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Barriers
One of our responsibilities/duties as state AA/PI SEPMs is to “ensure that all NRCS activities are free from discrimination and that barriers to the recruitment, employment, and advancement of Asian Americans and Pacific Islanders are addressed. AA/PI EPMs assist in evaluating the effectiveness of the overall equal opportunity program in their organizational units and assist in identifying new and changing program needs.” (GM_230_403_E - Subpart E - Asian American/Pacific Islander Emphasis Program, 403.78 Duties and Responsibilities of Collateral Duty State and Center AA/PIEPMs). To aid/assist you with this ongoing endeavor, the following are some basic steps to ‘Barrier Analysis’.
Kurencio B. Ngowakl
Nat’l AA/PI Emphasis Prgrm Mgr
Email: kurencio.ngowakl@pb.usda.gov
Barrier Documents
Barrier Analysis Handbook July 2011 AAPI Data Analysis Training July 2011
Six steps to barrier analysis
The barrier analysis process is broken down into six steps: (1) review policies, practices, and procedures; (2) analyze source material; (3) identify triggers; (4) determine root cause of triggers; (5) if root cause is a barrier, devise an action plan to eliminate the barrier; and (6) the EEO professional should follow up on the identified barrier at regular intervals to determine the success of the action plan. Both EEO and Non-EEO professionals should be involved in the process of barrier analysis, incorporating ideas to make the process more complete. Upper-level management must also be invested in the process in order for it to be successful.
1. Review policies, practices, and procedures
An EEO professional needs to be familiar with the agency’s policies, practices, and procedures in order to identify barriers. The areas which should be the subject of review are those in the natural employment progression, i.e., recruitment, hiring, training and career development, performance incentives and awards, competitive and career-ladder promotions, supervisory and managerial selections, disciplinary actions, and separations. There may be other examples specific to a particular agency, such as the process for security clearances in Department of Defense agencies.
2. Source material
The source materials for identifying anomalies are varied. These materials were described in the previous section and include workforce statistics (such as those found in the MD-715 Report Data Tables), EEO complaints, EEO and Human Resources office interviews or data, union and advocacy group interviews or data, employee surveys, focus groups, exit interviews, and studies done by outside organizations. The EEO professional must study these sources to ensure that a thorough review is conducted.
3. Identify triggers
As described in the previous section on triggers, the EEO professional should look at the source data and determine if any triggers are evident. For example, there may be anomalies in the workforce data tables, or recurring EEO complaints on a particular issue, against a particular manager, or in a particular office or section of the facility. Another example would be exit interviews which identify bias in employment decisions that lead to the increased separation of a particular protected group.
4. Determine root causes of triggers
A barrier is the root cause of the trigger. The goal is to pinpoint the root causes. The process can be analogized to peeling an onion, stripping away layers until there is an answer to the question “Why?” a condition exists. A simple example may be that the agency learns from a review of data that it has a low participation rate of Asians in its total workforce. A logical next step may be to examine the applicant flow data. The applicant flow data shows that the agency is not getting applications from Asians, but primarily from white and black applicants. Why is this? The next step would be to review the recruitment policies and process. It turns out that the agency is only recruiting from three colleges that do not matriculate many Asians. Why? Is it because the three schools are the alma maters of the top agency officials? The barrier in this case would be that little or no recruitment is done at universities with more diverse student populations.
5. Action plan for elimination of barrier
This step is straightforward, but not always easy: the agency must establish a plan of action to address the identified barrier, the root cause of the undesired condition. The specific barrier along with the action plan should be described in Part I of the agency’s MD-715 Report and updated every year. In the example above, the action plan would be to begin to recruit at a more diverse set of colleges. This would not mean that the agency would need to stop recruiting at the three colleges but could simply expand recruitment to areas of the country that have larger concentrations of Asians and NHOPIs.
6. Follow-up
The final step, and one that is often overlooked, is to assess whether the devised action plan was successful at eliminating the identified barrier. Possible indicators of success are: the participation rate is up, the separation rate is down, there are reduced complaints, and favorable responses in surveys or exit interviews conducted after the action plan has been implemented. In the example above, the agency would look to see if the participation rate of Asians is beginning to rise and may specifically want to investigate whether more applications are being received from Asian candidates. If the plan did not result in a greater participation rate or an increase in applications, then the agency can conclude that either the wrong barrier was identified or the action plan gave rise to a new barrier. This follow-up process requires the EEO professional to conduct a continuous assessment and monitoring process from year to year.
