U.S. Environmental Protection Agency
Report on Upward Mobility of
Hispanic Employees into the
Senior Executive Service
Trigger Identification

Office of Civil Rights
September 30, 2022

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Table of Contents

BACKGROUND	3

EPA BARRIER ANALYSIS INITIATIVE -TRIGGER IDENTIFICATION	5

Phase I Data Review: Permanent Workforce, Complaints Data, Federal Employee Viewpoint
Survey Results	5

1.	Permanent Workforce Data Table Analysis	5

A. Permanent Hispanic Employees (Source: MD-715 Tables)	6

Trigger Analysis for Permanent Hispanic Males in the GS13 to the SES	6

Trigger Analysis for Permanent Hispanic Females in the GS13 to the SES	6

2.	Complaints Data (EEOC 462 Complaints Report)	8

3.	Federal Employee Viewpoint Survey Data	8

PHASE II-DATA REVIEW-AGENCYWIDE UPWARD MOBILITY SURVEY	10

1.	Background	10

2.	The Upward Mobility Survey	11

Section I - Demographic Questions	11

Section II -Training	12

Section III - Individual Development Plan	12

Section IV - Mentoring and Coaching:	12

Section V - Upward Mobility:	13

Next Steps	15

Appendix 1. Upward Mobility Survey	16

SECTION I - Demographic Questions	11

SECTION II -Training Questions	17

SECTION III - Individual Development Plan Questions	20

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BACKGROUND

On January 18, 2017, the Office of Personnel Management (OPM) and the Equal Employment
Opportunity Commission (EEOC) issued a joint memorandum: "Hispanics in the Federal
Workforce." OPM and EEOC issued the memorandum as a concerted effort to address the
"persistent low representation of Hispanics/Latinos in the Federal Workforce." Id. The
memorandum urged agencies to conduct focused barrier analysis on Hispanic Employment.

"A barrier is an agency policy, principle, or practice that limits or tends to limit employment
opportunities for members of a particular EEO group based on their sex, race, ethnic
background, or disability status." EEOC instructions to Federal Agencies for preparing E

. The OPM/EEOC memorandum encouraged agencies to focus on the feeder pool grades
into the Senior Executive Service (SES) and the SES to identify and eradicate any barriers to
equal employment opportunity (EEO) consistent with the merit system principles and
applicable laws.

The memorandum highlighted the following as drivers of this initiative: Executive Order 13583,
Establishing a Coordinated Government-wide Initiative to Promote Diversity and Inclusion in the
Federal Workforce-, recommendations from the Hispanic Council on Federal Employment
(HCFE); and EEOC Management Directive 715 to remove barriers to EEO in the Federal
workplace. The memorandum suggested various barrier analysis activities, which agencies
could conduct based on their regular EEO planning and reporting requirements under EEOC
MD-715.

The goal of barrier analysis under EEOC Management Directive 715 is to identify the root causes
of disparities in equal employment opportunities so that federal agencies can take action to
remedy the policies, procedures, and practices that lead to such disparities.1 As depicted in
Figure 1, there are four steps in the Barrier Analysis Process.

1 https://www.eeoc.gov/federal-sector/management-directive/barrier-analysis-questions-guide-process

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Barrier Analysis Process

STEP (1) - IDENTIFY TRIGGERS

*	IDENTIFY POSSIBLE TRIGGERS USING A VARIETY OF SOURCES:

*	TAKE, REVIEW AND REFINE COMPULSORY SNAPSHOTS

*	TAKE ADDITIONAL SNAPSHOTS WHERE NEEDED

*	REVIEW OTHER INFORMATION SOURCES

*	ANALYZE ALL EMPLOYMENT PROCESSES

STEP (2) - INVESTIGATE BARRIERS

*	ATTEMPT TO PINPOINT ROOT CAUSES OF OBSERVED
TRIGGERS BY:

•	DEVELOPING REQUESTS FOR INFORMATION THAT FLOWS
FROM TRIGGERS;

*	REVIEWING PERTINENT DOCUMENTS; &

•	CONSULTING WITH KNOWLEDGEABLE INDIVIDUALS.

STEP (4}-ASSESS RESULTS

« ASSESS SUCCESS OF PLAN

•	TRACK PROGRESS; SHOULD BE MEASURABLE

•	HOLD AGENCY OFFICIALS ACCOUNTABLE

•	PERIODIC RE-ASSESSMENTS SHOULD BE DONE TO
DISCOVER IF PLAN NEEDS ADJUSTING

STEP (3) - DEVISE ACTION PLANS

•	DEVISE A PLAN TO ADDRESS BARRIER CAUSES

» DETERMINE WHETHER BARRIERS ARE JOB-RELATED AND
CONSISTENT WITH BUSINESS NECESSITY. IF NOT, PLAN TO
ELIMINATE THOSE BARRIERS.

•	CONSIDER MODIFICATIONS EVEN WHERE BARRIERS ARE
JOB-RELATED AND CONSISTENT WITH BUSINESS NECESSITY.

•	REPORT PLAN AND PROGRESS TO THE EEOC ANNUALLY

Figure 1. Barrier Analysis Process

This report depicts the actions taken and information gathered in Step (1) Identify Triggers. A
trigger is a trend, disparity, or anomaly that suggests the need for further inquiry into a
particular policy, practice, procedure, or condition. It is simply a red flag. Triggers can be
gleaned from various sources of information, beginning with workforce statistics.2

This report assisted in beginning to identify where in the employment lifecycle triggers may
exist for EPA's Hispanic workforce. There are five critical phases of the employment lifecycle: 1)
Recruitment; 2) Hiring; 3) Training and Development; 4) Promotions; and 5) Separations. Based
on the OPM/EEOC memorandum that encouraged agencies to focus on the SES and its feeder
pools, this report focused on that.

Separately, and more recently, EPA also began a similar national analysis on upward mobility
based on race and sex. The next step in EPA's upward mobility analysis will be to merge the two
efforts, including utilizing a statistically significant trigger analysis tool developed as part of the
race and sex upward mobility analysis. The tool's purpose is to assist in the analysis of
workforce data in a manner that identifies triggers and provides input regarding the priority of
barrier analysis. In the next step of the upward mobility analysis, we expect to complete our
investigation of barriers and devise action plans, as necessary, by FY23 Quarter 4. We have
reserved FY24 to assess the results of any action plans we devise.

2 https://www.eeoc.gov/federal-sector/management-directive/instructions-federal-agencies-eeo-md-715-
l#:~:text=Definition%20of%20Barrier,ethnic%20background%2C%20or%20disability%20status.

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EPA BARRIER ANALYSIS INITIATIVE - TRIGGER IDENTIFICATION

In fiscal year 2019 (FY19), the Office of Civil Rights (OCR) established an agencywide national
priority: The Upward Mobility of Hispanics from GS-13 to the Senior Executive Service (SES). The
analysis began at the GS-13 level, because the EEOC MD-715 workforce tables identify GS-13 to
SES as the senior-level grades. OCR reviewed the workforce demographics data for FY17
through FY21. The trigger identification analysis concentrated on whether there were triggers
to suggest the need to further investigate upward mobility for EPA's Hispanic employees.

The initial phase of data analysis included reviewing EPA's workforce data tables, EEO
complaints data gathered from its Annual Federal Equal Employment Opportunity Statistical
Report on Discrimination Complaints (EEOC 462 Complaints Report), and Federal Employee
Viewpoint Survey (FEVS) data.

The second phase of data review included the development and execution of an agencywide
employee survey. The survey was open to all EPA employees (Hispanic and non-Hispanic). The
survey consisted of forty-nine questions that were divided into five categories. Survey
participation was anonymous. The data collected in phase one and phase two serve as the
foundation for this trigger identification report.

Pkise I Data Review: Permanent Workforce, Complaints Data, Federal
Employee Viewpoint Mil vey Results

Phase 1 of the data review was focused on identifying triggers in data sets. Triggers in the data
sets were to help provide a platform to determine if there were potential upward mobility
barriers to investigate regarding EPA's Hispanic employees. Three data sets were reviewed:
FY17-21 Permanent Workforce GS-13-SES - Hispanic Participation Rates; EEOC 462 Complaints
Reports; and Federal Employee Viewpoint Survey Results.

The following is a summary of the findings for the data sets used for the phase 1 data review:

1. Permanent Workforce Data Table Analysis

The EEOC identifies the Glass Ceiling Barrier as one of three major barriers most likely to
impact an employee's career path to the executive level. A glass ceiling exists when a
particular EEO group cannot reach the executive level of leadership in an organization
despite their presence in positions that comprise the feeder pool for executive positions. An
upward mobility benchmark for determining a trigger to investigate the glass ceiling barrier
is the comparison between the target population (e.g., the SES participation rate) and the
population of the feeder pool, which are the grade levels immediately below the one under
review.

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A. Permanent Hispanic Employees (Source: MD-715 Tables)

Trigger Analysis for Permanent Hispanic Males in the GS13 to the SES:

Figure 2 demonstrates that from FY17 to FY21, each year the Hispanic male SES participation
rates has increased: in FY17 it was 3.38%, in FY21 it was 5.26%. Furthermore, although every
year the Hispanic male participation rates decreased from the feeder pools into the SES, which
are the GS13 to GS15, every year the SES participation rate exceeded the GS-15 feeder pool
upward mobility benchmark.

Workforce Data Table Analysis - Permanent Hispanic Males
(Source: MD-715 Tables)

FY17	FY18	FY19	FY20	FY21

¦ 13 ¦ 14 ¦ 15 ¦ SES

Figure 2. Permanent Hispanic Male Workforce Data Analysis

Additionally, in FY20 and FY21, the Hispanic male SES participation rate exceeded the GS13,
G14, and GS15 Hispanic male participation rate. Importantly, the FY21 GS15 Hispanic male
participation rate was 2.96%, yet EPA's male Hispanic SES participation rate was 5.26%.

Workforce data demonstrates that the percentage of Hispanic males in the SES has improved
over the last five years. As a result, the Hispanic male participation rate in the SES now exceeds
the upward mobility benchmark - feeder pool used in this trigger identification analysis. A
question that needs answering moving forward is whether the Hispanic male participation rate
in the feeder pools is at an anticipated participation rate so that Hispanic male upward mobility
allows for an anticipated participation rate of Hispanic males in the SES.

Trigger Analysis for Permanent Hispanic Females in the GS13 to the SES:

Figure 3 shows that each year, from FY17 to FY21, the Hispanic female participation rates
decreased from the G13 to the GS14. The participation rate similarly decreased each year from
the GS14 to the GS15.

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However, as with the male Hispanic data, each year between FY17 to FY21, the Hispanic female
SES participation rates increased: in FY17 it was 2.26%; in FY21, it was 3.38%. In FY21 the
Hispanic female SES participation rate surpassed the upward mobility benchmark, the GS15
feeder pool, by almost 1% (.76%).

Workforce Data Table Analysis - Permanent Hispanic
Females (Source: MD-715 Tables)

FY17	FY18	FY19	FY20	FY21

¦ 13 B14 115 SES
Figure 3. Permanent Hispanic Female Workforce Data Analysis

The FY21 accomplishment is positive, but the Agency will need to continue to monitor Hispanic
female upward mobility to determine whether the FY21 data is an outlier. Of particular
concern, FY21 also saw the greatest Hispanic female participation rate decreases from the GS-
14 to the GS-15, albeit by .69%.

Although not at the same rate as EPA's Hispanic male SES, permanent workforce data
demonstrates that the Hispanic female SES participation rate at EPA has improved over the last
five years. As a result, the Hispanic female SES participation rate now exceeds the Hispanic
female SES upward mobility benchmark. As with the male Hispanic analysis, a question that
needs answering moving forward is whether the Hispanic female participation rate in the
feeder pools is at an anticipated participation rate so that Hispanic female upward mobility
allows for an anticipated participation rate of Hispanic females in the SES.

Further Analysis: The agency needs to analyze whether certain occupations provide different
opportunities to advance to the executive level. It may be helpful to disaggregate the data by
occupations because not all occupations in the agency have the same career growth to either
the GS-14 or GS-15.

Additionally, do certain occupations base qualifications on unnecessary criteria. For example, if
there is a practice to favor education could the level of education be adjusted, eliminated, or
substituted? Could a more concerted effort be made to identify Hispanic employees who have
the level of education needed through improved outreach and/or recruitment?

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The analysis also needs to account for the fact that the agency does not fill all SES positions
from internal candidates. The agency will consider these and other issues as it unveils a more
refined upward mobility benchmark in conducting its analysis in FY23.

2. Complaints Data (EEOC462 Complaints Report)

The EEOC recommends that agencies in their trigger identification analysis should review
additional data including their EEOC 462 Complaints Report. Specifically, an agency should
determine whether there is a trend of complaint filings that allege a failure to promote or non-
selection based on national origin (Hispanic). EEOC instructions to Federal Agencies for
preparing EE

The following table provides information regarding failure to promote/non-selection
complaints based on national origin (Hispanic) for FY17- FY21:

Table 1. EEOC462 Complaints Data (FY17-FY21)

Fiscal
Year

Failure to Promote/Non-
Selection Complaints Based
on National Origin (Hispanic)

Total Number of Failure to

Promote/
Non-Selection Complaints

Total Number of
Complaints
(Regardless of Bases)

Percentage of Total

Complaints
(Regardless of Bases)

2017

2

21

78

2.6%

2018

0

10

57

0%

2019

1

7

63

1.6%

2020

1

14

63

1.6%

2021

2

7

44

4.5%

Table 1 shows that complaints alleging failure to promote or non-selection based on national
origin (Hispanic) did not exceed two in any year between FY17 and FY21. They ranged from zero
to two. The data did not demonstrate a trend of complaint filings that alleged a failure to
promote or non-selection based on national origin (Hispanic).

3. Federal Employee Viewpoint Survey Data

In January 2017, the EEOC released the following document: Barrier Analysis: Questions to
Guide the Process. The document serves as a tool to help guide a barrier analysis exercise and
contains a set of questions and suggested activities for the five most common areas to conduct
barrier analysis exercises: recruitment, hiring, training and development, promotions, and
separations.

This trigger identification analysis focused on identifying upward mobility triggers for further
investigation. The EEOC document suggests a review of two FEVS questions (22 and 67) to
determine if there are variations from the government-wide and agencywide responses.
Substantially more negative responses should be investigated as a data source to identify

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potential barriers. The following table summarizes the findings from the FY17-FY19 FEVS
reports for questions 22 and 67:3

FEVS Question 22: Promotions in my work unit are based on merit

A review of FEVS question 22, shows that Hispanic employees selected 'negative' at a higher
rate than the EPA-wide and EPA non-Hispanic rate, but at a lower rate than the Government-
wide rate with the exception of 2017. The negative response rate of EPA Hispanic employees
was 1.7% greater than EPA-wide employees and 2.6% greater than EPA non-Hispanic
employees; it was 2.2% less than the government-wide negative response rate.

The Hispanic negative response rate decreased by a greater percentage, 1.5%, during this
period than did the EPA-wide and EPA non-Hispanic percentages of .9% and 1.2%, respectively.
The government-wide negative response rate increased by .7%.

FY17 RESPONSES



Number of Responses

Positive

Neutral

Negative

Do Not Know

Government-wide

468,542

42.3%

25.4%

32.35%

16,412

EPA-wide

8,519

42.1%

27.7%

30.1%

840

EPA Hispanics

588

42.0%

25.6%

32.4%

56

EPA Non-Hispanics

7,473

42.7%

27.8%

29.5%

725



FY18 RESPONSES



Number of Responses

Positive

Neutral

Negative

Do Not Know

Government-wide

556,796

37.5%

28.3

34.3

37,646

EPA-wide

7,271

41.7%

28.3%

30.0%

661

EPA Hispanics

499

41.1%

27.9%

30.9%

34

EPA Non-Hispanics

6,298

42.6%

28.2%

29.3%

565



FY19 RESPONSES



Number of Responses

Positive

Neutral

Negative

Do Not Know

Government-wide

568,300

39.2%

27.7%

33.1%

38,099

EPA-wide

7,539

43.1%

27.7%

29.2%

714

EPA Hispanics

566

42.5%

26.6%

30.9%

44

EPA Non-Hispanics

6,461

44.2%

27.5%

28.3%

614

FEV Question 67: How satisfied are you with your opportunity to get a better job in your
organization?

Regarding FEVS question 67, the negative responses of EPA Hispanics was greater than the
negative responses of Government-wide, EPA-wide, and EPA non-Hispanics employees. The
percentage difference between the Hispanic response rate and the other response rates has
generally decreased. The greatest percentage difference each year was between EPA Hispanic
and EPA non-Hispanic employees. In FY17, the difference was 4.1%, but, in FY19, it had dropped
to 2.4%. The percentage differences are smaller between EPA Hispanic employees and
government-wide and EPA-wide employees.

3 The FY20 and 21 FEVS did not include these two questions.

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FY17 RESPONSES



Number of Responses

Positive

Neutral

Negative

Government-wide

466,843

37.1%

27.7%

35.3%

EPA-wide

9,147

33.5%

31.7%

34.8%

EPA Hispanics

647

33.6%

28.2%

38.2%

EPA Non-Hispanics

8,183

34.0%

31.9%

34.1%



FY18 RESPONSES



Number of Responses

Positive

Neutral

Negative

Government-wide

576,188

38.4%

27.6%

34.1%

EPA-wide

7,755

33.6%

32.3%

34.1%

EPA Hispanics

532

34.7%

29.7%

35.6%

EPA Non-Hispanics

6,855

34.0%

32.3%

33.6%



FY19 RESPONSES



Number of Responses

Positive

Neutral

Negative

Government-wide

584,169

40.7%

27.0%

32.3%

EPA-wide

8,029

37.1%

30.9%

31.9%

EPA Hispanics

607

41.0%

25.5%

33.6%

EPA Non-Hispanics

7,075

37.5%

31.3%

31.2%

Further Analysis: Determine whether evidence exists to corroborate employee perceptions. For
example, in EPA's barrier analysis report regarding the use of the Schedule A Hiring Authority,
the survey results contained evidence that supervisors and managers had witnessed biased
statements made about candidates actual or perceived disabilities

PHASE II - DATA REVIEW-AGENCYWIDE UPWARD MOBILITY SURVEY

1. Background

Originally, the second phase of data collection called for conducting open-door focus groups of
employees (Hispanic and non-Hispanic) in the four EPA offices with the largest number of
Hispanic employees: EPA Headquarters (HQ), Region 2, Region 6, and Region 9. The plan was to
hold two concurrent sessions: one for managers and one for non-managers with a team of EPA
facilitators to facilitate each session. OCR scheduled the initial session for March 10, 2019;
however, due to the COVID-19 pandemic it had to cancel the focus group sessions.

Instead, OCR decided to conduct an online survey. The purpose of the survey was to collect
qualitative information on employee perceptions toward upward mobility opportunities at EPA.
This was the first time EPA issued a survey of this nature agencywide. Specifically, the online
survey sought to collect data on employees' perspectives on upward mobility issues, such as
Individual Development Plans (IDPs), training, and mentoring/coaching. The survey provided
OCR the opportunity to expand EPA participation to all employees.

The survey was created by OCR's Affirmative Employment Analysis and Accountability office, in
conjunction with the Hispanic Employment Program (HEP), an EPA Special Emphasis Program
(SEP). The survey consisted of forty-nine questions. Participants had the option to include
demographic information voluntarily and anonymously.

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The responses were evaluated by OCR staff and SEP managers from the HEP. They grouped the
responses into common themes. Below is a brief snapshot of survey results. The survey served
as an informal tool to collect information on employee perceptions.

2. The Upward Mobility Survey

On March 10, 2021, OCR issued an agencywide mass mailer announcing that it had opened the
Upward Mobility Survey and encouraged all employees to complete it. The purpose of the
survey was to collect information on employee perceptions, in particular, Hispanic employees,
regarding upward mobility/career advancement at EPA.

The Survey consisted of five sections:

I.	Demographic Information

II.	Training

III.	Individual Development Plan

IV.	Mentoring/Coaching

V.	Upward Mobility

The survey remained open for three weeks; it closed on March 31, 2021.

SURVEY RESULTS:

The following is a summary of the survey tabulations. Appendix I includes the table of results.
For many questions, e.g., identify your EPA organization, a survey respondent could select from
multiple options provided. Other survey questions were open-ended. For conciseness, EPA
aggregated the responses of the multiple-choice and open-ended questions. All questions were
optional and not all respondents provided responses to every question.

Section I - Demographic Questions

•	At the time of the survey, EPA's workforce consisted of 14,848 total employees. 2,486 or
16.7% of employees responded to the survey.

•	At the time of the survey, EPA had 1,077 total Hispanic employees, which represented
7.25% of the EPA's total workforce.

•	395 survey respondents identified as Hispanic. These respondents represented 15.9% of
the 2,486 survey respondents and 36.7% of the 1,077 Hispanic employees at EPA. The
high percentage of employees that identified as Hispanic - the survey's main target
audience — suggests that surveys can be valuable tools for gathering barrier analysis
information.

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Section II - Training

•	68% of the survey respondents believe training is an important component in their
career path. The majority of respondents stated that they determine their training and
developmental skill needs through self-assessments and PARS discussions with their
manager/supervisor.

•	Most survey respondents believe that their supervisors/managers are supportive of
their professional growth and developmental opportunities.

•	The most common and second most common response non-Hispanic and Hispanic
female employees who stated supervisors/managers provided "no support" for
professional growth or career development were employee/supervisor issues and
funding. It was the reverse for Hispanic male employees. Time constraint was the third
most common reason provided by all three groups, although that response was tied
with discrimination amongst Hispanic male and Hispanic female employees who
responded to that question.

•	Most survey respondents stated that they have a career goal of advancing to a
supervisor/manager position and most respondents that have such a career goal
expressed interest in the SES.

•	Most survey respondents stated Non-Technical (Leadership/Management) as the area
where they needed improvement. Hispanic female respondents mentioned ECQ Skill
training as an area where they needed training.

•	Most survey respondents stated that they had participated in a career developmental
opportunity (CDO) program: FedTalent training was the most popular (31%) and Full-
Time Detail Assignments (21%) was the second most popular.

Section III - Individual Development Plan

•	Most survey respondents stated that they are aware of IDPs and recognize them as a
tool that provides benefits, such as setting career goals, improving communication with
supervisors/managers, and identifying training needs. Respondents stated that
employees take the lead to develop the IDP. For those respondents with an IDP, they
stated that they discussed the IDP with their managers.

•	Most survey respondents stated that they did not have an IDP. 67% of non-Hispanic
employees stated that, with Hispanic males above that percentage at 70% and Hispanic
females below that percentage at 64%. Most respondents that did not have an IDP
stated that it was because it is not a priority for the manager or because the respondent
finds it to be a waste of time.

Section IV- Mentoring and Coaching

•	Most survey respondents stated that they have a mentor or coach, who provide career
advice, feedback, and networking.

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•	Most survey respondents stated that they did not obtain their mentor/coach through an
EPA program.

•	Hispanic male (28%) and female (28%) respondents more often stated that they were
unaware that EPA offered mentors and coaches as compared to non-Hispanic
respondents (23%). Non-Hispanic respondents (28%) more often stated that they
utilized EPA's various mentoring and coaching programs as compared to Hispanic male
(22%) and female (27%) respondents.

Section V- Upward Mobility

•	Approximately 60% of survey respondents expressed interest and believed themselves
eligible for upward mobility opportunities into management positions; however,
approximately 70% stated that they had not applied for these opportunities or for an
upward mobility promotional detail in the last two years.

•	Nearly two thirds of non-Hispanic (61%) and Hispanic female (60%) respondents who
applied for an upward mobility management opportunity in the last two years
responded that they were asked to interview. In contrast, only about a third of Hispanic
male (36%) respondents who applied for an upward mobility management opportunity
in the last two years stated they were offered an interview.

•	Nine percent of Hispanic female respondents, 10% of non-Hispanic respondents, and
11% of Hispanic male respondents stated that they were selected for an upward
mobility opportunity in the last two years.

•	For survey respondents who were not selected, the majority stated that they reached
out to the hiring official to discuss their nonselection. The majority of Hispanic male and
female employees stated that they agreed with the feedback provided, while the
majority of non-Hispanic employees stated they did not. Survey respondents provided
limited information as to why they agreed or disagreed with the feedback received. For
those that agreed with the feedback, some of the responses they provided included an
identified need to obtain additional career experience or develop skills. For those that
disagreed, some stated they believed it was due to discrimination or pre-selection.

•	Most respondents selected "traditional" methods (i.e., training, improving skills sets,
and acquiring career experience) as the best way to advance their EPA career.

•	51% of Hispanic male and female respondents stated that there were no workplace
barriers to their career advancement at EPA because they are Hispanic. 49% of Hispanic
male and female respondents stated there were workplace barriers to their career
advancement at EPA because they are Hispanic. The most common workplace barriers
Hispanic survey respondents stated included the following:

o	Discrimination, stereotypes, biases

o	Flawed hiring process (including upward mobility)

o	Lack of management support

o	Lack of career development opportunities

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• Most non-Hispanic, Hispanic male, and Hispanic female respondents stated that they
did not believe there were current workplace barriers to career advancement due to
EEO protected bases. However, for those that stated that they believe workplace
barriers existed due to EEO protected bases, race was the leading basis identified by
non-Hispanic, Hispanic male, and Hispanic female respondents. Hispanic male
respondents stated that national origin was second leading basis, while Hispanic female
respondents stated national origin was third leading basis behind race and color.

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Next Steps

The agency has commenced an Upward Mobility analysis based on race and sex. The data and
information collected as part of this trigger identification analysis on upward mobility of
Hispanic employees will help inform that analysis. As the agency develops better and improved
tools to implement for national barrier analysis, it will apply them to the Hispanic upward
mobility analysis. The agency will also develop guidance to assist region and program offices in
conducting a review of their respective office data for EEO triggers and barriers.

In FY23, the agency will include improved analysis techniques. The trigger identification analysis
on the upward mobility of Hispanic employees at the agency from the GS13 to SES levels
identified the need for a more refined and inclusive upward mobility benchmark to determine
triggers. The new benchmark will seek to address that only certain occupations have a career
path to the senior grade levels. The new benchmark will also attempt to account for the fact
that the agency fills positions internally and externally. Analysis in FY23 may also identify other
areas to improve the benchmark.

Furthermore, the trigger analysis should determine the appropriate significance to prioritize a
trigger for further investigation. For example, determining what is a significant number of
complaints alleging failure to promote/non selection based on national origin (Hispanic) over
the last five years.

The employee survey identified that some employees perceive that there may be workplace
barriers for career advancement at EPA for Hispanic employees. The agency will determine
whether there is evidence to support such perceptions, including by reviewing outreach,
recruiting, and upward mobility applicant flow data. The agency also will hold listening sessions
for all employees on upward mobility issues/concerns and review the use/deployment of IDPs.

Finally, OCR recommends that each EPA region and program office conduct an organization
specific trigger identification analysis, and program offices. OCR invites all region and program
offices to join it in FY23 as it proceeds with the nationwide Hispanic upward mobility analysis.
Such participation should help each region and program office conduct its respective region or
program office analysis.

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Appendix 1. Upward Mobility Survey

SECTION I - Demographic Questions

Are you Hispanic/Latino-A person of Cuban, Mexican, Puerto Rican, South or Central American,
or other Spanish culture or origin, regardless of race?

Options

Count

Percentages

Yes

395

16.07%

No

2063

83.93%



Total = 2458



Please select the racial category or categories with which you most closely identify. Select as
many as apply.

Options

Count

Percentages

American Indian or Alaska Native

128

4.98%

Asian American

229

8.91%

Black or African American

470

18.30%

Native Hawaiian or other Pacific Islander

14

0.54%

White

1728

67.26%



Total = 2569



How long have you been an em

Dloyee of the Environmental Protection Agency?

Options

Count

Percentages

0-5 Years

690

27.89%

6-10 Years

243

9.82%

11-15 Years

370

14.96%

16-20 Years

306

12.37%

21+ Years

865

34.96%



Total = 2474



3lease select your organization.

Options

Count

Percentages

Office of the Administrator (OA)

45

1.83%

Office of Air and Radiation (OAR)

205

8.32%

Office of Chief Financial Office (OCFO)

63

2.89%

Office of Chemical Safety and Pollution Prevention (OCSPP)

171

6.94%

Office of Enforcement and Compliance Assurance (OECA)

139

5.64%

Office of General Counsel (OGC)

41

1.66%

Office of Inspector General (OIG)

15

0.61%

Office of International and Tribal Affairs (OITA)

9

0.37%

Office of Land and Emergency (OLEM)

100

4.06%

Office of Mission Support (OMS)

170

6.90%

Office of Research and Development (ORD)

210

8.52%

Office of Water (OW)

80

3.25%

Region 1

63

2.56%

Region 2

83

3.37%

Region 3

150

6.09%

Region 4

108

4.38%

Region 5

155

6.29%

Region 6

170

6.90%

Region 7

118

4.79%

Region 8

79

0.28%

Region 9

212

8.60%

Region 10

78

3.17%



Total = 2464



16


-------
What is your current grade leve

?

Options

Count

Percentages

GS 1-4

13

0.53%

GS 5-7

52

2.12%

GS 8-10

129

18.99%

GS 11

113

4.61%

GS 12

352

14.37%

GS 13

984

40.16%

GS 14

445

18.16%

GS 15

309

12.61%

SES

53

2.16%



Total = 2450



Are you currently a permanent EPA employee?

Options

Count

Percentages

Yes

2429

98.34%

No, 1 am a temporary EPA employee

41

1.66%



Total = 2470



SECTION II -Training Questions

How important do you believe training is to your career path?

Options

Count

Percentages

0- Not at All Likely

19

0.8%

1

16

0.7%

2

29

1.2%

3

48

2.0%

4

39

1.7%

5

113

4.8%

6

162

6.9%

7

334

14.2%

8

482

20.5%

9

338

14.4%

10 - Extremely Likely

773

32.9%

Total

2353



How do you determine your training and developmental skills needs? (Select all that apply)

Options

Count

Percentages

PARS4 discussion with my manager/supervisor

1693

25.40%

Feedback from my Mentor or Coach

823

12.34%

FedTalent training Programs

789

11.83%

Self-assessment

2005

30.07%

Discussions with work colleagues who are not in
management

1357

20.35%



Total = 6667



Do you discuss your training and or developmental skills needs wit

n your supervisor/manager?

Responses

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

YES

1731

85%

124

82%

181

84%

NO

316

15%

28

18%

35

16%

TOTAL

2047



152



216



4 Performance Appraisal and Recognition System (PARS).

17


-------
Is your supervisor/manager supportive when you have indicated that you want to apply for
arofessional growth and developmental training opportunities?

Responses

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

YES

1778

88%

131

86%

177

85%

NO

235

12%

21

14%

32

15%

TOTAL

2013



152



209



If No, list why not?

Non-Hispanic
Top Responses

Non-Hispanic
Responses &

% of all
Responses

Hispanic Male
Top Responses

Hispanic Male
Responses & %
of all
Responses

Hispanic Female
Top Responses

Hispanic Female
Responses
& % of all
Responses

Issues with
supervisor/not a
priority

126 = 51%

Funding

8 = 32%

Issues with
supervisor/not a priority

18 = 49%

Funding

66 = 27%

Issues with
supervisor/not a priority

6 = 24%

Funding

9 = 24%

Time Constraints/
FTEs

53 = 22%

Time Constraints - FTE

3 = 12%

Time Constraints - FTEs

3 = 8%





Discrimination/Favoritism

3 = 12%

Discrimination/Favoritism

3 = 8%

TOTAL

245 of 349
responses



20 of 25
responses



33 of 37
responses

Do have a career goal to advance to a management or supervisor position including Senior
Executive Service (SES) positions?

Options

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

YES - 1 am interested
in a management or
supervisor position -
but not in the SES

434

22%

40

27%

59

29%

YES - 1 am interested
in a management or
supervisor position -
including the SES

656

33%

71

48%

76

37%

No

902

45%

37

25%

72

35%

Totals

1992



148







Which of the following are areas you believe you need to improve the most for a management
opportunity? (Select all that apply)

Top Three Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic
Female
Responses

%Response

Non-Technical skills

546

53%

59

57%

70

57%

(Leadership/Management)













Technical skills

215

21%

20

19%

14

11%

(Subject Matter Expertise)













Both Non-Technical Skills

276

27%

25

24%

40

32%

and Technical Skills













TOTAL

1037







124



18


-------
What are your most critical Non-Technical skills

Leadership/Management) training needs?

Top Three Responses

Non-Hispanic Responses

Hispanic Males Responses

Hispanic Females Responses

1

General Training

General Training

General Training

2

Leadership/Management
Training

Leadership / Management
Training

Leadership / Management
Training

3

Detail or Temporary Promotion

Detail or Temporary Promotion

ECQ-Skill Set

What are your most critical Technical skills (Sub

ect Matter Expertise) training needs?

Top Three Responses

Non-Hispanic Responses

Hispanic Males Responses

Hispanic Females Responses

1

Subject Matter Expertise

Subject Matter Expertise

Subject Matter Expertise

2

Additional Career Experience /
Knowledge

General Training

Additional Career Experience /
Knowledge

3

General Training

Additional Career Experience /
Knowledge

General Training

If you had to prioritize between technical and non-technical skills training, which would be
more important to you?

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

Non-Technical skills

658

62%

66

60%

87

66%

(Leadership/Management)













Technical skills (Subject

404

38%

44

40%

45

34%

Matter Expertise)













TOTAL

1062



110



132



Based on your priority selection between technical and non-technical skills training. Why is one
more important to you than the other?

Priority

Non-Hispanic Responses

Hispanic Males Responses

Hispanic Females Responses

1

Technical Training

Non-Technical and Technical
Training (tied)

Non-Technical Training

2

Non-Technical Training



Technical Training

Select the career developmental opportunities you have participated in: (Select all that apply)

Options

Count

Percentages

EPA Career Coaching Program

467

9.82%

Executive Potential Program (e.g., USDA Graduate School)

157

3.30%

External Fellowship (e.g., Excellence in Government Fellows

105

2.21%

Program





FedTalent-Training Library Course

1480

31.12%

FEI Career Development Program

142

2.99%

Full-Time Details & Temporary

1004

21.11%

Lateral Reassignments

518

10.89%

Leaders and Learners Program, External Fellowship (e.g.,

383

8.05%

Excellence in Government Fellows Program)





SES Career Developmental Program

43

0.90%

Skills Marketplace (Part-time Projects)

344

7.23%

Treasury Executive Institute Career Coaching Program

113

2.38%



Total = 4756



Which career developmental opportunities would you like to learn more about (Select all that
apply)

Options

Count

Percentages

EPA Career Coaching Program

810

11.57%

Executive Potential Program (e.g., USDA Graduate School)

740

10.57%

External Fellowship (e.g., Excellence in Government Fellows Program

770

11.00%

FedTalent-Training Library Course

309

4.41%

FEI Career Development Program

651

9.30%

19


-------
Full-Time Details & Temporary

811

11.58%

Lateral Reassignments

527

7.53%

Leaders and Learners Program, External Fellowship (e.g., Excellence in
Government Fellows Program)

662

9.45%

SES Career Developmental Program

725

10.35%

Skills Marketplace (Part-time Projects)

493

7.04%

Treasury Executive Institute Career Coaching Program

504

7.20%



Total = 7002



SECTION III - Individual Development Plan Questions

Are you familiar with the term Individual Development Plan (IDP)?

Top Responses

Non-
Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

YES

1805

93%

120

79%

192

89%

NO

242

7%

31

21%

23

11%

TOTAL

2047



151



215



f yes, how did you learn about IDPs?

Top Three Responses

Non-Hispanic Responses

Hispanic Males Responses

Hispanic Females Responses

1

EPA Training /SEPMs5

PARS Supervisor / Manager

EPATraining

2

PARS Supervisor / Manager

EPATraining

PARS Supervisor / Manager

3

Another Agency

Colleague

Career Internship

Do you currently have an Individual Development Plan (ID

P)?

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

YES

591

33%

36

30%

68

36%

NO

1194

67%

83

70%

120

64%

TOTAL

1785



119



188



f yes, describe the benefits and/or limitations of having an IDP.

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

Career Goals/Structure

28

80%

1

100%

0

0%

Expectations/Communication
with Manager/Supervisor

4

11%

0

0

2

40%

Identify Training Needs

3

9%

0

0%

2

40%

In Progress - Developing IDP

0

0%

0

0%

1

20%

TOTAL

35



1



5



f you asked for an IDP, did your supervisor/manager work with you to execute and agreement?

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

YES

431

35%

30

35%

64

47%

NO

807

65%

56

65%

72

53%

TOTAL

1238



86



136



If no, why not?

5 Special Emphasis Program Managers (SEPMs).

20


-------
Top Three Responses for Non-
His panics

Top Three Responses for Hispanic
Males

Top Responses for Hispanic Females

IDP not a priority for manager

IDP not a priority for manager

IDP not a priority for manager

Did Not Ask for One-Waste of Time

Did Not Ask for One-Waste of Time

Various Other Responses: Lack of funding; Developed IDP
on own, In Progress of developing

Not Sure

Not Sure

Various Other Responses: Lack of funding; Developed IDP
on own, In Progress of developing

Do you discuss your IDP with your manager throughout the fiscal year?

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

% Response

Hispanic Female
Responses

% Response

YES

307

54%

21

60%

34

52%

NO

263

46%

14

40%

31

49%

TOTAL

570



35



65



SECTION IV- Mentoring and Coaching Questions

Are you aware that EPA offers mentors or coaches that are available to provide you career
advice/feedback?

Options

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

Yes

1567

77%

108

72%

154

72%

No

469

23%

44

28%

61

28%

Total

2036



152



215



Do you currently have a mentor or a coach that provides you with career advice/feec

back?

Options

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

Mentor

543

71%

28

60%

67

72%

Coach

128

17%

9

20%

15

16%

Both a Mentor and
Coach

95

12%

9

20%

11

12%

Total

766



46



93



Did you obtain your mentor or coach through one of EPA's programs (e.g., Leaders and
.earners, EPA Career Coaching Program, etc)?

Options

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

% Response

Yes

356

28%

22

22%

39

27%

No

919

72%

80

78%

106

73%

Total

1275



102



145



fyes, please identify which

EPA Program?

Top Three Responses

Response

1

EPA Career Coaching

2

EPA Leaders & Learners Mentoring Program

3

Mentoring Program

If you have a mentor or coach, what do you consider to be the benefits of having one and has a
mentor or coach helped your career advancement?

Options

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

No Assistance

8

11%

0

0%

1

7%

21


-------
Provides Career Advice -
Feedback - Networking

64

89%

1

100%

14

93%

Total

72



1



15



SECTION V- Upward Mobility

Are you interested in upward mobility opportunities into management positions?

Options

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

Yes

930

46%

96

65%

125

57%

No

564

28%

24

16%

37

17%

Maybe

539

27%

29

19%

56

26%

Total

2033



149



218



Are you eligible for upward mobility opportunities into management positions?

Options

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female

%

Response

Yes

1281

67%

113

79%

121

60%

No

624

33%

30

21%

81

40%

Total

1905



143



202



If eligible, have you applied for upward mobility management opportunities in the last two
years?

Options

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

Yes

422

25%

46

34%

54

30%

No

1276

75%

88

66%

125

70%

Total

1905



134



179



f yes, were you asked to interview for the position?

Options

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

Yes

369

39%

42

54%

47

40%

No

585

61%

36

46%

70

60%

Total

1698



78



117



n the last two years, were you selected for an upward mobility management position?

Options

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

No

1479

90%

118

91%

164

91%

Yes, Manager-Non-
Supervisor

52

3%

1

1%

8

4%

Yes, Manager-
Supervisor

94

6%

8

6%

9

5%

Yes, SES

12

1%

2

2%

0

0%

Total

1637



129



181



f you recently interviewed for a position in the last two years, was an interview panel used?

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

% Response

YES

677

64%

58

62%

46

94%

NO

385

36%

36

38%

3

6%

TOTAL





94







22


-------
Have you applied for an upwarc

mobility

promotional) detail in the

ast two years?

Top Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

YES

391

22%

38

28%

59

29%

NO

1411

78%

96

72%

145

71%

TOTAL

1802



134



204



If yes, were you selected?

Top Responses

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

YES

173

46%

15

41%

30

54%

NO

206

54%

22

59%

26

46%

TOTAL

379



37



56



If you applied for an upward mobility (promotional) detail in the past two years and you were
not selected, did you contact the hiring manager/selecting official to discuss why not selectee

Responses

Non-Hispanic
Responses

% Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

YES

146

52%

18

60%

24

59%

NO

136

48%

12

40%

17

41%

TOTAL

279



30



41



f yes, do you agree with reasons/feedback management provided? Yes or No. Explain why.

Responses

Non-Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

YES

36

34%

17

55%

11

55%

NO

71

66%

14

45%

9

45%

TOTAL

107



31



20



What is your opinion on how to

aest advance your career at EPA?

Top Responses

Non-
Hispanic
Responses

%

Response

Hispanic Male
Responses

%

Response

Hispanic Female
Responses

%

Response

Traditional (training, develop
skills, and career experience)

404

86%

37

82%

51

91%

Don't Know the Answer

33

7%

3

7%

3

5%

No interest

19

4%

2

4%

1

2%

Leave the Agency

15

3%

3

7%

1

2%

TOTAL

471



45



56



If you are Hispanic, do you believe there are any current EPA policies, practices or procedures
that are barriers to your career advancement because you are Hispanic?

Options

Hispanic Males Responses

%

Hispanic Females Responses

%

Yes

59

49%

86

49%

No

61

51%

90

51%

Total

120



176



f yes, what are the current workplace barriers that you believe exist?

TOP RESPONSES

Hispanic Males
Responses

%

Hispanic Females
Responses

%

Discrimination, Stereotypes, Biases

36

46%

47

48%

Hiring Process, Preselection, Selection, Upward
Mobility Process

21

27%

24

25%

Lack of Management Support

11

14%

20

20%

Lack of Opportunities or Development Program

11

14%

7

7%

TOTAL

79



98



23


-------
Do you believe there are any current EPA policies, practices or procedures that are barriers to
your career advancement due to your race, color, religion, sex (including pregnancy), national
origin, sexual orientation, gender identity, age (40 or older), disability, or genetic information?

Options

Non-Hispanic
Responses

%

Hispanic Males
Responses

%

Hispanic Females
Responses

%

Yes

617

41%

51

43%

75

45%

No

898

60%

66

56%

92

55%

Total

1515



117



167



f Yes, please identi

:y the basis/bases? (Select all that apply)

BASE

Non-Hispanic
Responses

% Response

Top 5

Hispanic Male
Responses

%

Response

Top 5

Hispanic Female
Responses

% Response

Top 5

Age (40 or older)

332

21%

2

20

14%

3

20

11%

5

Color

242

15%

4

18

13%

4

34

18%

2

Disability

107

1%

5

10

1%



11

6%



Gender Identity

77

5%



3

2%



7

4%



Genetic Information

17

1%



0

0%



3

.01%



National Origin

91

6%



24

17%

2

32

17%

3

Race

347

22%

1

39

28%

1

48

25%

1

Religion

50

3%



6

4%



3

2%



Sex (including pregnancy)

271

17%

3

11

8%

5

29

15%

4

Sexual Orientation

58

4%



9

6%



6

3%



TOTAL Responses

1592





140





193





24


-------