DOCUMENT BESUMI

06554 - f B1926918 1

Federal Employment of Handicapped Pecple. PPCD-78-41;B-164031(3). July 6, 1978. Released July 11, 1978. 2 pp. + 2appendices (20 pp.).

Beport to Rep. Olin E. Teague, Chairman, house Coemittee orkScience and Technology; by Elmer B. Staate, Ccmptrciler General.

Issue Area: Personnel Management and Ccup3nsaticn: EqualEmployment Opportunity (3n2); Personnel Management andCompenration (300).

Contact: Fe .eral Personnel and Ccaensation Div.Budget Function: General Science, Space, and Tuchnclogy 4250);

Education, manpower, and Social Services (5CO).organization Concerned: Department of State; Civil Service

Commission; General Services Aiministraticr; EqualEmployment Opportunity Commissicn.

Congressional Uelevance; House Committee on Scieace andTechnoloqy. Rep. Clin I. Teague.

Authority: Rehabilitation Act of 1913 (EoL. 93-112; 29 U.S.C.791). (P.L. 94-617; 5 U.S.C. 7'53). Back Pay Act 45 U.S.C.5596). Privacy Act (3 U.S.C. 552a). Vietnav Era Veteran'sReadjustment Assistance Act of 1974. Civil Rights Attorneys'Fees Award Act of 1976. 5 U.S.C. a1G9. 42 'J.S.C. 1981.Executive Order 11830. 42 Fed. Feg. 22676. 40 Fed. Beg.2411. Reorqanizaticn Plan 1 of 1976. F.E.M., chb. 306.

The Civil Service Commission 4CSC) is responsible forleadership in the Federal program for hiring, placing, andadvancing handicapped persons. A recently acceptedreorganization plan will transfer functions related to thisproqram at the Equal Employment Opportunit, Commission (EECC).The Chair of the EECC will become a co-ctaiL of the InteragencyCommittee on Handicapped Employees. Eindings/Ccnclusicms: Someproqress has been made towards imFrciang Federal employmentoFportunities tor the handicapped. Affirmative action plans arerequired at all executive agencies, and a 5-year experimentalspecial emphasis program will soon be implemented tc prcvideexpected hiring authority and special selecticn procedures.Complaint procedures hive been exFanded tc include appeals torcomplaints of discrimination based on handicaps. Agency advisorycommittees 4ere estabiish d, training ccurse.s were develcped,and tests were modified to accommodate handicapped applicants.The tollowing prr.blemi remain unsolved; definitions C."handicapped individuals" and "reasonable eccommodation" arevaque, attitudes of individuals hamper pzogress, cctdinatedresearch eftorts to develop assisiive devices are lacking, andrestrictive physica, requirements for Federal positionsunnecessarily exclude some .andicapped persons. Also, asreported in 1974, CSC still is taking cnly an -dt.oLry role,placement coordinators lacK adequate training a&L time, andproqram success cannot be measured btcuuse of the lack of

reliable data. Recommendations: In implementing their mneresponsibilities, the Chief of EEOC should: take a scredire:tive role toward the program than that assumed by the CSC;conduct indepth, compliance reviews aimed at assessing agencyaccomplishments; wovrk closely with the CSC and agency porscnneloffices to ensure that policies and Frccedires carry out programqoals; make sure that selective placement coordinators are givansufficient training, time, and resources; develop the capabilityand staff resourceu to provide more techaical assistance;address attitudinal barriers through an emloyee relationscampaiqn; work with the General Services Adainristraticn to seethat architectural barriers are removed Frcaptly; and see thatthe proqram for handicapped persons is not overshadowed kyproqrams for women -ad inoxiies. 1-be Co-n1res should enactleqislatiao to qive handicapped persons the rig§.ts etjoyid byothers. (HTV)

.. "STRICTD e *

REPEFORT BY THAE by the OIffce Co1n01recf*; . 'frld. O

Comptroller General RELEASEDOF THE UNITED STATES -1, I L

Federal Employment OfHandicapped People

What has happened to the Federal Govern-ment's hiring, placing, advancing, and retain-ing qualified handicapped individuals sinceGAO reported in 1974?

Concerned over apparent unresponsiveness ofFedaral departments to this national policy,the Chairman. House Committee on Scienceand Technology, asked GAO

--to look into the resons for lackofp'og-ress;

--to identify any research which mighthelp to more effectively recruit, em-ploy, and promote the tIandizappea;and

--to determine whether positive changeshad occurred.

Although employment opportunities haveimproved, problems still exist, and the re-port suggests possible legislative actions andrecommendations to the Equal EmploymentOpportunity Commission.

4')

F PCD-78-40

-CCOu, 4's JULY 6, 1978

COMPTROLLER GENERAL OF THE UNITED STATES

WAtAHINGTON, D.C. He

L-164031(3)

The Honorable Olin E. TeagueChairman, Committee on Science and TechnologyHouse of Representatives

Dear Mr. Chairman:

As requested in your July 8, 1977, letter, this reportreviews Federal employment opportunities for handicappedindividuals. It discusses both improvements in the Federalemployment picture since our 1974 report and problems thatremain.

The report suggests possible legislative actions andrecommendations to the Equal Employment Opportunity Coiimissionwhich, under the recently accepted Reorganization Plan No. 1,will have responsibility for enforcement and related functionsof programs for handicapped individuals.

At your request, we did not obtain written agency com-ments. We did, however, informally discuss our findingswith Civil Service Commission and Equal Employment Opportu--nity Commission officials and have included their commentswhere appropriate.

As arranged with your office, unless you publicly an-nounce its contents earlier, we plan no further distributionuntil 5 days from the date of the report. At that time, wewill send copies to interested parties and make copie_ avail-able to others upon request.

ly yours

Comptroller Generalof the United States

COMPTROLLER GENERAL'S FEDERAL EMPLOYMENT OFREPORT TO THE COMMITTEE HANDICAPPED PEOPLEON SCIENCE AND TECHNOLOGYHOUSE OF REPRESENTATIVES

DIGEST

Although progress cannot be statisticallyproven because reliable data are not availableto compare changes in hiring, retentions, andmobility, actions have been taken which shouldimprove the employment picture for handicappedFederal employees.

Under the recently accepted ReorganizationPlan No. 1 of 1978, favored by advocacygroups, all enforcement and other functionsrelating to Federal employment of handicap .dindividuals are expected to be transferred,along with other Federal equal employmentopportunity programs, from the Civil ServiceCommission to the Equal Employment Opportu-nity Commission. The Chair of the EqualEmployment Opportunity Commission will be-come a co-chair of the Interagency Com-mittee on Handicapped Employees. ThisCommittee was established by section 501of the Rehabilitation Act of 1973.

Affirmative action plans are now required ofall executive agencies, and a 5-year experi-mental special emphasis program soon willbe implemented to provide excepted hiringauthorit- and special selection procedures.

Existing complaints procedures have beenexpanded to include an appeals system forhearing complaints of discrimination basedon physical or mental handicap. Establish-ing agency advisory committees, developingtraining courses, providing training funds,and modifying tests to accommodate handi-capped applicants are recent steps giving

.handicapped persons the same opportunitiesafforded other individuals.

FPCD-78-40

~Tear SbI. Upon removal, the reportcover date should be noted hereon.

PROBLEMS

Despite these changes, the Federal Government'sprogram to increase employment opportunitiesfor handicapped persons is a long way from beingtruly effective. Vague and broad definitionsraise questions: Who is a "handicapped indivi-dual"? What are the Government's responsibili-ties for modifying jobs and worksites to provide"reasonable accommodation" for handicappedemployees?

Architectural barriers, the attitudes of handi-capped and nonhandicapped individuals, and thelack of a coordinated research effort todevelop and fully integrate simple assi3tivedevices hamper progress.

Outdated and restrictive physical requirementsfor Federal positions unnecessarily excludesome handicapped persons.

As GAO reported in 1974:

--The Civil Service Commission still is tak-ing an advisory rather than a directive rolein administering the program.

--The Commission has no sanctions to motivateuncooperative aiencies.

---Selective placement coordinators are notalways trained and cannot devote adequatetime to the program because of collateralduties.

-- Measuring program success is impossiblebecause of unreliable data and inconsistentdata collection.

Programs for handicapped individuals have neverreceived the resources and attention that thosefor other groups, such as minorities and women,enjoy. The handicapped population, unlike othergroups seeking equal opportunity, is not entitledto attorneys' fees for successful litigation,back pay for job applicants who successfullychallenge discrimination, or the right to

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proceed to Federal Lourt with a new case ifa formal complaint is tied up in administrativeprocedures for more than 180 days.

Merging Federal equal employment programs,transferring duties from the Civil ServiceCommission to the Equal Employment OpportunityCommission and possibly reorganizing the former,makes predicting future effectiveness of theprograms for handicapped individuals difficult.As requested by the Committee, GAO did not re-quest written agency comments. However, GAO,iscussed past weaknesses with officials ofboth agencies. But because duties have notbeen clearly delineated, neither they nor GAOcan be specific in addressing future plans.

RECOMMENDATIONS

In implementing these new responsibilities,the Chair, Equal Employment Opportunity Commis-sion should

-- take a more positive and directive roletoward the handicapped program than theadvisory role assumed by the Civil ServiceCommission;

-- conduct indepth, compliance reviews aimedat assessing agency accomplishments andcommitments toward stated goals;

-- work closely with the Civil Service Commis-sion and agency personnel offices to ensurethat personnel policies and procedures carryout the overall goals of the programs forhandicapped individuals;

-- make sure that selective placement coordi-nators are given sufficient training, time,and resources to carry out a successfulprogram;

-- develop the capability and staff resourcesto provide more technical assistance, par-ticularly relating to research and develop-ment of assistive devices, job restructur-ing, site mouifications, and accommodations;

I ;.L~jiefA ~i.ii

-- address attitudinal barriers through anemployee relations campaign aimed at dis-solving misconceptions about handicappedpeople;

-- work closely with the General ServicesAdministration to see that architecturalbarriers are removed as quickly as possible;and

-- see that the program for handicappedpersons is not overshadowed by the morefirmly established programs for women andminorities.

RECOMMENDATIONS TO THE CONGRESS

The Congress should enact legislation togive handicapped persons the rights enjoyedby others under title VII of the Civil RightsAct of 1964 and the Civil Rights Attecrneys'Fees Awards Act of 1976. These rights in-clude back pay for Federal job applicantswho successfully challenge discrimination,attorneys' fees for successful litigation,and 'he right to proceed to Federal courtwit;h a new case if a complaint is tied upin administrative procedures for more than180 days.

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Con tents

DIGEST

CHAPTER

1 INTRODUCTIONScope of review 2

2 IMPROVEMENTS IN THE FEDERAL EMPLOYMENTPICTURE 3

Reorganization of Equal EmploymentOpportunity programs 3

Interagency Committee on HandicappedEmployees 4

Affirmative action plans 4Unpaid work experience 6Complaint procedures 6Special emphasis program 7Other actions 8

3 REMAINING PROBLEMS 9Definitions 9Weaknesses reported by GAO in 1974 11Attitudinal barriers 19Architectural barriers 20Selective placement vs. equalopportunity 20

Civil rights afforded other groups 20Equal Employment Opportunity Com-mission 22

Research and technology 22Othec concerns of advocacy groups 24

4 CONCLUSIONS AND RECOMMENDATIONS 26Recommendations 26Recommendation to the Congress 27

APPENDIX

I Agencies whose selective placement coordi-nators were contacted 28

II Civil Service Commission report on statusof recommendations by the InteragencyCommittee on Handicapped Employees 29

ABBREVIATIONS

CSC Civil Service Commission

GAO :General Accounting Office

EEOC Equal Employment Opportunity Commission

HEW Department of Health, Education, and Welfare

CHAPTER '

INTRODUCTION

The 1970 census showed that 11,265,000 persons inAmerica considered themselves to have a health or physicalcondition which limited the kind of work they could do orthe amount. Thus, 1 person in 11, or 9 percent of theadult population, in the age range of 16 to 64 is handicapped.The census findings also showed that these persons have notfared as well in income, education, and -Employment as themainstream of America's population.

For many years the Federal Government has taken theposition that it is not only a desirable social objectivebut also good business to employ handicapped persons. AGovernment-wide survey disclosed that in 1977, 140,808(6.6 percent of the Federal work force) handicappedpersons :vere employed by the Government.

The Civil Service Commission (CSC), charged withleadership and direction of the Federal Government programfor hiring, placing, and advancing handicapped persons,has established an Office of Selective Placement in itsBureau of Recruiting and Examining. The target individualsare those who

--have a physical or mental impairment which substan-tially limits one or more of their major life activi-ties;

--have a record of such an impairment; or

--are regarded as having such an impairment.

Th(: legal basis for the program is Public Law 617(5 U.S.C. 7153(1976)) enacted in June 1948 which prohibitsdiscrimination because of physical handicap. Section 501 ofthe Rehabilitation Act of 1973, Public Law 93-112, (29 U.S.C.791 (Supp. V 1975)), authorized programs to promote and expandFederal employment opportunities for handicapped individualsby

--establishing an Interagency Committee on HandicappedEmployees,

-- requiring Federal agencies to submit affirmativeaction plans to the above committee and to the CSC,and

-- havinq CSC report annually to the appropriate congres-sional committees on Federal agencies' achievements.

The first formal policy statement on executive branchemployment of handicapped persons was a letter from the Presi-dent to agency heads in May 1957. Since that time, severalother policy statements have stressed employment of handicappedpersons in Federal service.

SCOPE OF REVIEW

In July 1977 the Chairman, House Committee on Science andTechnoloay, concerned over the apparent unresponsiveness ofFederal departments to the national policy of recruiting andemploying aualified handicapped individuals, requested that welook into the reasons for the lack of progress. The Chairmanalso asked us to identify any research which might la.lp tomore effectively recruit, employ, and promote handicapped in-dividuals and to determine whether positive changes had takenplace since our 1974 review. 1/

For this review we visited the Civil Service Commission,the General Services Administration, and the Department ofState and talked to selective placement coordinators at theagencies listed in appendix I. We reviewed affirmative actionplans, statistics, evaluation reports, correspondence, person-nel manuals, and other materials relating to handicapped em-ployment. We examined CSC policies, procedures, and guidanceissued to agencies and CSC's affirmative action plan reviewand approval procedures. We also interviewed handicapped em-ployees, representatives of special interest groups, and thedirector of the Job Development Laboratory at George Washing-ton University.

1/"Employment Opportunities in the Federal Government for thethe Physically Handicapped" (B-164031(3), Sept. 16, 1974).

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CHAPTER 2

IMPROVEMENTS IN THE FEDERAL

EMPLOYMENT PICTURE

Recent actions should improve Federal employment opportu-nities for handicapped individuals. Some of these result fromthe President's Reorganization Project and the RehabilitationAct of 1973, while others result from increased awareness ofhandicapped persons' problems and needs. However, becausereliable statistics are not available (see p. 18), we cannotassess the degree to which these changes have improved the em-ployment picture.

REORGANIZATION OF EQUALEMPLOYMENT OPPORTUNITY PROGRAMS

On May 5, 1978, Reorganization Plan No. 1 of 1978 was ac-cepted, consolidating the Federal Government's equal employmentopportunity activities by making the Equal Employment Opportu-nity Commission (EEOC) the principal agency for fair employ-ment enforcement in both the private and public sectors.Under the plan, authority to ensure nondiscrimination and af-firmative action in Federal employment, including CSC's re-sponsibilities under the Rehabilitation Act and the VietnamEra Veterans' Readjustment Assistance Act of 1974, will betransferred from CSC to EEOC before January 1, 1979. Thus theGovernment's program to improve employment for handicappedindividuals will be combined with other equal opportunityprograms and become part of a single coherent Federal programto combat job discrimination.

The President's Reorganization Project study, which ledto the reorganization plan, reported that equal opportunityand affirmative action have not been pursued vigorously oradmininistered effectively in Federal departments and agencies,that CSC had adopted substantially weaker standards than thoseimposed on Federal contractors in the private sector, and thatCSC's instructions on affirmative action were considerablyweaker than those required of Federal contractors. The studyconcluded that the Federal employment record was substantiallypoorer than that of private sector employers. The reportstates that transferring ArC's authority under the variousantidiscrimination laws will ensure that Federal employees havethe same rights and remedies as private sector employees.

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INTERAGENCY COMMITTEE ONHANDICAPPED EMPLOYEES

The Rehabilitation Act of 1973 established this commit-tee, orginally comprising the CSC Chairman, the Administratorof Veterans' Affairs, and the Secretaries of Labor &nd Health,Education and Welfare (HEW). It was later expanded by Execu-tive Order 11830 January 9, 1975 (40 Fed. Reg. 2411(1975))to include representatives from the Department of Defense,General Services Administration, and Federal CommunicationsCommission.

The committee's goals are to provide a focus for increasedemployment and to ensure an equitable, suitable, and function-al environment for handicapped individuals in the Federal ser-vice.

Since March 1974, the committee has recommended some 89changes relating primarily to developing complaint procedures,improving agency affirmative action plans, removing attitudinaland architectual barriers, and establishing an informationsystem to collect Federal employment data. Most recommenda-tions were forwarded to and affirmatively implemented by CSC.The status of the committee's recommendations is shown in ap-pendix II.

AFFIRMATIVE ACTION PLANS

The Rehabilitation Act and the Vietnam Era Veteran'sReadjustment Assistance Act of 1974 direct eich executivebranch department or agency, the Postal Service and PostalRate Commission, and such instrumentalities as the TennesseeValley Authority to submit to CSC affirmative action plans forhiring, placing, and advancing handicapped individuals, in-cluding separate specifications for disabled veterans. CSChas overall responsibility for issuing program guidance andapproving agency plans. CSC guidance to the agencies dictatesthat the action plans must address:

-- achieving full commitment to program goals,

-- committing adequate resources to support programefforts,

-- delegating appropriate authority to direct andaccomplish program efforts,

-- including sources of handicapped individuals anddisabled veterans in ongoing recruitment efforts,

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-- ensuring that handicapped individuals and disabledveterans receive equal opportunities in hiring,placement, and retention,

-- including handicapped employees in merit promotion,upward mobility, and training programs,

--evaluating program status and achievements in asystematic manner,

--maintaining an internal data collection system forprogram assessment and planning, and

-- ensuring accessibility of facilities.

Approval is based on information provided by agencies andnarrative reports of prior achievements. A satisfactoryrating requires completeness and compliance with CSC guid-ance.

According to CSC, weaknesses in agency programs fell intofour categories

--lack of comprehensive program assessment,

-- limited use of personnel management evaluation,

-- lack of action plan development and implementation,and

-- insufficient commitment of resources.

While the Office of Selective Placement assesses anagency's accomplishments through its affirmative action plan,CSC's Bureau of Personnel Management Evaluation evaluatesagency program effectiveness. In April ]976, as a result of arecommendation of the Interagency Committee on Handicapped Em-ployees, the Bureau's general agency evaluation looked forchanges resulting from the Rehabilitation Act and reasonz forlack of progress. The evaluation found a need for integratingthe selective placement program with all aspects of an agency'spersonnel management system and a need for onsite assessmentof agency programs below the headquarters level. The Bureauof Personnel Management Evaluation is developing a question-ninire on these issues for future general agency evaluations.

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UNPAID WORK EXPERIENCE

The Rehabilitation Act of 1',73 offers handicapped indivi-duals an opportunity to get unpaid work experience in Federalagencies. State vocational rehabilitation agencies developindividualized written rehabilitation programs, and Federalagencies are encouraged to supply the needed work experienceand training. Federal agency actions include, but are notlimited to

--determining if work locations are suitable forenro] lees,

-- contacting State vocational rehabilitation agenciesfor assistance in planning programs, and

-- specifying in working agreements duties to be performedby enrollees.

Since CSC does not maintain statistics or information on thenumber of persons participating, effectiveness of the programcannot be measured.

COMPLAINT PROCEDURES

There were no procedures for hearing complaints of dis-crimination based on physical or mental handicap other thanagency internal administrative procedures or negotiated agree-ments. In September 1977, CSC published for comment proposedadministrative proc.edures to hear discrimination complaints ofboth employees and Federal job applicants.

Most comments contended that the procedures for proces-sing complaints of discrimination based on race, color,religion, sex, national origin, and age shouild be used; somepeople questioned using these procedures because they are bur-densome and are prolonged by an enormous backlog of cases.CSC elected to expand these procedures to include complaintsof handicapping conditions rather than add a new system to thealready numerous and varied mechanisms.

In response to commentb by various advocacy groups, CSC3dded sections in the procedures to

-- partially clarify what "reasonable accommodations"an agency can or should make to employ handicappedindividuals,

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-- prohibit, except under certain circumstances, useof enmployment testing, preemployment medical examina-tions, and inquiries which tend to screen outqualified persons,

--ensure that qualified handicapped applicants andemployees are not discriminated against because of in-accessible buildings, and

-- make the procedures retroactive for 1 year prior toimplementation.

The final procedures became effective on April JO, 1978.Advocacy groups generally agree that the amended procedureswere greatly improved over the first version and should allowsubstantial progress, but they feel problems still exist.These are discussed in chapter 3.

Back pay

One benefit of initiating the complaint procedures isthat handicapped employees can now be awarded oack pay if theyhave been the subject of certain unwarranted or improper per-sonnel actions. Even though no express statutory authorityexists for awarding back pay to persons who can establish thatthey ware discriminated against because of a mental or physi-cal handicap, CSC in establishing the complaints procedures,took the position that the general authority of the Back PayAct (5 U.S.C. 5596(1976)) is applicable. The Back Pay Actprovides that an employee who successfully challenges an im-proper personnel action may be awarded pay and allowances forthe period from the time the action was effective.

SPELIAL EMPHASIS PROGRAM

This 5-year experimental program is expected to start in1978 and will cover persons with handicapping conditions,among others, who may be adversely affected by present hiringprocedures.

Under the program, CSC will determine whether persons inspecial emphasis groups are proportionally represented in agiven occupation. If not, excepted hiring authority andspecial selection procedures will be allowed for ttat particu-lar occupation.

Reliable statistics are not available to determinewhether any given occupation has a shortage of handicapped

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employees. However, handicapped persons will be included intarget recruiting since a shortage in any one special emphasisgroup triggers excepted hiring authority snd special selectionprocedures for all groups.

The program is expected to authorize appointments in theexcepted service to be converted to competitive status after2 years of successful work performance; thus these employeeswill be integrated with the mainstream of Federal employment.

OTHER ACTIONS

Other steps have been taken to improve the employmentpicture for handicapped people.

-- Agency advisory committees have been established toaparise management of the needs of handicapped employ-ees.

--Training courses have been developed for selectiveplacement coordinators and supervisors of handicappedemployees.

-- The Comptroller General decision of September 23, 1977,(B-188710) held that certain special expenses such asreaders, sign language interpreters, braille, etc.,necessary to participate in Government training coursesprovided under 5 U.S.C. 4109 may be paid with appro-priated funds.

-- CSC tests are now available in large print and braille,and some oral test requirements have been waived fordeaf applicants.

-- The Professional and Administrative Career Examinationhas been adapted for blind and deaf applicants.

-- The grade limitation for 700-hour (approximately 4months) trial appointments was eliminated in March 1977so persons can be employed at higher grades.

--Regulations on nepotism were amended to allow severelyhandicapped or mentally retarded persons to be employedat the same agency as a parent to help overcome trans-portation barriers.

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CHAPTER 3

REMAINING PROBLEMS

In spite of the changes discussed in the previouschapter, the program to improve employment opportunitiesfor handicapped individuals still faces many problems.Some obstacles surfaced from passage of the RehabilitationAct, while others are longstandirg, encompassing indivi-dual attitudes and commitments to the program.

DEFINITIONS

Broad definitions of terms, such as "handicappedindividual" and "reasonable accommodation, leave questionsas to who is handicapped and what are the Government'sresponsibilities to modify jobs and worksites to accommodateemployees.

Handicapped individual

Identifying persons who should be covered in theGovernment's efforts to improve employment opportunities iscomplicated by the inability to specifically define who ishandicapped. For example, there are more than three dozendefinitions in Federal legislation and regulations referringto handicapped and disability.

In May 1977, HEW issued regulations (42 Fed. Reg. 22676(1977)) to ensure that federally assisted programs and activi-ties are operated without discrimination on the basis ofhandicap. These regulations define handicapped persons andmajor terms in the Rehabilitation Act as follows:

"'Handicapped person' means any person who i) hasa physical or mental impairment which substantiallylimits one or more major life activities, ii) hasa record of such impairment or iii) is regarded ashaving such an impairment."

"'Physical or mental impairment' means (A) anyphysiological disorder or condition, cosmeticdisfigurement, or anatomical loss affecting one ormore of the following body systems: neurologicalmusculoskeletal; special sense organs; respiratory;including speech organs; cardiovascular; reproduc-tive; digestive; genito-urinary; hemic and lymphatic;skin; and endocrine; or (B) any mental or psychologi-cal disorder, such as mental retardation, organicbrain syndrome, emotional or mental illness, andspeciZic learning disabilities."

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"'Major life activities' means functions suchas caring for one's self, performing manualtasks, walking, seeing, hearing, speaking,breathing, learning, and working."

"'Has a record of such an impairment' means hasa history of, or has been misclassified ashaving, a mental or physical impairment thatsubstantially limits one or more major lifeactivities."

"'Is regarded as having an impairment' means(A) has a physical or mental impairment thatdoes not substantially limit major life activi-ties but that is treated by a recipient as con-stituting such a limitation; (B) has a physicalor mental impairment that substantially limitsmajor life activities only as a result of theattitudes of others toward such impairment;or (C) has none of the impairments definedbut is treated by a recipient as having suchan impairment."

The analysis of the regulation further explains thatthe definition includes such diseases as heart disease,diabetes, emotional illness, drug addiction, and alcoholism.Including drug addiction and alcoholism created considerablecontroversy, but they remained in the regulation after theAttorney General ruled these conditions are "physical andmental impairments" within the meaning of the RehabilitationAct. 1/ CSC has adopted the HEW definition.

Administering a program to cover such a broad rangeof handicapping conditions is difficult since each handicaphas unique problems and needs. Some people say the Rehabi-litation Act definition is so broad almost anyone can beconsidered handicapped. Others believe the broad coveragemay mean those who are severely disabled will not be hiredbecause agencies can meet their affirmative action goalsby hiring individuals with slight handicaps.

l/The issue is not closed, however, on May 16, 1978,H.R. 12467 was passed by the House of Representativeswhich in part would amend the Rehabilitation Act toexclude alcoholics and drug abusers in need of rehabili-tation from the employment discrimination provisions ofsections 503 and 504 of the act.

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Reasonable accommodation

CSC's recently adopted discrimination complaint ptoce-dures, following the regulations established by HEW, statethat:

"(a) An agency shall make reasonable accommodationto the known physical or mental limitationsof a qualified handicapped applicant oremployee unless the agency can demonstratethat the accommodation would impose an unduehardship on the operation of its program.

"(b) Reasonable accommodation may include, but shallnot be limited to: (1) making facilitiesreadily accessible to and usable by handicappedpersons, and (2) job restructuring, part-timeor modified work schedules, acquisition or modi-fication of equipment or devices, appropriateadjustment or modification of examinations, theprovision of readers and interpreters, and othersimilar actions.

In determining pursuant to paragraph (a) of thissection whether an accommodation would impose anundue hardship on the operation of the agency inquestion, factors to be considered include:

(1) the overall size of the agency's program withrespect to the number of employees, number andtype of facilities and size cf budget; (Z) thetype of agency operation, including the composi-tion and structure of the agency's workforce; and(3) the nature and the cost of the accommodation."

Although this describes "reasonable accommodation"somewhat, the definitions are still subject to interpreta-tion. For instance, advocacy groups believe the word "rea-sonable" is not strong enough to force employers to accomnio-date handicapped applicants and employees.

The problems surrounding these definitions are numerousand complex and perhaps can only be resolved as the defini-tions are refined through individual actions and court deci-sions.

WEAKNESSES REPORTED BYGAO IN 1974

In 1974, we reported that the Selective Placemaent Pro-gram could be strengthened by

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-- increasing CSC resources,

-- improving the agency coordinator systems, and

-- improving the system for collecting data to measureprogram effectiveness.

Four years later we find that while some progress hasbeen made along titese lines, many problems and weaknessesstill exist.

Civil Service Commission

Primary responsibility for the progra; o promotehandicapped employment is now vested in CS. £ Office ofSelective Placement. Under the recently accepted Reorgani-zation Plan No. 1 of 1978, the responsibilities dealing withreview and approval of affirmative action plans will move toEEOC but personnel policies and procedures for handicapperemployees will remain in CSC.

Staff resources were increased from two professionalsat the time of our 1974 review to seven professionals in1978. The staff is responsible for approving affirmativeaction plans, providing assistance to agencies, workingon grievance procedures, updating the Federal PersonnelManual, keeping abreast of technological developments,and providing staff support to the Interagency Committeeon Handicapped Employees. As in 1974, we found that theOffice of Selective Placement managers were personallycommitted to an effective program for employing disabledpersons. All of them felt they could use additional staffresources particularly with the anticipated workloadresulting from the new grievance procedures.

Most Federal agency coordinators whom we contactedspoke favorably of the efforts and support rendered by theCSC staff. Several commented, however, that the CSC man-agers should work more closely with them. One agency coordi-nator said the Office of Selective Placement's activitieswere primarily ceremonial or window dressing and CSC shouldprovide more technical and actual day-to-day program assist-ance. He also felt more could be done to provide an exchangeof information among the agencies so coordinators could gainfrom others' experiences.

CSC has always taken a leadership or advocacy rolerather than an enforcement role in administering the FederalGovernment's handicapped program. According to the reportaccompanying the President's Reorganization Plan No. 1 of1978, CSC, in all equal employment opportunity programs, has,

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for the most part, adopted weaker standards of performanceand weaker instructions on affirmative actions tnan thoseimposed on Federal contractors by the Department of Labor.In addition, CSC has no sanction to force negligent orrecalcitrant agencies to be more responsive. The strongestaction taken to date was a letter signed by the Co-chair ofthe Interagency Committee on Handicapped Employees to thefollowing agencies which had not submitted satisfactoryplans for 1978.

Civil Aeronautics BoardCommunity Services AdministrationEqual Employment Opportunity CommissionExport-Import BankFarm Credit AdministrationU.S. InfoLmation AgencyDepartment of JusticeDepartment of StateOccupational Safety and Health Review CommissionPension Benefit Guaranty CorporationSmall Business AdministrationSmithsonian InstituteSoldiers' and Airmen's Home

Only EEOC has not responded to the Co-chair's letter.

Evaluating agency progress is, for the most part,limited to approval of program assessments in affirmativeaction plans. Evaluations are based primarily on paperworksubmitted by the agencies and rarely involves a site visit.CSC's Bureau of Personnel Management Evaluation is develop-ing a questionnaire for future general evaluations. How-ever, it will not provide an indepth analysis or point outproblem areas that a compliance review would.

The agency coordinator system

CSC describes the Selective Placement Program as a"chain of cooperation," extending from CSC through theFederal agencies to the State rehabilitation services withthe agency coordinators being the key to success. Thereare about 1,800 selective placement coordinators at twolevels within most Federal agencies. Staff coordinatorsat the agency level are concerned with program matters,and operating coordinators at the field or component levelare concerned with recruiting, placing, and counseling.

Responses to a 1973 GAO questionnaire showed employingand advancing handicapped persons was hampered becausecoordinators

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--were not selected on the basis of interest orqualifications,

--were assigned other duties and could not devote suf-ficient time to the program,

--did not monitor progress of handicapped employeesafter placement, and

-- did not actively recruit, conduct job surveys, orrestructure jobs.

Through our discussion with selective placement coordi-nators we learned:

--Coordinators still do not feel they have sufficienttime to devote to the program because of otherduties.

-- Most coordinators were designated or assigned theresponsibility. 1/

-- Most coordinators were aware of their duties andresponsibilities as set forth in the Federal Per-sonnel Manual.

-- Only 5 of the 16 coordinators contacted had hadtraining relating to the handicapped program. Sixmore were scheduled to take the CSC course for coor-dinators.

-- Most coordinators were not aware of the CSC trainingpackage for supervisors of handicapped employees.

--Management commitment ranged from very little supportto extremely positive. Those coordinators indicatingpoor support said managers were so bombarded withspecial emphasis programs, no one program could begiven the attention it deserved.

--Most agencies do not have advisory committees.

--The agencies we contacted do not have active recruit-ing programs solely for handicapped persons. Vacancyannouncements are sent to sources of handicapped ap-

1/Even though most of the coordinators with whom we spokehad not volunteered for the assignment, all seemed in-terested and concerned with doing their best.

14

plicants, such as State rehabilitation services,schools, and advocacy groups.

-- Some coordinators made surveys to identi¥v jobswhich could be filled by handicapped persons. Othersfelt this was not necessary because, with the broaddefinition of handicapped, every job could be filledby a handicapped person.

When asked what could be done to improve the selectiveplacement program, coordinators suggested the need to

-- give the coordinators more :ime and resources,

-- work with attitudes of managers and supervisors toaccept handicapped employees,

-- have greater management support,

-- take more aggressive actoris in recruiting and otherpersonnel activities, and

-- formally identify jobs th'-t can te performed byhandicapped persons.

We visited two agencies and found great disparity be-tween their selective placement programs.

General Services Administration

The General Services Administration had a full-timecoordinator who had developed very comprehensive affirmativeaction plans as well as an internal assessment program. Thecoordinator was selected because of her interest and hadattended CSC training courses. She felt she had the fullsupport and commitment of top management. Files evidencedclose contact with regional coordinators as well as advo-cacy groups, researchers, and other agency coordinators.The files also included policy statements, notices, andother materials publicizing the program.

Department of State

The Department of State, on the ether hand, had littleto show that it had a program at all. The selective place-ment coordinator stated that he spent minimal time on the pro-gram, and the files showed no evidence of management support.At the time of our review, the Department was 8 months latein submitting an affirmative action plan in spite of a let-ter from the Interagency Committee on Handicapped Employees.

15

The Department has always contended that its require-ment that Foreign Service emplove-s be available for assign-ment anywhere in the world precl Jed hiring handicappedindividuals because of limited melical facilities atisolated posts. According to one State Department official,the attitude of worldwide availability also affects employ-ment of handicapped people in the agency's 4,000 civilianpositions in the United States.

Advocacy groups have strongly attacked the Department'spolicy toward Foreign Service hiring and the Department hashad to answer numerous congressional inquiries. In March1976, the Interagency Committee on Handicapped Employeessent a letter to the Secretary of State recommending thatphysical standards be revised to eliminate unnecessary employ-ment barriers. In December 1977 new standards Ware approved,but changes were limited to allowing single amputees or per-sons with vision in one eye or cosmetic disfigurements toenter the Foreign Service.

In July 1977 a State Department affirmative actiontask force criticized the Department's attitudes and abysmalrecord in handicapped employment. The report stated thatthe Department consistently pursued unwritten policieswhich were totally inconsistent with affirmative action andviolated the spirit of the Rehabilitation Act.

The task force made several recommendations, includingestablishing a high-level handicapped coordinator position,designatei.-' posts abroad suitable for handicapped persons,modifying the Foreign Service officer examination, acceler-ating recruiting and hiring for stateside positions, andallowing persons with unchanging disabilities in the foreignservice. As of May 1978, an implementation working group hadsubmitted proposals to the secretary on how to implement therecommendations of the affirmative action task force and aselective placement coordinator had been named.

Data collection to measure program results

Using samples of the American national population, the1970 census questioned persons about their disabilities af-fecting employment and the duration of the disability. Thequestions were self-defining; the person alone decided whetherhe was handicapped. The President's Committee on Employmentof the Handicapped did nct feel that self-identificationlessened the value of the sampling since handicapped persons'status in society very often depends on how they perceivethemselves.

Identifying the handicapped labor force is further com-plicated because there are two ways to look at unemployment.

16

One way is to consider only those persons who are unemployedand actively seeking work. By this definition, the censusfound that the unemployment rate of the handicapped popula-'ion was about the same as the general unemployment rate--iround 5 percent. The other is to consider those people whoare not working nor looking for work. According to thissecond definition, the census showed that only 42 percent ofthe handicapped population is employed compared to 59 per-cent of the total population.

Accurate data collection within the Government has al-ways been a problem in measuring success of efforts to hire,place, advance, and retain handicapped individuals. Statis-tics on excepted appointment of handicapped individuals showthat appointments have increased steadily since the pro-gram's inception in 1964.

Calendar years Excepted appointments

1964-65 191966-67 1291968-69 3851970-71 9101972-73 7891974-75 1,2851976-77 2,200

These excepted appointments, however, represent only asmall fraction of the handicapped persons actually employedby the Federal Government.

For its annual reports to the Congress, CSC, based onagency data, reported:

Percentage ofAs of Number of Total Handicapped handicappedDecember 31 agencies emloyes empl oyees employees1973 88 2,674,021 77,753 2.911974 78 2,722,343 76,627 2.811975 77 2,730,342 74,400 2.721976 78 2,625,667 73,457 2.80The 1973 data was the first attempt to report all han-dicapped employees, and there was considerable confusion asto whom to report. Consequently, CSC believes the 1973 datamight not be comparable to data for later times.

17

In 1974, GAO, recognizing the need for reliablestatistics, recommended a Government-wide survey. CSCresisted because it feared that "to significant numbers ofpersons, this survey would be viewed as an affront. Stillothers would be seriously concerned about the invasion oftheir right to privacy." CSC foresaw a "high probability ofinaccuracy, inconsistency, and honest disagreement."

In 1977, as a result of the Interagency Committee onHandicapped Employees' recommendation, CSC restructuredits data collection procedures for handicapped employees.The new data was initially collected through a one-timeGovernment-wide self-identification survey and will beupdated with new accessions and separations to reflectchanges. Agencies were instructed to emphasize that thesurvey was strictly voluntary and employees were to bemade fully aware that the information would not be usedagainst them in any way.

The number of handicapped employees amounted to2.80 percent of the work force in December 1976 and jumpedto 6.64 percent in March 1977.

Not identified, Percentage ofTotal Handicapped available, or handicapped

employees employees specified employees

3/31/77 2,121,786 140,808 513,530 6.64

The increased percentage reflected the broadened defi-nition of handicapping conditions under the RehabilitationAct and the new self-identification procedures. Whetherthe number and types of handicapped employees included inearlier surveys increased or nit is unknown.

The Office of Selective Placement believes the surveywas a "good data collection effort." It plans to purifythe data somewhat by followup with agencies having a highpercentage of employees who did not respond to the question-naire. CSC does not feel, however, it has the resources orauthority to completely validate the data through an auditor other evaluation technique. The issue is further com-plicated by the Privacy Act (5 U.S.C. 552a (1976)) and thesensitivity of employees.

The data base is updated with new accessions or sepa-rations. CSC plans to use the data in the future to measure

18

program results. New hires, employee mobility, advancement,training, retention, and other aspects of employment willbe analyzed. However, because time is needed to developthe computer program, purify the data, and establish trends,CSC does not foresee full use of the data system to providethese statistical analyses for several years.

Cursory review of the unedited data discloses thatalmost 25 percent of the total work force covered wereeither not identified, rnot available, or otherwise unspeci-fied. In two agencies this figure was as high as 60 per-cent. Many handicapped and nonhandicapped employees wereoffended by the survey and felt it was "none of manage-ment's business." Some entire work sections are said tohave indicated a particular handicap. The survey wasalso based on an individual's perception of his physicalcondition. thus, some handicapped persons indicated nodisability while others who may have had slight impair-ments identified themselves as being handicapped. Accord-ing to some agency coordinators, handicapped persons didnot want to identify themselves for fear of discriminationor for personal reasons. For example, one blind employeevery concerned with handicapped activities did not consi-der himself handicapped in performing his job so he chosenot to identify himself.

ATTITUDINAL BARRIERS

A difficult problem to deal with is the attitude ofnonhandicapped people who look at handicapped individuals'disabilities rather than abilities. Attitudinal barriersare very complex encompassing pity, paternalism, fear ordiscomfort around handicapped persons, lack of knowledge,and the general attitude that disabled persons are "dif-ferent."

Ironically, program effectiveness is also hampered bythe attitude of the handicapped population itself. Manyhandicapped individuals do not want to be singled out orhave attention drawn to them, as evidenced by resistance tothe self-identification survey. Even the "OutstandingHandicapped Federal Employee of the Year" program, which wasestablished in 1968 to focus attention on the capabilitiesand contributions of handicapped employees and to publicizecareer opportunities, is viewed distastefully by some em-ployees as fostering separateness and inequality. In oneagency, a frequently heard complaint wp? that the awardsingles out the disabled as members of a minority groupand it applies negative connotations.

19

ARCHITECTURAL BARRIERS

In July 1975, GAO issued a comprehensive report 1/identifying numerous problems hampering the removal ofarchitectural barriers in public buildings. In April 1977a congressional panel 2/ found that existing public laws forbarrier free buildings were inadequately enforced. We didnot further address these problems, but we did learn thatthe General Services Administration has accelerated itsremodeling program to provide "essential access" which in-cludes modifying entrances, restrooms, fountains, and tele-phones. The completion date was moved forward from 1981 tothe end of 1979.

SELECTIVE PLACEMENTVS. EQUAL OPPORTUNITY

The Federal Government has been involved in combatingemployment discrimination since 1940 when PresidentRoosevelt issued the first order prohibiting discriminationby Government agencies. Historically, the Selective Place-ment Program, concerned primarily with hiring, placing, andand advancing handicapped individuals, has not received theresources and attention that programs for other groups suchas women and minorities have enjoyed. While most of the1,800 selective placement coordinators spend less than 10percent of their time on the handicap program, over 12,000staff-years, including 3,151 full-time employees, are de-voted to other groups' activities. Their programs includecomplaint investigation and conciliation, upward mobilityand program direction, and research.

CIVIL RIGHTS AFFORDEDOTHER GROUPS

Handicapped 'ndividuals are not afforded the same civilrights that other groups enjoy. They are not entitled toattorney's fees for successful litigation, back pay for ap-plicants who successfully challenge discrimination practices,or certain rights pertaining to review in Federal courts.

l/"Further Action Needed to Make All Public BuildingsAccessible to the Physically Handicapped" (FPCD-75-166,July 15, 1975).

2/Report of the Panel on Research Program to Aid the Handi-capped to the Committee on Science and Technology, U.S.House of Representatives, April 1977.

20

Back pay for applicants

While the recently implemented complaint procedureallows for back pay for employees who bring a successfulcomplaint of discrimination, it does not apply to appli-cants. CSC does not have the legal authority to do thisfor applicants complaining of handicap discrimination,although it does have such authority for complaints undertitle VII of the Civil Rights Act of 1964, as camended, in-volving discrimination on the basis of race, color,religion, sex or national origin.

Review in Federal courts

Once an agency makes an adverse decision in a handicapdiscrimination case, the complainant may appeal that deci-sion under the Federal Administrative Procedure Act. Undertitle VIT, complainants may proceed into Federal Court ifthey have not received a final decision 180 days after acomplaint was filed. However, discrimination based on handi-capping condition is not included under the Civil Rights Act;thus, handicapped complainants cannot proceed into FederalCourt until all administrative procedures have been con-cluded. In some cases, this could take years because theadministrative procedures are complicated and time consumingand the complaint system is backlogged.

Another issue involves the standard of review inFederal court. The U.S. Supreme Court 1/ has held thatpersons complaining of discrimination based on race, sex,religion, color, or national origin under title VII areentitled to a new trial or a trial from the beginning.Since handicapping condition was not included in the deci-sion, handicapped complainants under the Federal Administra-tive Procedure Act would be restricted to review of the admin-istrative record and the complainant would have to show thatthe agency decision was "arbitrary, capricious or an abuseof discretion or otherwise not in accordance with the law"or "unsupported by substantial evidence."

Attorneys' fees

Since handicapped persons are not covered under the CivilRights Attorneys' Fees Award Act of 1976 (42 U.S.C. 1981 note,1988), they are not entitled to attorneys' fees if the decision

1/Chandler v. Roudebush, 425 U.S. 840 (1976).

21

is made in their favor. Thus, the litigation costs must betotally borne by the complainant. This situation may dis-courage or thwart actions which otherwise may be taken if thecomplainant had the same rights afforded other groups. 1/

EQUAL EMPLOYMENT OPPORTUNITYCOMMISSION

As stated earlier, under the recently accepted Reorgani-zation Plan No. 1, overall responsibility for equal employ-ment opportunity programs and the handicapped program willbe transferred from CSC to EEOC.

The report accompanying the plan recognized that EEOChas had serious problems in the past including poor manage-ment, lack of adequate staff training, excessive delays inprocessing charges, and failure to address systemic discri-mination. Advocacy groups have pointed out EEOC has a pooremployment record for handicapped *mployees, 0.04 percent 2/compared to the overall Government average of 6.64 percent.Such architectural barriers as inaccessible entrances, bath-rooms, telephone booths, and drinking fountains also makethe EEOC building an undesirable working place for handi-capped individuals. In addition EEOC did not submit anapproved affirmative action plan for 1978.

RESEARCH AND TECHNOLOGY

The April 1977 congressional panel issued a report tothe House Committee on Science and Technology addressingproblems in research programs for the handicapped public.The panel concluded that present research efforts by theGovernment and private enterprise are miniscule and ex-tremely fragmented with little or no coordination c£direction. Compounding the problem is the fact that theresults of such research are often unavailable to thehandicapped public. Among other things, the panel foundthat emphasis was being placed on high technological solu-tions and complex devices, particularly for severely handi-

1/On May 16, 1978, the House of Representatives passedH.R. 12467 which amends the Rehabilitation Act of 1973to allow for attorneys' fees awards to successful com-plainants.

2/Only one handicapped employee was identified in aMarch 1977 survey.

22

capped persons' employment prospects in both the public andprivate sectors.

Handicapped people can perform many jobs if simple jobmodifications are made or assistive devices are provided.The Job Development Laboratory at George Washington Univer-sity has demonstrated the success of this approach. TheLaboratory's primary function is to design inexpensive andsimple devices to help handicapped persons obtain and re-tain jobs. In a recent program, the Laboratory placed 80individuals in Government and private jobs. The averagecost to modify the job site or provide assistive deviceswas only $153, and the time needed to develop the neededdevices was 2 hours. For example, a 41-year-old man withcerebral palsy who had a master's degree in sociology couldnot get a job. By purchasing a microfilm reader so hewould not have to handle pages of source documents, theLaboratory found him a job as a locator with a Governmentagency. After about 18 months, the man was promoted to ajob classification specialist.

The Director of the Job Development Laboratory believesthe greatest hindrance to better use of assistive devices isthe lack of centralized or coordinated effort by research-ers. He stated, however, that researchers are becomingaware of the problems and recognize the need for a central-ized data bank. He added that, in his dealings with Fed-eral selective placement coordinators, he found a generallack of knowledge of technological developments, and hefelt that coordinators should be better educated as to theneeds of handicapped people and what equipment was avail-able. He believed part of the problem was the limitedtime (less than 10 percent) spent by the coordinator onselective placement.

We found no one in the Federal Government responsiblefor ensuring that the Government takes advantage of techno-logical advances and no one with the technical expertise toduplicate the successes of the Job Development Laboratory.The program managers in the Office of Selective Placementwere aware of some technological developments and one man-ager was assigned to keep abreast of the technology, butshe did not consider herself by any means an expert. Sincethere is no focal point in either private industry or in

23

the Government, agency selective placement coordinators areleft to their own means to modify or restructure work-sites. 1/

OTHER CONCERNS OF ADVOCACYGROUPS

Recognizing that beneficial changes are being made,advocacy groups are still concerned with certain problemareas. These groups strongly advocate that the physicalrequirements spelled out for each job classification inthe Qualifications Standards Handbook (X118) be revised.The standard paragraphs used for many positions have notbeen revised since 1961 and could unnecessarily precludehandicapped applicants. For instance, the standard para-graph setting the physical requirements for the managementanalysis series reads:

"Good distant vision in one eye and ability toread without strain printed material the sizeof typewritten characters are required, glassespermitted. Ability to hear the conversationalvoice, with or without a hearing aid. In mostinstances, an amputation of arm, hand, leg, orfoot will not disqualify an applicant forappointment, although it may be necessary thatthis condition be compensated by use of satis-factory prosthesis."

By this standard neither blind nor deaf persons couldbe employed for jobs for which primary requirements are agood "analytical ability and a practical and theoreticalknowledge of the functions, processes, and principles ofmanagement." The same paragraph applies to the entirebiological sciences group--a discipline which is oftenperformed in a laboratory environment where deaf personscould work quite effectively.

CSC is now reviewing the physical standards to avoidunnecessarily precluding qualified handicapped individuals.

Advocacy groups have suggested that:

L/H.R. 12457 passed by the House of Representatives onMay 16, 1978, includes extensive provisions for promotingand coordinating rehabilitation research and programs.

24

-- Preemployment medical exanrnations for certain jobsmay unnecessarily preclude qualified handicappedapplicants from obtaining a job.

-- The complaints procedures which became effective onApril 10, 1978, be made retroactive to the date ofthe Rehabilitation Act, September 26, 1973. CSC,after reviewing the issue from an administrativestandpoint, determined it was not feasible to recon-struct circumstances that far back but did compromiseby making the procedures retroactive for 1 year priorto implementation.

-- CSC increase public awareness by more widely dissem-inating information and regulations concerning therights of handicapped individuals and the responsi-bilities of the Federal Government to employ theseindividuals.

25

CHAPTER 4

CONCLUSIONS AND RECOMMENDATIONS

Employment opportunities for handicapped persons inboth private industry and the Federal sector should improvewith the effects of the Rehabilitation Act and the increas-ing demands for rights for handicapped people. Changesresulting from the President's Reorganization Plan No. 1,the CSC's proposed Special Emphasis Program, and the newlyestablished complaints procedures along with other changes,such as providing training and adapting employment tests,should improve opportunities.

Problems still exist, many of which are complex andhave no simple or immediate solutions. Assessing past prog-ress is impossible because of unreliable statistics,changes in data collection methods, and expanded defini-tions of handicapping condition. Measuring progress in thefuture may be difficult because data collection is inherentlyhampered by employee privacy rights and the sensitivity ofhandicapped employees.

The extent to which recent definitions of "handicappedindividual" and "reasonable accommodation" will complicatethe Government's program remains to be seen, and it is pos-sible that the terms will be clarified and refined onlythrough individual cases and court decisions.

Other problems, however, can be addressed through strongcommitment and affirmative action on the part of legislators,administrators, agency heads, agency coordinators, managers,and employees at all levels. Handicapped individuals shouldbe provided the same legal rights afforded other groups undertitle VII of the Civil Rights Act and the Civil Rights Attor-neys' Fees Awards Act. The agency coordinator system needs tobe strengthened; and attitudinal, architectural, and technolog-ical barriers must be removed so handicapped persons can befully integrated into the mainstream of employment.

RECOMMENDATIONS

These problems require a strong and effective approachby the agency having overall responsibility for the Govern-ment's program. Under the recently accepted ReorganizationPlan No. 1 of 1978, all enforcement and other functions re-lating to Federal employment of handicapped individuals areexpected to be transferred along with other equal employmentopportunity programs from CSC to EEOC. We recommend that, inimplementing these new responsibilities, the Chair, EEOC

26

-- take a more positive and directive role toward thehandicapped program than the advisory role assumed byCSC,

-- conduct indepth compliance reviews aimed at assess-ing agency accomplishments and commitments towardstated goals,

-- work closely with CSC and agency personnel offices toensure that their personnel policies and procedurescarry out the overall goals of the programs for handi-capped individuals.

-- ensure that selective placement coordinators aregiven sufficient time, training, and resources tocarry on a successful program,

--develop the capability and staff resources to providemore technical assistance, particularly relating toresearch and development of assistive devices, jobrestructuring, site modifications, and accommoda-tions,

-- address attitudin.l barriers through an employee re-lations campaign aimed at dissolving misconceptionsabout handicapped people,

-- work closely with the General Services Administrati nto see that architectural barriers are removed asquickly as possible, and

-- see that the program for handicapped persons is notovershadowed by the more firmly established programsfor women and minorities.

RECOMMENDATION TOTHE CONGRESS

The Congress should enact legislation to give handicappedpersons the rights enjoyed by others under title VII and theCivil Rights Attorneys' Fees Awards Act of 1976. Theserights include back pay for applicants who successfullychallenge discrimination, attorneys' fees for successfullitigation, and the right to proceed to Federal courts witha new case if a complaint is tied up in administrative pro-cedures for more than 180 days.

27

APPENDIX I APPENDIX I

AGENCIES WHOSE SELECTIVE PLACEMENT

COORDINATORS WERE CONTACTED

Office of the Secretary of DefenseDepartment of CommerceDepartment of AgricultureDepartment of the InteriorDepartment of LaborDepartment of StateEnvironmental Protection AgencyFederal Communications CommissionGeneral Services AdministrationInterstate Commerce CommissionVeterans Administration

28

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APPENDIX II APPENDIX II

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APPENDIX II APPENDIX II

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