Are you plugged into Management Directive (MD) 715?Manager’s Booklet

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Introduction

The Management Directive 715 (MD-715) is a roadmap to establishing and maintaining effective affirmative programs of equal employment opportunity (Model EEO Program). MD-715 requires agencies to take appropriate steps to ensure that all employment decisions are free from discrimination.

The MD-715 outlines six essential elements of a Model EEO Program: A) Demonstrated commitment from agency leadership, B) Integration of EEO into the agency’s strategic mission, C) Management and program accountability, D) Proactive prevention of unlawful discrimination, E) Efficiency, and F) Responsiveness and legal compliance.

Each year the MD-715 requires the agency to conduct a self-assessment. The self-assessment is used to identify strengths and weaknesses in the agencies EEO programs. Not only does the agency have to report weaknesses, it has to report plans to overcome those identified weaknesses. The agency is held accountable for its plans.

Bottom-line: Employees and managers are responsible for the creation of a Model EEO Program.

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A Message from the Assistant Administrator for Civil Rights and FAA Diversity Advocate...

August 2010

It is the standard mission of the Office of Civil Rights that the Federal Aviation Administration (FAA) develops and implements the essential elements of a model EEO program, as defined by the Equal Employment Opportunity Commission Management Directive 715 (MD-715). The MD-715 program is designed to identify and eliminate barriers in all aspects of employment, including management policies, procedures, and practices. We must fully utilize all employees’ talents without regard to race, color, sex, age, sexual orientation, religion, national origin, disability, genetic information, or reprisal for engaging in prior protected activity. This includes promoting an atmosphere where employment opportunities are open to all candidates.

The FAA EEO Program and the contents of this booklet strive to incorporate the principles of equal opportunity into our organizational structure and institutionalize the elements as standard business practice.

Equality of opportunity is essential to attracting, developing, and retaining the most skilled workforce. EEO is an integral part of making the FAA competitive and an employer of choice. We cannot attain this status without holding personnel, at all levels, accountable for modeling behavior that supports equal opportunity. We also cannot attain this status without identifying and removing all barriers to equal opportunity. Only then will the talents represented by a diverse workforce be fully utilized in support of the FAA’s strategic mission.

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Essential Element A: Demonstrated Commitment from Agency Leadership

Requires the Agency Leadership to issue written policy statements expressing commitment to EEO and a workplace free of discriminatory harassment.

Compliance Indicators• EEO policy statements are up-to-date.• EEO policy statements have been communicated to

all employees.• FAA EEO policy is vigorously enforced by management.

Outcomes• FAA’s EEO policies and procedures will be trusted

and respected.

Strategies• EEO must be:

- embraced by agency leadership; and- communicated through the ranks from the top down.

• EEO principles must be made a fundamental part of FAA’s culture.

• Agency leadership must issue annual EEO and anti-harassment policy statements.

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Essential Element B: Integration of EEO into the Agency’s Strategic Mission

Requires FAA’s EEO programs be organized and structured to maintain a workplace that is free from discrimination in any of the agency’s policies, procedures or practices, and supports the agency’s strategic mission.

Compliance Indicators• The reporting structure for the EEO Program provides the

Assistant Administrator for Civil Rights with appropriate authority and resources to effectively carry out a successful EEO Program.

• The Assistant Administrator for Civil Rights and other EEO specialists responsible for EEO programs have regular and effective means of informing the Administrator and senior management officials of the status of EEO Programs and are involved in, and consulted on, management/personnel actions.

• FAA has committed sufficient human resources and budget allocations to its EEO programs to ensure successful operation.

Outcomes• Senior leadership and employees are involved in the

implementation of the MD-715 and are aware of EEO.

Strategies• All senior leadership must be aware of their respective

Civil Rights Directors.• Assistant Administrator for Civil Rights must have regular

access to agency leadership and senior management and be involved in all major human resources decisions.

• Collaboration and responsibility for MD-715 between all Lines of Business and Staff Offices’ leadership.

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Strategies (cont.)• EEO programs have sufficient resources.• Managers and employees are involved in implementation

of the agency’s Title VII and Rehabilitation Act programs.

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Essential Element C: Management and Program Accountability

Requires the Agency Leadership to hold all managers, supervisors, and EEO Officials responsible for the effective implementation of the agency’s EEO Program.

Compliance Indicators• Civil Rights Directors advise and provide appropriate

assistance to managers/supervisors about the status of EEO Programs within their area of responsibility.

• The Assistant Administrator for Human Resource Management and the Assistant Administrator for Civil Rights meet regularly to assess whether personnel programs, policies, and procedures are in conformity with the FAA’s Model EEO Program, as well as EEOC regulations and management directives. [See 29 CFR § 1614.102(b)(3).]

• When findings of discrimination are made, the agency determines the appropriateness of taking disciplinary action.

Outcomes• FAA personnel policies, selection and promotion

procedures, evaluation procedures, rules of conduct, and training systems are fairly implemented.

• Establish and maintain a workplace that is free from discrimination in any of its management policies, practices or procedures.

• FAA answers “Yes” on the Annual Self-Assessment, indicating barriers are being eliminated.

• Hire, develop, and retain top-notch employees.

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Strategies• Conduct regular internal audits of the FAA’s Model EEO

Program to evaluate efficiency and effectiveness. The National Model EEO Program Office can assist you in this capacity (contact information on the back).

• Establish procedures to prevent all forms of discrimination.

• Evaluate managers and supervisors on efforts to ensure equality of employment opportunity.

• Maintain effective reasonable accommodation procedures.

• Maintain clearly defined and fair personnel policies, selection and promotion procedures, evaluation procedures, rules of conduct and training systems.

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Essential Element D: Proactive Prevention

Requires the Agency Leadership makes early efforts to prevent discriminatory actions and eliminate barriers to equal employment opportunity in the workplace.

Compliance Indicators• Analyses to identify and remove unnecessary barriers to

employment are conducted throughout the year.• The use of Alternative Dispute Resolution (ADR) is

encouraged by senior management.

Outcomes• Decrease in the number of complaints filed.• Decrease in the number of complaints that go formal.• Free and open competition in the workplace.• Well informed managers, supervisors, and employees on

matters of diversity, EEO, accessibility and reasonable accommodation.

• FAA achieves percentage improvements in the retention of women, minorities, and persons with disabilities.

• No findings of discrimination based on any affected groups.

Strategies• Develop strategic plans, per MD-715, to eliminate

identified barriers.• Train managers, supervisors, and employees annually

regarding diversity, EEO, accessibility, and reasonable accommodation.

• Promote and assess the use of ADR at the informal and formal stages.

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Strategies (cont.)• Conduct an annual assessment to identify, investigate,

eliminate, and monitor barriers where they may exist in the following areas:- Recruitment- Hiring and Placement- Employee Development and Training Opportunities- Award Distribution- Discipline- Separations- Promotions and other internal selections

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Essential Element E: Efficiency

Requires the Agency Leadership to have an efficient and fair dispute resolution process, and effective systems for evaluating the impact and effectiveness of its EEO Programs.

Compliance Indicators• FAA has sufficient staffing, funding, and authority to

achieve the elimination of identified barriers.• FAA has an effective complaint tracking and monitoring

system in place to increase the effectiveness of the agency’s EEO Programs.

• FAA has sufficient staffing, funding, and authority to comply with the time frames in accordance with the EEOC (29 CFR Part 1614) regulations for processing EEO complaints of employment discrimination.

• There is an efficient and fair dispute resolution process and effective systems for evaluating the impact and effectiveness of the agency’s EEO complaint processing program.

Outcomes• Sustain an efficient, fair, and impartial EEO complaint

resolution process.• Adequate and accurate information collection systems that

will provide the ability to conduct a wide array of periodic examinations of the agency’s Title VII workforce profile.

Strategies• Utilize quantitative and qualitative data from various

systems to:- focus training efforts to improve the timeliness of

complaint processing and resolution;

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Strategies (cont.)- track trends in employee expressions of fair and

respectful treatment;- evaluate data by race, national origin, sex, and disability;

and- identify work areas needing remediation.

• Maintain an efficient, fair and impartial complaint resolution process.

• Establish and encourage the widespread use of Alternative Dispute Resolution (ADR).

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Essential Element F: Responsiveness and Legal Compliance

Requires that FAA is in full compliance with EEO statutes and EEOC regulations, policy guidance, and other written instructions.

Compliance Indicators• FAA personnel are accountable for timely compliance with

orders issued by EEOC Administrative Judges.• FAA’s system of management controls ensures that the

agency timely completes all ordered corrective action and submits its compliance report to EEOC within 30 days of such completion.

Outcomes• FAA maintains full compliance with Title VII and the

Rehabilitation Act, including EEOC regulations, orders, and other written instructions.

• FAA reports program efforts and accomplishments to the Department and EEOC.

Strategies• FAA includes a substantive EEO element in all its

supervisory performance standards.• Ensure full compliance with Title VII and Rehabilitation

Act, including EEOC regulations, orders and other written instructions.

• Report agency program efforts and accomplishments to EEOC.

• Comply with final EEOC orders for corrective action and relief.

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ManagementDirective 715ManagementDirective 715

DemonstratedCommitment fromAgency Leadership

Integration of EEOin the Agency's

Strategic Mission

Management and Program Accountability

ProactivePrevention

Efficiency Responsive andLegal Compliance

Office of Civil Rights Contacts for MD-715

Director of the National Model EEO Program(202) 267-7442

MD-715 Program Coordinator(202) 267-9928

Equal Employment Opportunity Specialist(202) 267-9926

Equal Employment Opportunity Specialist(202) 267-7334

Equal Employment Opportunity Specialist(202) 493-4645

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To obtain a copy of the MD-715 Plan, please visit the Office of Civil Rights MD-715 website at:

https://employees.faa.gov/org/staffoffices/acr/ eeo_affirm_program/manag_direc/ or contact the Office of Civil Rights.