This is the accessible text file for GAO report number GAO-11-81SP entitled 'Highlights of a Forum: Participant-Identified Leading Practices That Could Increase the Employment of Individuals with Disabilities in the Federal Workforce' which was released on October 5, 2010. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. 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Why GAO Convened This Forum: The Rehabilitation Act of 1973 (Rehabilitation Act) requires agencies to take proactive steps to provide equal opportunity to qualified individuals with disabilities, but their rate of employment with the federal government remains low. GAO was asked to identify barriers to the employment of people with disabilities in the federal workforce and leading practices that could be used to overcome these barriers. On July 20, 2010, GAO convened a forum to identify leading practices that federal agencies could implement within the current legislative context. In preparation for the forum, GAO surveyed a wide range of knowledgeable individuals to identify barriers and leading practices. Forum participants were selected from among respondents (or their representatives) to reflect varying expertise and views concerning the employment of individuals with disabilities. The survey results formed the basis for the initial forum agenda, and were refined by participants to focus on actions they deemed most important. Comments in this report do not necessarily represent the views of any individual participant or the organizations that these participants represent or with which they are affiliated, including GAO. What Participants Said: Participants said that the most significant barrier keeping people with disabilities from the workplace is attitudinal, which can include bias and low expectations for people with disabilities. According to participants, there is a fundamental need to change the attitudes of hiring managers, supervisors, coworkers, and prospective employees, and that cultural change within the agencies is critical to this effort. Participants identified practices that agencies could implement to help the federal government become a model employer for people with disabilities. Participants reached the following conclusions: 1. Top leadership commitment is key to implementing and sustaining improvements. Unless top agency officials are committed, improvements will not happen. 2. Accountability is critical to success; goals can help guide and sustain efforts and should be reflected in human capital and diversity strategy plans. 3. Regular surveying of the workforce on disability issues provides agencies with important information. Participants suggested that surveying be implemented at all stages of the employment life cycle. 4. Better coordination could help improve employment outcomes, as coordination within and across agencies is critical. 5. Training for staff at all levels can disseminate leading practices throughout the agency. This provides agencies the opportunity to communicate expectations regarding the implementation of policies and procedures related to improving employment of people with disabilities. 6. Career development opportunities inclusive of people with disabilities could facilitate advancement and increase retention. Participants suggested that agencies offer details, rotational assignments, and mentoring programs that are fully accessible to all employees. 7. A flexible work environment can increase and enhance employment opportunities for people with disabilities. Participants emphasized telework as a key component, as well as flexible work times and job sharing. 8. Centralizing funding at the agency level can help ensure that reasonable accommodations are provided. Participants stated that effective centralized funds should include accountability, flexibility, and universal availability. Although forum discussion focused on practices agencies could implement, participants also noted the need for model policies and guidance from the Equal Employment Opportunity Commission and the Office of Personnel Management (OPM). This is consistent with the July 2010 executive order that directs OPM to work with other agencies to design model recruitment and hiring strategies for individuals with disabilities. View [hyperlink, http://www.gao.gov/products/GAO-11-81SP] or key components. For more information, contact Laurie E. Ekstrand at (202) 512-6806 or ekstrandl@gao.gov. [End of section] Contents: Letter: Background: Overcoming Attitudinal and Other Barriers Requires a Comprehensive and Integrated Solution: Guidance from Oversight Agencies Can Assist Agencies in Implementing Leading Practices: Appendix I: Scope and Methodology: Appendix II: List of Forum Participants: Appendix III: GAO Contact and Staff Acknowledgments: [End of section] United States Government Accountability Office: Washington, DC 20548: October 5, 2010: The Honorable Daniel K. Akaka: Chairman: The Honorable George V. Voinovich: Ranking Member: Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia: Committee on Homeland Security and Governmental Affairs: United States Senate: Federal employees and applicants for employment with disabilities are protected from discrimination by the Rehabilitation Act of 1973 (Rehabilitation Act).[Footnote 1] Under the Rehabilitation Act, as amended, a person is considered to be disabled if the individual has a physical or mental impairment that substantially limits one or more major life activities, has a record of such impairment, or is regarded as having such impairment. The Rehabilitation Act further requires federal agencies to take proactive steps to provide equal opportunity to qualified individuals with disabilities in all aspects of federal employment. To further encourage the employment of people with disabilities, two executive orders were signed in 2000, including one calling for the hiring of 100,000 more employees with disabilities in the federal workforce.[Footnote 2] However, even with existing federal provisions, concerns have been raised about the low level of employment of people with disabilities in the federal workforce. You requested that we identify barriers to the employment of people with disabilities in the federal workforce and leading practices that could be used to overcome these barriers. As agreed with your offices, we convened a forum that consisted of a cross section of stakeholders and knowledgeable individuals on July 20, 2010, at GAO headquarters. (See appendix I for more details.) To ensure that we efficiently focused on the most important issues in a limited amount of time, prior to the forum we surveyed 55 individuals with subject matter or professional knowledge to solicit input and help identify barriers and leading practices. We received responses from 34 of these individuals. To select forum participants, we identified survey recipients representing a cross section of experiences and knowledge on issues related to the employment of individuals with disabilities. The 20 forum participants represented federal agencies that oversee and provide guidance and assistance on this issue and governmental and nongovernmental organizations, and others were individuals with extensive knowledge and experience in this area. Participants included those representing the viewpoints of employers and employees with disabilities. (See appendix II for a list of forum participants.) Participants discussed leading practices generated by the survey and prioritized the list during the first part of the forum. Participants then self-divided into three breakout groups based on subject matter-- recruiting and hiring, career development and retention, and provision of reasonable accommodations--to discuss the priority areas they identified.[Footnote 3] Each group's goal was to develop strategies that would not require legislative changes and that agencies could immediately begin implementing. Trained facilitators used a structured format to guide discussion around goals to be achieved; inputs, such as necessary resources; implementation steps; and evaluation criteria. Later, the breakout groups reported the results of their discussions to the entire panel, which was given a chance to react and provide additional input.[Footnote 4] We provided the draft report to participants for technical comments and incorporated their comments as appropriate. This report summarizes the ideas and themes that emerged at the forum and the collective discussion of participants. It reports more fully on those ideas that were substantively discussed by forum participants. Comments summarized in this report do not necessarily represent the views of any individual participant or of the organizations that these participants represent or are affiliated with, including GAO. We conducted our work from March 2010 to October 2010 in accordance with all sections of GAO's Quality Assurance Framework that are relevant to our objectives. The framework requires that we plan and perform the engagement to obtain sufficient, appropriate evidence to meet our stated objectives and to discuss any limitations in our work. We believe that the information and data obtained, and the analysis conducted, provide a reasonable basis for any findings and conclusions. Background: The 20th anniversary of the Americans with Disabilities Act (ADA), which prohibits discrimination against people with disabilities in private sector and state and local government employment, has renewed attention to the low employment rate of people with disabilities. [Footnote 5] In the federal executive branch, the Rehabilitation Act provides similar protection from employment discrimination as is provided under the ADA.[Footnote 6] Such protection from discrimination includes the requirement that employers provide reasonable accommodations for known physical or mental limitations of otherwise qualified individuals with disabilities, unless it results in undue hardship.[Footnote 7] An accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities. Unlike the ADA, the Rehabilitation Act also requires federal agencies to develop affirmative action program plans for hiring, placement, and advancement of people with disabilities. To help agencies carry out their responsibilities under the Rehabilitation Act, federal law also provides special hiring authorities for people with disabilities. These include Schedule A excepted service hiring authority for people with disabilities--which permits the noncompetitive appointment of individuals with intellectual disabilities, severe physical disabilities, or psychiatric disabilities[Footnote 8]--and appointments and noncompetitive conversion for veterans who are 30 percent or more disabled.[Footnote 9] If an employee or applicant reports a disability, a number of individuals or offices may provide support for the employee or applicant. These individuals include selective placement coordinators[Footnote 10] and other human capital staff, hiring officials, reasonable accommodations coordinators, information technology (IT) staff (if accommodations include technology), workers' compensation staff (if the employee is injured on the job), disability program managers (DPM),[Footnote 11] and other equal employment opportunity (EEO) staff. An employee's supervisors may also have a role in the process. Outside the agency, job placement professionals, such as vocational rehabilitation counselors, may help place individuals in an agency. In addition, the Department of Labor's (DOL) Job Accommodation Network (JAN) provides free consulting services for federal employers, including one-on-one consultation about workplace accommodations. The Department of Defense's (DOD) Computer/Electronic Accommodations Program (CAP) provides assistive technology and services to people with disabilities, federal managers, supervisors, and IT professionals across executive branch agencies.[Footnote 12] The Equal Employment Opportunity Commission (EEOC) and the Office of Personnel Management (OPM) play important roles in fostering fair, equitable, and inclusive workforces at federal agencies through their leadership and oversight.[Footnote 13] EEOC is responsible for providing agencies with policy guidance and standards for establishing and maintaining effective affirmative action programs under the Rehabilitation Act through its Management Directive 715 (MD-715), which also includes a framework for agencies to determine whether barriers to EEO exist and to identify and develop strategies to eliminate the barriers to participation. Under MD-715, EEOC requires agencies to report the results of their analyses annually. OPM is responsible for providing human resource advice and leadership to federal agencies, supports these agencies with human resource policies, holds agencies accountable for their human capital practices, and upholds the merit system principles that among other things prohibit discrimination in all aspects of federal employment.[Footnote 14] In doing so, OPM provides technical assistance regarding the employment of individuals with disabilities to agencies and applicants and assesses and reports on agencies' adherence to the merit system principles, veterans' preference, and other governmentwide standards. Other federal agencies also provide support roles in the federal employment of individuals with disabilities, including DOD, the Department of Education, the Social Security Administration, and the Department of Veterans Affairs. [Footnote 15] Despite federal laws and support systems, according to EEOC the percentage of individuals with targeted disabilities in the federal government has not increased since 1994.[Footnote 16] At a previous GAO forum held in March 2010 on actions that could increase work participation for adults with disabilities, participants stated that the federal government could do more to be a model employer of individuals with disabilities.[Footnote 17] In commemoration of the 20th anniversary of the ADA, the President signed an executive order stating that as the nation's largest employer, the federal government must become a model for the employment of individuals with disabilities.[Footnote 18] The executive order directs executive departments and agencies to improve their efforts to employ workers with disabilities through increased recruitment, hiring, and retention of these individuals. Overcoming Attitudinal and Other Barriers Requires a Comprehensive and Integrated Solution: At our July 2010 forum on employment of people with disabilities in the federal workforce, participants said that the most significant barrier keeping people with disabilities from the workplace is attitudinal. Attitudinal barriers can include bias against and low expectations for people with disabilities--a focus on disabilities rather than abilities. Participants also discussed other barriers, including physical barriers and lack of knowledge regarding policies and procedures. For example, participants said that there could be an erroneous belief that reasonable accommodations cannot be easily provided. Participants stated that there is a fundamental need to change the attitudes of hiring managers, supervisors, coworkers, and prospective employees, and that cultural change within the agencies is critical to this effort. They continued that the key to improving employment opportunities for individuals with disabilities is to eliminate bias and negative attitudes through education and showcasing examples of success in the workplace. Participants also stated that less attention is given to hiring people with disabilities than to other groups, such as minorities and women. They suggested that this disparity may exist because the disability rights movement is younger than other civil rights movements. Participants equated talking about best practices for employing people with disabilities today with talking about best practices for employing women in the 1950s. They stressed that hiring people with disabilities is a both a civil rights and an EEO issue. Participants acknowledged that there are many existing federal programs and policies to protect the employment rights of people with disabilities, but stated that efforts to protect these rights of people with disabilities will only make piecemeal progress until agencies change their workplace cultures. Participants stated that the leading practices they discussed during the forum would not work in isolation but instead need to reinforce each other. GAO has previously reported that all aspects of human capital are interrelated.[Footnote 19] The principles of effectively managing people are inseparable and must be treated as a whole. Human capital issues cannot be compartmentalized and dealt with in isolation from one another. Accordingly, participants concluded that overcoming these barriers would require a comprehensive solution that includes addressing attitudinal barriers in relation to each of the practices discussed during the forum. Participants Identified Eight Leading Practices That Could Improve Participation of People with Disabilities in the Federal Workforce: Participants prioritized the leading practices generated by the survey to identify steps that agencies could take to help the federal government become a model employer for people with disabilities.[Footnote 20] Participants agreed on eight leading practices that if implemented as a comprehensive solution can mitigate attitudinal and other barriers. Specifically, participants reached the following conclusions: 1. Top leadership commitment is key to implementing and sustaining improvements in the employment of individuals with disabilities. 2. Accountability is critical to success. 3. Regularly surveying the workforce on disability issues provides agencies with important information on potential barriers. 4. Better coordination could improve workforce outcomes for employees with disabilities. 5. Training for staff at all levels can disseminate leading practices throughout the agency. 6. Career development opportunities inclusive of people with disabilities can facilitate advancement and increase retention. 7. A flexible work environment can increase and enhance employment opportunities for individuals with disabilities. 8. Centralizing funding can help ensure that reasonable accommodations are provided. Top Leadership Commitment Is Key to Implementing and Sustaining Improvements in the Employment of Individuals with Disabilities: Participants emphasized that involvement of top agency leadership is necessary to overcome the resistance to change that agencies could face when mitigating attitudinal barriers. As we have previously reported, perhaps the single most important element of successful management improvement initiatives is the demonstrated commitment of top leaders to change.[Footnote 21] Participants added that unless top agency officials are committed to improvements, they will not happen. Participants stated that agency leaders should make communicating new policies to enhance the employment of people with disabilities a priority and could demonstrate that commitment on their agency intranet and public Web sites. This is consistent with our prior work showing that communication of commitment from senior management throughout the organization sends a clear message to others in the organization about the seriousness and business relevance of diversity management.[Footnote 22] Participants' suggestions on this practice are consistent with EEOC's MD-715, which requires, as one of the six elements of a model EEO program, that agency officials demonstrate commitment to equality of opportunity for all employees and applicants for employment.[Footnote 23] According to MD-715, leadership must take measures necessary to incorporate the principles of EEO into the agency's organizational structure, including disseminating a written policy statement to all employees expressing leadership's commitment to EEO and a workplace free of discriminatory harassment at the beginning of their tenure and thereafter on an annual basis. MD-715 states that even the best workplace policies and procedures will fail if they are not trusted, respected, and vigorously enforced. Accountability Is Critical to Success: Participants reported that accountability is critical to ensuring the success of an agency's efforts to implement leading practices and improve the employment of individuals with disabilities. Participants stated that agencies should enact policies and processes to ensure both individual and institutional accountability. To ensure accountability, participants discussed the importance of setting goals, determining measures to assess progress toward goals, evaluating staff and agencies to hold them responsible, and reporting results publicly. Participants concluded that what gets measured gets done. Participants also discussed the need to incorporate findings from evaluations into policies and practice. Well-reasoned goals can help guide and sustain an agency's efforts and resources to improve employment of people with disabilities. As participants stated, agencies should set goals that cover the employment life cycle from recruitment and hiring through retention, return to work, and advancement of individuals with disabilities. They suggested that agencies establish timetables for implementing these goals. Participants emphasized linking organizational goals to performance measures. As we have previously reported, this can create powerful incentives to influence organizational and individual behavior. [Footnote 24] These goals should be reflected in agencies' human capital and diversity strategic plans. Further, participants suggested that agencies evaluate their progress toward achieving these goals using both process measures and outcome measures. Process measures assess the extent to which a program is operating as it was intended. For example, an agency could assess the extent to which it met interim milestones for program implementation. Outcome measures assess the extent to which a program achieves its outcome-oriented objectives, or the effectiveness of the program. We have previously reported that workforce outcomes could include wages and job retention information, which could indicate whether services were effective.[Footnote 25] To avoid duplication of efforts, participants suggested that agencies should use measures they are already required to collect, where possible. For example, EEOC's MD-715 requires agencies to collect data by disability status on applicants, new hires, promotions, awards, separations, and grade level. In addition, participants noted that agencies can gather information on employee satisfaction and related topics through employee surveys, which are discussed later in this report. To hold individuals accountable, participants suggested that agencies should link agencywide strategic goals and metrics with individual performance goals and measures.[Footnote 26] Agencies can use tools, such as individual performance plans that document each staff member's role as well as how to assess performance in that role. Such tools can help set agencywide expectations and align individual performance expectations with agencywide goals.[Footnote 27] Participants stated that agencies can increase institutional accountability by making their goals and results public. Participants suggested that publicly reporting results could make agencies more proactive about increasing employment of individuals with disabilities. For example, participants suggested that agencies could post their MD-715 reports on their external Web sites. This would be similar to the requirement in the Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002 that calls for federal agencies to post statistical data on EEO complaints filed by their current and former employees or applicants for employment.[Footnote 28] Regularly Surveying the Workforce on Disability Issues Provides Agencies with Important Information on Potential Barriers: According to participants, having more information about employees with disabilities is part of a comprehensive solution to increasing the number of people with disabilities in the federal workforce. To collect this information, participants suggested that agencies survey their workforces on disability issues at least annually. Participants suggested that agencies should survey their workforces at all stages of the employment life cycle. Questions related to disability status should be included on employee feedback surveys and in exit interviews, including those for employees with disabilities who are leaving the agency.[Footnote 29] Participants suggested that agencies should also encourage employees to update their disability status. These suggestions are consistent with EEOC guidance on MD-715, which lists employee surveys and exit interviews as sources agencies should use to identify potential barriers to employment for people with disabilities. Further information on these suggestions follows. Employee feedback surveys and focus groups: Participants suggested that agencies include questions related to disability on employee feedback surveys as a way to provide an agency with information on the effectiveness of the reasonable accommodations process and the extent to which employees with disabilities find the workplace environment friendly.[Footnote 30] Participants discussed the need to have someone accountable for administering the surveys and stated that agencies should pretest survey questions with a diverse group of employees, including some with disabilities, in order to develop meaningful questions. Participants also noted that agencies should have a process for analyzing the results of these surveys and creating action plans for implementing needed changes. Participants agreed that there is a need to ensure confidentiality of survey responses and noted that hiring an outside contractor to administer surveys might be one way to do so. This may help ensure that people with disabilities are comfortable expressing their opinions regarding their agencies' policies, practices, and procedures. Another way to do this could be aggregating responses so that none of the respondents could be identified.[Footnote 31] Participants also stated that focus groups could provide an alternative method for agencies to obtain information on the work experiences of employees with disabilities. While it may be difficult to ensure confidentiality, since individuals participate in a group, this method might be used to identify strengths, weaknesses, and needed improvements particular to a program, such as the reasonable accommodations process. For smaller organizations, participants suggested that an agency could bring in a third party to interview people periodically to learn about the individual experiences instead of conducting an agencywide survey. Updating disability status: Participants stated that agencies could invite employees to update their disability status through the Standard Form 256 (SF-256), Self-Identification of Handicap. This optional form offers federal employees the opportunity to report any disabilities they may have.[Footnote 32] Participants stressed that encouraging employees to regularly update their SF-256s would allow the agency to be aware of any employees who acquire a disability after they have been hired as well as those who originally chose not to fill out the form but were willing to update their status at a later date. Some agencies have resurveyed their workforces as part of a larger effort to ask employees to verify human capital data on a number of issues, including race, national origin, and benefit information. This helps agencies ensure that they have the most accurate information needed for human capital management. It also facilitates compliance with MD-715, which instructs agencies to maintain accurate information on employees' disability status and to periodically resurvey their workforces. Participants noted that agencies must ensure that responses are appropriately protected so that employees feel safe in disclosing their status.[Footnote 33] Exit interviews: Participants also suggested that exit interviews of employees would provide agencies an opportunity to learn about employees' perceptions of the work environment, reasonable accommodations process, and other factors. As we previously reported, collecting data on attrition rates and the reasons for attrition are important to workforce planning, and one approach to collecting such data is through exit surveys.[Footnote 34] In general, exit surveys request demographic information, type of separation (e.g., voluntary, involuntary, retirement, etc.), reason for leaving, and future intentions for employment. Participants agreed that some agencies do not have standardized exit interviews, which could pose a barrier to implementing this practice. Better Coordination Could Improve Outcomes for Employees with Disabilities: Participants stated that better coordination of roles and responsibilities related to the employment of people with disabilities within and across agencies is critical to improving federal workforce outcomes. Within an agency, participants stated, responsibilities related to employment of individuals with disabilities are often dispersed among departments, such as the civil rights/EEO office, the human capital office, the office of workers' compensation, the IT department, and others. When agencies decentralize responsibilities without careful coordination, they can create barriers to hiring, providing reasonable accommodations, evaluating results of agency efforts, and other processes. Participants stated that a lack of coordination can be a barrier, particularly, for example, if one party defers action, thinking that it is someone else's responsibility. Forum participants also emphasized that better coordination across agencies can help to more effectively address barriers to individuals with disabilities seeking and maintaining federal employment. DOD's CAP and DOL's JAN were specifically mentioned as resources that federal agencies could draw on to potentially reduce duplication and take advantage of economies of scale. We have previously reported that an agency can face major obstacles when implementing comprehensive, successful, and timely interventions if responsibility for crucial supports and services is spread across various agencies.[Footnote 35] For example, in 2005, we identified over 20 federal agencies and almost 200 federal programs that provided a wide range of assistance to individuals with disabilities, such as employment-related services, medical care, and monetary support.[Footnote 36] These programs often have different missions, goals, funding streams, eligibility criteria, and policies that sometimes work at cross-purposes with other federal programs. Training for Staff at All Levels Can Disseminate Leading Practices throughout the Agency: Participants stated that training for all personnel can provide agencies the opportunity to communicate expectations regarding the implementation of policies and procedures related to improving employment of people with disabilities. We have previously identified training as an important strategic human capital practice that empowers and involves employees.[Footnote 37] Participants stated that agencies must involve people with disabilities in designing training programs and, as much as possible, in conducting the training. Participants suggested that agencies implement training on (1) hiring policies and processes, (2) reasonable accommodations policies and processes, and (3) diversity awareness. Hiring: Participants agreed that agencies need to provide training on issues related to hiring individuals with disabilities. Training should be provided to all individuals involved in and affected by the hiring process, including hiring managers, human capital staff, selective placement coordinators, disability hiring managers, and job placement professionals. This should include training on Schedule A, student employment programs, disabled veterans' hiring authorities, and the competitive process. Participants stated that training should also cover legal rights and responsibilities related to hiring individuals with disabilities. Providing training to everyone involved with and affected by the process would provide a consistent message across the agency and help build support for improving the employment of people with disabilities. Participants also noted that this training may increase hiring managers' sensitivity to disability issues as well as improve and increase usage of Schedule A and other hiring authorities. Participants suggested that agencies reach out to applicants and provide information to them on the same issues, noting that increasing applicants' knowledge about the hiring process could increase their employment opportunities. Participants noted one agency that provides training on the application and hiring process at job fairs to applicants with disabilities and suggested that others might implement a similar approach. Reasonable accommodations: Participants also stated that agencies need to provide training on employees' right to reasonable accommodations and the process for providing these accommodations. Such training should be provided to all staff but should be tailored for the audience; training for human capital staff, supervisors, and IT staff should be different than training for all staff. This training would help ensure compliance with reasonable accommodations processes and policies, correct myths or misconceptions, and increase sensitivity to disability issues. Participants noted that this training should cover the process for providing reasonable accommodations to individuals who are temporarily disabled as well as those whose disabilities are permanent. Participants stated that training should emphasize that reasonable accommodations take many forms, involve an interactive process between the employee and the employer, and are determined on a case-by-case basis. Participants noted that some agencies are currently providing higher-quality training on reasonable accommodations processes than other agencies and called for increased consistency across agencies. Diversity awareness: Participants stated that disability issues must be included in diversity awareness training. Such training should include a rights and responsibilities component since, as participants noted, inclusion of employees with disabilities is a matter of law, not choice. In addition, participants stated that this training should be a component of core training that all employees receive at the beginning of their tenure with an agency and throughout their careers at the agency. However, participants emphasized that training courses alone were not sufficient to overcome attitudinal barriers. Career Development Opportunities That Include People with Disabilities Could Facilitate Advancement and Increase Retention: Participants discussed a range of career development opportunities that agencies could offer to help improve the workforce outcomes of employees with disabilities. They suggested that agencies offer details, rotational assignments, and mentoring programs at all stages of the employment life cycle. Participants noted that career development opportunities could lead to increased retention and improved employee satisfaction.[Footnote 38] Participants discussed the importance of career development efforts and stated that agencies need to ensure that career development opportunities are fully accessible to all employees. For example, participants noted that certain core training required for employees newly promoted to the Senior Executive Service is often held off-site, which limits the participation of some employees who require reasonable accommodations. Participants stated that these training sites should be accessible, and reasonable accommodations should be provided at training sites as well as at the workplace. Participants agreed that when possible and appropriate, agencies should centralize the operation of career development opportunities, but they recognized that this would not always be possible and that sometimes these opportunities would instead occur at the team level. Participants also suggested that agencies publicize career development opportunities on their internal and external Web sites. They discussed potential barriers to implementation, noting that small agencies might lack the capacity to create and implement these programs. A Flexible Work Environment Can Increase and Enhance Employment Opportunities for Individuals with Disabilities: Participants stated that a flexible work environment can help increase and enhance employment opportunities of individuals with disabilities. Participants suggested that the benefits of flexible work hours, telework, and other types of reasonable accommodations could result in cost savings for an agency. Participants emphasized telework--where an employee performs assigned duties at home or an alternative location--as a key component of a flexible work environment, but noted that flexible work times and job sharing are also important. According to OPM, telework is valuable for the recruitment and retention of employees regardless of disability status.[Footnote 39] In addition, we have previously testified that telework is increasingly recognized as an important means to achieving a number of federal efforts, including effective strategic human capital management of the federal workforce.[Footnote 40] Participants noted the benefits of telework and related flexibilities for increasing the employment of individuals with disabilities.[Footnote 41] To effectively implement telework and other flexibilities for employees with disabilities, participants stated that it is critical to provide assistive technology for employees at their homes. For example, CAP reports that it will provide computer and assistive devices for use at home. Participants also expressed concern that people who become unable to perform job duties because of health conditions that developed during the course of their employment are often overlooked. As we have previously reported, while some health conditions may be too severe to allow for continued employment, research shows that with appropriate and tailored supports--such as a wheelchair, a flexible work schedule, or text-reading software--some individuals with disabilities can successfully function in the work environment.[Footnote 42] Participants agreed that it is important for workers to know that a flexible workplace, including telework options, is available to facilitate their return to work. Centralizing Funding Can Help Ensure That Reasonable Accommodations Are Provided: Participants stated that a perceived "lack of funding should never be the reason why reasonable accommodation does not occur." Participants noted that managers may be reluctant to provide reasonable accommodations out of their departmental or operational budgets because managers may have incorrect perceptions of the costs of reasonable accommodations. Participants suggested that agencies should centralize the budget for reasonable accommodations at the highest level of the agency to ensure that employees with disabilities have access to the reasonable accommodations to which they are legally entitled. These suggestions were consistent with the July 2010 executive order that directs OPM, in consultation with DOL and EEOC, to assist agencies in implementing the use of centralized funds to provide reasonable accommodations.[Footnote 43] Participants also emphasized that a centralized fund is essential because DOD's CAP, which provides assistive technology to its federal agency partners, only covers some types of reasonable accommodations. Participants said that an effective centralized fund should be designed to include accountability, flexibility, and universal availability. They also stated that all individuals involved in providing the reasonable accommodation should be held accountable. For example, although the fund would be centralized, first-line managers and supervisors must still be held accountable for their part in ensuring that their staff members receive reasonable accommodations. As participants noted, the fund should be flexible enough to cover a broad range of reasonable accommodations, such as personal assistants during work or training. They also reported that funds should be universally available to accommodate staff regardless of staff level, position, or location. Participants further noted that these centralized funds should be available to field offices as well as headquarters. To facilitate implementation, participants stated that training on how the fund is used is essential. Guidance from Oversight Agencies Can Assist Agencies in Implementing Leading Practices: Participants agreed that increasing participation of individuals with disabilities in the federal workforce requires comprehensive and coordinated action from agency leadership, which is best facilitated by clear and consistent governmentwide guidance. For example, participants agreed that guidance from OPM and EEOC could help clarify implementing instructions for Schedule A and other hiring authority guidance. Participants recognized that OPM and EEOC currently provide technical assistance to agencies, but suggested that they develop additional model policies, procedures, and programs for agencies to follow. Participants' suggestions were consistent with the July 2010 executive order that directs OPM, in consultation with DOL, EEOC, and the Office of Management and Budget (OMB), to design model recruitment and hiring strategies for individuals with disabilities and develop mandatory training programs for human capital personnel and hiring managers on the employment of individuals with disabilities.[Footnote 44] The executive order also calls for OPM, in consultation with DOL and EEOC, to identify and assist agencies in implementing strategies for retaining federal workers with disabilities in federal employment, including, but not limited to, training, using centralized funds to provide reasonable accommodations, increasing access to appropriate accessible technologies, and ensuring the accessibility of physical and virtual work spaces. In addition, the order also directed each agency to work with OPM and OMB to establish its own plan for promoting the employment of individuals with disabilities and directed OPM to assist agencies with implementation of their plans. We will send copies of this report to interested parties. This report also is available at no charge on the GAO Web site at [hyperlink, http://www.gao.gov]. If you or your staff have questions about this report, please contact me at (202) 512-6806 or ekstrandl@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Staff who made major contributions are listed in appendix III. Signed by: Laurie E. Ekstrand: Director, Strategic Issues: [End of section] Appendix I: Scope and Methodology: To identify barriers to the federal employment of individuals with disabilities and leading practices that could overcome those barriers, we solicited the views of a wide range of knowledgeable individuals through a survey and forum. Based on a literature review and related GAO work, we identified a combination of leaders in the private and public sectors and employer and employee organizations as well as researchers with experience on issues related to employment of individuals with disabilities. We designed, pretested, and distributed the survey with open-ended questions asking respondents to identify barriers and leading practices related to recruiting and hiring, retention, reasonable accommodations, and other issues related to the employment of individuals with disabilities in the federal workforce. We distributed 55 surveys and received 34 responses. We grouped similar responses and developed a list of potential leading practices, which was used as the initial list of topics for discussion at the forum. To select individuals to participate in the forum, we identified survey recipients representing a cross section of experiences and knowledge on issues related to the employment of individuals with disabilities. The 20 forum participants represented federal agencies that oversee and provide guidance and assistance on this issue and governmental and nongovernmental organizations, and others were individuals with extensive knowledge and experience in this area. Participants included those representing the viewpoints of employers and employees with disabilities. Two GAO officials responsible for equal employment opportunity and diversity issues, including employment of people with disabilities, participated in the forum. At the forum, participants initially discussed and prioritized leading practices generated by the survey for improving (1) recruitment and hiring, (2) career development and retention, and (3) the provision of reasonable accommodations. Participants then divided into breakout groups, each discussing the priorities within each of the three respective subject areas. Each group's goal was to develop strategies that agencies could immediately begin to implement without legislative changes. Trained facilitators used a structured format to guide discussion around goals to be achieved; inputs, such as necessary resources; implementation steps; and evaluation criteria. At the end of the forum, the breakout groups reported the results of their discussions to the entire panel, which was given a chance to react and provide additional input. We also provided the draft report to participants for technical comments and incorporated their comments as appropriate. Forum discussions were documented through a combination of electronic recording and note taking. We analyzed this documentation to develop the information on the barriers to the employment of people with disabilities and the eight leading practices that agencies could implement to mitigate those barriers. This set of participants chose to discuss the topics that are included in this report. It is possible that other groups of knowledgeable individuals may have selected other topics or potential leading practices as subjects of discussion. In developing the contents of this report, we also referred to prior GAO work relating to the barriers and leading practices identified at the forum. Comments in this report do not necessarily represent the views of any individual participant or of the organizations that these participants represent or are affiliated with, including GAO. We conducted our work from March 2010 to October 2010 in accordance with all sections of GAO's Quality Assurance Framework that are relevant to our objectives. The framework requires that we plan and perform the engagement to obtain sufficient, appropriate evidence to meet our stated objectives and to discuss any limitations in our work. We believe that the information and data obtained, and the analysis conducted, provide a reasonable basis for any findings and conclusions. [End of section] Appendix II: List of Forum Participants: Participant: John Benison; Title and organization: Senior Advisor to the Deputy Director; Office of Personnel Management. Participant: Susanne M. Bruyère, Ph.D.; Title and organization: Associate Dean of Outreach and Director of Employment and Disability Institute; Cornell University ILR School. Participant: Dinah Cohen; Title and organization: Director, Computer/Electronic Accommodations Program; U.S. Department of Defense. Participant: Janet Fiore; Title and organization: Chief Executive Officer; The Sierra Group. Participant: Douglas Fitzgerald; Title and organization: Director, Division of Federal Employees' Compensation, Office of Workers' Compensation Programs; U.S. Department of Labor. Participant: Gary Goosman; Title and organization: Director, Tools on Work and Employment Readiness Initiative; U.S. Business Leadership Network. Participant: Shelby Hallmark; Title and organization: Director, Office of Workers' Compensation Programs; U.S. Department of Labor. Participant: Charma Haskins; Title and organization: Acting Supervisor of Rehabilitation Services, Vocational Rehabilitation and Employment Service; U.S. Department of Veterans Affairs. Participant: Gerrie Drake Hawkins, Ph.D.; Title and organization: Senior Program Analyst; National Council on Disability. Participant: Anne Hirsh; Title and organization: Co-Director, Job Accommodation Network; U.S. Department of Labor. Participant: Jo Linda Johnson; Title and organization: Director, Federal Training & Outreach Division; U.S. Equal Employment Opportunity Commission. Participant: Reginald E. Jones; Title and organization: Managing Director, Office of Opportunity and Inclusiveness; U.S. Government Accountability Office. Participant: Alison Levy; Title and organization: Program Manager, Selective Placement Program; U.S. Department of Transportation. Participant: Dylan Orr; Title and organization: Special Assistant, Office of Disability Employment Policy; U.S. Department of Labor. Participant: Jorge E. Ponce; Title and organization: Director, Policy and Evaluation Division; U.S. Department of Commerce. Participant: Robin Shaffert; Title and organization: Senior Director of Corporate Social Responsibility; American Association of People with Disabilities. Participant: Jennifer Sheehy; Title and organization: Director of Policy, Office of Special Education and Rehabilitative Services; U.S. Department of Education. Participant: Derek Shields; Title and organization: Project Director, Social Security Administration Ticket to Work Recruitment & Outreach; Cherry Engineering Support Services Incorporated, Division of Axiom. Participant: Marie Strahan; Title and organization: Chief of Staff, Office of Disability Employment Policy; U.S. Department of Labor. Participant: Carolyn Taylor; Title and organization: Special Assistant to the Acting Comptroller General for Diversity Issues; U.S. Government Accountability Office. Source: GAO. [End of table] [End of section] Appendix III: GAO Contact and Staff Acknowledgments: GAO Contact: Laurie Ekstrand, (202) 512-6806 or ekstrandl@gao.gov: Staff Acknowledgments: In addition to the contacts named above, the following individuals made key contributions to this report: Daniel Bertoni, Director; Patricia Owens, Director; Neil Pinney, Assistant Director; Crystal Bernard; Karin Fangman; Rachel Fichtenbaum; Robert Gebhart; Amanda Harris; Terry Richardson; Cynthia Saunders; Andrew Stavisky; Tamara Stenzel; and Gregory Wilmoth. We are grateful to the following individuals who provided assistance on the day of our forum: Shea Bader, Laurel Beedon, Megan Bourke, Susan Christiansen, Fran Davison, Shannon Finnegan, Janice Latimer, Margit Myers, Melanie Papasian, Justin Reed, Jessica Thomsen, Kan Wang, Jeff Wojcik, and Amy Zettle. [End of section] Footnotes: [1] Pub. L. No. 93-112, § 501, 87 Stat. 355, 390-391 (Sept. 26, 1973), codified at 29 U.S.C. §791. Section 508 of the Rehabilitation Act, as amended, also requires agencies to provide federal employees with disabilities access to information and data that is comparable to the access provided to federal employees without disabilities. See 29 U.S.C. § 794d. [2] Exec. Order No. 13163, Increasing the Opportunity for Individuals with Disabilities to be Employed in the Federal Government, 65 Fed. Reg. 46563 (July 26, 2000). A second executive order issued on the same day required agencies to establish effective written procedures for processing requests for reasonable accommodation. Exec. Order 13164, Requiring Federal Agencies to Establish Procedures to Facilitate the Provision of Reasonable Accommodation, 65 Fed. Reg. 46565 (July 26, 2000). [3] For the purposes of this report, "participants" refers to the entire forum or subgroups of forum participants. [4] This set of participants chose to discuss the topics that are included in this report. It is possible that other groups of knowledgeable individuals may have selected other topics or potential leading practices as subjects of discussion. [5] The ADA prohibits discrimination on the basis of disability in a number of other areas beyond employment, including public services, transportation, and accommodations. Title I of the ADA addresses employment discrimination. Pub. L. No. 101-336, 104 Stat. 327 (July 26, 1990). Title I is codified at 42 U.S.C. §§ 12111-12117. [6] The ADA and the Rehabilitation Act share a common definition of disability and standards in determining whether an employer engaged in prohibited discrimination. See 42 U.S.C. § 12102(1) and 29 U.S.C. § 705(9) and § 791(g). [7] 42 U.S.C. § 12111(10) and § 12112(b)(5) and 29 C.F.R. § 1614.203(b) and § 1630.9. [8] Under its authority to except positions from competitive examination requirements, the Office of Personnel Management has established several categories (or schedules) of excepted service positions. Schedule A authorizes a number of different excepted service appointments for positions that are not of a confidential or policy-determining character for which it is impractical to hold a competitive examination, including the appointment of attorneys and chaplains. 5 C.F.R. § 213.3102(a) and (d). Schedule A also includes the appointment (on a permanent, time-limited, or temporary basis) of individuals with mental retardation, severe physical disabilities, or psychiatric disabilities. 5 C.F.R. § 213.3102(u). [9] 5 U.S.C. § 3112 provides authority for the noncompetitive appointment and conversion to career employment of disabled veterans with compensable service-connected disabilities of 30 percent or more. [10] A selective placement coordinator may serve as the principal advisor on policy, strategic planning, and program and policy implementation relating to the full employment life cycles of persons with disabilities--including recruitment, hiring, advancement, and retention. [11] A DPM may, among other duties, be responsible for the development, implementation, and operation of an agency's disability program. DPMs may review, analyze, and evaluate policies, procedures, and practices that affect workers with disabilities by conducting periodic assessments and making recommendations regarding employment programs, outreach strategies, and internal programs for people with disabilities. [12] Other agencies also provide assistive technology and services to federal employees, for example, the Department of Agriculture's Target Center and the Library of Congress's Assistive Technology Demonstration Center. [13] GAO, Equal Employment Opportunity: Improved Coordination Needed between EEOC and OPM in Leading Federal Workplace EEO, [hyperlink, http://www.gao.gov/products/GAO-06-214] (Washington, D.C.: June 16, 2006). [14] Federal personnel management is to be implemented consistent with the merit system principles enumerated under 5 U.S.C. § 2301(b). [15] See GAO, Highlights of a Forum: Actions That Could Increase Work Participation for Adults with Disabilities, GAO-10-812SP (Washington, D.C.: July 2010). [16] United States Equal Employment Opportunity Commission, Annual Report to the Federal Workforce, Fiscal Year 2009, [hyperlink, http://www.eeoc.gov/federal/reports/fsp2009/index.cfm] (accessed Aug. 4, 2010). GAO has not verified the accuracy of the information contained in this report. [17] [hyperlink, http://www.gao.gov/products/GAO-10-812SP]. [18] Exec. Order No. 13548, Increasing Federal Employment of Individuals with Disabilities, 75 Fed. Reg. 45,039 (July 26, 2010). [19] GAO, Human Capital: A Self-Assessment Checklist for Agency Leaders, [hyperlink, http://www.gao.gov/products/GAO/OCG-00-14G] (Washington, D.C.: September 2000). [20] Neither the numbering nor ordering of the suggested practices reflects the frequency at which they were mentioned or their relative importance as derived from the forum participants and selection methodology. [21] GAO, Diversity Management: Expert-Identified Leading Practices and Agency Examples, [hyperlink, http://www.gao.gov/products/GAO-05-90] (Washington, D.C.: Jan. 14, 2005). In other reports, we have also reported that top leadership must play a critical role in creating and sustaining high-performing organizations as well as transforming the culture of organizations and ensuring that new visions and ways of doing business take root. See, for example, GAO, Managing for Results: Federal Managers' Views Show Need for Ensuring Top Leadership Skills, [hyperlink, http://www.gao.gov/products/GAO-01-127] (Washington, D.C.: Oct. 20, 2000); Management Reform: Using the Results Act and Quality Management to Improve Federal Performance, [hyperlink, http://www.gao.gov/products/GAO/T-GGD-99-151] (Washington, D.C.: July 29, 1999); and Management Reform: Elements of Successful Improvement Initiatives, [hyperlink, http://www.gao.gov/products/GAO/T-GGD-00-26] (Washington, D.C.: Oct. 15, 1999). [22] [hyperlink, http://www.gao.gov/products/GAO-05-90]. [23] MD-715 elements of a model EEO program are (1) demonstrated commitment from agency leadership, (2) integration of EEO into the agency's strategic mission, (3) management and program accountability, (4) proactive prevention of unlawful discrimination, (5) efficiency, and (6) responsiveness and legal compliance. [24] GAO, Executive Guide: Effectively Implementing the Government Performance and Results Act, [hyperlink, http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June 1996). [25] GAO, Veterans' Employment and Training Service: Flexibility and Accountability Needed to Improve Service to Veterans, [hyperlink, http://www.gao.gov/products/GAO-01-928] (Washington, D.C.: Sept. 12, 2001). [26] We have previously reported that accountability is a key element for organizations to ensure the success of a diversity management effort, as it provides a means for ensuring that managers at all levels are made responsible for diversity in their organizations and are evaluated on their progress toward achieving their diversity goals and their ability to manage a diverse group of employees. See [hyperlink, http://www.gao.gov/products/GAO-05-90]. [27] GAO, Results-Oriented Cultures: Insights for U.S. Agencies from Other Countries' Performance Management Initiatives, [hyperlink, http://www.gao.gov/products/GAO-02-862] (Washington, D.C.: Aug. 2, 2002). [28] Pub. L. No. 107-174, 116 Stat. 566 (May 15, 2002). [29] We have previously reported that regular employee input could help an agency identify potential barriers to EEO and could enhance the agency's efforts to acquire, develop, motivate, and retain talent that reflects all segments of society and our nation's diversity. GAO, Equal Employment Opportunity: DHS Has Opportunities to Better Identify and Address Barriers to EEO in Its Workforce, [hyperlink, http://www.gao.gov/products/GAO-09-639] (Washington, D.C.: Aug. 31, 2009). [30] This would include questions that would allow results to be sorted in relation to disability status. [31] Generally, results are not reported when there are too few responses to protect the identity of respondents through aggregation. [32] Completing the SF-256 is voluntary. [33] EEOC regulations require that all medical or disability-related information be kept confidential. Under these regulations, such information must be collected and maintained on forms kept in separate files and treated as confidential medical records. 29 C.F.R. § 1630.14(b)(1). [34] GAO, Homeland Security: DHS's Actions to Recruit and Retain Staff and Comply with the Vacancies Reform Act, [hyperlink, http://www.gao.gov/products/GAO-07-758] (Washington, D.C.: July 16, 2007). [35] [hyperlink, http://www.gao.gov/products/GAO-10-812SP]. [36] GAO, Federal Disability Programs: Coordination Could Facilitate Better Data Collection to Assess the Status of People with Disabilities, [hyperlink, http://www.gao.gov/products/GAO-08-872T] (Washington, D.C.: June 4, 2008). [37] GAO, Human Capital: Practices That Empowered and Involved Employees, [hyperlink, http://www.gao.gov/products/GAO-01-1070] (Washington, D.C.: Sept. 14, 2001). [38] We reported that mentoring can help new employees adjust to an organization's culture. It can also help identify and develop high- potential employees, improve employee productivity and performance, and promote retention and diversity. See [hyperlink, http://www.gao.gov/products/GAO-05-90]. [39] OPM has set a strategic goal to increase the number of eligible federal employees who telework by 50 percent from fiscal years 2009 through 2011. [40] GAO, Human Capital: Telework Programs Need Clear Goals and Reliable Data, [hyperlink, http://www.gao.gov/products/GAO-08-261T] (Washington, D.C.: Nov. 6, 2007). [41] Congress is currently considering two bills that would require agencies to set policies on telework and ensure that employees are not treated differently if they telework. See H.R. 1722 and S. 707, 111th Cong. (2010). [42] [hyperlink, http://www.gao.gov/products/GAO-10-812SP]. [43] Exec. Order No. 13548. [44] Exec. Order No. 13548. 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