Equal Employment Opportunity: The Postal Service Needs to Better Ensure
the Quality of EEO Complaint Data (Letter Report, 09/28/1999,
GAO/GGD-99-167).

GAO reviewed certain discrepancies in the complaint data that the Postal
Service reported to the Equal Employment Opportunity Commission (EEOC)
and the need for the Service to take additional steps to ensure that
such data are complete, accurate, and reliable.

GAO noted that: (1) in GAO's limited analyses of the data the service
reported to EEOC, GAO found errors in statistics on the underlying bases
for EEO complaints and on the length of time complaints had been in
inventory; (2) GAO found that required data on the issues raised in
complaint information system; (3) these discrepancies were generally
linked to statistical reports generated by the Service's automated
complaints were not completely reported; (4) after GAO brought these
discrepancies to the attention of Postal Service staff, they promptly
corrected them and appeared to correct the underlying causes for the
errors, with one exception; (5) that situation need not be resolved
until EEOC revises its reporting form; and (6) because GAO examined only
a portion of the reported data for obvious discrepancies and because the
errors GAO identified were related to data generated by an automated
complaint information system put in 1995, GAO has concerns about the
completeness, accuracy, and reliability of the data that GAO did not
examined.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-99-167
     TITLE:  Equal Employment Opportunity: The Postal Service Needs to
	     Better Ensure the Quality of EEO Complaint Data
      DATE:  09/28/1999
   SUBJECT:  Data collection
	     Employment discrimination
	     Information systems
	     Postal service employees
	     Statistical data
	     Fair employment programs
	     Data integrity
	     Internal controls
	     Reporting requirements

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    United States General Accounting Office GAO               Report
    to the Postmaster General of the United States September 1999
    EQUAL EMPLOYMENT OPPORTUNITY The Postal Service Needs to Better
    Ensure the Quality of EEO Complaint Data GAO/GGD-99-167 United
    States General Accounting Office
    General Government Division Washington, D.C.  20548 B-283618
    September 28, 1999 William J. Henderson Postmaster General U.S.
    Postal Service Dear Mr. Henderson: During the course of our work
    examining trends in federal employees' discrimination complaints,
    we analyzed equal employment opportunity (EEO) complaint data that
    the Postal Service and other federal agencies reported to the
    Equal Employment Opportunity Commission (EEOC).1 The purpose of
    this report is to bring to your attention certain discrepancies in
    the complaint data that the Postal Service reported and the need
    for the Service to take additional steps to ensure that such data
    are complete, accurate, and reliable. In our limited analyses of
    the data the Postal Service reported to EEOC, Results in Brief
    we found errors in statistics on the underlying bases for EEO
    complaints and on the length of time complaints had been in
    inventory. We also found that required data on the issues raised
    in complaints were not completely reported. These discrepancies
    were generally linked to statistical reports generated by the
    Service's automated complaint information system. After we brought
    these discrepancies to the attention of Postal Service staff, they
    promptly corrected them and appeared to correct the underlying
    causes for the errors, with one exception. That situation need not
    be resolved until EEOC revises its reporting form. Because we
    examined only a limited portion of the reported data for obvious
    discrepancies and because the errors we identified were related to
    data generated by an automated complaint information system put in
    place in 1995, we have concerns about the completeness, accuracy,
    and reliability of the data that we did not examine. Therefore, we
    are recommending that the Postal Service review its controls over
    the recording and reporting of the data that it submits to EEOC.
    1Equal Employment Opportunity: Rising Trends in EEO Complaint
    Caseloads in the Federal Sector (GAO/GGD-98-157BR, July 24, 1998)
    and Equal Employment Opportunity: Data Shortcomings Hinder
    Assessment of Conflicts in the Federal Workplace (GAO/GGD-99-75,
    May 4, 1999). Page 1
    GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data B-
    283618 Federal regulations and EEOC policy require federal
    agencies to report Background              certain EEO complaint-
    related data annually to EEOC. Agencies report these data on EEOC
    form 462, Annual Federal Equal Employment Opportunity Statistical
    Report of Discrimination Complaints. EEOC compiles the data from
    the agencies for publication in the annual Federal Sector Report
    on EEO Complaints Processing and Appeals. According to EEOC
    Management Directive 110, agencies should make every effort to
    ensure accurate recordkeeping and reporting of these data. In our
    recent report, we said that reliable data are important to program
    managers, decisionmakers, and EEOC in identifying the nature and
    extent of workplace conflicts.2 We analyzed the data contained in
    EEOC's annual federal sector reports to Scope and
    prepare our reports dealing with employment discrimination
    complaint Methodology             trends. Because the Postal
    Service accounts for a large share of complaints filed by federal
    employees with their agencies, we analyzed forms 462 submitted by
    the Service for fiscal year 1991 through fiscal year 1998, as well
    as other complaint data provided at our request.3 Because our
    studies generally focused on trends in the number and age of
    unresolved complaints in inventory, the number of complaints
    filed, the bases and issues cited in complaints, and complaint
    processing times, we did not examine the full scope of data
    reported on form 462. Although we did not examine the Service's
    controls for ensuring accurate recordkeeping and reporting or
    validate the data the Service reported, we examined the data for
    obvious inconsistencies or irregularities. We requested comments
    on a draft of this report from the Postmaster General. The Postal
    Service's oral comments are discussed near the end of this letter.
    We performed our work in July and August 1999 in accordance with
    generally accepted government auditing standards. The most
    significant error that we identified in Postal Service data
    Discrepancies in the    involved the number of race-based
    complaints filed by white postal Postal Service's EEO    workers.
    EEOC requires agencies to report the bases (e.g., race, sex,
    disability) for complaints that employees file. For fiscal year
    1996, the Complaint Data          Postal Service had reported that
    9,044 (about 68 percent) of the 13,252 complaints filed contained
    allegations by white postal workers of race discrimination. For
    fiscal year 1997, the Service had reported that 10,040 (70
    percent) of the 14,326 complaints filed contained such
    allegations. 2GAO/GGD-99-75, May 4, 1999. 3In fiscal year 1998,
    postal workers accounted for about half of the discrimination
    complaints filed by federal employees. Page 2
    GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data B-
    283618 These figures represented significant increases over the
    figures reported for previous fiscal years. For example, in fiscal
    year 1995, the Service reported to EEOC that 1,534 of the
    complaints filed contained allegations by white postal workers of
    race discrimination. In fiscal year 1994, the figure reported was
    2,688. We questioned Postal Service officials about the sudden
    increase in the number of complaints containing allegations by
    white postal workers of race discrimination. The officials said
    that they also had been concerned about these data, and had
    discussed the data with EEOC officials. After we raised this
    issue, the officials intensified their efforts to identify the
    true magnitude and source of the increase and subsequently found
    that a computer programming error had resulted in a significant
    overcounting of these complaints. They said that the corrected
    figures were 1,505 for fiscal year 1996 (or 11.4 percent of the
    13,252 complaints filed) and 1,654 for fiscal year 1997 (or 11.5
    percent of the 14,326 complaints filed). They also provided these
    figures to EEOC. In explaining how the error occurred, the
    officials said that each automated case record in the complaint
    information system contains a data field for race, which is to be
    filled in with a code for the applicable racial category when an
    employee alleges racial discrimination. If an employee alleges
    discrimination on a basis or bases other than race, this data
    field is to remain blank. According to the officials, the faulty
    computer program counted each blank racial data field as
    indicating an allegation by a white employee of racial
    discrimination. These results were then tallied with complaints in
    which the data field was properly coded as an allegation by a
    white employee of racial discrimination. The officials advised us
    that the programming error had been corrected. Although we did not
    examine the computer program, our review of the data reported on
    the Postal Service's form 462 for fiscal year 1998 appeared to
    confirm that the correction had been made. Other errors that we
    found in data that the Service reported on form 462 related to the
    age of cases in the inventory of unresolved complaints. EEOC
    requires agencies to report statistics on the length of time that
    cases have been in the agencies' inventories of unresolved
    complaints, from the date of complaint filing. These data are
    broken out by each stage of the complaint process-
    acceptance/dismissal, investigation, hearing, and final decision.
    We questioned figures for fiscal year 1997 about the age of (1)
    cases pending acceptance/dismissal, because the reported total
    number of days such cases had been in inventory seemed unusually
    high, and (2) cases pending a hearing before an EEOC
    administrative judge, because the Page 3
    GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data B-
    283618 reported average age of such cases seemed unusually low.
    After we brought the questionable figures to the attention of the
    Postal Service EEO Compliance and Appeals Manager, he provided
    corrected figures and said that the errors, like the problem with
    the reporting of complaint bases described previously, were due to
    a computer programming error. He said that the faulty computer
    program had been corrected. In addition, the Service provided the
    corrected figures to EEOC. We also found that the Postal Service
    has not been reporting all issues- the specific conditions or
    events that are the subjects of complaints-as EEOC requires.
    Because some complaints involve more than one basis or more than
    one issue, EEOC's instructions for completing part IV of form 462
    require agencies to include all bases and issues raised in
    complaints. While the Postal Service's complaint information
    system allows more than one complaint basis (like racial and
    sexual discrimination) to be recorded, the system's data field
    allows only one "primary" issue (like an adverse personnel action)
    to be recorded for each complaint, regardless of the number of
    issues that a complainant raises. Although this practice results
    in underreporting complainants' issues to EEOC, the EEO Compliance
    and Appeals Manager said that the Postal Service adopted this
    approach to give the data more focus by identifying the primary
    issues driving postal workers' complaints. This matter has not
    been resolved. In order to report more than one issue for each
    complaint, the Service would have to modify the automated
    complaint information system to allow for the recording of more
    than one issue for a complaint. However, we have reported that
    part IV of form 462 for reporting statistics on bases and issues
    is methodologically flawed and results in an overcounting of bases
    and issues.4 We have made a recommendation to EEOC that it correct
    this problem, and the agency said that it would address our
    concerns.5 Therefore, we believe that it would be prudent for the
    Postal Service to wait for EEOC to resolve this issue before
    modifying its data recording and reporting practices. In addition
    to the discrepancies already noted, we found that the Postal
    Service's statistical reports to EEOC for fiscal years 1996 and
    1997 did not include data for complaints involving certain
    categories of primary issues. 4GAO/GGD-99-75, May 4, 1999. 5EEOC,
    with the National Partnership for Reinventing Government, is
    cosponsoring the Interagency Federal EEO Task Force. One task
    force team of representatives from federal agencies and
    departments, in response to recommendations made in GAO/GGD-99-75,
    is to review and recommend approaches to improve the type and
    quantity of data, the method of collection, the accuracy and
    reliability of the data, and the timeliness and availability of
    the data. Page 4                                          GAO/GGD-
    99-167 Quality of Postal Service EEO Complaint Data B-283618 The
    form 462, which EEOC requires agencies to complete, contains a
    list of issues. For its own management needs, the Service
    supplemented EEOC's list with three additional categories of
    specific issues: (1) denial of worker's compensation, (2) leave,
    and (3) other pay. However, we found that in completing part IV of
    EEOC form 462 for fiscal years 1996 and 1997, the Service omitted
    the data about complaints in which these additional issues were
    cited. After we brought our observations to the attention of
    Service officials, they provided the omitted data to EEOC. The
    officials explained that, for fiscal year 1998, in lieu of
    including data about complaints involving the three additional
    issues on part IV of form 462, they provided these data separately
    to EEOC. The EEO Compliance and Appeals Manager explained that he
    did not want to "force fit" the data about the three issues into
    one of the categories listed on the form 462, such as "other,"
    because the issues thereby would lose their identity and
    significance. He added that part IV of form 462 needs to be
    revised because the categories of issues listed are too broad and
    do not recognize emerging issues. Further, we found certain
    underreportings of the bases and issues cited in complaints for
    fiscal year 1995. After we brought the underreporting to the
    attention of the Postal Service officials, they provided corrected
    data to EEOC and us. Service officials attributed this
    underreporting to difficulties associated with implementing a new
    complaint information system in fiscal year 1995. Both Postal
    Service management and EEOC need complete, accurate, and
    Conclusions          reliable information to deal with EEO-related
    workplace conflicts. Discrepancies that we found in our limited
    review of the Postal Service's EEO complaint data raised questions
    about the completeness, accuracy, and reliability of the reported
    data, particularly data generated through the automated complaint
    information system. All but one of the reporting problems we found
    and their underlying causes appear to have been corrected.
    However, because we examined only a limited portion of the
    reported data for obvious discrepancies and because the errors we
    identified were related to data generated by an automated
    complaint information system put in place in 1995, we have
    concerns about the completeness, accuracy, and reliability of the
    data that we did not examine. To help ensure that the EEO
    complaint data submitted to EEOC are Recommendation to
    complete, accurate, and reliable, we recommend that you review the
    the Postmaster       Postal Service's controls over the recording
    and reporting of these data, including evaluating the computer
    programs that generate data to prepare General Page 5
    GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data B-
    283618 the EEOC form 462, Annual Federal Equal Employment
    Opportunity Statistical Report of Discrimination Complaints. We
    recognize that recording and reporting issues raised in complaints
    are matters that cannot be completely addressed until EEOC
    resolves the methodological flaws in part IV of form 462. In oral
    comments on a draft of this report made on August 20, 1999, the
    Agency Comments and Postal Service Manager, EEO Compliance and
    Appeals, generally Our Evaluation                concurred with
    our observations and offered comments of a clarifying nature. In
    response to our recommendation that the Service's controls over
    the recording and reporting of EEO complaint data to EEOC be
    reviewed, this official said that the Postal Service plans to
    adopt more comprehensive management controls to ensure that the
    data submitted are complete, accurate, and reliable. The official
    further said that these controls would involve (1) an analysis of
    trend data to identify anomalies and (2) an examination of data
    categories in which discrepancies have previously been found. He
    also said that complaint information system controls would be
    examined to determine whether they ensure that data recorded and
    reported are complete, accurate, and reliable. He said, however,
    that because the complaint information system has been certified
    for year 2000 compatibility and because the Service has decided
    not to modify any computer systems until March 2000, any
    modifications to improve the complaint system will not be made
    until then. We believe that the actions the Postal Service
    proposes, if carried out, will address the substance of our
    recommendation. We are sending copies of this report to Senators
    Daniel K. Akaka, Thad Cochran, Joseph I. Lieberman, and Fred
    Thompson and Representatives Robert E. Andrews, John A. Boehner,
    Dan Burton, William L. Clay, Elijah E. Cummings, Chaka Fattah,
    William F. Goodling, Steny H. Hoyer, Jim Kolbe, John M. McHugh,
    David Obey, Harold Rogers, Joe Scarborough, Jose E. Serrano, Henry
    A. Waxman, and C. W. Bill Young in their capacities as Chair or
    Ranking Minority Member of Senate and House Committees and
    Subcommittees. In addition, we will send a copy to Representative
    Albert R. Wynn. We will also send copies to the Honorable Ida L.
    Castro, Chairwoman, EEOC; the Honorable Janice R. Lachance,
    Director, Office of Personnel Management; the Honorable Jacob Lew,
    Director, Office of Management and Budget; and other interested
    parties. We will make copies of this report available to others on
    request. Because this report contains a recommendation to you, you
    are required by 31 U.S.C. 720 to submit a written statement on
    actions taken on this recommendation to the Senate Committee on
    Governmental Affairs and Page 6                 GAO/GGD-99-167
    Quality of Postal Service EEO Complaint Data B-283618 the House
    Committee on Government Reform not later than 60 days after the
    date of this report and to the House and Senate Committees on
    Appropriations with the agency's first request for appropriations
    made more than 60 days after the date of this report. If you or
    your staff have any questions concerning this report, please
    contact me or Stephen Altman on (202) 512-8676. Other major
    contributors to this report were Anthony P. Lofaro, Gary V.
    Lawson, and Sharon T. Hogan. Sincerely yours, Michael Brostek
    Associate Director, Federal Management and Workforce Issues Page 7
    GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data Page 8
    GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
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