Response
On November 23, 2021, the White House released the Government-wide Strategic Plan to Advance. Diversity, Equity, Inclusion, and Accessibility in the Federal Workforce (https://www.whitehouse.gov/wp-content/uploads/2021/11/Strategic-Plan-to-Advance-Diversity-Equity-Inclusion-and-Accessibility-in-the-Federal-Workforce-11.23.21.pdf). (the “Plan”)
The Plan addresses many aspects of increasing DEIA in the federal workforce. The Plan is comprehensive and meaningful as it elevates all of the protected classes of the EEOC and extends the definition of those underrepresented in the federal workforce to include parents, immigrants, first-generation professionals, individuals with limited English proficiency, people from rural areas, and others. It establishes five operating principles, and lists eleven priority areas for every Department/Agency, and it acknowledges that efforts to increase DEIA in the federal workforce require time and a data-driven approach.
We applaud the Biden Administration’s efforts to advance diversity, equity, inclusion, and accessibility in the federal workforce. The Administration can build on the Plan by: (1) endorsing the enactment of the PLUM Act, which would increase the transparency of data collected by the federal government regarding officials in senior government positions, and (2) acting on the recommendations outlined below.
- Accountability Mechanisms: The Plan frequently indicates that Department/Agency leaders “should” advance DEIA policies; however, key concerns remain unaddressed, including:
o The accountability mechanisms to ensure these actions are taken; and
o The consequences if these actions are not taken (e.g., employment, compensation, promotion opportunities, etc.).
- Exit Interviews: We suggest the use of exit interviews during the off-boarding process of federal employees. These may be helpful in increasing the level of accountability among Department/Agency leadership. These exit interviews might be particularly useful sources of information on leaders who are politically appointed as these leaders are often not reviewed annually by Human Resources.
- Inclusion Rule for Hiring and Promotion: The Plan directs each Department/Agency to create multi-year hiring projections and develop outreach and recruitment plans to seek a diverse applicant pool to fill their hiring needs. We agree with this approach, but want to note that research shows that it is critical to put systems in place to ensure those hiring projections are met. The legal community’s Mansfield Rule is a great model to adopt/adapt. Learn more about our recommendations to increase diversity in hiring here: www.InclusiveAmerica.org/eo-diversity.
- Transparency of Data: Making the data collected for these efforts available to the American people is critical to ensuring and demonstrating that the Plan is working. Because data released by the White House Office of Presidential Personnel and by the Office of Personnel Management are often delayed and aggregated, it is difficult for the public to know whether the Plan is working or assess how it might be improved. The Administration should support the PLUM Act, which would help provide this data in a timely and transparent manner. Learn more about The PLUM Act here: www.InclusiveAmerica.org/bills-plum-act.
- Transparency of Plans: The Administration has not publicly disclosed its own DEIA reports (e.g., the Interagency Working Group on the National Security Workforce has developed but not publicly released at least two quarterly reports). The opacity of the Administration’s DEIA efforts reduces trust from federal employees, Employee Resource Groups, advocates and the general public.
- Accessible Technology: While the Plan indicates that each Department/Agency should build and sustain an accessible federal technology environment, so far we have not seen this happen. We are particularly concerned that the Intelligence Community has struggled to hire, retain, and promote People with Disabilities. Learn more about our recommendations to improve accessibility in the Intelligence Community here: www.InclusiveAmerica.org/eo-ic-pwd.
- Religious Inclusion: While the Plan recognizes diversity includes individuals who belong to communities that face discrimination based on their religion, religion is often treated as a less important protected class. Learn more about our recommendations to prevent and combat discrimination on the basis of religious belief and affiliation here: www.InclusiveAmerica.org/eo-religious-inclusion.