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EEO and Diversity Strategic Action Plan

Office of Equal Employment Opportunity Strategic Action Plan
FY 2008 and Beyond…

Executive Summary


Ensuring a high quality, diverse, and motivated workforce is one of the key objectives in the Food and Drug Administration's (FDA) Strategic Action Plan. It is a pivotal component of achieving the FDA's critical mission of protecting and advancing America's health. A prerequisite for achieving this objective is supporting the principles of equity and diversity in the workforce. No organization in the 21st century can excel in the global community in which we live unless it is firmly rooted in these fundamental principles. To that end, the Office of Equal Employment Opportunity (OEEO) serves to lead the effort in developing policies and programs that ensure equal employment opportunity (EEO), promote inclusiveness, and foster a culture that values diversity and empowers individuals in the workforce.



The FDA is an operating division of the U.S. Department of Health and Human Services dedicated to the protection and advancement of the public health. Headquartered in Montgomery County, Maryland, the FDA is a premier scientific agency that regulates the safety and efficacy of America's foods, drugs, and medical devices. To successfully perform its critical mission, the FDA must recruit highly qualified administrative, professional, and scientific talent from around the world. The FDA's 10,000 employees represent the organization's most valuable asset – its human capital.


Maintaining a world class public service workforce requires strategic efforts to tap into the intellectual capital of our global economy. The 2000 Census has revealed major shifts in the demographic profile of the population we serve and the labor force from which we recruit. In Montgomery County alone, minorities represent nearly 40 percent of the population. Virtually every racial and ethnic group experienced a marked increase in its representation since 1990. Nationally, by the year 2040, it is projected that no single racial or ethnic group will comprise the majority of the United States population. The changes associated with our increasingly pluralistic society bring concomitant opportunities and challenges to public sector employers such as the FDA, who strive to remain competitive in a high-end employment market and reflect the public they serve. They also demand a change in the way we, as public employers, must view diversity management.

In addition to changes in the external environment, organizations have been faced with internal fiscal challenges that demand creative solutions. In an effort to enhance administrative efficiencies and improve its internal customer service, the FDA embarked on an internal reorganization that resulted in the centralization and consolidation of administrative functions, including its EEO and diversity management functions. On October 1, 2003, the newly created Office of Equal Employment Opportunity became operational. The reorganization created the need for a "macro" view of service delivery in the EEO and diversity area. As such, OEEOemployees were asked to develop individual team strategic plans that reflected the best practices of EEO and diversity management functions in and outside the public sector. That effort yielded the FY 2004 and Beyond EEO and Diversity Management Strategic Action Plan.


It has been three years since the development of that initial Strategic Plan. We are pleased to report that OEEO has accomplished the vast majority of the objectives outlined in that Plan. Accordingly, it is time to revisit the goals and develop an updated Strategic Action Plan for FY 2008 and Beyond. This Strategic Action Plan represents the culmination of an employee-driven effort to build a framework for building upon the achievements of our inaugural Plan and implementing best practice strategies from the Private and Federal sectors. With our revised Plan, OEEO will be able to continue in its role as a respected leader in the Federal EEO community and the FDA can go to the next level as a world class public service organization. The Plan presents OEEO's vision, mission, goals, objectives, strategies, and measures for a comprehensive and model EEO and diversity management program.



The OEEO views EEO and diversity as both moral and economic imperatives in American society. EEO refers to the set of laws and policies that mandate all individuals' rights to equal opportunity in the workplace, regardless of race, color, sex, sexual orientation, religion, national origin, age, or disability. The unequivocal protection of these fundamental civil rights in the workplace is the cornerstone of our American democracy and the foundation upon which diversity can thrive. Diversity management, in contrast, is a proactive response to the changing profile of our world. The OEEO recognizes that in order to be relevant in the global economy of the 21st century, the FDA must recruit, develop, promote and retain a world class workforce that reflects the pluralistic society it serves. The OEEO defines diversity as the full spectrum of human uniqueness, including but not limited to physical, social, economic, educational, cultural, religious, personal, and philosophical perspectives.


As a scientific agency, the FDA strongly supports the concept of diversity of thought, which is inextricably rooted in diversity of humanity. The OEEO promotes the business case for diversity by highlighting the strong empirical correlation between workforce diversity and high performing organizations. Diversity and the accompanying divergent thought processes are essential to excellence and the discovery of knowledge. Finally, the OEEO understands that to be effective, organizations must empower individuals to work, participate and contribute to their optimum potential, and manage conflict constructively toward creative outcomes.



The mission of the OEEO is to promote an inclusive work environment in the FDA that ensures equal employment opportunity, fosters a culture that values diversity and empowers individuals to participate constructively to their fullest potential in support of the FDA mission.



It is the vision of the OEEO that EEO and diversity management are separate but symbiotic functions essential to the success of the FDA as a high performing organization. EEO refers to the unfettered guarantee of all individuals' rights to equal opportunity in the workplace. EEO compliance is the adherence to those laws and policies that protect all individuals' rights to work and participate in the terms and conditions of employment free from discrimination. Diversity management is the proactive effort to promote inclusion and diversity in the broadest context. It is the recognition that diversity includes but is not limited to social, physical, economic, educational, cultural, religious, personal, and philosophical perspectives. It is everyone's champion and gives voice to their issues. Finally, it is the OEEO's vision that individuals must be empowered to fully engage in the FDA mission by managing conflict constructively and channeling differences creatively. Together, these functions create synergy and coalesce into a whole that is greater than the sum of its parts.

Guiding Principles


The FDA is committed to the principles of equity and diversity in the workplace. It is the policy of the FDA to ensure equal employment opportunity, prohibit discrimination, retaliation and harassment in all its forms, and promote diversity and inclusiveness in the FDA workplace. To this end, the OEEO seeks to lead by example by embracing the certain fundamental values. We believe that there is no higher calling than public service, and no more important work in public service than the pursuit of civil equity. We understand that our credibility and efficacy in the area of EEO is inextricably linked to our integrity and impartiality. We know that we cannot protect the rights of any unless we protect the rights of all, without bias or favoritism. We also know that we are strengthened by our diversity, and empowered by our inclusiveness. Finally, we believe it is our obligation to give voice to those voices unheard. The OEEO stands in the vanguard of the effort to cultivate an environment that promotes inclusion, values diversity, and respects the dignity of every individual.



The following primary goals have been identified in pursuit of this mission:

  • Eradicate discrimination in the workplace by enforcing Federal equal employment opportunity laws, regulations, and policies;
  • Promote inclusion and diversity in all levels of the workforce; and
  • Empower individuals by promoting constructive conflict management so that they may participate to their fullest potential and advance the mission of the FDA.



The following present the programmatic objectives, strategies, and measures designed to achieve the identified goals. Implementation of this Strategic Action Plan is intended to be a multi-year effort. This Plan is also designed to be a "living" document that grows and changes in response to the emerging needs of the organization. This Plan will be implemented by the staff of the OEEO, in collaboration with its partners throughout the agency and beyond, and is a testament to their dedication to the principles of equity and diversity in the FDA.




Goal 1: Eradicate discrimination in the workplace by enforcing Federal equal employment opportunity laws, regulations, and policies.

Objective 1A: Administer a timely and effective EEO complaint processing program in order to resolve complaints of discrimination. 


  • Annually issue and distribute to all agency employees updated EEO policies signed by the Commissioner of the Food and Drug Administration.
  • Develop and implement standard operating procedures for a Federally compliant EEO complaint process.
  • Provide counseling services in accordance with Federal regulations and within mandated timeframes (29 CFR Part 1614).
  • Provide Alternate Dispute Resolution (ADR) services in accordance with Management Directive 110 and within mandated timeframes.
  • Process formal complaints in accordance with Federal Regulations and within mandated timeframes (29 CFR Part 1614).
  • Issue EEO complaints activity report (462 report) in accordance with EEOC requirements.
  • Post numerical EEO complaints activity on FDA internet and intranet websites and provide notification to employees in compliance with Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002 (No FEAR Act).
  • Provide mandatory EEO Compliance training for supervisors and managers.
  • Provide EEO Compliance training for employees.
  • Provide mandatory Workplace Harassment Prevention training for supervisors and managers.
  • Provide Workplace Harassment Prevention training for employees.
  • Provide mandatory training to counselors in accordance with MD-110.
  • Meet with Center/Office contacts and provide quarterly Reports of Complaints Activity.
  • Promote and encourage communication and other activities among OPDIVS by pooling resources to keep EEO in the forefront of DHHS operations.
  • Solicit feedback from individuals who utilize compliance services to gauge effectiveness, responsiveness, etc.
  • Provide training to complaints specialist to keep them apprised of current laws and regulations.
  • Promote and encourage cross-training within Compliance, the OEEO and other government agencies.

Program Measures:

  • Maintain the minimum percentage stated in the Office of Shared Services (OSS) Service Level Agreement (SLA) that counseling intakes are processed within mandated timeframes.
  • Maintain the minimum percentage stated in the OSS SLA that ADR services are completed within mandated timeframes.
  • Increase number of complaint resolutions.
  • Maintain the minimum percentage stated in the OSS SLA formal complaint investigations are completed within mandated timeframes.
  • Ensure the timeliness and accuracy in issuing 462 Report, No FEAR Report and Quarterly Compliance Reviews.
  • Ensure the timeliness and thoroughness in issuing EEO policies and procedures.
  • Track number of employees, supervisors, and managers provided training on EEO compliance issues.
  • Process complaints in accordance with timeframes and guidelines listed in the SOP.
  • Analyze customer feedback to determine if services provided by Compliance Staff are effective.

Objective 1B: Provide timely and effective reasonable accommodation/accessibility and Section 508 compliance so that individuals with disabilities may enjoy full access to equal employment opportunity.


  • Continue to implement and promote the agency Staff Manual Guide (SMG) on reasonable accommodation/accessibility and Section 508 Compliance.
  • Process reasonable accommodation/accessibility requests and Section 508 compliance in accordance with Federal guidelines and Department policy.
  • Provide training to employees, supervisors, and managers on reasonable accommodation/accessibility and Section 508 compliance policy and procedures.
  • Increase Reasonable Accommodation (RA) presence at each Center/Office.
  • Continue participating on agency committees to address building and facility accommodation/accessibility issues.
  • Incorporate entelliTrak data management system into daily operations.
  • Provide training to reasonable accommodation specialists to keep them apprised of current laws and regulations.
  • Enhance relationships between the Reasonable Accommodation Team, the Employee/Labor Relations Office, the FDA Occupational Safety and Health Office, the Federal Occupational Health (FOH) Service and agency management.

Program Measures:

  • Issue and implement SOP on Section 508 Complaints.
  • Maintain the minimum percentage stated in the OSS SLA that reasonable accommodation/accessibility requests are processed within timeframes established in the agency SMG.
  • Track the request and cost of reasonable accommodations/accessibility for applicants/employees.
  • Collaborate with the Employee/Labor Relations Office, the FDA Occupational Safety and Health Office, FOH and agency management.

Objective 1C: Develop and maintain internal tracking systems, program measures, and performance measures.


  • Maintain a Federally compliant automated EEO complaints tracking and reporting system (iComplaints).
  • Maintain a reasonable accommodation/accessibility and interpreting services automated tracking and reporting system (entelliTrak).
  • Maintain an Alternative Dispute Resolutions automated tracking and reporting system (entelliTrak).
  • Keep relevant data updated in each iComplaints and entelliTrak applications.
  • Develop and implement an inquiry log to capture service requests and general inquires not captured in systems listed above to include Diversity Management and Administrative Services.
  • Develop and implement cost allocation module automated tracking system.

Program Measures:

  • Improve timeliness in implementing, monitoring and maintaining tracking systems.
  • Perform audits of data on a quarterly basis of all tracking systems to ensure accuracy.

Goal 2: Promote inclusion and diversity in all levels of the workforce.

Objective 2A: Identify underrepresentation of EEO groups in accordance with Federal laws and regulations.


  • Develop, provide, and advise the FDA Succession Planning Committee with the appropriate workforce data, i.e., mission critical occupations at the agency and subcomponent levels.
  • Conduct and report at the agency and subcomponent level workforce analysis in areas relevant to the Affirmative Employment Program.
  • Continue to develop, prepare, and disseminate the FDA Annual EEO Program Status Report in compliance with MD-715.
  • Implement the strategies defined in the FDA Annual EEO Program Status Report to eliminate barriers to equal opportunity.
  • Continue to prepare the Federal Equal Employment Opportunity Recruitment Report in conjunction with the Rockville Human Resources Center.
  • Continue to conduct on-site technical review visits to Centers/Offices/ORA.
  • Resurvey agency workforce via the SF-256 Self Identification of Handicap form.
  • Resurvey agency workforce via the Applicant Background Survey form.
  • Investigate if agency applicant flow data is available.

Program Measures:

  • Develop and supplement as necessary workforce analyses and reports.
  • Increase the quality and timeliness of workforce analyses and reports.
  • Ensure timeliness in completing all Federally mandated reports.
  • Increase the frequency of on-site technical review visits to Centers/Offices/ORA.
  • Monitor workforce database to ensure that the FDA personnel records are updated.
  • Provide employees with the appropriate venue to easily update their disability, and race/national origin information.

Objective 2B: Identify barriers to EEO through data analyses and develop recommendations for corrective actions.


  • Develop ad hoc barrier analyses and evaluative reports for Agency/Centers/Offices/ORA.
  • Respond to requests for workforce analyses information related to EEO complaints.
  • Participate and collaborate with other agencies and department's committees and councils to share information on regulatory developments, current trends, and best practices.
  • Participate and collaborate on FDA committees as a subject matter expert, i.e., awards, QRBs, A-76 Studies, etc., to address issues related to adequate representation of all EEO groups.
  • Identify barriers (hiring, promotion, retention) affecting the FDA workforce and implement corrective actions to resolve the undesired conditions.

Program Measures:

  • Augment as necessary the number of barrier analyses/reports developed for Centers/Offices/ORA.
  • Ensure timeliness and accuracy of workforce reports and analyses.
  • Ensure timeliness and accuracy on requests for information and ad hoc reports.
  • Increase EEO participation role on internal/external committees.
  • Identify workforce barriers and propose corrective actions recommended.

Objective 2C: Promote and participate in commemorative observances, cultural awareness and Special Emphasis Programs (SEP) in collaboration with Department and Operating Divisions.


  • Continue networking with Opdiv SEP managers and other special interest groups to support, collaborate and implement the African American Employment Program, Federal Women's Program, Hispanic Employee Program, Employment of People with Disabilities Program, Asian Employee Initiative, the American Indian Employee Initiative and other special interest groups.
  • Maintain and promote calendar of events aimed at promoting SEP initiatives.
  • Respond to White House and Departmental Initiatives, etc. that address SEP areas.

Program Measures:

  • Promote participation/attendance in special SEP and outreach events.
  • Issue appropriate responses in a timely manner to the White House and Departmental initiatives/orders related to SEP issues.

Objective 2D: Recruit, retain, and develop a highly qualified and diverse workforce.

Strategies: ·

  • Establish and maintain partnerships with various professional and educational organizations.
  • Participate in job fairs, college fairs, and other recruitment outreach venues targeted at underrepresented groups.
  • Maintain and promote calendar of recruitment outreach events aimed at promoting diversity in the workforce.
  • Participate in discussions with Center/Office/ORA management to increase outreach of underrepresented groups.
  • Utilize and promote intern programs aimed at supporting workforce diversity.
  • Continue to develop and implement the FDA Mentoring Program.
  • Collaborate and coordinate with Centers/Offices/ORA on initiatives designed to recruit and retain a diverse workforce.
  • Conduct exit interviews with employees who leave the agency.

Program Measures:

  • Increase in representation of underrepresented groups in the FDA workforce.
  • Increase in representation of underrepresented groups in promotions.

Goal 3: Maintain a harmonious work environment by resolving workplace conflicts at the earliest possible stage.

Objective 3A: Maintain a comprehensive Conflict Prevention and Resolution (CPR) program to address and resolve conflict before it escalates.


  • Adhere to the established Code of Conduct for participation as a Mediator as codified by the Ombudsman Association's Code of Ethics and Standards of Practice.
  • Evaluate the performance of Mediators.
  • Continue to develop standard training for Mediators to ensure they are kept aware of the latest trends in mediation and gain additional industry and technical knowledge.
  • Sponsor annual CPR informational site visits to each Center/Office/ORA.

Program Measures:

  • Evaluate Mediator performance after every CPR event.
  • Conduct meetings with all Mediators on a quarterly basis.
  • Review and report the number and percentage of EEO complaints resolved through mediation.
  • Review and report the number and percentage of CPR events, i.e., counseling, intervention, training, team building and facilitation.
  • Increase number of disputes resolved through CPR within mandated timeframes.
  • Provide training for Mediators on a continuous basis.

Objective 3B: Develop and maintain conflict prevention and resolution report analyses for the agency.


  • Identify root causes of work place conflict and make presentations to the offices regarding climate, cost of conflict and need for training of workforce.
  • Meet quarterly with Center Directors and Executive Officers to discuss cost of conflict, trends, issues and training needs.

Program Measures:

  • Conduct Cost of Conflict Analysis on each CPR event, as appropriate.
  • Perform bi-annual analysis of conflict trends, impact analysis.
  • Develop quarterly ad hoc reports reflecting the workplace issues for each Center/Office/ORA.

Objective 3C: Increase access to EEO and diversity training, other educational opportunities and informational resources.


  • Maintain OEEO training database.
  • Continue to develop and provide customized EEO, Diversity, and Conflict Prevention and Resolution (CPR) training for employees and managers that is available to all field offices via pic-tel and or web cast.
  • Develop "voice-over" training module to address EEO, Diversity, Conflict management, as necessary, in compliance with the Rehabilitation Act.
  • Ensure that all training modules developed by the OEEO are 508 compliant.
  • Develop and implement Diversity training module for managers and supervisors, which includes Reasonable Accommodations/Disability sensitivity.
  • Implement mandatory CPR training for all managers and supervisors.
  • Develop and implement a training module to provide an annual basic 32 hour EEO counselor training, 8 hour re-fresher for EEO counselors, collateral-duty counselors and mediators.
  • Partner with Office of the Commissioner/Office of Management Programs to develop/incorporate training modules and or materials into FAME and the Emerging Leaders Program (ELP).
  • Partner with HHS University to develop and implement EEO and Diversity training programs.
  • Develop and implement the business case for Diversity training module(s).

Program Measures:

  • Increase the percentage of employees trained in EEO, Diversity, and CPR.
  • Maintain satisfaction ratings on the OEEO training and educational events via the Likert scale.
  • Monitor number of visits to EEO and Diversity Management websites.
  • Coordinate with the FDA's 508 Team to ensure each training module is accessible prior to release.
  • Increase participation in diversity related educational and informational programs.
  • Track number of training sessions delivered through HHS University, FAME and ELP.
  • Provide EEO, Diversity and CPR trainings via pic-tel or web cast as appropriate.
  • Increase participation rate in mandatory EEO and CPR training.

Objective 3D: Develop and implement Agency-wide mechanisms that promote diversity and address diversity issues, concerns, and initiatives throughout the agency.


  • Annually update and issue the EEO and Diversity Policy Statement signed by the Commissioner of FDA and distribute to all agency employees.
  • Issue agency-wide call for Diversity Council membership per their charter.
  • The OEEO will continue to provide support to the Diversity Council via staff and monetary contributions.
  • Support the Diversity Council in its activities including Diversity Summit, Diversity Fair and other Diversity Council initiatives.

Program Measures:

  • Annually update and issue the FDA EEO & Diversity Policy Statement.
  • Increase participation and satisfaction in Diversity Council sponsored events.

Objective 4: Through multi-media forms, consistently and comprehensively demonstrate FDA's commitment to EEO and diversity.


  • Disseminate the OEEO Strategic Plan and promote it among all FDA audiences.
  • Examine current FDA communications to ensure a global perspective.
  • Develop an agency-wide Diversity Communication Strategy Plan to ensure that all internal and external communications are consistent with the operational definitions for diversity.
  • Include a diversity related article in regularly published documents as appropriate.
  • Seek and identify activities that highlight diversity best practices.
  • Develop, publish, and disseminate general advertising and public relations material to project the desired EEO and diversity image.
  • Survey workforce for opinions and recommendations on diversity and equity at the FDA.
  • Continue to enhance the OEEO webpage and newsletter as vehicles to transmit EEO information to the agency.
  • Develop and present PowerPoint presentations and other promotional material (brochures, fact sheets, videos) on EEO, Diversity and CPR.
  • Promote and advertise existing and forthcoming training modules in the OEEO newsletter and through FDA all-hands e-mails.
  • Increase communication by utilizing marketing strategies to keep the workforce apprised of the complaint process and other EEO issues through the OEEO newsletter, etc.
  • Promote the use of reasonable accommodation resources, such as Computer/Electronics Accommodations Program (CAP), Job Accommodations Network (JAN) and USDA Target Center, etc.

Program Measures:

  • Ensure that the OEEO Strategic Plan is published and posted on the OEEO website.
  • Perform semi-annual review of current FDA communications.
  • Develop and distribute Diversity Communication Strategy Plan.
  • Develop a variety of informative articles, editorials, and features for publication.
  • Develop and issue brochures, media campaigns, videos, emails, and leaflets that promote diversity.
  • Increase number of focus groups, employee's surveys, comments and feedback questionnaires.
  • Improve the timeliness and quality in updating the OEEO webpage and ensure that it is 508 complainant.