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United States Government Accountability Office:


Before the Subcommittee on Oversight of Government Management, the 
Federal Workforce, and the District of Columbia, Committee on Homeland 
Security and Governmental Affairs, United States Senate: 

For Release on Delivery: 
Expected at 2:30 p.m. EST: 
Wednesday, February 16, 2011: 

Federal Workforce: 

Practices to Increase the Employment of Individuals with Disabilities: 

Statement of Yvonne Jones, Director:
Strategic Issues: 


United States Government Accountability Office:
Washington, DC 20548: 

February 16, 2011: 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss possible strategies for 
improving the rate of federal employment of individuals with 
disabilities. My testimony today is based on our October 2010 report 
that discussed barriers to the employment of people with disabilities 
in the federal workforce and leading practices that could be used to 
overcome these barriers.[Footnote 1] To identify these barriers and 
leading practices, we solicited the views of a wide range of 
knowledgeable individuals through a survey and forum held at GAO on 
July 20, 2010. Participants in the forum concluded: 

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 within and across agencies could improve 
employment 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 within an agency can help ensure that 
reasonable accommodations are provided. 

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 (for a list of forum 
participants, see app. I to this testimony and for details on the 
objectives, scope and methodology of the forum see appendix I of the 
report). We conducted our work for the forum 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. 


In brief, Mr. Chairman, participants at the forum 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. 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 agencies is critical to this effort. Participants also 
discussed other barriers, including physical barriers and lack of 
knowledge regarding policies and procedures. For example, some 
participants said that there could be an erroneous belief that 
reasonable accommodations cannot be easily provided. 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 will only make 
piecemeal progress until agencies change their workplace cultures. 

Participants identified eight leading practices, noted above, 
generated by the survey that agencies could implement to mitigate 
these barriers and help the federal government become a model employer 
for people with disabilities. Participants emphasized that these 
practices would not work in isolation but instead need to reinforce 
each other. 


Federal employees and applicants for employment with disabilities are 
protected from discrimination by the Rehabilitation Act of 1973 
(Rehabilitation Act).[Footnote 2] 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 also requires that 
federal agencies take proactive steps to provide equal opportunity to 
qualified individuals with disabilities in all aspects of federal 
employment. Federal law also provides special hiring authorities for 
people with disabilities, including Schedule A excepted service hiring 
authority.[Footnote 3] However, even with existing federal provisions, 
concerns have been raised about the low level of employment of people 
with disabilities in the federal workforce.[Footnote 4] 

On July 26, 2010, in commemoration of the 20th anniversary of the 
Americans with Disabilities Act (ADA),[Footnote 5] 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 6] 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. 

Practices to Mitigate Barriers: 

I will now briefly discuss each of the eight leading practices that 
agencies could implement to mitigate barriers. 

1. Top leadership commitment is key to implementing and sustaining 
improvements. Unless top agency officials are committed, improvements 
will not happen. 

Forum 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 
reported, perhaps the single most important element of successful 
management improvement initiatives is the demonstrated commitment of 
top leaders to change.[Footnote 7] Participants stated that agency 
leaders should make communicating new policies to enhance the 
employment of people with disabilities a priority and could 
demonstrate such commitment on their agency intranet and public Web 
sites. Participants' suggestions on this practice are consistent with 
the Equal Employment Opportunity Commission's (EEOC) Management 
Directive-715 (MD-715), which requires, as one of the six elements of 
a model equal employment opportunity (EEO) program, that agency 
officials demonstrate commitment to equality of opportunity for all 
employees and applicants for employment.[Footnote 8] 

2. Accountability is critical to success; goals can help guide and 
sustain efforts and should be reflected in human capital and diversity 
strategy plans. 

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, and 
evaluating staff and agencies to hold them responsible. 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. 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, which assess 
the extent to which a program is operating as it was intended, and 
outcome measures, which assess the effectiveness of the program. 
Participants concluded that what gets measured gets done. To avoid 
duplication of efforts, participants suggested that agencies should 
use measures they are already required to collect, where possible. For 
example, MD-715 requires agencies to collect data by disability status 
on applicants, new hires, promotions, awards, separations, and grade 
level. Finally, participants stated that if agencies made their goals 
and results public, they could be 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. 

3. Regular surveying of the workforce on disability issues provides 
agencies with important information on potential barriers. 
Participants suggested that surveying be implemented at all stages of 
the employment life cycle. 

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 and 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 for employees with disabilities who are leaving 
the agency. Participants agreed that there is a need to ensure 
confidentiality of survey responses to help ensure that people with 
disabilities are comfortable expressing their opinions regarding their 
agencies' policies, practices, and procedures. Participants suggested 
that agencies should encourage employees to update their disability 
status, which 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 report a disability they may have, but were 
willing to update their status at a later date. Focus groups could be 
used as an alternative method for agencies to obtain relevant 
information, such as employees' perceptions of the work environment or 
the reasonable accommodations process.[Footnote 9] 

4. Better coordination could help improve employment outcomes, as 
coordination within and across agencies is critical. 

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. Without careful coordination, this arrangement 
can create barriers to hiring, providing reasonable accommodations, 
evaluating results of agency efforts, and other processes. 

Forum participants also emphasized that better coordination across 
agencies can help to more effectively address barriers. While there 
are many agencies and programs that provide assistance to individuals 
with disabilities, they often have different missions, goals, funding 
streams, eligibility criteria, and policies that sometimes work at 
cross-purposes with other federal programs. The Department of 
Defense's Computer/Electronic Accommodations Program (CAP)[Footnote 
10] and the Department of Labor's Jobs Accommodation Network (JAN) 
[Footnote 11] were specifically mentioned as resources that federal 
agencies could draw on to potentially reduce duplication and take 
advantage of economies of scale. 

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. 

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. 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 the 
following areas: 

* Hiring: All individuals involved in and affected by the hiring 
process should be provided training on Schedule A, student employment 
programs, disabled veterans' hiring authorities, and the competitive 
process, as well as the legal rights and responsibilities related to 
hiring individuals with disabilities. 

* Reasonable accommodations: All staff should receive training on 
reasonable accommodations rights and processes. Training 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. 

* Diversity awareness: Disability issues must be included in diversity 
awareness training. Such training should include a rights and 
responsibilities component, since inclusion of employees with 
disabilities is a matter of law, not choice, and should be a component 
of core training that all employees receive at the beginning of their 
tenure and throughout their careers at the agency. 

6. Career development opportunities inclusive of 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, including 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, 
and that these opportunities must be fully accessible to all 
employees. Participants also suggested that agencies publicize career 
development opportunities on their intranet and external Web sites. 

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 

Participants suggested that the benefits of flexible work hours, 
telework--where an employee performs assigned duties at home or an 
alternative location--and other types of reasonable accommodations 
could result in cost savings for an agency. Participants noted that 
flexible work times and job sharing are also important. 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. 

Participants 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 12] 

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. 

Participants stated that a perceived "lack of funding should never be 
the reason why reasonable accommodation does not occur" and noted that 
managers may incorrectly perceive how much reasonable accommodations 
cost and be reluctant to provide the accommodations out of their 
departmental or operational budgets. 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.[Footnote 13] The fund should be flexible 
enough to cover a broad range of reasonable accommodations, such as 
personal assistants during work or training, and universally available 
to accommodate staff regardless of staff level, position, or location. 
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. 

Finally, in addition to identifying these practices, participants 
agreed that 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 the Office of Personnel Management and EEOC could help 
clarify implementing instructions for Schedule A and other hiring 
authority guidance. Participants recognized the technical assistance 
that the Office of Personnel Management and EEOC provide, but 
suggested that they develop additional model policies, procedures, and 
programs for agencies to follow. 

Mr. Chairman, this concludes my statement. I would be pleased to 
respond to any questions you or other members of the subcommittee may 

Contacts and Acknowledgments: 

For questions about this statement, please contact Yvonne Jones at 
(202) 512-2717 or Individuals who made key 
contributions to this testimony include Daniel Bertoni, Director; 
Patricia Owens, Director; Neil Pinney, Assistant Director; Charlesetta 
Bailey; Crystal Bernard; Benjamin Crawford; Karin Fangman; Rachel 
Fichtenbaum; Robert Gebhart; Amanda Harris; Terry Richardson; Cynthia 
Saunders; Andrew Stavisky; Tamara Stenzel; and Greg Wilmoth. 

[End of section] 

Appendix I: List of Forum Participants[Footnote 14] 

John Benison; 
Senior Advisor to the Deputy Director; 
Office of Personnel Management: 

Susanne M. Bruyère, Ph.D. 
Associate Dean of Outreach and Director of Employment and Disability 
Cornell University ILR School: 

Dinah Cohen; 
Director, Computer/Electronic Accommodations Program; 
U.S. Department of Defense: 

Janet Fiore; 
Chief Executive Officer; 
The Sierra Group: 

Douglas Fitzgerald; 
Director, Division of Federal Employees' Compensation, Office of 
Workers' Compensation Programs; 
U.S. Department of Labor: 

Gary Goosman; 
Director, Tools on Work and Employment Readiness Initiative; 
U.S. Business Leadership Network: 

Shelby Hallmark; 
Director, Office of Workers' Compensation Programs; 
U.S. Department of Labor: 

Charma Haskins; 
Acting Supervisor of Rehabilitation Services, Vocational 
Rehabilitation and Employment Service; 
U.S. Department of Veterans Affairs: 

Gerrie Drake Hawkins, Ph.D. 
Senior Program Analyst; 
National Council on Disability: 

Anne Hirsh; 
Co-Director, Job Accommodation Network; 
U.S. Department of Labor: 

Jo Linda Johnson; 
Director, Federal Training & Outreach Division; 
U.S. Equal Employment Opportunity Commission: 

Reginald E. Jones; 
Managing Director, Office of Opportunity and Inclusiveness; 
U.S. Government Accountability Office: 

Alison Levy; 
Program Manager, Selective Placement Program; 
U.S. Department of Transportation: 

Dylan Orr; 
Special Assistant, Office of Disability Employment Policy; 
U.S. Department of Labor: 

Jorge E. Ponce; 
Director, Policy and Evaluation Division; 
U.S. Department of Commerce: 

Robin Shaffert; 
Senior Director of Corporate Social Responsibility; 
American Association of People with Disabilities: 

Jennifer Sheehy; 
Director of Policy, Office of Special Education and Rehabilitative 
U.S. Department of Education: 

Derek Shields; 
Project Director, Social Security Administration Ticket to Work 
Recruitment & Outreach; 
Cherry Engineering Support Services Incorporated, Division of Axiom: 

Marie Strahan; 
Chief of Staff, Office of Disability Employment Policy; 
U.S. Department of Labor: 

Carolyn Taylor; 
Special Assistant to the Acting Comptroller General for Diversity 
U.S. Government Accountability Office: 

[End of section] 

[1] GAO, Highlights of a Forum: Participant-Identified Leading 
Practices That Could Increase the Employment of Individuals with 
Disabilities in the Federal Workforce, [hyperlink,] (Washington, D.C.: October 5, 

[2] 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. 

[3] 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 intellectual disabilities, severe physical 
disabilities, or psychiatric disabilities. 5 C.F.R. § 213.3102(u). 

[4] At a GAO forum held in March 2010 on actions that could increase 
work participation for adults with disabilities, experts in the issue 
area and officials representing a variety of views on employment of 
individuals with disabilities discussed the federal government's 
potential role in becoming a model employer of individuals with 
disabilities. See GAO, Highlights of a Forum: Actions That Could 
Increase Work Participation for Adults with Disabilities, [hyperlink,] (Washington, D.C.: July 29, 

[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] Exec. Order No. 13548, Increasing Federal Employment of 
Individuals with Disabilities, 75 Fed. Reg. 45,039 (July 26, 2010). 

[7] GAO, Diversity Management: Expert-Identified Leading Practices and 
Agency Examples, [hyperlink,] 
(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,] (Washington, D.C.: 
Oct. 20, 2000); Management Reform: Using the Results Act and Quality 
Management to Improve Federal Performance, [hyperlink,] (Washington, D.C.: July 
29, 1999); and Management Reform: Elements of Successful Improvement 
Initiatives, [hyperlink,] 
(Washington, D.C.: Oct. 15, 1999). 

[8] 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. 

[9] Participants noted that agencies must ensure that responses are 
appropriately protected so that employees feel safe in disclosing 
their status. 

[10] CAP provides assistive technology and services to people with 
disabilities, federal managers, supervisors, and IT professionals 
across executive branch agencies. 

[11] JAN provides free consulting services for federal employers, 
including one-on-one consultation about workplace accommodations. 

[12] [hyperlink,]. 

[13] These suggestions were consistent with the executive order issued 
in July 2010 that directs the Office of Personnel Management, in 
consultation with the Department of Labor and EEOC, to assist agencies 
in implementing the use of centralized funds to provide reasonable 

[14] Forum participants' titles and organizations were as of the date 
of the forum and may have changed since. 

[End of section] 

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