Justification of Emergency Processing Memo - DEIA Survey

June 16, 2022

MEMORANDUM
TO:

Michael McManus, USAID Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget

FROM:

Neneh Diallo, Chief Diversity Officer

SUBJECT:

Justification for Emergency Processing

Background
From the start, the Biden-Harris Administration has emphasized the importance of our Federal
public servants—our dynamic and committed workforce. The strength of any organization rests on
its most important asset—its people. Taking the President’s lead, the President’s Management
Council (PMC), together with the Office of Management and Budget, the Office of Personnel
Management, and the General Services Administration, launched a pilot of a first-ever,
Government-wide pulse survey, inviting roughly 2 million civilian employees across the 24
agencies represented by the PMC to respond with a quick “pulse check,” so that agency leadership
could hear from employees on three timely topics:
● Navigation of the ongoing pandemic and the safe, increased return of Federal employees to
physical workplaces
● Equity and inclusion
● Employee engagement and burnout
While the pilot, known as the Federal Employee Viewpoint Survey (FEVS), seeks to capture
employee experiences around an Agency’s climate, in order to provide insights into whether, and to
what extent workplace conditions are successful, and to inform organizational change and
development initiatives, it is not representative of or captures the viewpoints of all of USAID’s
workforce around Diversity, Equity, Inclusion, and Accessibility (DEIA).

Justification
5 C.F.R. § 1320.13(a)(2) allows for emergency processing of collections of information in instances
where an agency “... cannot reasonably comply with the normal clearance procedures under this
part because... (i) Public harm is reasonably likely to result if normal clearance procedures are
followed.”
USAID’s workforce comprises various hiring categories, including U.S. Direct Hires (USDHs),
Personal Services Contractors (PSCs), and Institutional Support Contractors (ISCs). Of our entire
workforce of approximately 11,000 individuals, more than 5,500 are PSCs with almost 1,500 ISCs,
comprising around 64% of our entire workforce.
The annual Agency-wide DEIA survey will establish a baseline for DEIA related metrics and
enable longitudinal evaluation at the Agency level and within Bureaus, Independent Offices and
Missions (B/IO/M). The USAID DEIA survey will support USAID’s implementation of
government-wide initiatives to strengthen DEIA in the federal workforce and deliver equitable
outcomes for the American people through the Agency’s outward-facing policies, programs,
regulations, contracting opportunities, and services. Development and implementation of the survey
will be conducted in accordance with guidance from the White House Domestic Policy Council
(DPC), U.S. Equal Employment Opportunity Commission (EEOC), U.S. Office of Personnel
Management (OPM), and U.S. Office of Management and Budget (OMB).
The Biden-Harris Administration’s Government-wide DEIA Strategic Plan released in November
2021, specifically outlines a priority to “improve the collection of voluntarily self-reported
demographic data about the federal workforce to take an evidence-based approach to reduce
potential barriers in hiring, promotion, professional development, and retention practices.”
The inaugural USAID DEIA Survey will, to the greatest extent practicable or appropriate:
● Capture the viewpoints and perceptions of USAID headquarters and overseas workforce
across all hiring mechanisms and at all grades and ranks
● Allow for data disaggregation by B/IO/M, consistent with the Federal Employee Viewpoint
Survey
● Provide data for analysis to support an evidence-based and data-driven approach to
determine whether and to what extent Agency policies, programs, and/or practices present
barriers to equal and equitable employment opportunities and outcomes, and what needs to
be changed or developed to remove those barriers
● Support USAID’s efforts to monitor and report on DEIA and EEO program effectiveness,
enabling continuous program improvement
Currently, USDHs and PSCs voluntarily report demographic data only on race, ethnicity, sex at
birth, and disability status. Only USDH data is analyzed and reported to the EEOC in the annual
Management Directive (MD) -715 Report. USAID, like most federal government agencies, does
not collect data on sexual orientation or gender identity, which results in a data gap that prevents
analysis to identify potential areas of underrepresentation of Lesbian, Gay, Bisexual, Transgender,
Queer and Intersex (LGBTQI+) people and the barriers to equal employment at USAID for
LGBTQI+ people; resulting in invisibility, biases, and inefficient policies and programming

USAID’s leadership continues to advocate for all of our employees to be able to participate in
government-wide initiatives to ensure evidence-based decision making and action-planning.
Therefore, it is imperative that we request emergency processing for this expanded data collection,
so as to not cause further harm and invisibility of certain groups in our workforce. By expediting
this review, we will be able to improve the quality and effectiveness of public policy, ensure
inclusion and equity, and gain useful and meaningful insights into USAID’s climate around DEIA.
This survey collection will allow respondents to voluntarily and anonymously submit responses.
The data collected will in turn be provided in aggregate to USAID stakeholders to review, analyze,
and identify trends, including viewpoints and perceptions of all groups in USAID’s workforce,
using demographic data in a variety of ways including:
● Overall Agency and B/IO/M level;
● Hiring category/mechanism (e.g., federal employee (permanent or temporary), personal
services contractor, institutional support contractor, Cooperating Country National);
● Sexual Orientation and Gender Identity (USDHs, USPSCs, ISCs); and
● Expanded Race and Ethnicity Questions (USDHs, USPSsC, ISCs)
This “do no harm” approach will allow USAID to perform its decision-making in a manner that
does not tolerate or contribute to inequity, discrimination, exclusion, or stigma toward any
population or group, avoiding public harm. Survey data will be limited to authorized channels
within USAID; a privacy review and risk assessment will be conducted prior to sharing survey
results. Additionally, upon successful completion of the survey, the Agency will determine whether
expanding demographic data collection is feasible to collect within Agency-wide systems that allow
for more comprehensive workforce data reporting.
With no Government-wide effort, USAID decided that it needed to contact the Office of
Information and Regulatory Affairs (OIRA) to find a way to move forward independently in order
to be able to conduct a DEIA survey inclusive of our entire workforce.
In order to promote the priorities of this Administration as outlined in Executive Order 14035:
Diversity, Equity, Inclusion and Accessibility in the Federal Workforce; Executive Order 13985:
Advancing Racial Equity and Support for Underserved Communities through the Federal
Government; Executive Order 14031: Advancing Equity, Justice, and Opportunity for Asian
Americans, Native Hawaiians, and Pacific Islanders; and Executive Order 13988: Preventing and
Combatting Discrimination on the Basis of Gender Identity or Sexual Orientation in a
timely-manner, USAID needs to collect information from all categories of the workforce in order to
institutionalize these priorities.
The survey is broken down into 6 main categories on a 5-point Likert scale.
11 profile questions, 7 equity questions, 14 accessibility questions, 13 diversity questions, 38
inclusion questions, and 29 talent impact questions.
Therefore, USAID respectfully requests emergency approval to launch the DEIA Survey to staff
who have a usaid.gov e-mail address irrespective of their employment status to be administered as
quickly as possible, with a total of up to an estimated 11,000 respondents, as the information
obtained in the survey would inform Agency leadership and support decision making in delivering
on President Biden’s mandate in the previously mentioned Executive Orders. USAID cannot

reasonably comply with the normal clearance procedures under the PRA because doing so would
delay the Agency's efforts to assess and provide ongoing, real-time input to our workforce around
DEIA and act appropriately to any findings to ensure all the workforce feels supported and
empowered. As such, we request expedited approval of this information collection. The Agency
will issue a Federal Register Notice notifying the public of this request.

Sincerely,
Neneh Diallo

DJEINABU N
DIALLO
(affiliate)

Digitally signed by
DJEINABU N DIALLO
(affiliate)
Date: 2022.07.07
16:33:54 -04'00'

Neneh Diallo, Chief Diversity Officer
Office of the Administrator
Office of the Chief DEIA Officer