their employment with the agency.
Provide training to all hiring managers and supervisors on the use of NRC hiring authority equivalent to Schedule A and other disability hiring authorities. One 10/01/2018 Ongoing method will be to include a segment on disability hiring authorities in the annual mandatory EEO and Diversity &
Inclusion Training for Supervisors and Managers.
Provide training to the disability program staff sufficient to increase their knowledge and skills regarding disability hiring programs; answer disability related questions; 10/01/2018 provide job applicants with necessary reasonable Ongoing accommodations; accept, validate, and forward applications for appointment under hiring authorities that take disability into account to the relevant hiring official
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy) and; oversee any other disability related hiring program.
Evaluate hiring managers on their support of EEO and 10/01/2018 Diversity efforts including helping to meet disability goals Ongoing in their annual performance appraisal.
Report of Accomplishments Fiscal Year Accomplishments NRCs Disability Program Strategic Project Plan was published in FY 2020 and 2020 posted on NRCs internal and external Web sites on April 14, 2020. For more information click on Disability Program Strategic Project Plan 2019-2024.
NRCs OCHCO is continuing to work on developing a Career Development Tracking System. Efforts were initiated on January 23-28, 2020 to identify long-term requirements to track application and participation rates. OCHCO staff were able to generate an initial dataset of FY 2019 information and worked to produce summary reports. On January 31, 2020 staff started to get the training data connected with the PWD and PWTD data. On a high level, OCHCO begin exploring ways they could organize the data in TMS, connect to related HR data, and generate this type 2020 of reporting quicker in the future. To comply with MD-715 requirements that agencies track their career development opportunities to permit analyses of potential barriers to equality of opportunity for women, minorities, and individuals with disabilities, OCHCO created a Microsoft Excel spreadsheet of training for FY 2019 by Disability category. The spreadsheet tracks employees who applied for internal and external training and those selected (including PWD and PWTD), by numbers and percentages for the FY 2019 MD-715 Report. The same processes are being used to generate for FY 2020 information.
In 2020, the EEO office/ADEM, OCHCO, and OGC conducted four EEO and Diversity & Inclusion training courses for managers and supervisors, which covered 2020 disability regulations and requirements including the NRC procedures and processes, and manager/supervisor responsibilities related to reasonable accommodations.
NRC Disability program staff continued to implement the Disability Affirmative Action Plan. Promoted the use of our Schedule A equivalent hiring authority by 2020 providing training for supervisors on special hiring authorities and forwarding resumes of eligible applicants to hiring managers.
NRC hired 13 persons with disabilities, of which one person had a targeted 2020 disability, compared to eight hires and one hire with a targeted disability in FY 2019.
NRC staff referred 14 resumes from the WRP data base for consideration in the Temporary Summer Student Program and seven offers extended. Of the seven offers extended, four were accepted, two declined, and one withdrew from 2020 consideration. One student from the WRP accepted an offer to return for a second internship over winter break. Referred and subsequently hired a Wounded Warrior as an Intelligence Analyst.
All NRC vacancy announcements include information on how to request a reasonable accommodation when applying to a vacancy posting; however, there were no requests for reasonable accommodations from job applicants in 2020 FY 2020. There was one request for reasonable accommodations made during the new hire process for a deaf summer intern. There was also one request for reasonable accommodations during the promotional process for a GG-14 staffer who was promoted to a GG-15 Branch Chief position.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT NRC processed 115 requests for reasonable accommodations in FY20.
Approximately 68 of those requests were processed since mid-March 2020, when 2020 the agency began teleworking due to COVID-19. This is about a 17% increase in requests from the previous year.
To improve career advancement opportunities for PWD and PWTD, the NRC 2020 offered training, internship, and mentoring programs.
NRCs Advisory Committee for Employees with Disabilities (ACED) sponsored the 2020 Disability Employment Awareness Month Luncheon and a lunch and learn on Aphasia Awareness.
As of 09/30/20, the NRC had partnered with the Department of Defense Operation Warfighter (OWF) Program, which provides Federal internship opportunities in a supportive work setting to recovering service members. The NRC also partnered with the Department of Labors Workforce Recruitment Program (WRP) by accessing their resume database to search for candidates for Administrative Assistant, Information Technology, and Temporary Summer Student positions. The 2020 NRC strengthened its relationship with the Wounded Warrior Project (WWP), and in June 2020 NRC staff conducted an informational session with WWP constituents on special hiring authorities. And, NRC participated in recruiting events and/or posted job vacancies on job boards with Equal Opportunity Publications (EOP), Ability Corps/Ability Magazine, MD Workforce Exchange job board, MD DORS, and GettingHired.com.
In 2020, the OCHCO Disability program staff participated in training sessions such as: Building Understanding of Employment of People with Disabilities in Federal Agencies (FEED); Federal Equal Employment Opportunity Laws and the COVID-19 Pandemic (EEOC); Federal Agency Telework Considerations for Employees with 2020 Disabilities (FEED); 5 Tips for Disability Hiring(Disability Solutions); Connecting Agency Practices to Federal Disability Discrimination Complaints (FEED);
Resolving Complex Reasonable Accommodation Issues in the Federal Workplace (Federal Webinars-LRP Publications)
In 2020, NRC posted notices explaining employees and applicants rights under 2020 applicable regulations, including how to file a complaint.
See additional agencywide accomplishments captured in MD-715 Part E3, 2020 Workforce Analysis.
See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
See additional accomplishments captured in MD-715 Part J, Special Program Plan 2020 for the Recruitment, Hiring, Advancement, and Retention of Persons with Disabilities.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table In 2020, the answer was, no and a MD-715 Part H plan was put into place.
PRIOR YEAR FINDINGS In FY 2018, the answer was, no. In FY 2019, the answer was yes. Mitigating and corrective strategies were put in-place, which included more efficient utilization of the iComplaint tracking system; and establishing 60 days as a reasonable time metric for issuing acceptance letters and dismissal decisions consist with MD-110 provisions. In FY 2020, the answer is no. A review of the 462 Report for the reporting period (10/01/2019-09/30/2020) reflects there were six complaints pending decision to accept/dismiss. The Summary of Pending Complaints by Category reflect that the number of days these cases were in pending status was 1,015, with the average number of days identified as 169, and pending time for the oldest case was 552 days.
EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Determine whether the agency is in compliance with the following provision:
MD-715 Part G - Self- Does the agency issue acceptance letters/dismissal decisions Assessment E.1.d. with a reasonable time (e.g., 60 days) after receipt of the written EEO Counselor report, pursuant to MD-110, Ch. 5(I)?
If so, please provide the average processing time in the comments Review the 462 report to determine the date of issuance for 462 Report accept/dismissal letters.
MD-715 Part E.2 Executive Examination of complaint processing activity related to Summary - Essential Elements issuance of accept/dismissal letters.
A-F
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice Agency is not in compliance of 29 C.F.R. 1614 regulations.
Objective(s) and Dates for EEO Plan Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
In accordance with 29 CFR 1614 Yes Report and EEOC Management Directive outcomes (MD) 715, make a conscious effort annually via 10/01/20 9/30/21 to issue acceptance EEOC MD-letters/dismissal decisions within a 715 Report thirty (30) day timeframe.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
EEO and D&I in Director, Office of Small Business and Civil Vonna Ordaz Performance Elements &
Rights (SBCR)
Standards EEO and D&I in Deputy Director, SBCR Jeanne Dempsey Performance Elements &
Standards EEO and D&I in Program Manager, SBCR Stephen Smith Performance Elements &
Standards Planned Activities Toward Completion of Objective Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Hire additional staff to manage and oversee the EEO 12/01/19 01/31/2021 complaint processing activities
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Continue to assess and implement process improvement 10/01/20 measures to increase program efficiency and 09/30/2021 effectiveness Continue to optimize the use of the iComplaints Case Management System to monitor the complaint activity to 10/01/20 09/30/2021 ensure that all required timelines are being met (i.e.,
investigations)
Report of Accomplishments Fiscal Year Accomplishments June 2020 A senior civil rights specialist was hired in June 2020 Holds regularly scheduled team meetings and to discuss creative and innovated On-going ways to improve complaint processing activities by eliminating impediments CR has implemented new internal controls for complaint processing activities to October 2020 include a tracking spreadsheet which monitors a formal complaints life cycle Developed templates for standardizing all correspondence supporting the EEO October 2020 complaint process Reestablished clear internal complaint processing procedures by revising the acceptance/dismissal analysis stage to be completed within twenty (20) days December 2020 and provide legal sufficiency with the required ten (10) days for review and approval.
January 2021 A senior EEO specialist was hired in January 2021 See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table E.1.f. Does the agency timely complete investigations, pursuant to 29 CFR
§ 1614.108?
No. This determination was made based on a review of the agencys EEOC SF462 Report for 2020. Pursuant to 29 CFR § 1614.108 the agency is required to investigate a discrimination complaint in a timely manner. The investigation must be appropriate, impartial, and completed within 180 days of filing the complaint, or within the time period contained in an order from the Office of Federal Operations on an appeal from a dismissal pursuant to 29 CFR § 1614.107(a). The EEO Director or designee and the complainant may agree in writing, consistent with 29 CFR § 1614.108(e), to an extension of not more than ninety (90) days; or within the period of time set forth in 29 CFR §§ 1614.108(e) or 1614.606 if there are multiple complainants with similar allegations of discrimination or complainant has filed multiple complaints which the agency has consolidated. If the agency fails to complete the investigation EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Shows that the investigations conducted were outside of the 462 Report Yes regulatory timeframes for completion.
MD-715 Part E.2 Yes Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table E.1.f. Does the agency timely complete investigations, pursuant to 29 CFR
§ 1614.108?
No. This determination was made based on a review of the agencys EEOC SF462 Report for 2020. Pursuant to 29 CFR § 1614.108 the agency is required to investigate a discrimination complaint in a timely manner. The investigation must be appropriate, impartial, and completed within 180 days of filing the complaint, or within the time period contained in an order from the Office of Federal Operations on an appeal from a dismissal pursuant to 29 CFR § 1614.107(a). The EEO Director or designee and the complainant may agree in writing, consistent with 29 CFR § 1614.108(e), to an extension of not more than ninety (90) days; or within the period of time set forth in 29 CFR §§ 1614.108(e) or 1614.606 if there are multiple complainants with similar allegations of discrimination or complainant has filed multiple complaints which the agency has consolidated. If the agency fails to complete the investigation EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Shows that the investigations conducted were outside of the 462 Report Yes regulatory timeframes for completion.
MD-715 Part E.2 Yes Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice See MD-715 E.2 Objective(s) and Dates for EEO Plan Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
In accordance with 29 CFR § Yes Report 1614.108 and EEOC Management outcomes Directive (MD) 715, its mandated annually via that Federal agencies must have in 10/01/2020 09/30/2021 Ongoing EEOC MD-place an effective EEO complaint 715 Report processing measure to issue investigations within 180 days.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Director, Office of Small Business and Civil Yes Vonna Ordaz Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Civil Rights Program Stephen Smith Yes Planned Activities Toward Completion of Objective Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Hire additional staff to manage and oversee the EEO 1/31/21 12/1/19 complaint processing activities.
Continue to assess and implement process improvement Report annually 10/1/20 measures to increase program efficiency and Ongoing via MD-715 effectiveness. Report Continue to optimize the use of the iComplaints Case Report annually Management System to monitor the complaint activity to via MD-715 10/1/20 Ongoing ensure that all required timelines are being met (i.e., Report investigations).
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Report of Accomplishments Fiscal Year Accomplishments June 2020 A senior civil rights specialist was hired in June 2020 Holds regularly scheduled team meetings and to discuss creative and innovated Ongoing ways to improve complaint processing activities by eliminating impediments Developed templates for standardizing all correspondence supporting the EEO October 2020 complaint process CR has implemented new internal controls for complaint processing activities to October 2020 include a tracking spreadsheet which monitors a formal complaints life cycle Reestablished clear internal complaint processing procedures, on-going team trainings, revised processing timeframes for our contractors with established October 2020 penalties for untimely products, and certainly the hard work, passion, and commitment of the CR team January 2021 A senior EEO specialist was hired in January 2021 NRC issued its annual EEO Policy Statement reminder, which was distributed to all 2020 NRC employees through an agency Yellow Announcement.
In 2020, the EEO office, OCHCO, and OGC conducted four mandatory EEO and 2020 Diversity & Inclusion Training courses, which included a segment on EEO, legal updates, ADR, Harassment and a number of other topics.
Briefed the Commission biannually on the accomplishments and plans of the 2020 Agencys EEO affirmative employment and diversity management program at the Mid-Year Human Capital Briefing and end-of-the year EEO Briefing.
Timely submitted the No Fear Act Report to EEOC and posted information on 2020 NRCs public and internal Web sites.
NRC sent annual notification to all employees of their whistleblower protection rights, as required by the Office of Special Counsel, for Agency certification under 5 2020 U.S.C. Section 2302(c); In addition, NRC reviewed and updated its internal and external web pages to publicize these rights as well.
See additional agencywide accomplishments captured in MD-715 Part E3, 2020 Workforce Analysis.
See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
See additional agency accomplishments captured in MD-715 Part E2, Executive 2020 Summary: Essential Element A-F.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table E.3.f. Does the agency annually evaluate the effectiveness of its ADR program?
[see MD-110, Ch.3(II)(D)]?
Low participation rate of employees in the ADR during the pre-complaint process EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No) 462 Report Y Mediations were below EEOCs ADR goal of 50 percent.
Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice EEOC identified low participation as a deficiency and the agencies are required to meet EEOCs ADR goal of 50 percent.
Objective(s) and Dates for EEO Plan
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Sufficient Date Target Modified Date Objective Funding &
Initiated Date Date Completed (mm/dd/yyyy) (mm/dd/yyyy) Staffing? (mm/dd/yyyy) (mm/dd/yyyy)
(Yes or No)
To increase employee participation Yes Report for ADR to reflect 50 percent or outcomes more of the aggregate amount of 10/01/2020 09/30/2021 annually via pre-complaints being processed for EEOC MD-completion 715 Report Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Director, Office of Small Business and Civil Yes Vonna Ordaz Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, SBCR Stephen Smith Yes ADR Manager/Program Coordinator Rhonda Dorsey Yes Planned Activities Toward Completion of Objective Completion Target Date Modified Date Planned Activities Date (mm/dd/yyyy) (mm/dd/yyyy)
(mm/dd/yyyy)
Heavily promote and market ADR (i.e., brochures, desk 10/01/2020 aids, FAQs, etc.)
Continue to assess and implement ADR process 10/01/2020 improvement measures to increase program efficiency and effectiveness.
Continue to optimize the use of the iComplaints Case Management System to monitor the complaint 10/01/2020 events/activities to ensure that all events/activities are accurately reflected as required (i.e., ADR)
Produce an outreach video on the benefits of the ADR 10/01/2020 program and post it on the SBCRs webpage to meet the outreach and training objective for the ADR program.
Report of Accomplishments Fiscal Year Accomplishments The Agency issued the Alternative Dispute Resolution (ADR) Program Manual for the purpose of making all NRC employees and stakeholders aware of the Agencys October 2019 ADR program and procedural processes and to assist individuals in better understanding how to resolve EEO complaints fast, confidentially, and effectively.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT On April 26, 2017, the EEOC conducted a teleconference with NRC to review the status of its compliance and noted through its feedback that the Agency identified a program deficiency that involves a low ADR participation rate in the pre-complaint stage of the EEO process. After reviewing the Agencys 462 Reports, it was determined that the participation rate in the ADR program during the pre-complaint stage decreased from 44 percent in FY 2014 to 17 percent in FY 2016, which was below EEOCs goal of 50 percent.
Although it was noted that the Agency did not establish a plan to address this deficiency in Part H of its FY 2016 MD-715 Report, the Agency has since established a Part H plan to address this deficiency in its FY 2017 MD-715 Report and in satisfying this compliance indicator, closed-out this program deficiency in Part H of its FY 2019 MD-715 Report by exceeding the 50 percent participation goal of employees in the ADR program during pre-complaint processing.
May 2020 Moreover, and for its FY 2020 MD-715 Report, the Agency determined that its ADR participation rate in the pre-complaint stage of the EEO process dropped slightly to 39 percent. After reviewing the Agencys 462 Report, it was reported that there were 39 pre-complaints initiated during this reporting period and 8 pre-complaints on hand at the beginning of the reporting period for a total of 41 pre-complaints. Of the 41 pre-complaints, all participants were offered ADR (100 percent) and 39 pre-complaints were completed (95 percent) during this reporting period. Of the 39 pre-complaints that were completed, 11 were withdrawn (28 percent) now resulting in a total of 28 pre-complaints. Of the 28 pre-complaints, 11 were counseled where the employee participated in ADR resulting in 39 percent.
Therefore, the Agency has decided to establish a Part H plan to address this triggered deficiency of its FY 2020 MD-715 Report on the low participation rate of employees in the ADR during the pre-complaint process.
First time ever, the Agency issued the Chairmans Alternative Dispute Resolution May 2020 Program for Equal Employment Opportunity Complaints and Related Issues (Policy Statement).
Holds regularly scheduled team meetings and to discuss creative and innovated Ongoing ways to improve ADR processing activities and eliminate any impediments Annually conducts four (4) mandatory EEO and Diversity & Inclusion trainings for managers/supervisors which includes modules on EEO, legal case law updates, September 2020 ADR, harassment, reasonable accommodation, and a number of other topics.
These training sessions were attended by 108 mid and senior level managers and supervisors.
CR has implemented a virtual platform to coordinate and administer the ADR October 2020 process supporting the pre-complaint and formal complaint process CR has implemented new internal controls for complaint processing activities to October 2020 include a tracking spreadsheet which monitors a complaints life cycle.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT MD-715 - Part I Agency EEO Plan to Eliminate Identified Barrier Please describe the status of each plan that the agency implemented to identify possible barriers in policies, procedures, or practices for employees and applicants by race, ethnicity, and gender.
If the agency did not conduct barrier analysis during the reporting period, please check the box.
Statement of Condition That Was a Trigger for a Potential Barrier:
Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table The overriding objective of MD-715 is to ensure that all employees and applicants for employment enjoy equality of opportunity in the Federal workplace regardless of race/ethnicity, sex, disability, other protected groups, or reprisal for engaging in prior protected activity. Federal agencies must position themselves to attract, develop and retain a top-quality workforce that can deliver results and ensure our nation's continued growth and prosperity.
FY 2020 FINDINGS In 2020, the EEO office determined that there was some increase noted in representation of women, minorities and individuals with disabilities.
However, this determination is not conclusive due to the limited information, data, and number of positions provided for review and analysis. The EEO office determined continued underrepresentation of women, minorities, and individuals with disabilities, based on a review of the workforce tables related to NRCs total workforce composition, permanent workforce complement, temporary workforce complement, executive and senior level grades, and participation rates of NRC mission critical and standard occupations. This determination is made based on review and analysis of the following information and data:
Total Workforce Composition - Workforce Tables a.1, a.2, b.1-1, b.1-2; Permanent Workforce Complement - Workforce Tables a.1, a.2, b.2; Temporary Workforce Complement - Workforce Tables a.1, b.1-1, b.1-2; Executives, Managers, Supervisors, SES, AD13/14, GG-15, and GG Workforce Tables a.3, a.4p, a.6 a.7, a.8, b.3 b.4 b.6, b.7, b.8 and other information contained in MD-715 Part E.3 Workforce Analysis.
FY 2019 PRIOR YEAR FINDINGS The NRCs policy is to have a workforce that reflects diversity in gender, ethnicity, education, occupation, age, and thought related to the working environment and safety culture. However, NRCs employment representation for women, minorities, and individuals with disabilities is below the civilian labor force (CLF) percentages and governmentwide statistics.
Based on a comparative review of NRCs demographic data and the FEORP published by OPM in October 2019 Federal Workforce and Civilian Labor Force (CLF) tables, the EEO office determined that triggers exist with regard to the representation of minority males (Hispanic, Black, Native Hawaiian or Pacific Islander; and individuals two or more races) and females (White, Hispanic, Native Hawaiian or Pacific Islander; American Indian or Alaska Native; and individuals two or more races) in NRCs permanent workforce. [see MD-715, Part E3, Workforce Analysis].
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Specific Source of Workforce Narrative Description of Trigger the Trigger Data Table Based on a comparative review of the demographic data and the CLF, the EEO office determined that triggers exist with regard to the current representation of females, minorities, and PWD and PWTD in the following classifications: Senior Level Services (SLS) classification; mid-level officials and managers; team leaders; and Tech Managers and Supervisors. The EEO office was unable to make assessments at this time for GG-04 through GG-15, due to unavailability of workforce tables.
Based on a comparative review of NRCs demographic data and the Federal government statistics published by OPM in October 2019, the EEO office determined that triggers continue to exist with regard to the current representation of Senior Executive Services (SES) females (White; Black or African American; Hispanic or Latino; Asian; Native Hawaiian or Pacific Islander; and individuals two or more races) and minority (Hispanic; American Indian or Alaska Native; and individuals two or more races) at the NRC.
EEO Group(s) Affected by Trigger EEO Group All Groups Barrier Analysis Process Source Sources of Data Reviewed? Identify Information Collected (Yes or No)
Representation of females, minorities, and persons with Workforce Data Tables Yes disabilities within the NRC workforce.
Status of Barrier Analysis Process Barrier Analysis Process Completed? Barrier(s) Identified?
(Yes or No) (Yes or No)
Yes Yes Statement of Identified Barrier(s)
Description of Policy, Procedure, or Practice Inconsistency and failure to follow HR hiring and promotional policies and practices.
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Objective(s) and Dates for EEO Plan Sufficient Date Date Target Modified Funding & Complete Objective Initiated Date Date (mm/dd/yyyy (mm/dd/yyyy Staffing? d (Yes or No) (mm/dd/yyyy) (mm/dd/yyyy
) )
)
Yes This is an ongoing Increase representation of women, effort that minorities, and individuals with will be disabilities and targeted disabilities 10/01/17 Ongoing 09/30/2021 reported working at NRC in the above annually via classifications.
the MD-715 Report.
Responsible Official(s)
Performance Standards Title Name Address the Plan?
(Yes or No)
Deputy Chief Human Capital Officer, Yes Office of the Chief Human Capital Officer Mary Lamary (OCHCO)
Deputy Chief Human Capital Officer, Yes Ashley Roberts OCHCO Associate Director for HR Operations and Yes Susan Salter Policy Branch Chief, Workforce Management and Yes Tamla Ransford Benefits Branch Special Placement Program Coordinator Yes Kimberly English (Individuals with Disabilities), OCHCO Reasonable Accommodation Specialist, N/A Anne Silk OCHCO Director, Office of Small Business and Yes Vonna Ordaz Civil Rights (SBCR)
Deputy Director, SBCR Jeanne Dempsey Yes Program Manager, Affirmative Yes Employment and Diversity Management Tuwanda M. Smith (AEDM) Program, SBCR Program Manager, Special Emphasis Yes Dorothea Washington Programs, SBCR AEDM Specialist, SBCR Stephanie Garland Yes
EEOC FORM U.S. Equal Employment Opportunity Commission FEDERAL AGENCY ANNUAL EEO PROGRAM STATUS REPORT Planned Activities Toward Completion of Objective Modified Completion Target Date Planned Activities Date Date (mm/dd/yyyy)
(mm/dd/yyyy) (mm/dd/yyyy)
The EEO office and OCHCO will coordinate efforts, This is an and meet regularly to address concerns, review ongoing effort processes and procedures, hiring selections, that will be incorporated awareness training as part of the EEO reported 08/01/19 and Diversity Management training for managers and 03/30/21 annually via the supervisors, and monitor progress. The EEO office will MD-715 continue to coordinate efforts with OCHCO to target Report.
Minority Serving Institution grant recipients for entry level hiring.
Identify current and future employment gaps, establish This is an strategic plans to fill those gaps, and offer opportunities ongoing effort to attract diverse skilled individuals from all segments that will be 10/01/17 of society. 09/30/21 reported annually via the MD-715 Report.
Increase participation of women and minorities in SES This is an CDPs. ongoing effort that will be 10/01/17 09/30/21 reported annually via the MD-715 Report Continue to provide outreach and recruitment efforts This is an that include all segments of the population. ongoing effort that will be 10/01/17 09/30/21 reported annually via the MD-715 Report.
Report of Accomplishments Fiscal Year Accomplishments 2020 See recruitment efforts and agencywide performance results captured in MD-715 Report, Part E3, Workforce Analysis.