Four-Step Approach to EEOC MD-715 EEO Programs

By: Keli Wilson

Government agencies annually prepare for the Equal Employment Opportunity Commission (EEOC) Management Directive 715 (MD-715) filing and undergo periodic self-assessments to identify barriers to equal employment opportunity. In addition to the EEOC MD-715, the Executive Order 14035 also directs the Federal Government to remove barriers to equal opportunity and role model efforts to increase diversity, equity, inclusion, and accessibility (DEIA) in the workforce and workplace.  

A barrier analysis is an important evaluation and provides useful insights for agencies to act on (e.g., highlight DEIA progress, identify organizational barriers). If you are new to conducting barrier analysis work or would like to understand other perspectives on this process, DCI offers a four-step approach as a framework. This framework can be adopted to diagnose root cause issues and prescribe evidence-based practices towards a more equitable workplace. 

  1. Identify a Labor Force Benchmark for Workforce Representation Comparison.
    To understand whether underrepresentation exists for any group of interest, an availability statistic representing people with requisite skills in a recruitable geographical location is a first step. Once this labor force benchmark is identified, for each job or analysis group, then a comparison between current workforce representation and labor force benchmark percentages may be performed. 
  2. Conduct Diversity Diagnostic Analytics.
    A variety of quantitative analysis approaches are available to leverage, pending what employment practice areas are of focus (e.g., employment applications, hiring decisions, promotions, attrition, professional development programs, pay and compensation.). For example, selection outcomes may be reviewed to understand if a protected group is being screened out at a disproportionate rate to other protected groups. A barrier, or flag, may be identified with statistical and practical significance thresholds. 
  3. Review Policies, Procedures, and Employee Perceptions.
    A qualitative study of policies, procedures, and practices is another method to understand systemic concerns or bias issues that can stem from misuse, misunderstanding, or lack of oversight. In addition, coupling this review with employee perceptions of fairness, experiences, and attitudes can provide invaluable first-hand information. 
  4. Develop a Roadmap of Change for Addressing Equal Opportunity Barriers.
    To mitigate risk and scrutiny, an action-oriented step should be based on legal decisions and judgments, as well as empirical research articles with evidence-based findings.
The underlying barrier, or root cause concern, to underrepresentation in the workforce can vary across agencies. Common themes identified in such studies include inconsistent selection practices, lack of transparency or understanding of policies, discretion with setting new hire salary or promotional increases, and no internal oversight or auditing procedures. In general, tying barriers to an action-oriented next step is an essential part of change management.  

As it gets closer to the February 28 filing deadline, stay connected with DCI for information on training and educational resources. 

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