Barrier Analysis From the Ground Up

Barrier Identification and Elimination Under

Management Directive 715Department of Veterans AffairsOffice of Diversity and Inclusion

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.

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.

Terminology

Current (MD-715) – Less than expected, Low Participation Rates compared against benchmarks

Outdated (MD-712, 713, 714) - Underrepresentation

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Outdated (MD-714) – Women and Minorities

Crucial Distinctions Triggers Barriers EEO Program Deficiencies (Part G)

“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-715-01, 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.

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.

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.

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.

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.

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.

Barriers Institutional or Structural

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 .

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.

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

Barrier IdentificationStep 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 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?

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

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

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

Looking for Triggers Workforce data from different tables can be grouped in

ways that reveal patterns:

Overall WorkforceTotal Participation – Table 1Organizational Component – Table 2Hiring – Table 8Separations – Table 14

Senior and mid-level Management Officers and Managers – Table 3Promotions – Tables 9 and 11

Looking for Triggers, cont. Senior Grades (Glass Ceilings)

Pay Level Distribution – Table 4-2Competitive Promotions – Table 11

Major Occupations On Board Rate – Table 6Hiring – Table 7Competitive Promotions – Table 9

Barrier I&EStep 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 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

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 I&E - Step 5Follow-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 upSeparation rates downDrop in complaints

If plan did not yield desired results, then the wrong barrier was identified or the Action Plan needs to be revised

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 715-01• Title VII of the Civil Rights Act of 1964• Rehabilitation Act of 1973• 29 C.F.R. 1614

Office of Diversity and InclusionOutreach and Retention Team

(202) 461-4131