Equal Employment Opportunity Commission: Actions Taken, but	 
Agency Restructuring Efforts Could Benefit from a More Systematic
Consideration of Advisory Panel's Recommendations (28-OCT-05,	 
GAO-06-10).							 
                                                                 
In May 2001, EEOC and other federal agencies were directed by the
Office of Management and Budget (OMB) to prepare restructuring	 
plans to make government more responsive to citizens' needs. By  
June 2001, agencies were to submit a workforce analysis to OMB	 
that would include, for example, demographic information on the  
agency's employees and would serve as the baseline for		 
agency-specific restructuring plans. Agencies were to submit	 
restructuring plans to OMB with fiscal year 2003 budget 	 
submissions and annual performance plans. These submissions were 
due to OMB September 2001. OMB's directive required agencies with
more than 100 full-time employees to develop restructuring plans 
with the goal of flattening the federal hierarchy. The OMB	 
directive stated that plans should describe the specific	 
activities and actions each agency planned to take, associated	 
resources, expected outcomes, and tools to measure performance.  
In order to ascertain what progress EEOC has made in reorganizing
its operations, we determined (1) whether EEOC implemented OMB's 
directive to develop a restructuring plan and (2) what actions	 
EEOC is taking to restructure and make its operations more	 
efficient and effective.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-10						        
    ACCNO:   A40560						        
  TITLE:     Equal Employment Opportunity Commission: Actions Taken,  
but Agency Restructuring Efforts Could Benefit from a More	 
Systematic Consideration of Advisory Panel's Recommendations	 
     DATE:   10/28/2005 
  SUBJECT:   Accountability					 
	     Agency evaluation					 
	     Federal agency reorganization			 
	     Strategic planning 				 

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GAO-06-10

United States Government Accountability Office

GAO

                       Report to Congressional Requesters

October 2005

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Actions Taken, but Agency Restructuring Efforts Could Benefit from a More
          Systematic Consideration of Advisory Panel's Recommendations

GAO-06-10

                                    Contents

        Letter                                                              1 
                                    Summary of Findings                     3 
                                        Conclusions                         5 
                            Recommendation for Executive Action             5 
                            Agency Comments and Our Evaluation              5 
      Appendix I                      Briefing Slides                  
      Appendix II    Sixty-four Recommendations from the National      
                         Academy of Public Administration to EEOC      

      Appendix III     Comments from the U.S. Equal Employment       
                                  Opportunity Commission                   34 
                                       GAO Comments                        44 
       Appendix IV         GAO Contact and Staff Acknowledgments     

  Related GAO Products

Abbreviations

EEOC Equal Employment Opportunity Commission NAPA National Academy of
Public Administration OMB Office of Management and Budget

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separately.

United States Government Accountability Office Washington, DC 20548

October 28, 2005

The Honorable Frank R. Wolf
Chairman
The Honorable Alan B. Mollohan
Ranking Member
Subcommittee on Science, the Departments of State,

Justice, and Commerce, and Related Agencies Committee on Appropriations
House of Representatives

The Honorable Jose E. Serrano House of Representatives

The Equal Employment Opportunity Commission (EEOC) promotes equal
opportunity in the workplace and enforces federal laws that prohibit
employment discrimination. EEOC investigates charges of discrimination
from the public, litigates major discrimination cases, and reaches out to
federal agencies and the public to educate and prevent discrimination.
EEOC serves every industry, every segment of the population, and every
part of the country. Since EEOC was established over 40 years ago, its
core mission has not changed, but new issues continue to emerge. For
example, the agency is experiencing an increase in charges of sexual
harassment of teenagers in the workplace and discrimination against
individuals who speak with accents. EEOC has also seen an increase in
employer reprisals against employees who complain about discriminatory
treatment, cooperate with EEOC investigations, or file formal charges.

In May 2001, EEOC and other federal agencies were directed by the Office
of Management and Budget (OMB) to prepare restructuring plans to make
government more responsive to citizens' needs.1 By June 2001, agencies
were to submit a workforce analysis to OMB that would include, for
example, demographic information on the agency's employees and would serve
as the baseline for agency-specific restructuring plans. Agencies were to
submit restructuring plans to OMB with fiscal year 2003 budget submissions
and annual performance plans. These submissions were due to OMB September
2001. OMB's directive required agencies with more

1OMB Bulletin No. 01-07, "Workforce Planning and Restructuring," May 8,
2001.

than 100 full-time employees to develop restructuring plans with the goal
of flattening the federal hierarchy. The OMB directive stated that plans
should describe the specific activities and actions each agency planned to
take, associated resources, expected outcomes, and tools to measure
performance.

In order to ascertain what progress EEOC has made in reorganizing its
operations, we determined (1) whether EEOC implemented OMB's directive to
develop a restructuring plan and (2) what actions EEOC is taking to
restructure and make its operations more efficient and effective.

To determine whether EEOC implemented OMB's directive to develop a
restructuring plan, we obtained and reviewed OMB's directive, the
President's Management Agenda, and other guidance. We interviewed key EEOC
officials in headquarters to identify the steps that the agency took in
order to implement OMB's directive. We interviewed key OMB officials to
determine the extent to which EEOC's actions had met the OMB requirements.
To determine what actions EEOC is taking to restructure and make its
operations more efficient and effective, we interviewed key EEOC officials
and reviewed documents pertaining to the agency's restructuring efforts.
To learn how these restructuring efforts would affect EEOC's operations,
we visited EEOC headquarters, the national contact center, and EEOC
district offices in Chicago and San Antonio. In these district offices, we
interviewed staff from all major functions and at different levels. To
gain additional perspectives, we interviewed district directors from
another five EEOC field locations (Atlanta, Detroit, Philadelphia,
Phoenix, and San Francisco). We also interviewed representatives from an
advisory panel of the National Academy of Public Administration (NAPA)2
and the American Federation of Government Employees, EEOC Locals 216. We
conducted our work between October 2004 and September 2005 in accordance
with generally accepted government auditing standards.

On September 19, 2005, we briefed your staff and other staff of the
Subcommittee on the results of our work based on the briefing slides we
include in appendix I. The purpose of this letter is to formally publish
the briefing slides and to officially transmit our recommendation to the
Chair of EEOC.

2NAPA is an independent organization chartered by Congress to improve
governance.

  Summary of Findings

Although EEOC did not develop or submit to OMB a restructuring plan as
required, it has developed and submitted a workforce analysis to OMB,
contracted with the National Academy of Public Administration (NAPA) for a
study of its operations, and taken action to implement some of the study's
recommendations. OMB officials stated that they have found EEOC's
restructuring approach to be acceptable. EEOC chose to implement three
major initiatives from the study of its operations but did not have an
organized strategy to consider all of the study's recommendations. These
wide-ranging recommendations address multiple topics, including EEOC's
mission, needed technological improvements, and human capital management.

In this report, we are making a recommendation to the Chair of EEOC to
develop and implement an organized strategy to consider all of the NAPA
recommendations. EEOC disagreed with this recommendation, indicating that
they had already implemented such a strategy. We continue to believe that
EEOC needs to more systematically evaluate each of the NAPA
recommendations, which would include an examination of the implementation
costs, contributions to Commission goals, as well as establishing a means
for measuring the impact of those recommendations that are implemented.

    Status of EEOC's Implementation of OMB's Directive

EEOC did not develop or submit a restructuring plan as the OMB directive
required but took actions OMB officials have found to be acceptable.
According to EEOC officials, EEOC did not meet the directive's requirement
because the agency was unsure of how to conduct a restructuring effort
given the financial difficulties the agency was facing. Further, EEOC was
experiencing management challenges at the time. According to EEOC
officials, the agency was undergoing a major management transition to a
new chair.

EEOC's Actions to To prepare for restructuring, EEOC commissioned a study
of its

Restructure 	operations by a NAPA advisory panel in June 2002. NAPA's
February 2003 report emphasized three major initiatives and identified 64
wide-ranging recommendations that EEOC should implement.3 The 64
recommendations address multiple topics such as creating a balance

3"A Report by the Panel of the National Academy of Public Administration
for the U.S. Equal Employment Opportunity Commission: Organizing for the
Future," February 2003.

among enforcement, outreach and prevention, and mediation activities;
needed technological improvements; and human capital management. Appendix
II contains a list of these recommendations. EEOC addressed some of these
recommendations, however, it did not have an organized strategy for
considering all of them.4 Instead, EEOC considers addressing the three
major initiatives as the completion of its primary restructuring efforts.
To address the three initiatives, EEOC (1) established a pilot test of a
national contact center to take calls from the public, (2) recently
approved a plan to streamline its field structure, and (3) intends to
reorganize its headquarters operations at an undetermined date once the
structure of its field operation has been determined.

                            National Contact Center

EEOC's national contact center, which is operated by a contractor, became
operational in March 2005 and will continue as a pilot test for 18 months.
Contact center representatives provide callers with basic information but
do not take charges of discrimination, contrary to NAPA's recommendation.
Instead, contact center representatives refer potential charges of
discrimination to EEOC field locations for investigation. The contact
center also processes postal mail and e-mail inquiries from the public. As
a part of the pilot test, the EEOC Inspector General is conducting a
review of the contact center.

                               Field Streamlining

EEOC approved its field streamlining plan in July 2005 and plans to begin
implementing it in October 2005. The plan would increase the total number
of field locations nationwide, but it would change the size level of some
offices. In an effort to better match workload with the size of its field
locations, EEOC's plan would reduce the number of district and area
offices and increase the number of field and local offices. Further, it
would change the menu of services available at select locations to
correspond with their new size levels. According to EEOC officials,
workload and geography were the primary criteria used to determine each
field location's level. EEOC will not lay off any employees or force them
to relocate as a result of implementing the streamlining plan. Employees
will leave these positions through attrition or through voluntary
reassignment. EEOC officials estimate that implementing the field
streamlining plan will free up $8.26 million through fiscal year 2013.
However, EEOC will not

4Although EEOC contracted with NAPA to conduct the study, the agency is
under no obligation to implement the recommendations.

begin to realize these financial benefits until fiscal year 2010 because
of the immediate costs of opening two new local offices and the time
needed for employees to leave their eliminated positions.

Headquarters Reorganization

Conclusion

Recommendation for Executive Action

Agency Comments and Our Evaluation

EEOC intends to reorganize its headquarters operations, but it does not
yet have a plan or specific time frame for doing so. According to EEOC
officials, the agency will begin reorganizing its headquarters operations
after its field streamlining is under way-at some time during fiscal year
2006. As a part of the headquarters reorganization, the agency intends to
shift 20 percent of resources-a combination of human resources and
funding-from its headquarters to the field in order to better serve the
public.

In the last year, EEOC took major restructuring actions that could
fundamentally change the way the agency serves the public. Given its role
as the preeminent antidiscrimination enforcement agency, making such
important changes in how the agency is structured and operates calls for
carefully considering all available options. NAPA completed a major study
of EEOC's operations and created an extensive list of recommendations.
However, EEOC has no organized approach to consider each of these
recommendations. Without such an approach, EEOC lacks assurance that each
recommendation has been fully considered. As a result, EEOC may miss an
opportunity to fully benefit from NAPA's work, become more efficient and
effective, and further improve its ability to enforce the nation's civil
rights laws.

In order to improve the Commission's restructuring efforts, we recommend
that the Chair of EEOC develop and implement an organized strategy to
consider all of the NAPA recommendations. This strategy should include,
among other things: (1) an examination of each recommendation from the
perspective of its potential to aid in achieving the strategic goals and
objectives of the agency, (2) an evaluation of the costs associated with
their implementation, and (3) a means of measuring the impact of any
recommendations that are implemented.

We provided officials at EEOC an opportunity to comment on a draft of this
report. In general, EEOC disagreed with our findings, conclusion, and
recommendation regarding the agency's lack of an organized approach to
consider all of NAPA's recommendations. EEOC's assertion, that it has

developed an organized and comprehensive framework for considering and
implementing NAPA's recommendations, does not correspond with the results
of our review. More specifically, over the course of our review, we sought
documentation supporting the agency's strategy for reviewing and
implementing the NAPA recommendations; however, EEOC officials told us on
several occasions that such documentation did not exist. Only after we
completed our review and discussed our preliminary findings did EEOC
provide us with an internal tracking document that discussed its
implementation of many of NAPA's recommendations. Only in response to a
draft of this report did the Commission provide us with an additional
document that listed the implementation status of each of the
recommendations. Neither of these documents contained, nor could we obtain
from the agency, evidence of the strategy EEOC said it developed to
evaluate the NAPA recommendations, or evidence of the kind of strategic
approach that we continue to recommend: (1) an examination of each
recommendation from the perspective of its potential to aid in achieving
the strategic goals and objectives of the agency, (2) an evaluation of the
costs associated with their implementation, and (3) a means of measuring
the impact of any recommendations that are implemented. EEOC's comments
and our response are reproduced in appendix III.

We are sending copies of this report to the Chairman and Ranking Member,
House Subcommittee on Science, the Departments of State, Justice, and
Commerce, and Related Agencies, Committee on Appropriations; other
interested parties; and will make copies available to others upon request.
We are also sending copies to the Chair of the EEOC. In addition, the
report will be available at no charge on GAO's Web site at
http://www.gao.gov.

If you have any questions about this report, please contact me at (202)
512-7215. Contact points for our Offices of Congressional Relations and
Public Affairs may be found on the last page of this report. GAO staff who
made major contributions to this report are listed in appendix IV.

Robert E. Robertson Director, Education, Workforce, and Income Security
Issues

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

                          Appendix I: Briefing Slides

Appendix II: Sixty-four Recommendations from the National Academy of Public
Administration to EEOC

Aligning Mission and Functions Initiative 1: Establish a nationwide call
center.

1. 	Establish a toll-free national call center staffed by individuals who
have been thoroughly trained in both responding to questions about EEOC's
mission and services, and in taking charges over the phone.

          Initiative 2: Realign field offices and administrative work.

Initiative 3: Realign headquarters.

Harnessing Technology to Achieve the Mission Design secure technology
tools for electronic charge filing.

10. 	Ensure that the secure technology tools for electronic filing be
designed so that customer service is user-friendly, staff can routinely
follow up on Internet-filed charges with phone or in-person interviews,
and information can be promptly provided to those whose queries or
submissions do not involve employment discrimination.

Appendix II: Sixty-four Recommendations from the National Academy of
Public Administration to EEOC

Institute pilot telework programs and develop the secure technology to
support them.

Ensure that senior management candidates understand the value of
technology.

17. 	Make it a condition of advancing to a senior management position that
an individual understand the value of technology in accomplishing EEOC's
mission and demonstrate an ability to lead others in applying this value.

Making the Best Use of EEOC's Workforce Realign staff through work with
OPM and union.

Enhance agency leadership through leadership programs and improved
accountability.

Create strategic human capital plan expeditiously and link it to the
planning and budget processes.

Appendix II: Sixty-four Recommendations from the National Academy of
Public Administration to EEOC

Develop a multi-year training plan for supervisors, managers, SES
candidates, and other mission-critical staff.

Align support staff responsibilities with fully-trained support staff.

                Revamp the agency awards and evaluation systems.

Delegate authorities to senior executives with accompanying budgets,
management tools, and accountability.

Ensure cases are closed with the most appropriate resolution at the most
appropriate time.

Appendix II: Sixty-four Recommendations from the National Academy of
Public Administration to EEOC

     Expand capacity to analyze, validate, and disseminate best practices.

Develop methods to demonstrate the impact EEOC work has on reducing
employment discrimination in the workplace.

Develop an implementation strategy and detailed implementation plan.

                   Develop a communication strategy and plan.

62. 	Develop a communication strategy and plan that identifies all the
internal and external stakeholders, the issues and communications
methodologies to be used with each, the frequency of communications, and
the mechanisms for stakeholder feedback.

Develop resource estimates for implementation.

63. 	Develop resource estimates: The Academy Panel stresses that
substantive improvements require real increases in resources each year for
several years. This would be over and above the flexibility that can be
realized against internal realignment and reallocations.

    Develop appropriate training for staff on the new methods and policies.

64. 	Develop appropriate training to ensure that staff members who use or
are responsible for the new methods and policies have the knowledge to
fulfill their new roles and responsibilities successfully.

Source: National Academy of Public Administration.

Appendix III: Comments from the U.S. Equal Employment Opportunity Commission

                                 See comment 1.

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

                                 See comment 2.

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

                                 See comment 3.

                                 See comment 4.

                                 See comment 5.

                                 See comment 6.

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

  GAO Comments

1. 	EEOC's assertion, that it has developed an organized and comprehensive
framework for considering and implementing NAPA's recommendations, does
not correspond with the results of our review. More specifically, over the
course of our review, we sought documentation supporting the agency's
strategy for reviewing and implementing the NAPA recommendations; however,
EEOC officials told us on several occasions that such documentation did
not exist. Only after we completed our review and discussed our
preliminary findings did EEOC provide us with an internal tracking
document that discussed its implementation of many of NAPA's
recommendations. Only in response to a draft of this report did the agency
provide us with an additional document that listed the implementation
status of each of the recommendations. Neither of these documents
contained, nor could we obtain from the agency, evidence of the strategy
EEOC said it developed to evaluate the NAPA recommendations, or evidence
of the kind of strategic approach that we continue to recommend.

2. 	EEOC asserted that our report overlooks that EEOC is a multi-member
Commission that decides whether to approve agency reorganizations by vote
of all of its members. Our finding that EEOC did not have an organized
strategy to consider all of NAPA's recommendations is not based on EEOC's
organizational structure. We believe EEOC's current organizational
structure allows the agency to develop and implement such a strategy.

3. 	EEOC asserted that NAPA, in a letter to the Commission, expressed
confidence in EEOC's implementation actions in response to its 2003
report. We reviewed this letter and acknowledge that NAPA expresses
confidence in EEOC's field streamlining plan. However, NAPA's letter does
not address all of EEOC's restructuring actions or the many other NAPA
recommendations, and NAPA's comments are qualified by the statement "Given
that we have not had the opportunity to restudy the issues addressed in
this report, our comments in this letter are based solely on current
information supplied by EEOC."

4. 	EEOC claimed that our report reflects a fundamental misunderstanding
of its strategy for addressing NAPA recommendations, and it has carefully
evaluated all the NAPA recommendations and has documentation to support
its decisions. See comment 1.

5. 	EEOC stated that it provided us with an internal tracking document
listing the implementation status of each recommendation and is
disappointed that we did not use this information in our draft report. See
comment 1.

Appendix III: Comments from the U.S. Equal Employment Opportunity
Commission

6. 	EEOC stated that we had not previously provided it with appendix II of
our draft report. However, this appendix is merely a listing of the
recommendations contained in the February 2003 NAPA report that should
have been the Commission's starting point for systematically evaluating
each of the recommendations and their potential to improve EEOC's
operations. We have included EEOC's chart as an attachment to its letter.
However, we cannot verify many of the actions that EEOC claims it has
taken because the agency did not provide the supporting documentation.

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact Robert E. Robertson (202) 512-7215 or [email protected]

David Lehrer, Assistant Director; Margaret Armen; Neal
Gottlieb;Acknowledgments Paul Schearf; and Rosemary Torres Lerma made
significant contributions to this report.

Related GAO Products

Equal Employment Opportunity: The Policy Framework in the Federal
Workplace and the Roles of EEOC and OPM. GAO-05-195. Washington, D.C.:
April 29, 2005.

Diversity Management: Expert-Identified Leading Practices and Agency
Examples. GAO-05-90. Washington, D.C.: Jan. 14, 2005.

Equal Employment Opportunity: Discrimination Complaint Caseloads and
Underlying Causes Require EEOC's Sustained Attention. GAO/T-GGD-00-104.
Washington, D.C.: Mar. 29, 2000.

Equal Employment Opportunity: Complaint Caseloads Rising, with Effects of
New Regulations on Future Trends Unclear. GAO/GGD-99-128. Washington,
D.C.: Aug. 16, 1999.

Equal Employment Opportunity: Data Shortcomings Hinder Assessment of
Conflicts in the Federal Workplace. GAO/GGD-99-75. Washington, D.C.: May
4, 1999.

Equal Employment Opportunity: Rising Trends in EEO Complaint Caseloads in
the Federal Sector. GAO/GGD-98-157BR. Washington, D.C.: July 24, 1998.

Equal Employment Opportunity: Administrative Judges' Recommended Decisions
and Agencies' Actions. GAO/GGD-98-122R. Washington, D.C.: June 10, 1998.

Alternative Dispute Resolution: Employers' Experiences with ADR in the
Workplace. GAO/GGD-97-157. Washington, D.C.: Aug. 12, 1997.

EEOC: Burgeoning Workload Calls for New Approaches. GAO/T-HEHS-95170.
Washington, D.C.: May 23, 1995.

EEOC: An Overview. GAO/T-HRD-93-30. Washington, D.C.: July 27, 1993.

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