The Results Act: Observations on Department of Labor's June 1997 Draft
Strategic Plan (Correspondence, 07/11/97, GAO/HEHS-97-172R).

Pursuant to a congressional request, GAO reviewed the Department of
Labor's June 1997 draft strategic plan.

GAO noted that: (1) to meet the Government Performance and Results Act's
requirement for an agency strategic plan, Labor elected to submit
individual plans from various agency component units supplemented by a
strategic plan overview that addresses some Results Act requirements at
the agency level; (2) however, Labor's overview does not meet Office of
Management and Budget (OMB) guidance to provide an agencywide strategic
overview that links individual strategic plans; (3) while Labor's
strategic plan overview contains a mission statement for the agency, as
required, the statement itself does not appear to be sufficiently
descriptive of Labor's basic purpose; (4) Labor's strategic plan
overview also does not appear to meet the requirement contained in OMB
Circular A-11 that it contain an overall statement of departmental
goals; (5) instead, Labor has excerpted and listed the goals contained
in the component unit plans; (6) although Labor did not include agency
goals in its strategic overview, the Department set forth agencywide
goals in recent congressional testimony; (7) the goals stated in the
overview and in individual unit plans are consistent with Labor's
statutory responsibilities; (8) in addition, the mission statements
cover all of Labor's major functions and operations; (9) Labor's
strategic plan overview recognizes the roles of other organizations,
such as other federal agencies and state and local governments, and the
importance of establishing partnerships in carrying out such functions
as ensuring safe and healthful workplaces; (10) the overview does not
acknowledge that the nation's federally funded employment training
system is a patchwork of multiple programs, many of which are in
departments and agencies other than Labor; nor does it set forth goals
pertaining to the development of a cohesive, integrated, and coordinated
system; (11) Labor's capacity to provide reliable information for use in
its agencywide management is questionable; (12) Labor's overview plan
does not discuss with any specificity how Labor plans to use information
technology to achieve its mission, goals, and objectives; nor does the
plan describe with sufficient clarity how Labor intends to use
information technology to improve performance and reduce costs; and (13)
Labor's strategic overview plan could be improved by including a
discussion of its technology investment control process, a process that
can help agencies reduce the risk and maximize the net benefits from
their information technology investments.

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

 REPORTNUM:  HEHS-97-172R
     TITLE:  The Results Act: Observations on Department of Labor's June 
             1997 Draft Strategic Plan
      DATE:  07/11/97
   SUBJECT:  Strategic planning
             Agency missions
             Interagency relations
             Public administration
             Strategic information systems planning
             Information resources management
             Employment or training programs
             Occupational health/safety programs
             Intergovernmental relations
             Congressional/executive relations

             
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Cover
================================================================ COVER



September 1997


GAO/HEHS-97-172R

Labor's Draft Strategic Plan

(205347)


Abbreviations
=============================================================== ABBREV

  BOP - Federal Bureau of Prisons
  CFO - Chief Financial Officers
  DEA - Drug Enforcement Administration
  DOJ - Department of Justice
  ERISA - x
  ESA - x
  ETA - x
  FBI - Federal Bureau of Investigation
  FECA - x
  FMSHA - x
  GPRA - x
  INS - Immigration and Naturalization Service
  JTPA - x
  MSHA - x
  NPR - National Performance Review
  OASAM - x
  OCFO - x
  OIG - x
  OLMS - x
  OMB - Office of Management and Budget
  OSH - x
  OSHA - x
  PBGC - x
  PWBA - x
  VETS - x
  WHD - x

Letter
=============================================================== LETTER


B-277414

July 11, 1997

The Honorable Richard K.  Armey
Majority Leader
House of Representatives

The Honorable John R.  Kasich
Chairman, Committee on the Budget
House of Representatives

The Honorable Dan Burton
Chairman, Committee on Government Reform
 and Oversight
House of Representatives

The Honorable Bob Livingston
Chairman, Committee on Appropriations
House of Representatives

Subject:  The Results Act:  Observations on Department of Labor's
June 1997 Draft Strategic Plan

On June 12, 1997, you asked us to review the draft strategic plans
submitted by the cabinet departments and selected major agencies for
consultation with the Congress as required by the Government
Performance and Results Act of 1993 (the Results Act).  This letter
is our response to that request concerning the Department of Labor
(Labor). 

Labor's strategic plan consists of a department-level document, which
it designates as a "strategic plan overview," supplemented by
strategic plans for 15 of its component offices or units.  As agreed
with your offices, this letter includes our analysis of the overview
and selected analyses of individual plans.  As you requested, we will
provide additional detailed analyses on individual plans submitted by
the Employment and Training Administration (ETA), the Occupational
Safety and Health Administration (OSHA), and the Employment Standards
Administration (ESA) by the end of July. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :1

Our overall objective was to review and evaluate Labor's draft
strategic plan overview, as submitted to congressional staff on June
11.  As you requested, we specifically (1) assessed compliance with
the act's requirements and the strengths and weaknesses of the
elements of the plan; (2) described Labor's key statutory authorities
and how they relate to the mission and goals in the strategic plan;
(3) identified Labor's programs, activities, and functions that are
crosscutting in that they are similar to or related to goals,
activities, or functions of other agencies and assessed the extent to
which the plan reflects interagency cooperation; (4) discussed the
extent to which Labor's management challenges were addressed in the
plan; and (5) described Labor's capacity to provide reliable
information about performance. 

As agreed, our assessment of the strategic plan overview was
generally based on our previous work.  Our overall assessment of
Labor's draft strategic plan overview was generally based on our
knowledge of Labor's operations and programs, our numerous reviews of
Labor, and other existing information available at the time of our
assessment.  Specifically, the criteria we used to determine whether
Labor's draft strategic plan overview complied with the requirements
of the Results Act were the Results Act and the Office of Management
and Budget's (OMB) guidance on developing the plans (Circular A-11,
part 2).  To make judgments about the overall quality of the
overview, we used our May 1997 guidance for congressional review of
the plans (GAO/GGD-10.1.16) as a tool.  To determine whether the plan
contained information on interagency coordination and addressed
management problems previously identified, we relied on our general
knowledge of Labor's operations and programs, and the results of our
previous reports.  (See Related GAO Products at the end of this
correspondence.)

To describe Labor's key statutory responsibilities and how they
relate to Labor's mission and goals, we reviewed Labor's overview
strategic plan and the supplemental unit plans.  As requested, we
coordinated our work on Labor's key statutory authorities and
capacity to provide reliable information with the Congressional
Research Service and Labor's Inspector General, respectively. 

In passing the Results Act, the Congress anticipated that several
planning cycles might be need to perfect the process of developing a
strategic plan and that the plan would be continually refined.  Thus,
our comments reflect a "snapshot" of the status of the plan at a
particular point.  We recognize that developing a strategic plan is a
dynamic process and that Labor is continuing to work to revise the
draft with input from OMB, congressional staff, and other
stakeholders. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Labor, established as a Department in 1913, administers and enforces
a variety of federal labor laws guaranteeing workers' rights to a
workplace free from safety and health hazards, a minimum hourly wage
and overtime pay, family and medical leave, freedom from employment
discrimination, and unemployment insurance.  Labor also protects
workers' pension rights; provides job training programs; helps
workers find jobs; works to strengthen free collective bargaining;
and keeps track of changes in employment, prices, and other national
economic measures. 

Labor's diversity of functions is carried out by different offices in
a decentralized organizational structure.  It has 24 component
offices or units, with over 1,000 field offices, to support its
various functional responsibilities.  (Fig.  1 shows the
organizational structure of Labor.) However, its many program
activities fall into two major categories:  enhancing workers' skills
through job training and ensuring worker protection.  A third
category relates to developing economic statistics, such as the
Consumer Price Index, which is used by business, labor, and
government in formulating fiscal and monetary policy and in making
cost-of-living adjustments. 

   Figure 1:  Department of Labor
   Organization

   (See figure in printed
   edition.)

In fiscal year 1997, Labor has an estimated budget of $34.4 billion
and is authorized 16,614 full-time-equivalent staff-years.  About
three-fourths of Labor's budget is composed of mandatory spending on
income maintenance programs, such as the unemployment insurance
program. 


      RESULTS ACT REQUIREMENTS AND
      OMB GUIDANCE ON PREPARING
      AND SUBMITTING STRATEGIC
      PLANS
---------------------------------------------------------- Letter :2.1

The Results Act requires virtually every executive agency to develop
a strategic plan covering a period of at least 5 years from the
fiscal year in which it is submitted.  The act is aimed at improving
program performance.  It requires that agencies, in consultation with
the Congress and other stakeholders, clearly define their mission and
articulate a comprehensive mission statement that defines their basic
purpose.  It also requires that they establish long-term strategic
goals, as well as annual goals linked to them.  Agencies must then
measure their performance against the goals they have set and report
publicly on how well they are doing.  In addition to monitoring
ongoing performance, agencies are expected to perform evaluation
studies of their programs and to use information obtained from these
evaluations to improve the programs. 

OMB Circular A-11 provides additional guidance on the development of
agency strategic plans.  The Circular strongly encourages agencies to
submit a single, agencywide strategic plan.  It states, however, that
an agency with disparate functions, such as Labor, may prepare
several strategic plans for its major components or programs.  When
an agency does prepare multiple strategic plans for component units,
Circular A-11 further provides that these not be merely packaged
together and submitted as a single strategic plan because the size
and detail of such a compilation will reduce the plan's usefulness. 
Moreover, the agency is to prepare an agencywide strategic overview
that will link individual plans by giving an overall statement of the
agency's mission and goals. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :3

To meet the Results Act requirement for an agency strategic plan,
Labor elected to submit individual plans from various agency
component units supplemented by "a strategic plan overview" that
addresses some Results Act requirements at the agency level. 
However, Labor's overview does not meet OMB guidance to provide an
agencywide strategic overview that links individual strategic plans. 
Furthermore, while Labor's strategic plan overview contains a mission
statement for the agency, as required, the statement itself does not
appear to be sufficiently descriptive of Labor's basic purpose. 
Labor's strategic plan overview also does not appear to meet the
requirement contained in Circular A-11 that it contain an overall
statement of departmental goals.  Instead, Labor has excerpted and
listed the goals contained in the component unit plans.  For example,
goals of Labor component units responsible for workplace safety, such
as OSHA and the Mine Safety and Health Administration (MSHA), are
summarized in the worker protections section of the overview but are
not integrated into an overall agency goal. 

Although Labor did not include agency goals in its strategic
overview, the Department set forth agencywide goals in recent
congressional testimony.  For example, the Secretary cited as a goals
equipping every working American with the skills needed to find and
hold a good job, and helping people move from welfare to work.  In
addition, Labor's strategic plan overview is organized around three
major categories--lifelong learning, worker protections, and
statistics--that could serve as the basis from which to develop
crosscutting departmental goals. 

Labor's five areas of major statutory responsibility--employment and
training, health and safety in the workplace, pension and welfare
benefits, employment standards, and labor statistics--are covered in
its draft overview and supplemental unit plans.  The goals stated in
the overview and in individual unit plans are consistent with Labor's
statutory responsibilities.  In addition, the mission statements
cover all of Labor's major functions and operations. 

Labor's strategic plan overview recognizes the roles of other
organizations, such as other federal agencies and state and local
governments, and the importance of establishing partnerships in
carrying out such functions as ensuring safe and healthful
workplaces.  Labor's overview could be improved, however, by
recognizing the importance of other participants, namely the other 14
federal agencies involved in one major area of responsibility--job
training.  The overview does not acknowledge that the nation's
federally funded employment training system is a patchwork of
multiple programs, many of which are in departments and agencies
other than Labor; nor does it set forth goals pertaining to the
development of a cohesive, integrated, and coordinated system. 

Finally, Labor's capacity to provide reliable information for use in
its agencywide management is questionable.  Its overview plan
recognizes the importance of additional information to ensure timely
and sound evaluations to assess agency progress in meeting goals. 
However, its overview does not describe its strategy for ensuring
that such information is collected and used to assess progress and
performance.  In addition, Labor's overview plan does not discuss
with any specificity how Labor plans to use information technology to
achieve its mission, goals, and objectives; nor does the plan
describe with sufficient clarity how Labor intends to use information
technology to improve performance and reduce costs.  Furthermore,
Labor's strategic overview plan could be improved by including a
discussion of its technology investment control process, a process
that can help agencies reduce the risk and maximize the net benefits
from their information technology investments. 


   LABOR'S AGENCYWIDE PLAN DOES
   NOT CONTAIN ALL ELEMENTS
   REQUIRED BY RESULTS ACT AND OMB
   GUIDANCE
------------------------------------------------------------ Letter :4

The Results Act requires that strategic plans include six components: 
(1) a mission statement, (2) goals and objectives, (3) approaches or
strategies to achieve the goals and objectives, (4) a discussion of
the relationship between long-term goals and annual performance
goals, (5) key external factors affecting goals and objectives, and
(6) evaluations used to establish goals and objectives.  OMB Circular
A-11 provides guidance to agencies submitting plans and, in
particular, to agencies like Labor that comprise disparate components
or programs.  As permitted by Circular A-11, Labor elected to submit
individual plans from its different components, supplemented by an
agency-level document intended to be the strategic plan overview. 

Labor's overview does not integrate information from individual
strategic plans of its components into a single agencywide strategic
overview document, as stated in OMB guidance.  Rather it is a
compilation of excerpts from individual plans that does not identify
strategic departmental goals.  The overview plan also does not
include the other elements of a strategic plan identified by the act,
such as strategies to achieve goals and evaluations used to establish
goals.  Further, a majority of the individual unit plans did not
include all the elements required by the act, such as the approaches
or strategies to achieve the goals or key factors affecting goals. 

The overview plan could be a more useful document if it included all
the elements identified by the act--for example, crosscutting
strategies used to achieve departmental goals.  According to OMB
guidance, strategic plans, because of their scope and importance, may
be the best basis for developing a comprehensive and integrated
approach to performance management. 

The Results Act and OMB guidance require a comprehensive mission
statement for the agency.  Labor's strategic plan overview
articulates its overall mission as helping "assure opportunity and
security for American workers and their families in the changing and
competitive global marketplace." This mission statement could be
improved if it were more descriptive about what the agency does.  As
pointed out in Circular A-11, the mission statement should define the
basic purpose of the agency, with particular focus on its core
programs and activities.  The mission statement could communicate
more about Labor's purpose if it referred to such basic
responsibilities as job skills development, job placement, and worker
protection. 

Labor's plan does not appear to meet the requirement related to
agency goals and objectives.  Circular A-11 states that strategic
plans should set out general goals and objectives of the agency,
which should elaborate on "how the agency is carrying out its mission
and very often will be outcome-type goals." Labor's overview does not
contain departmental strategic goals; instead Labor has excerpted and
listed the goals contained in the component unit plans.  The overview
does not include departmentwide, overarching goals that would
facilitate Labor's functioning as a unified organization with central
direction.  Agencywide goals are important to allow a future
assessment of the agency's performance overall, as discussed in
Circular A-11. 

Although Labor does not include agencywide goals in its strategic
overview, it did set forth agencywide goals in congressional
testimony.  In June 1997, the Secretary of Labor testified before the
Subcommittee on Human Resources, House Committee on Government Reform
and Oversight, on the issues and challenges facing Labor.  In that
testimony, the Secretary stated five goals for addressing these
challenges: 

     "One, equip every working American with the skills to find and
     hold good jobs, with rising incomes throughout their lives;
     [t]wo, help people move from welfare to work; [t]hree, assure
     that working Americans enjoy secure pensions when they retire;
     [f]our, guarantee every American a safe, healthy workplace free
     of employment-related discrimination; and, [f]ive, help working
     people balance work and family."

The Secretary further stated that Labor's 1998 budget request
included the resources needed to pursue these goals. 

In addition, Labor organizes its strategic plan overview around three
programmatic categories:  lifelong learning, worker protections, and
statistics.  While identifying these three broad categories as its
fundamental areas of activity and responsibility, Labor does not
develop them into goals.  Instead, each of these three sections in
the overview merely summarizes the missions, goals, and activities of
individual component units with responsibilities related to the
overall category.  The Secretary's stated goals and the three
categories organizing the plan could serve as the basis from which to
develop overarching departmental goals that are results oriented and
set out the long-term programmatic, policy, and management goals of
the agency. 

A few Labor unit-level officials have had preliminary discussions
with congressional staff to consult on their individual unit plans. 
However, neither officials from the Office of the Secretary of Labor
or from the Office of the Assistant Secretary for Administration and
Management, the office responsible for implementation of the Results
Act, have consulted with congressional staff regarding the strategic
plan overview or individual unit plans.  This level of consultation
would probably be useful in helping the Congress and Labor to ensure
a more complete understanding of departmental goals and how those
goals guide programmatic, policy, and management decisions. 


      LABOR'S STRATEGIC PLAN
      CONTAINS 15 UNIT/SUBUNIT
      PLANS
---------------------------------------------------------- Letter :4.1

Labor's strategic plan consists of individual plans for 15 of its
component offices or subunits and a strategic plan overview. 
Although Labor has 24 offices/units, not all submitted strategic
plans.  Discretion is allowed by Circular A-11, which states that
agencies can submit strategic plans that cover only major functions
or operations; however, Labor provided no indication as to why
certain offices were included and others excluded. 

Labor's many program activities are carried out by its seven program
agencies.  However, only six of these--the Bureau of Labor
Statistics, ETA, MSHA, OSHA, the Pension and Welfare Benefits
Administration, and the Veterans' Employment and Training
Service--submitted strategic plans.  The seventh, ESA, submitted
separate plans for the four subunits under its responsibility--the
Office of Federal Contract Compliance Programs, the Office of
Workers' Compensation Programs, the Office of Labor Management
Standards (OLMS), and the Wage and Hour Division (WHD).  However, it
did not prepare an overall comprehensive plan that pulls together the
ESA strategy to be followed, as a single organizational unit, in
working toward achieving its desired results. 

Two of Labor's seven departmental staff and support offices also
submitted strategic plans--the Office of the Inspector General (OIG)
and the Office of the Chief Financial Officer (OCFO).  Another
support office, the Office of the Assistant Secretary for
Administration and Management (OASAM), which has overall management
responsibility for implementing the Results Act, did not submit a
strategic plan for its operations.  Yet in Labor's overview plan, it
was noted that the Department's commitment to the Results Act is
specifically reflected in the strategic plans of OASAM, as well as
those of OIG and OCFO. 


      LABOR HAS TRADITIONALLY
      OPERATED WITH DECENTRALIZED
      MANAGEMENT APPROACH
---------------------------------------------------------- Letter :4.2

Labor's draft strategic plan submission reflects the current
Department management structure and operations; that is, the plan
consists of a number of discrete plans for carrying out Labor's
various responsibilities largely independently and without a
cohesive, overall plan.  Our past work indicates that Labor
traditionally has operated as a conglomeration of individual
agencies/units, each working largely independently of the other and
with limited central direction and control.  Our 1985 report on the
overall management of Labor pointed out that Labor had no systematic,
departmentwide, long-range policy planning process.\1 Instead,
departmental plans were essentially compilations of individual
agencies' 2-year objectives.  Furthermore, due to the lack of strong
direction and control, organizational components traditionally
operated independently with limited oversight from the Office of the
Secretary.  We recommended a series of actions to deal with specific
management problems, such as developing a long-range planning process
to help ensure that desired program and policy decisions are achieved
in a planned and orderly fashion. 

Labor has initiated actions in the past to develop more comprehensive
approaches to departmental management.  The follow-up report to our
study of Labor's overall management recognized action by the
Secretary of Labor to establish a system that integrated agency and
departmentwide goals and provided a mechanism for monitoring progress
and providing feedback to the component agencies.\2 It appears that
Labor may not have continued this integrated management approach. 
Our 1996 report containing information on the field offices
supporting Labor pointed out that Labor does not centrally maintain
information on its components' field office locations, staffing, and
costs.\3 Instead, each component maintains such information itself
and provides OASAM with information as requested.  Thus, in
responding to our request for information we needed for our 1996
study, OASAM had to go to individual components.  To further
illustrate the decentralized nature of Labor's management structure,
OASAM was uncertain, immediately after the Oklahoma City bombing,
whether it had field office staff located in the bombed federal
building.  To obtain this information, Labor had to query staff in
each of the major program divisions to ascertain whether the
divisions had field offices in Oklahoma City and the location of the
offices. 


--------------------
\1 Strong Leadership Needed to Improve Management at the Department
of Labor (GAO/HRD-86-12, Oct.  21, 1985). 

\2 Department of Labor:  Assessment of Management Improvement Efforts
(GAO/HRD-87-27, Dec.  31, 1986). 

\3 Education and Labor:  Information on the Departments' Field
Offices (GAO/HEHS-96-178, Sept.  16, 1996). 


   LABOR'S PLAN ADDRESSES
   STATUTORY RESPONSIBILITIES
------------------------------------------------------------ Letter :5

We identified the following areas of major statutory responsibility
for Labor:  (1) employment and training, (2) health and safety in the
workplace, (3) pension and welfare benefits, (4) employment
standards, and (5) labor statistics.  Labor has covered each of these
in its draft overview and supplemental unit plans, and the goals
stated therein are consistent with its statutory responsibilities. 

As noted earlier, the overview plan does not contain agencywide goals
or strategies; rather, the goals and strategies in the plan are those
of various components of Labor.  To determine whether the goals
reflected Labor's statutory authority, we reviewed the individual
unit plans as well as the overview.  We found that some of the goals
for each of Labor's component agencies are established by law, either
expressly or by implication; others, while consistent with the law,
cannot be directly linked to anything in the laws dealing with
Labor's responsibilities.  For example, OSHA' s strategic goal of
"securing public confidence through excellence in the development and
delivery of its programs and services" is not based on specific
requirements in Labor statutes.  Similarly, the goals of WHD, which
include "increase compliance with the laws and regulations
administered and enforced by WHD, increase customer satisfaction with
the services provided by WHD, and achieve a high performance
workplace which anticipates and is responsive to the needs of our
customers and all our employees," are not based on specific statutory
requirements. 

Overall, the overview plan and supplemental unit plans cover all of
Labor's major functions and operations.  The enclosure discusses the
goals and related statutory responsibilities for each component/unit. 


   DESCRIPTION OF CROSSCUTTING
   PROGRAM ACTIVITIES
------------------------------------------------------------ Letter :6

Labor is responsible for a diversity of functions, many of which are
also carried out, at least in part, by other federal agencies and
involve the participation of state and local agencies as well as
private sector organizations.  Labor's strategic plan overview
recognizes the roles of other organizations and the importance of
establishing partnerships in carrying out some of these functions. 
For example, the overview points out, in the worker protections area,
that "OSHA does not have sole responsibility for safety and health in
the workplace.  The Agency works closely with other partners in the
Department, in the Federal government, with state and local
governments, and the private sector."

Labor's overview could be improved by recognizing the substantial
number of other participants involved in job training.  The overview
does not acknowledge a key aspect of the nation's federally funded
employment training system, namely, that it is not a cohesive,
integrated, or coordinated system.  In 1995, we identified 163
employment training programs spread across 15 federal departments and
agencies, including Labor.\4 By recognizing in the overview the
substantial number of the nation's job training programs that are
outside its purview, Labor could then discuss how its programs could
fit in with a broader national job training strategy and the
coordination required to develop and implement such a strategy.  The
coordination strategy could focus on identifying and taking advantage
of opportunities to realize efficiencies through coordination and,
possibly, consolidation.  Passage of the recent welfare reform
legislation puts even greater demands on an employment training
system that appears unprepared to respond.  Labor's overview does
provide a general reference to "working closely with other agencies,
states, and communities to leverage our resources to address the
special needs of welfare recipients" but does not provide more
detailed information on what Labor will be doing. 


--------------------
\4 Multiple Employment Training Programs:  Major Overhaul Needed to
Create a More Efficient, Customer-Driven System (GAO/T-HEHS-95-70,
Feb.  6, 1995). 


   LABOR MANAGEMENT CHALLENGES
------------------------------------------------------------ Letter :7

The Results Act poses challenges to Labor to become more businesslike
in its operations.  Labor's strategic plan overview, however, does
not fully address these challenges and how Labor plans to respond. 

Managing in the "businesslike" manner envisioned by the Results Act
will be a substantial challenge for Labor, but the experiences of one
of its component agencies as a pilot could be helpful.  OSHA, as one
of the Results Act's pilot agencies, has been involved in a number of
activities geared toward making the management improvements intended
by the Results Act.\5 It has been working to develop a comprehensive
performance measurement system that will focus on outcomes to measure
its own effectiveness.  OSHA and state representatives have discussed
the application of this comprehensive system to OSHA's monitoring of
state safety and health programs.  Although not a requirement of the
strategic planning process, a discussion in Labor's overview related
to the experiences gained from the OSHA pilot project--including
lessons learned and whether best practices or other lessons could be
applied agencywide or in units with similar functions--could be
helpful in meeting the current challenge of managing under the
Results Act. 


--------------------
\5 Under the Results Act, OMB designated approximately 70 pilot
projects in performance measurement for fiscal years 1994, 1995, and
1996.  The pilot projects were to undertake the preparation of
performance plans and program performance reports for one or more of
the major functions and operations of the agency participating in the
pilot. 


   LABOR'S CAPACITY TO PROVIDE
   RELIABLE INFORMATION FOR AGENCY
   MANAGEMENT IS QUESTIONABLE
------------------------------------------------------------ Letter :8

To efficiently and effectively operate, manage, and oversee its
diversity of functions, Labor needs reliable data.  In past work, we
have identified weaknesses in Labor's information management
practices.  For example, our review of Labor's field offices
demonstrated the lack of centrally located information on key
departmental functions, such as field office locations, staffing, and
costs.  In our report on Labor's Davis-Bacon Act wage determination
process, we also identified limited computer capabilities as a reason
for the process' vulnerability to use of fraudulent or inaccurate
data.\6

We found a lack of both computer software and hardware that could
assist wage analysts in their reviews.  The OIG also cited areas in
which Labor needed to improve its information management practices,
especially those used to support financial accounting systems. 

Given these past findings, it is important for Labor to delineate in
its plan how it as an agency, along with specific unit initiatives,
will produce the requisite information to assess its progress.  In
its overview plan, Labor recognizes that if it is to ensure timely
and sound evaluations to assess agency progress in meeting goals
required by the act, additional information may need to be obtained
from its stakeholders.  However, its statement--"Resources for such
information collection and evaluation activities will need to be
addressed"--does not describe its strategy for ensuring that
information from evaluations and other ongoing systems will be
collected and used to assess progress and performance. 

Labor has made some efforts to improve its information management
systems; for example, it has appointed a Chief Information Officer. 
However, this individual also serves as the Assistant Secretary for
Administration and Management, and questions have been raised about
whether an individual can fulfill both responsibilities. 

As we have noted in our past work, sound application and management
of information technology to support strategic program goals must be
an important part of any serious attempt to improve agency mission
performance, cut costs, and enhance responsiveness to the public. 
Labor's overview plan does not discuss with any specificity how Labor
plans to use information technology to achieve its mission, goals,
and objectives, nor does the plan describe with sufficient clarity
how Labor intends to use information technology to improve
performance and reduce costs. 

According to its draft plan, Labor is focusing on "employing
innovative uses of technology." The plan states that "DOL [Labor] is
expanding the use of the Internet to make standards and
interpretations more accessible" and is testing software to allow the
public to comment electronically through the Internet.  Also, the
plan states that Labor is developing expert systems to assist
employers in complying with regulatory standards. 

In addition, Labor--like many other federal agencies--faces a major
challenge in managing information resources to ensure that
information technology tools and resources are consistent with the
agency's mission.  While Labor's draft overview cites information
technology initiatives, it does not contain a discussion of Labor's
information technology strategy.  This strategy should include how
Labor plans to address the "year 2000 problem," which involves the
need for computer systems to be changed to accommodate dates beyond
the year 1999.  In addition, the information technology strategy
should contain information on how Labor plans to comply with the
Clinger-Cohen Act of 1996.  The act calls for agencies to implement a
framework of modern technology management based on the practices
followed by leading private- and public-sector organizations that
have successfully used technology to dramatically improve performance
and meet strategic goals. 


--------------------
\6 Davis-Bacon Act:  Process Changes Could Raise Confidence That Wage
Rates Are Based on Accurate Data (GAO/HEHS-96-130, May 31, 1996). 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :9

In commenting on a draft of this correspondence, officials at Labor
generally disagreed with our observations.  These disagreements
related to (1) an interpretation of what Labor's strategic plan
overview does or does not include; (2) an interpretation of whether
Labor's strategic plan overview adequately addresses what is required
by the Results Act and OMB guidance in preparing a strategic plan;
and (3) whether it is appropriate to include certain information in
the overview, even though such information is not required. 

First, Labor officials disagreed with our statement that the overview
does not provide an agencywide strategic overview that links
individual strategic plans.  These officials contend that the plan
links individual strategic plans by presenting its major budget and
program themes with the appropriate agencies and their goals listed
under each appropriate theme.  However, we believe that listing the
three broad programmatic categories and excerpting goals from
individual plans and inserting them under the appropriate category
does not provide a sufficient linkage. 

Second, Labor officials disagreed with our statement that the
overview does not include all the elements identified by the Results
Act.  In this connection, Labor officials point out that agencies
that use strategic overviews are authorized by Circular A-11 to
present them in either of two forms; Labor officials say that
although Labor used the second form, we criticized the agency for
failing to meet the requirement for the first form.  We believe,
however, that Labor's overview does not satisfy another portion of
Circular A-11 that applies regardless of which form is used:  "The
overview links individual strategic plans by giving an overall
statement of the agency's mission and goals." We modified our
correspondence to make clearer the basis for our belief that the
overview does not include all the elements required by the Results
Act and OMB guidance. 

Third, officials at Labor disagreed with the appropriateness of
including certain information in the overview even though it is not
required.  For example, they said that it is inappropriate to include
a discussion of management challenges and Labor's capacity to provide
reliable information for Labor's management.  Our discussion of these
two issues is in direct response to this congressional request. 

Finally, Labor officials did agree with some of our statements and
agreed to take corrective action.  For example, they agreed to
include an explanation of why some Labor components prepared and
submitted strategic plans and others did not.  Similarly, they agreed
that the overview did not include overarching goals and that these
goals would be included in future revisions of the plan. 

We have incorporated Labor's comments and made technical changes to
our correspondence where appropriate. 


---------------------------------------------------------- Letter :9.1

As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this
correspondence until 30 days after its issue date.  At that time, we
will send copies to the Ranking Minority Members of your Committees
and to the Chairmen and Ranking Minority Members of other Committees
that have jurisdiction over Department of Labor activities; the
Secretary of Labor; and the Director, Office of Management and
Budget.  We will also send copies to others on request. 

Please contact me at (202) 512-7002 if you or your staffs have any
questions concerning this letter.  Major contributors to this letter
were Harriet C.  Ganson, Assistant Director; Thomas N.  Medvetz,
Evaluator-in-Charge; Robert Crystal, Assistant General Counsel;
Julian P.  Klazkin, Senior Attorney; David B.  Alston, Assistant
Director; and Thomas L.  Davies, Senior Evaluator. 

Carlotta C.  Joyner
Director, Education and Employment Issues

Enclosure


GOALS AND STATUTORY
RESPONSIBILITIES OF LABOR'S
COMPONENT UNITS
=================================================== Appendix Enclosure

Labor's five major areas of statutory responsibility--employment and
training, employment health and safety, pension and welfare benefits,
employment standards, and labor statistics--are discussed below. 


      EMPLOYMENT AND TRAINING
----------------------------------------------- Appendix Enclosure:0.1

Labor's major responsibilities in this area are covered by a number
of statutes administered by the Employment and Training
Administration (ETA) and the Veterans' Employment and Training
Service (VETS).  Under titles III and IX of the Social Security Act
(42 U.S.C.  501, 1101), Labor administers the Federal/State
Unemployment Compensation Program.  The Wagner-Peyser Act (29 U.S.C. 
49) provides authority for grants to states to establish and maintain
a system of local public employment offices.  Workers receive
training and retraining under title III of the Job Training
Partnership Act (JTPA) (29 U.S.C.  1651) and other acts.  Youth,
adults, and specific groups facing serious barriers to employment
receive assistance through grants to states under JTPA (29 U.S.C. 
1501). 

The mission of ETA, as expressed in the plan,\7 is to provide support
to the public and private sectors in response to changes in the labor
market, ensure that Americans have access to the information and
resources necessary to compete successfully in the job market, and
assist businesses in gaining access to skilled workers and training
resources to compete successfully in a global economy. 

ETA's goals are to (1) "[i]mprove systems to enhance and leverage
investments in service delivery for youth, adults and employers, and
to improve the functioning of labor markets"; (2) "[a]ssure that
America's youth, particularly at risk youth, acquire the knowledge,
skills, and abilities they need to earn a decent living"; (3)
"[p]rovide adult unemployed, disadvantaged and dislocated workers the
services which will help them find and hold good jobs at decent wages
with career potential"; (4) ensure that "[e]mployers value the public
workforce development system managed by ETA and its partners as being
integral to their competitiveness strategies and are among its
primary investors and customers"; and (5) "[i]n partnership with
employees and their representatives, achieve greater operating
efficiency, provide better services at reduced costs and increase
customer satisfaction."

The first goal is consistent with the purpose of JTPA, as well as
with the purpose of the Wagner-Peyser Act, which authorizes funding
to establish local public employment offices.  The second and third
goals reflect the very purpose of JTPA, which is "to establish
programs to prepare youth and adults facing serious barriers to
employment for participation in the labor force .  .  ." (29 U.S.C. 
1501).  The fourth goal is consistent with various statutes.  The
fifth goal is not based on a specific statutory requirement. 

VETS' goals are to provide (1) timely and fair resolution of
complaints; (2) employee development opportunities, supportive
services, and job openings; (3) timely and accurate information and
direction to customers, the Congress, and others regarding agency
services and accomplishments; (4) effective referrals of clients
whose needs cannot be totally met by VETS and its grantees; and (5)
quality training to service provider staff. 

VETS' first goal is not based on a specific statutory requirement. 
The second goal is specifically required under JTPA (29 U.S.C. 
1721).  Part of the third goal is clearly envisioned in the statutory
requirement that the Secretary support outreach and public
information activities to inform veterans about services and jobs (29
U.S.C.  1721(a)(3)(c)).  Reports of accomplishments are to be
included in an annual report to the Congress (29 U.S.C.1579(d)).  The
fourth goal appears to come from the requirement that Labor provide
employment and training information to veterans that is available
under statutes and other provisions of law (29 U.S.C. 
1721(a)(3)(C)).  This is, in effect, a referral.  The fifth goal is
not based on a specific statutory requirement. 


--------------------
\7 The word "plan" as used in this enclosure encompasses both the
overview plan and the component plans. 


      EMPLOYMENT HEALTH AND SAFETY
----------------------------------------------- Appendix Enclosure:0.2

The Occupational Safety and Health Act (OSH Act) (29 U.S.C.  651),
which is carried out by the Occupational Safety and Health
Administration (OSHA), and the Federal Mine Safety and Health Act
(FMSHA) (30 U.S.C.  801), which is carried out by the Mine Safety and
Health Administration (MSHA), establish Labor's major statutory
responsibilities in this area. 

The plan quotes the following specific mission from the OSH Act: 
"Assure so far as possible every working man and woman in the Nation
safe and healthful working conditions." It then sets out separate
strategic goals for OSHA and MSHA.  OSHA's goals are to (1) "ensure
healthful and safe working conditions for all workers, as evidenced
by fewer hazards, reduced exposures, and fewer injuries, illnesses
and fatalities"; (2) "change workplace culture to increase employer
and worker awareness of, commitment to, and involvement with safety
and health"; and (3) "secure public confidence through excellence in
the development and delivery of its programs and services." The first
goal reflects purposes declared in the OSH Act.  Although the act
does not explicitly require Labor to reduce hazards, exposures,
injuries, illnesses, or fatalities, such a goal is consistent with
the overall purpose of the act.  The second goal also reflects
purposes declared in the act, and it is driven by the act, but it
does not reflect a specific mandate.  The third goal does not appear
to be based on specific provisions of law. 

MSHA's goals are to (1) "reduce the number, rate and severity of
accidents and injuries"; (2) "reduce recurring accidents and
injuries"; (3) "reduce high incidence miner illnesses"; (4) "address
safety and health issues resulting from technological changes in the
mining industry"; and (5) "develop and implement site-specific
training programs." Although the act does not specifically require
any reductions, the first three goals reflect the overall purpose,
including declared purposes, of FMSHA.  The fourth goal is generally
consistent with the act in that it relates to miners' safety and
health, but the act does not mention technological changes.  The
fifth goal reflects various requirements in the act related to
training. 


      PENSION AND WELFARE BENEFITS
----------------------------------------------- Appendix Enclosure:0.3

The Employee Retirement Income Security Act of 1974 (ERISA) (29
U.S.C.  1001) establishes Labor's major responsibilities in this
area.  The Pension and Welfare Benefits Administration (PWBA)
administers title I of ERISA.  The Pension Benefits Guaranty
Corporation (PBGC) administers title IV of ERISA. 

Under the plan, the mission of PWBA is to "protect the pension and
welfare benefits of the over 150 million participants and
beneficiaries in private sector employee benefit plans." The goals of
PWBA are to (1) "[e]nsure workers get the information they need to
protect their benefit rights"; (2) "[a]ssist plan officials and
service providers in understanding the requirements of the relevant
statutes in order to meet their legal responsibilities"; (3)
"[d]evelop policies and laws that encourage the growth of
employment-based benefit plans"; and (4) "[d]eter and correct
violations of the relevant statutes." The first and fourth goals of
PWBA are statutory requirements.  The second, although not
specifically required by statute, is consistent with ERISA.  The
third is stated in the law, which refers only to "policies."

The stated mission of PBGC is to protect participants' benefits and
promote a healthy retirement system by encouraging continuation and
maintenance of private pension plans, protecting benefits, paying
benefits in a timely manner, and keeping costs and premiums low.  The
goals of PBGC are to (1) "[p]rotect existing defined benefit plans
and their participants, and encourage new plans"; (2) "[p]rovide high
quality services, and accurate and timely payment of benefits to
participants"; (3) "[s]trengthen financial programs and systems"; and
(4) "[i]mprove internal management support operations." The first and
second goals reflect the purposes of ERISA.  The latter two are not
based on specific statutory requirements. 


      EMPLOYMENT STANDARDS
----------------------------------------------- Appendix Enclosure:0.4

The following establish Labor's major statutory responsibilities in
this area:  the Fair Labor Standards Act (29 U.S.C.  201) and the
Contract Work Hours and Safety Standards Act (29 U.S.C.  327), which
are carried out by the Wage and Hour Division (WHD); acts such as the
Davis-Bacon Act (40 U.S.C.  276a) and the Service Contract Act (41
U.S.C.  351), which establish wage and other labor standards for
government contracts also carried out by WHD; and the Federal
Employee's Compensation Act (FECA) (5 U.S.C.  8101), the Longshore
and Harbor Workers' Compensation Act (33 U.S.C.  901), and the Black
Lung Benefits Act (30 U.S.C.  901), which are carried out by the
Office of Workers' Compensation Programs. 

WHD's goals are as follows:  (1) "increase compliance with the laws
and regulations administered and enforced by WHD"; (2) "increase
customer satisfaction with the services provided by WHD"; and (3)
"achieve a high performance workplace which anticipates and is
responsive to the needs of our customers and all our employees."
These goals are not based on specific statutory requirements. 

The goals of the Office of Workers' Compensation Programs are as
follows:  (1) ensure that "[u]nder the FECA, employees return to work
following a work injury at the earliest appropriate moment"; (2)
ensure that "[t]he FECA program, employing agencies, and Federal
unions work as partners to improve the delivery of Federal employees'
compensation benefits"; (3) "[a]pply tools and technology to expand
FECA program capabilities and enhance program effectiveness"; (4)
"[c]ontinue to organize and support national union/management
reengineering teams as vehicles for broad based participation in
decisions"; (5) "[p]romote a more efficient Black Lung benefit
delivery system"; (6) "[p]rovide a secure, effective, efficient and
prompt compensation and service delivery system for the Longshore
Program"; (7) "[e]nhance adjudicatory efficiency and quality"; (8)
ensure that "[i]njured FECA workers are served by a fair, swift, and
people-oriented compensation system"; (9) "create a leaner Black Lung
organization that delivers improved program services and eases
stakeholder burdens by reinventing and reengineering"; (10) "[i]nsure
fair, swift, cost-effective and people-oriented services for Black
Lung customers"; (11) "[r]educe the burden of reporting for
Longshore's customers"; (12) "[e]nhance public awareness and
voluntary compliance with the provisions of the Longshore Act"; (13)
"[m]aintain the fiscal integrity of the FECA system and deliver
cost-effective services"; and (14) "[e]xercise fiscal responsibility
in Black Lung while accomplishing the mission."

The first goal is not a specific statutory requirement but is
consistent with FECA, which allows Labor to require an injured
employee to submit to a physical examination as often as necessary (5
U.S.C.  8123).  Goals two, three, four, seven, eight, and thirteen
are not linked to specific statutory requirements but are consistent
with the Secretary's authority to administer the FECA program (5
U.S.C.  8145).  Goals five, nine, ten, and fourteen deal with the
Black Lung Program, and are not based on a specific statutory
requirement.  Goals six, seven, eleven, and twelve all relate to the
Longshore and Harbor Workers' Compensation Program.  (As noted above,
goal seven also relates to FECA.) Although none of the goals is
required by law, each is consistent with the Longshore Act. 


      LABOR STATISTICS
----------------------------------------------- Appendix Enclosure:0.5

The Bureau of Labor Statistics carries out Labor's responsibilities
for collecting, analyzing, and disseminating labor statistics.  The
law that establishes Labor's major statutory responsibilities in this
area appears at 29 U.S.C.  1. 

The Bureau's mission, as stated in the strategic plan, is to provide
comprehensive and timely labor market information to the American
public, the Congress, other federal agencies, state and local
governments, business, labor, and every agency within Labor.  The
Bureau has established two strategic goals:  (1) "[p]roduce and
disseminate timely, accurate, and relevant information in [the
Bureau's] areas of expertise" and (2) "[i]mprove accuracy,
efficiency, and relevancy of [the Bureau's] program outputs through
increased application of state-of-the-art statistical techniques,
economic concepts, technology, and management processes." The first
goal clearly reflects a statutory mandate.  The second, although not
specifically required by the applicable law, is consistent with it. 


============================================================ Chapter 0


RELATED GAO PRODUCTS
============================================================ Chapter 1

Veterans' Employment and Training Service:  Focusing on Program
Results to Improve Agency Performance (GAO/T-HEHS-97-129, May 7,
1997). 

Department of Labor:  Challenges in Ensuring Workforce Development
and Worker Protection (GAO/T-HEHS-97-85, Mar.  6, 1997). 

Managing for Results:  Using GPRA to Assist Congressional and
Executive Branch Decisionmaking (GAO/T-GGD-97-43, Feb.  12, 1997). 

Information Technology Investment:  Agencies Can Improve Performance,
Reduce Costs, and Minimize Risks (GAO/AIMD-96-64, Sept.  30, 1996). 

Education and Labor:  Information on the Departments' Field Offices
(GAO/HEHS-96-178, Sept.  16, 1996). 

Information Management Reform:  Effective Implementation Is Essential
for Improving Federal Performance (GAO/T-AIMD-96-132, July 17, 1996). 

Executive Guide:  Effectively Implementing the Government Performance
and Results Act (GAO/GGD-96-118, June 1996). 

Davis-Bacon Act:  Process Changes Could Raise Confidence That Wage
Rates Are Based on Accurate Data (GAO/HEHS-96-130, May 31, 1996). 

Employment Training:  Successful Projects Share Common Strategy
(GAO/HEHS-96-108, May 7, 1996). 

OSHA:  Potential to Reform Regulatory Enforcement (GAO/T-HEHS-96-42,
Oct.  17, 1995). 

Job Corps:  High Costs and Mixed Results Raise Questions About
Program's Effectiveness (GAO/HEHS-95-180, June 30, 1995). 

Multiple Employment Training Programs:  Information Crosswalk on 163
Employment Training Programs (GAO/HEHS-95-85FS, Feb.  14, 1995). 

Executive Guide:  Improving Mission Performance Through Strategic
Information Management and Technology (GAO/AIMD-94-115, May 1994). 


*** End of document. ***