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Learn the legal requirements for hiring and promoting people with disabilities, understand the targeted disabilities, and know how to recruit qualified candidates. This session will cover the Rehabilitation Act, VA's hiring goals, Schedule A appointments, and steps to achieving hiring goals.
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Hiring and PromotingPeople with Disabilities Christy Compton VA Disability Program Manager Outreach and Retention DivisionOffice of Diversity and Inclusion
Learning Objectives Participants in this session will : • Learn the legal requirements for hiring and promoting people with disabilities. • Understand the targeted disabilities. • Understand the Schedule A excepted appointment authority. • Know how to recruit qualified candidates.
Rehabilitation Act Congress charged each federal agency to promote the hiring and retention of individuals with disabilities by: • Being a model employer through use of meaningful affirmative hiring, placement, and advancement opportunities; and • Preventing discrimination against applicants and employees with disabilities, and providing reasonable accommodation.
Targeted Disabilities EEOC Reports Participation Rate Annually for • In FY 2000, VA had 1.8% employees with targeted disabilities. • In FY 2010, the ratio was 1.55%
VA’s 2% Goal • Secretary Shinseki issued a memorandum on September 7, setting a hiring goal of 2%. • Of all hires in FY 2011, 2% are to be individuals with targeted disabilities. • On November 15, 2010, the Secretary asked the Executive Leadership Board if they were aware of the goal and if they felt they could meet it. (They said “yes.”) • Meeting the goal will be considered in the EEO performance element evaluation for SES level managers.
Hiring Individuals with Targeted Disabilities – Steps to Achieving Goals • Recruit specifically for this group. • If two candidates are equally qualified, encourage the hiring official to hire the one with a targeted disability. • Use the Schedule A non-competitive excepted appointment authority for Title 5 positions. (www.diversity.hr.va.gov/disabilities.htm) Note: Schedule A hires MUST complete the SF 256, so hires with targeted disabilities will definitely be counted toward the hiring goals.
OPM Guidance: • Agencies must increase their use of Schedule A. • Vacancy announcements must invite individuals with disabilities to apply. • All job announcements must state the physical requirements (and medical standards). • Job announcements must avoid creating barriers to applicants with disabilities. (Ex. Ability to communicate orally.) • Agencies must increase their hires and retention of individuals with targeted disabilities.
Schedule A Steps • Recruit suitable candidates with targeted disabilities. Obtain a resume and Schedule A letter. • Match the applicant to a funded Title 5 vacancy (does not have to be announced). • Give the resume/application to the hiring official. • If the manager agrees to interview the candidate, set up an interview, with accommodation if needed. • Coach any manager who has never interviewed or employed an individual with a disability.
Schedule A Steps, continued • The hiring official should not see the Schedule A letter if it specifies the disability. • When making an offer, inquire whether an accommodation will be needed. • Establish an on board date. • Arrange any requested accommodations. • Ensure that the accommodations will be installed and working by the new employee’s on board date.
Schedule A Appointments • We report the number of hires annually. • Three types of appointments are available: • Temporary • Time-limited (NTE) • Permanent Tip: If a candidate does not have a certification of job readiness, s/he can be hired in a temporary position and converted to Schedule A after satisfactory performance.
Schedule A Letters • Before they are hired, candidates must submit a Schedule A letter. A sample letter is on VA’s disability web page. • The letter provides proof of (long term or permanent) disability and certification of job readiness. This can be from a: • Licensed medical professional • Licensed VR Specialist • Any Federal, state, DC, or US territory agency that provides disability benefits.
Coding Information • The Nature of Action Codes (NOAC) are 170, 171, 190, 570, 571, and 590. • All Schedule A hires of individuals with disabilities fall under 213.3102(u). • The Legal Authority Code for individuals with: • Physical disabilities is WUM • Intellectual disabilities is WTA • Psychiatric disabilities is WTB
Conversion • After two years of satisfactory performance, a Schedule A employee should be converted to a career conditional position, and after another year, to career. • If there are any performance issues, the supervisor should inquire whether there is anything that can be done to help the employee perform better. (This opens the door for the employee to request an accommodation.) • Performance issues should be addressed the first year, not at the end of the second year.
Schedule A is Flexible • No job announcement is necessary. Allows VA to hire qualified individuals quickly, within one to two weeks, depending on the facility’s on-boarding process. • Schedule A candidates can apply after the announcement closes, up to the time a job offer is made. • Can be used for Title 5 positions at any GS/GM/WG grade level.
Schedule A is Flexible, continued • There is no limit to the number of times an individual can use Schedule A. • There is no requirement for an updated Schedule A letter. • There is no requirement for VA to “verify” the statements in the letter. • Veterans with disabilities can be hired via Schedule A.
Using Schedule A for Promotion • Federal agencies are required to provide promotion opportunities for employees with disabilities. • Employees who are in a “dead end” position and performing well may be interested in a promotion via Schedule A. • One VA facility is promoting employees from the top of 5-7-9 ladders to an 11-12-13 ladder using Schedule A. • Employees promoted in this manner will repeat the two year probation period.
Promoting Schedule A Employees • This is a very useful tool for retaining employees with disabilities who are an asset to the facility. • Employees with disabilities who are not under Schedule A can use Schedule A to obtain another position or a promotion non-competitively. • Not all employees with disabilities are aware of the Schedule A options. Each facility should identify employees with disabilities who have the education or skills making them eligible for a promotion.
Title 38 Positions • Since all Title 38 positions are non-competitive, Schedule A does not apply. • HR staff can recruit qualified candidates with targeted disabilities for Title 38 positions and submit their resumes to the hiring official. • Depending on the union rules, there may be no need to advertise the position. • Hiring officials should always be informed when a qualified individual with a targeted disability applies to a Title 38 position, even one that was announced.
VA has PWTDs in Title 38 Positions • 94 Medical Officers • 286 Nurses • 98 Practical Nurses • 118 Nursing Assistants • Several other job series have a smaller number of employees with targeted disabilities. • IT CAN BE DONE!
Promotion Potential and Retention • VA has a high separation rate for employees with targeted disabilities. • The Rehabilitation Act requires agencies to do affirmative hiring, placement, and provide advancement opportunities. • VA employees with targeted disabilities have a glass ceiling at the GS 12-13 level; in some facilities, the glass ceiling is much lower. • VA needs to place these individuals in career ladder positions and develop advancement opportunities for this group.
Where can I find qualified candidates? • Vocational Rehabilitation Agencies • Career One-Stop Centers • Veteran Service Organizations • Workforce Recruitment Program • Employer Assistance & Resource Network • Veterans with disabilities who are VA clients • The college or university office that provides services to students with disabilities.
Hiring Official “Dos” and “Don’ts” • Don’t ask an applicant if they have a disability or ask about the nature or severity of their disability. • Do focus on the applicant’s qualifications and skills. • Do use a list of questions and ask every candidate the same questions. • Do ask every applicant to describe or demonstrate how, with reasonable accommodation if necessary, they will perform the duties of the job. • Don’t eliminate a qualified applicant based on assumptions about their disability.
Best Practices • If an applicant submits a “Private Sector” resume but has good experience which would fit your vacancy, provide instructions for a federal resume or links to the OF 0612 or the USAJOBS resume builder. • If a candidate seems ideal, invite them to submit a resume in person and introduce the individual to appropriate hiring officials. • Educate local non-profit community agencies that provide employment services to people with disabilities, so they understand the Federal process.
Additional Guidance: • Schedule A applications must be accepted at the facility level; do not send candidates to USAJOBS. • Seek individuals with targeted disabilities for all pay levels; when they are limited to the lower pay grades it creates a negative impression. • Ensure that the hiring official understands the focus should be on the person’s abilities and skills. • Give Occupational Health a list of only the physical requirements that were listed on the job announcement.
Retention Issues • Your recruitment efforts are wasted if VA does not retain the employee. • If Occupational Health flags a disability, remember to seek appropriate accommodations before deciding the applicant can’t be hired. • Be alert for supervisors who dismiss a Schedule A employee before considering accommodation. • Find ways to ensure that the employee feels welcome and is integrated into the work force.
What are you doing? Share! • The Cleveland, OH MC created a booklet for local non-profits serving people with disabilities. The booklet explains the Federal employment process and Schedule A. They had significant improvement in hires this year. • The Birmingham, AL MC has HR staff who make an effort to introduce promising applicants with disabilities to hiring officials (which leads to actual interviews and hires). • VBA hires clients who are Veterans.
Resources VA’s Disability Program web site http://www.diversity.va.gov/programs/pwd.aspx VHA – Roberto.Rojo@va.gov VBA - Gwendolyn.Gantt@va.gov and Kenya.Brown@va.gov NCA – Perdita.Johnson-Abercrombie@va.gov VA Disability Program Manager Christy.Compton@va.gov Asst. Disability Program Manager Joe.Frazier4@va.gov