1. Barrier Analysis From the Ground Up
Barrier Identification and Elimination Under Management Directive 715
On August 25, 2003,the Commissioners of the EEOC voted unanimously to approve the new management directive known as MD-715
On October 1, 2003, the state of Fiscal Year 2004, MD-715 became effective, and replaced directives 712, 713, and 714.
MD-715 provides policy guidance and standards for establishing and maintaining effective affirmative programs of equal employment opportunity
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.
Fourth Element: Proactive Prevention of unlawful discrimination. Submission of workforce data tables
Barrier analysis: Title VII, Rehabilitation Act, Triggers identified using tables and 462 part IV
When Barriers are identified; Action plans developed. Last: Follow-up;
Check Part I to see if agency identified trigger or barrier

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.

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Outdated (MD-712, 713, 714) - Underrepresentation

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Outdated (MD-714) – Women and Minorities

6. Crucial Distinctions Triggers Barriers
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.
“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.

8. Examples of EEO Program Deficiencies
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 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
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.

10. Trigger A trigger is a "red flag.”
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.
Facilities must investigate triggers to determine whether actual barriers are at work.
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 participation rate of Hispanic women is lower than the RCLF.
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.
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 Attitudinal Physical
Example: Agency will hire only at higher grades, as opposed to hiring at entry level.
Attitudinal
Example: Belief on part of senior executives that women will not be as committed to the agency’s mission after having a child.
Physical
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.
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.
Biased/hostile attitude of management toward certain EEO-protected groups.

15. The Barrier Analysis Process: An Overview
Review sources of information
Identify triggers – i.e., red flags
Determine root cause of trigger
If root cause is a barrier within the control of the agency, devise action plan
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
Barrier analysis should be: (1) focused; (2) methodical; and (3) involve the participation of all relevant agency officials.

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?
After reviewing source material, sort issues into triggers and program deficiencies.
Program deficiencies should be addressed in Part H
Barrier analysis should be: (1) focused; (2) methodical; and (3) involve the participation of all relevant agency officials.

18. Analyzing Workforce Data Tables
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
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 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 A6 – Compare participation in major occupations to Occupational RCLF
Table A8 – Compare total new hires to RCLF
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 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 B6 – no benchmark
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

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

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

23. Investigate and Assess
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?
Barrier analysis should be: (1) focused; (2) methodical; and (3) involve the participation of all relevant agency officials.

24. Barrier Identification
How much information is enough?
A drill-down process
Keep asking why until you have an answer
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

25. Action Plan: What Should Be in Part I
Barrier I&E Step 4
Action Plan: What Should Be in Part I
Trigger Identified
Barrier Analysis Explained
Barrier Identified with Specificity
Objective for Eliminating Barrier Specified (align with VA Diversity and Inclusion Strategic Plan)
Responsible Official Identified
Timeline – start and complete dates
Milestones with target dates
Follow-Up: Accomplishments from previous years
Barrier analysis should be: (1) focused; (2) methodical; and (3) involve the participation of all relevant agency officials.

26. Follow-Up: What to Look For
Barrier I&E - Step 5
Follow-Up: What to Look For
Caveat: results hard to assess after only one reporting cycle
Assess whether action plan was successful in eliminating barrier
Indicators of Success:
Participation rates up
Separation rates down
Drop in complaints
If plan did not yield desired results, then the wrong barrier was identified or the Action Plan needs to be revised
Barrier analysis should be: (1) focused; (2) methodical; and (3) involve the participation of all relevant agency officials.

27. Statutes and Authority:
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.
Statutes and Authority:
Equal Employment Opportunity Management Directive
Title VII of the Civil Rights Act of 1964
Rehabilitation Act of 1973
29 C.F.R. 1614

28. Office of Diversity and Inclusion Outreach and Retention Team
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