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Barrier Analysis From the Ground Up Barrier Identification and Elimination Under Management Directive 715 Department of Veterans Affairs Office of Diversity.

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Presentation on theme: "Barrier Analysis From the Ground Up Barrier Identification and Elimination Under Management Directive 715 Department of Veterans Affairs Office of Diversity."— Presentation transcript:

1 Barrier Analysis From the Ground Up Barrier Identification and Elimination Under Management Directive 715 Department of Veterans Affairs Office of Diversity and Inclusion

2 Barrier Analysis - Element 4 of the Model EEO Program: Proactive Prevention Agencies have an ongoing obligation to prevent discrimination on the basis of race, color, national origin, religion, sex, age, reprisal and disability, and eliminate barriers that impede free and open competition in the workplace. As part of this obligation, agencies must conduct ongoing self- assessment to monitor progress, identify areas where barriers may exclude certain groups, and develop action plans to eliminate identified barriers. Agencies have an ongoing obligation to prevent discrimination on the basis of race, color, national origin, religion, sex, age, reprisal and disability, and eliminate barriers that impede free and open competition in the workplace. As part of this obligation, agencies must conduct ongoing self- assessment to monitor progress, identify areas where barriers may exclude certain groups, and develop action plans to eliminate identified barriers.

3 What is Barrier Analysis? An investigation of the any triggers indicating that workplace policies, procedures, or practices are having a negative impact on one or more protected EEO groups, with an eye toward identifying the root causes of those anomalies so that they can be addressed and eliminated, if possible. An investigation of the any triggers indicating that workplace policies, procedures, or practices are having a negative impact on one or more protected EEO groups, with an eye toward identifying the root causes of those anomalies so that they can be addressed and eliminated, if possible.

4 Terminology Current (MD-715) – Less than expected, Current (MD-715) – Less than expected, Low Participation Rates compared against benchmarks Outdated (MD-712, 713, 714) - Underrepresentation Outdated (MD-712, 713, 714) - Underrepresentation

5 Terminology Current (MD-715) – Specific EEO Groups: Current (MD-715) – Specific EEO Groups: Men, Women Men, Women Hispanic or Latino Men/Women Hispanic or Latino Men/Women White Men/Women White Men/Women Black Men/Women Black Men/Women Asian Men/Women Asian Men/Women Native Hawaiian & Other Pacific Islander (NHOPI) Men/Women Native Hawaiian & Other Pacific Islander (NHOPI) Men/Women American Indian or Alaska Native (AIAN) Men/Women American Indian or Alaska Native (AIAN) Men/Women Two or more races Men/Women Two or more races Men/Women Outdated (MD-714) – Women and Minorities Outdated (MD-714) – Women and Minorities

6 Crucial Distinctions Triggers Triggers Barriers Barriers EEO Program Deficiencies (Part G) EEO Program Deficiencies (Part G)

7 “EEO Program Deficiencies” A problem that inhibits an agency's efforts to develop a model EEO program. Agencies should use the Self- Assessment Checklist, (MD , Part G (123 measures)) to identify strengths and weaknesses in their EEO program. A problem that inhibits an agency's efforts to develop a model EEO program. Agencies should use the Self- Assessment Checklist, (MD , Part G (123 measures)) to identify strengths and weaknesses in their EEO program. “EEO Program Deficiencies” in Part G which the Agency answers “No” are to be identified as opportunities to bring the Program into compliance with the model. “EEO Program Deficiencies” in Part G which the Agency answers “No” are to be identified as opportunities to bring the Program into compliance with the model. Remember, “EEO Program Deficiencies” can lead to triggers and/or barriers, but not necessarily. Remember, “EEO Program Deficiencies” can lead to triggers and/or barriers, but not necessarily.

8 Examples of EEO Program Deficiencies All new supervisors are not provided a copy of Equal Employment Opportunity policies upon their appointment. All new supervisors are not provided a copy of Equal Employment Opportunity policies upon their appointment. Lack of consistent coordination among Human Resources (HR) and EEO Office on matters affecting the integration of equal employment opportunity in the Agency's strategic mission. Lack of consistent coordination among Human Resources (HR) and EEO Office on matters affecting the integration of equal employment opportunity in the Agency's strategic mission. Lack of involvement of senior managers and supervisors in working with Human Resources and EEO Office to identify barriers to equal employment opportunity for all groups during the development of the EEOC MD-715 Annual Plans. Lack of involvement of senior managers and supervisors in working with Human Resources and EEO Office to identify barriers to equal employment opportunity for all groups during the development of the EEOC MD-715 Annual Plans.

9 Treatment of “EEO Program Deficiencies” EEO Program Deficiencies should be identified by answering “No” in Part G and addressed through action plans developed in Part H, not part I EEO Program Deficiencies should be identified by answering “No” in Part G and addressed through action plans developed in Part H, not part I Completed objectives in Part H should indicate that the deficiency reported have been eliminated. Completed objectives in Part H should indicate that the deficiency reported have been eliminated. Once eliminated, EEO program deficiency no longer need to be reported under MD-715, unless it resurfaces. Once eliminated, EEO program deficiency no longer need to be reported under MD-715, unless it resurfaces.

10 Trigger A trigger is a "red flag.” A trigger is a "red flag.” Triggers are conditions, disparities, or anomalies warranting further inquiry. Triggers are conditions, disparities, or anomalies warranting further inquiry. A trigger alerts the facility that additional scrutiny of the area where the trigger occurred is necessary. A trigger alerts the facility that additional scrutiny of the area where the trigger occurred is necessary. Facilities must investigate triggers to determine whether actual barriers are at work. Facilities must investigate triggers to determine whether actual barriers are at work. Remember, triggers can lead to barriers, but not necessarily. Remember, triggers can lead to barriers, but not necessarily.

11 Examples of Triggers The net change for individuals with targeted disabilities declined by 3.3% as compared to a 3.0% increase for the overall workforce. The net change for individuals with targeted disabilities declined by 3.3% as compared to a 3.0% increase for the overall workforce. The participation rate of Hispanic women is lower than the RCLF. The participation rate of Hispanic women is lower than the RCLF. High separation rate for Hispanics, compared to their on board ratio. High separation rate for Hispanics, compared to their on board ratio. Low ratio of Asian men in senior level positions, compared to their on board ratio. Low ratio of Asian men in senior level positions, compared to their on board ratio. Employees are transferring to other agencies for promotions. Employees are transferring to other agencies for promotions.

12 Barrier Any employment policy, procedure, practice, or condition, or facet thereof, that limits or tends to limit employment opportunities for members of a particular Race/Ethnic Background/ Gender or based on an individual’s disability status.

13 Barriers Institutional or Structural Institutional or Structural Example: Agency will hire only at higher grades, as opposed to hiring at entry level. Example: Agency will hire only at higher grades, as opposed to hiring at entry level. Attitudinal Attitudinal Example: Belief on part of senior executives that women will not be as committed to the agency’s mission after having a child. Example: Belief on part of senior executives that women will not be as committed to the agency’s mission after having a child. Physical Physical Example: Building does not have an elevator, making it inaccessible to employees who use wheelchairs. Example: Building does not have an elevator, making it inaccessible to employees who use wheelchairs.

14 Examples of Barriers Single-source or limited-source recruiting. Single-source or limited-source recruiting. Some employees are not provided information on training development opportunities due to limited or no access to computers. Some employees are not provided information on training development opportunities due to limited or no access to computers. Use of overly narrow selection criteria, e.g., highly specialized / exotic experience requirements that potential applicants are not likely to have. Use of overly narrow selection criteria, e.g., highly specialized / exotic experience requirements that potential applicants are not likely to have. Biased/hostile attitude of management toward certain EEO-protected groups. Biased/hostile attitude of management toward certain EEO-protected groups.

15 The Barrier Analysis Process: An Overview Review sources of information Review sources of information Identify triggers – i.e., red flags Identify triggers – i.e., red flags Determine root cause of trigger Determine root cause of trigger If root cause is a barrier within the control of the agency, devise action plan If root cause is a barrier within the control of the agency, devise action plan Assess results through follow-up Assess results through follow-up

16 Barrier Identification Step 1 Identify Source Material ■ Workforce statistics ■ Part IV of Form 462 – Bases / Issues Matrix ■ EEO complaints ■ Input from EEO and human resources staff ■ Input from Unions and advocacy groups ■ Surveys, focus groups and exit interviews ■ Studies by outside agencies

17 Barrier Identification and Elimination (I&E) - Step 2 Identify Triggers/Red Flags ■ Lower than expected participation rates for one or more groups? ■ High separation rates for one or more groups? ■ A surge in EEO complaints out of one shop/region or on one particular basis? ■ Unfavorable responses on employee surveys? ■ High termination rates for a particular group? ■ Others?

18 Analyzing Workforce Data Tables Compare workforce population to benchmark (source population for the personnel action) Compare workforce population to benchmark (source population for the personnel action) Hires - If hire rate is below benchmark (R/CLF), then we have a trigger Hires - If hire rate is below benchmark (R/CLF), then we have a trigger Separations – If separation rate is above onboard rate, then we have a trigger Separations – If separation rate is above onboard rate, then we have a trigger

19 Identifying Benchmarks – A Tables Table A1 – Compare workforce percentages to civilian labor force (R/CLF) Table A1 – Compare workforce percentages to civilian labor force (R/CLF) Table A3 – Compare the ratios for Officials and Managers to the ratio of each group in the total workforce Table A3 – Compare the ratios for Officials and Managers to the ratio of each group in the total workforce Table A4-2 – Compare each pay grades to the “All” column for that pay grade Table A4-2 – Compare each pay grades to the “All” column for that pay grade Table A6 – Compare participation in major occupations to Occupational RCLF Table A6 – Compare participation in major occupations to Occupational RCLF Table A8 – Compare total new hires to RCLF Table A8 – Compare total new hires to RCLF Table A14 – Compare total separations to workforce Table A14 – Compare total separations to workforce

20 Identifying Benchmarks– B Tables Table B1 - Compare the ratio of persons with targeted disabilities (PWTDs) with the Federal high Table B1 - Compare the ratio of persons with targeted disabilities (PWTDs) with the Federal high Table B3 – Compare the ratio of PWTDs in “Officials and Managers” with the total on board ratio for PWTDs. Table B3 – Compare the ratio of PWTDs in “Officials and Managers” with the total on board ratio for PWTDs. Table B 4-2 – Compare the ratio of PWTDs in each pay grade with the ratio in the “ALL” column for that grade. Table B 4-2 – Compare the ratio of PWTDs in each pay grade with the ratio in the “ALL” column for that grade. Table B6 – no benchmark Table B6 – no benchmark Table B8 – Compare the hire ratio for PWTDs to the 25 hiring goal. Table B8 – Compare the hire ratio for PWTDs to the 25 hiring goal. Tables B7/9/11/12 Compare the ratio of PWTDs selected to their ratio in applicant pool/onboard Tables B7/9/11/12 Compare the ratio of PWTDs selected to their ratio in applicant pool/onboard

21 Looking for Triggers Workforce data from different tables can be grouped in ways that reveal patterns: Workforce data from different tables can be grouped in ways that reveal patterns: Overall Workforce Overall Workforce Total Participation – Table 1 Total Participation – Table 1 Organizational Component – Table 2 Organizational Component – Table 2 Hiring – Table 8 Hiring – Table 8 Separations – Table 14 Separations – Table 14 Senior and mid-level Management Senior and mid-level Management Officers and Managers – Table 3 Officers and Managers – Table 3 Promotions – Tables 9 and 11 Promotions – Tables 9 and 11

22 Looking for Triggers, cont. Senior Grades (Glass Ceilings) Senior Grades (Glass Ceilings) Pay Level Distribution – Table 4-2 Pay Level Distribution – Table 4-2 Competitive Promotions – Table 11 Competitive Promotions – Table 11 Major Occupations Major Occupations On Board Rate – Table 6 On Board Rate – Table 6 Hiring – Table 7 Hiring – Table 7 Competitive Promotions – Table 9 Competitive Promotions – Table 9

23 Barrier I&E Step 3 Investigate and Assess ■ How do I pinpoint the policy, practice or procedure that is the root cause? ■ What’s my investigative plan? ■ What questions need to be asked? ■ Who needs to be interviewed? ■ What documents do I need, if any?

24 Barrier Identification How much information is enough? How much information is enough? A drill-down process A drill-down process Keep asking why until you have an answer Keep asking why until you have an answer Key: The identification of a barrier is always a working hypothesis Key: The identification of a barrier is always a working hypothesis The barrier identification should be detailed enough to allow the facility to develop an action plan that will yield the desired results The barrier identification should be detailed enough to allow the facility to develop an action plan that will yield the desired results

25 Barrier I&E Step 4 Action Plan: What Should Be in Part I Trigger Identified Trigger Identified Barrier Analysis Explained Barrier Analysis Explained Barrier Identified with Specificity Barrier Identified with Specificity Objective for Eliminating Barrier Specified (align with VA Diversity and Inclusion Strategic Plan) Objective for Eliminating Barrier Specified (align with VA Diversity and Inclusion Strategic Plan) Responsible Official Identified Responsible Official Identified Timeline – start and complete dates Timeline – start and complete dates Milestones with target dates Milestones with target dates Follow-Up: Accomplishments from previous years Follow-Up: Accomplishments from previous years

26 Barrier I&E - Step 5 Follow-Up: What to Look For Caveat: results hard to assess after only one reporting cycle Caveat: results hard to assess after only one reporting cycle Assess whether action plan was successful in eliminating barrier Assess whether action plan was successful in eliminating barrier Indicators of Success: Indicators of Success: Participation rates up Participation rates up Separation rates down Separation rates down Drop in complaints Drop in complaints If plan did not yield desired results, then the wrong barrier was identified or the Action Plan needs to be revised If plan did not yield desired results, then the wrong barrier was identified or the Action Plan needs to be revised

27 Policy Intent: To ensure that all employees and applicants for employment enjoy equality of opportunity in the federal workplace regardless of race, sex, national origin, color, religion, disability or reprisal for engaging in prior protected activity. To ensure that all employees and applicants for employment enjoy equality of opportunity in the federal workplace regardless of race, sex, national origin, color, religion, disability or reprisal for engaging in prior protected activity. Statutes and Authority: Equal Employment Opportunity Management Directive Equal Employment Opportunity Management Directive Title VII of the Civil Rights Act of 1964 Title VII of the Civil Rights Act of 1964 Rehabilitation Act of 1973 Rehabilitation Act of C.F.R C.F.R. 1614

28 Office of Diversity and Inclusion Outreach and Retention Team (202)


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