The Results Act: Observations on the Draft Strategic Plans of Selected
Department of Labor Components (Correspondence, 07/31/97,
GAO/HEHS-97-188R).

Pursuant to a congressional request, GAO reviewed the draft strategic
plan submitted by the Department of Labor, as required by the Government
Performance and Results Act, and the draft strategic plans of the
Employment and Training Administration (ETA), Occupational Safety and
Health Administration (OSHA), and Employment Standards Administration
(ESA), as submitted by Labor.

GAO noted that: (1) Labor elected to submit a strategic plan overview
that addresses some Results Act requirements at the Department level,
and it also submitted individual plans for certain agency component
units; (2) Labor's overview does not comply with guidance to integrate
information from individual strategic plans of its components into a
single agencywide strategic overview document; (3) while Labor's
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
meet the guidance that it contain an overall statement of departmental
goals; (5) Labor's draft overview and supplemental unit plans cover the
five areas of major statutory responsibility; (6) Labor's strategic plan
overview recognizes the roles of other organizations and the importance
of establishing partnerships in carrying out functions; (7) Labor's
overview could be improved by recognizing the importance of other
participants, namely the other 14 federal agencies involved in one major
area of responsibility--job training; (8) 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
strategies pertaining to the development of a cohesive, integrated, and
coordinated system; (9) Labor's capacity to provide reliable information
for use in its agencywide management is questionable; (10) its overview
plan recognizes the importance of additional information to ensure
timely and sound evaluations to assess agency progress in meeting goals;
(11) its overview does not describe its strategy for ensuring that such
information is collected and used to assess progress and performance;
(12) 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; (13) the strategic plans of
ETA and OSHA address most of the elements in the Results Act; (14)
improvements could be made by including more detailed discussions of
evaluation strategies, crosscutting activities, and generating reliable
performance information; (15) both plans could benefit by including more
results-oriented goals and objectives; and (16) because ESA did not
prepare an overall strategic plan, it may not be in the position to
address common themes among its four program agencies.

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

 REPORTNUM:  HEHS-97-188R
     TITLE:  The Results Act: Observations on the Draft Strategic Plans 
             of Selected Department of Labor Components
      DATE:  07/31/97
   SUBJECT:  Interagency relations
             Strategic planning
             Agency missions
             Intergovernmental relations
             Employment or training programs
             Program evaluation
             Congressional/executive relations
             Information resources management
             Management information systems
             Public administration

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



September 1997


GAO/HEHS-97-188R

Labor Components' Strategic Plans

(205348)


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

  ESA - x
  ETA - x
  FECA - x
  JTPA - x
  LMRDA - x
  OMB - x
  OFCCP - x
  OLMS - x
  OSHA - x
  OWCP - x
  WHD - x

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


B-277573

July 31, 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 the Draft Strategic Plans
of Selected Department of Labor Components

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
completes our response to that request concerning the Department of
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, we analyzed Labor's overview and performed
selected analyses of individual plans.  The results of our analysis
of Labor's overview were sent to you in a letter dated July 11,
1997.\1 As you further requested, this letter provides additional
detailed analyses on the individual draft strategic plans submitted
by the Employment and Training Administration (ETA), the Occupational
Safety and Health Administration (OSHA), and the Employment Standards
Administration (ESA). 


--------------------
\1 The Results Act:  Observations on Department of Labor's June 1997
Draft Strategic Plan (GAO/HEHS-97-172R, July 11, 1997). 


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

Our overall objective was to review and evaluate the draft strategic
plans for three of Labor's components--ETA, OSHA, and ESA--as
submitted by Labor to congressional staff on June 11.  Specifically,
we (1) determined whether the plans included the elements required by
the Results Act and assessed the strengths and weaknesses of the
elements contained in them; (2) discussed the components' key
statutory responsibilities and how they were addressed in each of the
plans; (3) identified each component's programs, activities, and
functions that are crosscutting in that they are similar or related
to goals, activities, or functions of other agencies and the extent
to which the plan reflects interagency cooperation; (4) discussed the
extent to which management challenges were addressed in each plan;
and (5) described the three components' capacities to provide
reliable information about performance. 

As agreed, our assessment of the component strategic plans was based
generally on our previous work, our knowledge of the components'
operations, numerous reviews of Labor, and other information
available at the time of our assessment.  Specifically, the criterion
we used to determine whether the components' draft strategic plans
complied with the requirements of the Results Act was the Results Act
itself, supplemented by 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 plans, we used our May
1997 guidance for congressional review of strategic plans
(GAO/GGD-10.1.16) as a tool.  To determine whether the plans
contained information on interagency coordination, addressed
management problems previously identified, and reflected a capacity
to provide reliable performance information, we relied on our general
knowledge of Labor's operations and programs, and the results of our
previous work. 

Although we assessed the three Labor components' plans in terms of
the Results Act, individual components are not required to submit
strategic plans.  According to the act and OMB Circular A-11,
executive agencies such as Labor are required to submit a plan, and
the agencies can use discretion as to which of their component units
must submit plans.  There is no requirement that the component plans
that are submitted include the six elements specified in the act.  As
you requested, however, we reviewed the component plans in terms of
how they address the six elements considered essential to a strategic
plan. 

To review the key statutory responsibilities of each of the three
components and how they relate to their missions and goals, we
examined the applicable statutes.  As requested, we coordinated our
work on key statutory authorities and the 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 needed 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
component plans at a particular point.  We recognize that developing
a strategic plan is a dynamic process and that Labor and its
component units are continuing to work to revise the draft with input
from OMB, congressional staff, and other stakeholders. 


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

Labor administers and enforces a variety of federal labor laws
guaranteeing workers' rights to a work place 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, and over 1,000 field offices to support its various
functional responsibilities.  In fiscal year 1997, Labor has an
estimated budget of $34.4 billion and is authorized 16,614
full-time-equivalent staff-years. 

   Figure 1:  Department of Labor
   Organization

   (See figure in printed
   edition.)


      EMPLOYMENT AND TRAINING
      ADMINISTRATION
---------------------------------------------------------- Letter :2.1

ETA administers a number of statutes related to employment and
training services for the unemployed and underemployed, employment
security for workers, and other programs that are directed to meeting
the employment needs of the nation.  A major ETA responsibility is to
carry out the Job Training Partnership Act, which established a
decentralized structure for the delivery of employment and training
services funded through grants and administered predominantly by the
states.  ETA's employment security functions are carried out by the
Unemployment Insurance Service, which administers a nationwide
unemployment compensation system, and the Employment Service, which
administers a nationwide public employment service system.  ETA has
an estimated budget of $31.4 billion in fiscal year 1997; $6.2
billion of this amount is for employment and training programs.  The
remaining $25 billion is for mandatory spending on income maintenance
programs, such as the unemployment insurance program, and comes
primarily from the unemployment insurance trust fund, which is
financed by federal and state employer payroll taxes. 


      OCCUPATIONAL SAFETY AND
      HEALTH ADMINISTRATION
---------------------------------------------------------- Letter :2.2

OSHA administers policies and programs to ensure safe and healthful
working conditions for over 100 million workers covered by the
Occupational Safety and Health Act of 1970.  OSHA sets and enforces
national standards for work places to reduce or eliminate safety and
health hazards, encourages employers and employees to reduce work
place hazards through voluntary programs, offers training to improve
the competence of occupational safety and health personnel, and
provides for the development and approval of state occupational
safety and health programs.  OSHA's estimated budget for fiscal year
1997 is $325 million. 


      EMPLOYMENT STANDARDS
      ADMINISTRATION
---------------------------------------------------------- Letter :2.3

ESA is responsible for administering and directing a variety of
programs that protect the basic rights of workers.  These include
programs dealing with minimum wage and hour standards, workers'
compensation programs, equal employment opportunity programs, and
affirmative action programs for government contract employees, and
programs protecting workers' rights as union members.  ESA
administers these programs through four offices--the Office of
Federal Contract Compliance Programs (OFCCP), the Office of Workers'
Compensation Programs (OWCP), the Wage and Hour Division (WHD), and
the Office of Labor Management Standards (OLMS).  In fiscal year
1997, ESA has an estimated budget of $1.6 billion. 

OFCCP is responsible for enforcing requirements governing the
employment practices of federal contractors and subcontractors that
ensure equal employment opportunity for minorities, women,
individuals with disabilities, and disabled and Vietnam Era veterans. 
OWCP administers three major disability compensation programs by
providing cash benefits, medical treatment, vocational
rehabilitation, and other benefits to certain workers who have
work-related injuries or diseases.  WHD administers and enforces a
wide range of laws that collectively cover virtually all private as
well as state and local government employment.  Its activities
include ensuring compliance with minimum wage, overtime, child labor,
and other employment standards.  OLMS collects and makes available
for public disclosure union constitutions and financial reports,
audits union financial records, and investigates possible
embezzlement of union funds. 


      RESULTS ACT REQUIREMENTS AND
      OMB GUIDANCE ON PREPARING
      AND SUBMITTING STRATEGIC
      PLANS
---------------------------------------------------------- Letter :2.4

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 plans are to contain the
following six elements:  (1) an agency mission statement, (2)
long-term goals and objectives, (3) approaches to achieve goals and
objectives, (4) a description of the relationship between annual
goals and long-term goals and objectives, (5) key external factors
that could affect achievement of goals, and (6) evaluations used in
establishing the strategic plan and schedule for future program
evaluations. 

The Results Act is aimed at improving program performance.  It
requires that federal agencies consult with the Congress and other
stakeholders to clearly define their missions and articulate a
comprehensive mission statement that defines the basic purpose of the
agency.  It also requires that they establish long-term strategic
goals as well as annual goals that are 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 evaluate
their programs and to use information obtained from these evaluations
to improve their 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 should 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. 


      SUMMARY OF LABOR'S STRATEGIC
      PLAN OVERVIEW
---------------------------------------------------------- Letter :2.5

As we reported to you on July 11, 1996, to meet the Results Act
requirement for an agency strategic plan, Labor elected to submit "a
strategic plan overview" that addresses some Results Act requirements
at the Department level.  It also submitted individual plans for
certain agency component units.  However, Labor's overview does not
comply with OMB guidance to integrate information from individual
strategic plans of its components into a single agencywide strategic
overview document.  Furthermore, while Labor's 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 meet the
guidance 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. 

Labor's draft overview and supplemental unit plans cover the five
areas of major statutory responsibility--employment and training,
health and safety in the work place, pension and welfare benefits,
employment standards, and labor statistics.  The goals stated in the
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 work
places.  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 strategies 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 it will 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.  The plan also
does not include a discussion on the need for computer systems to be
changed to accommodate dates beyond the year 1999--the "year 2000
problem." 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. 


   OVERVIEW OF THREE COMPONENTS'
   PLANS
------------------------------------------------------------ Letter :3

The strategic plans of ETA and OSHA address most of the elements in
the Results Act.  Improvement could be made, however, by including
more detailed discussions of evaluation strategies, crosscutting
activities, and generating reliable performance information.  In
addition, both plans could benefit by including more results-oriented
goals and objectives.  On the other hand, ESA did not prepare an
overall strategic plan.  Rather, it submitted plans for each of its
four program offices.  Because ESA did not prepare an overall plan,
it may not be in a position to address common themes among its four
program agencies, such as better serving customers, relying on
information technology, and working with reduced resources. 

A more detailed analysis of ETA's and OSHA's plans are included in
enclosures I and II, respectively.  A review of the statutory
requirements of ESA are included in enclosure III. 


      ETA'S STRATEGIC PLAN
---------------------------------------------------------- Letter :3.1

ETA's draft strategic plan includes five of the six elements
delineated in the Results Act, but it does not provide the required
information about program evaluations.  Furthermore, some of the
elements, such as strategies to achieve goals and the factors
affecting ETA's ability to achieve the goals, are discussed in
greater detail and are developed more fully than others.  Other
useful information related to crosscutting functions and management
challenges is not provided.  ETA's mission statement does not cover
its key statutory responsibilities, but ETA's goals do reflect these
responsibilities. 

ETA's plan provides a fairly broad mission statement; for example, it
generally focuses on "ensuring that Americans have access to the
information and resources they require to successfully manage their
job lives." Its mission statement could be improved if ETA combined
it with the responsibilities it clearly set out in its vision
statement, such as providing high-quality job training, employment,
and income maintenance services through state and local workforce
development systems. 

ETA's description of long-term goals and objectives, strategies to
achieve them, and linkage to annual goals could also be improved. 
The goals of the plan cover the range of ETA's responsibilities and
generally allow for the future assessment of whether they are being
achieved.  But ETA could improve its strategic plan by developing
objectives that are more results oriented and measurable.  The
strategic objectives currently in the plan appear to be strategies to
achieve goals rather than objectives.  For example, the plan includes
the following as a strategic objective:  "Through Job Corps provide
alternative education and job skills preparation in a safe living and
learning environment, for disadvantaged, low income youth who dropped
out of school or who are at risk of dropping out of school." However,
this is essentially a strategy for achieving one of the strategic
goals, that is, "Assure that America's youth, particularly at risk
youth, acquire the knowledge, skills and abilities they need to earn
a decent living."

In addition, the plan would be more useful if it provided a schedule
for initiating and completing its strategies and described how it
would communicate strategic goals throughout the organization and how
it plans to hold management accountable for achieving goals. 

The plan includes a brief discussion of the relationship of the
annual plan to the long-term strategic plan and cites examples of
performance measures likely to be included in the annual plan.  Some
examples cited are "the number of states that demonstrate and pursue
one-stop building principles, the number of local communities which
will have access to employment and training services through an
integrated one-stop career center system," "the number of job
vacancies available on the Internet .  .  .," and "the number of Job
Corps students who are placed into jobs or other suitable outcomes."
The performance measures it finally selects would be more useful if
they included more results-oriented, outcome measures than those now
listed as possible measures. 

ETA's draft plan could also be improved by including a more detailed
discussion of external factors that could affect it and by including
the required information about program evaluations.  ETA's draft plan
describes the external factors that could affect its ability to
achieve its goals, such as pending legislation to consolidate
employment and training programs, resource availability, and changes
in the economy.  A strengthened discussion of the impact of recently
passed welfare legislation would be helpful, however, given its
potentially great impact on employment and training programs at the
state and local levels.  The draft plan makes no reference to program
evaluations conducted or planned.  It does state that program
requirements, with respect to performance measurement information,
will be assessed after the strategic plan is completed, but it is not
clear whether the reference is to discrete evaluation studies or
ongoing performance measures. 

Two of the goals outlined in ETA's plan reflect the requirements of
law; the rest do not, but are consistent with the law.  For example,
ETA's goal of assuring that America's youth, particularly at-risk
youth, acquire the knowledge, skills, and abilities they need to earn
a decent living reflects a requirement of law in that the very
purpose of the Job Training Partnership Act is to establish programs
to train youths and adults facing serious barriers to employment. 

The draft plan would also be improved by a discussion of coordination
about crosscutting issues and acknowledgment of management challenges
in implementing the plan, including obtaining reliable information
about performance.  All of these features are missing from the
current draft, even though there are significant crosscutting issues
that should be addressed (for example, the fact that multiple
agencies are responsible for employment training programs) and a
major management challenge facing ETA is the difficulty of producing
reliable information to assess program implementation and
performance. 


      OSHA'S STRATEGIC PLAN
---------------------------------------------------------- Letter :3.2

OSHA's draft strategic plan includes all but one of the six elements
delineated in the Results Act.  It also addresses crosscutting issues
and discusses major management challenges such as obtaining reliable
information. 

OSHA's mission statement--"assure so far as possible every working
man and woman in the nation safe and healthful working
conditions"--clearly and succinctly describes why OSHA exists and how
it carries out its work.  The goals OSHA sets forth in its plan
convey its principal functions and operations and are directly
related to its mission.  For example, the first goal in OSHA's plan
is to "assure safe and healthful working conditions for all workers,
as evidenced by fewer hazards, reduced exposures, and fewer injuries,
illnesses, and fatalities. 

OSHA's plan presents a broad discussion of the strategic tools that
it will rely on to achieve its goals.  However, the strategic plan
focuses more on describing particular strategies rather than on
articulating clear linkages between the individual strategies and the
achievement of the plan's goals.  For example, although the plan
discusses the various types of strategies OSHA will use to achieve
its goals (such as increased use of information technology or problem
analysis), OSHA did not include information about how these
strategies (which strive for improved data collection) can facilitate
achievement of its goals. 

The plan includes strategic measures to assess whether the related
goals and objectives have been achieved.  Although some of the plan's
performance measures are clearly outcome oriented, others are
ambiguous, posing measurement and interpretation problems.  Other
performance measures are essentially strategies for achieving the
goals, rather than measures.  For example, a measure such as
"developing and delivering training to workers and employers in the
skills necessary for effective worker involvement in safety and
health" is more of a strategy for achieving a goal rather than an
indicator for measuring progress. 

Also, the plan does not include a schedule for initiating or
completing significant actions nor the level of resources deemed
necessary.  Similarly, the plan does not address the process to be
followed to communicate goals and objectives throughout the agency
and to assign accountability to managers and staff for achievement of
objectives.  OSHA's plan does not specifically define the annual
performance goals; the plan could be improved by identifying the
appropriate data and measures OSHA will use to monitor progress on
these goals. 

OSHA's strategic plan includes a discussion of the external factors
that could influence the achievement of its strategic goals.  As the
plan notes, agency performance in improving worker safety and health
can be significantly affected by general economic conditions,
workforce demographics, and changes in the economy's job mix. 
However, it does not convey the extent to which these factors might
affect the achievement of the goals.  It also does not describe how
program evaluations were used in developing the plan or what future
evaluations will be used for measuring progress. 

Two of the three goals laid out in OSHA's plan reflect the purposes
delineated in the Occupational Safety and Health Act, OSHA's enabling
legislation.  For example, the first goal enunciated in OSHA's plan,
which is to ensure healthful and safe working conditions for all
workers, as evidenced by fewer hazards and injuries, clearly reflects
the purpose of the legislation, which is to "assure so far as
possible every working man and woman in the Nation safe and healthful
working conditions." The third goal is a general management goal that
does not reflect a specific provision of law. 

OSHA's plan acknowledges the importance of coordinating with agencies
such as the Department of Transportation and ETA that have related
missions and authority.  It also addresses the major management
challenge of producing reliable data to measure and track its
performance.  It includes as one of its strategic measures the full
implementation of an information system necessary to collect and
analyze OSHA data. 


      ESA'S STRATEGIC PLANNING
      APPROACH
---------------------------------------------------------- Letter :3.3

ESA has not developed a strategic plan or a strategic plan overview
for its various functions and responsibilities.  Rather, ESA
submitted a strategic plan for each of its four offices--WHD, OFCCP,
OWCP, and OLMS.  While the Results Act and Circular A-11 do not
require agency components, such as ESA, to submit strategic plans, it
is not clear why Labor chose to submit plans for other component
program offices at ESA's level but did not submit one for ESA.  Labor
indicated that it would explain in its revised strategic plan why
some components provided strategic plans and others did not. 

ESA's decentralized strategic planning effort, as indicated by its
choosing to submit individual plans for its four program operations,
mirrors the approach used by Labor to meet the requirements of the
Results Act.  As we previously reported, Labor's draft strategic plan
consisted of separate plans from 15 of its 24 agencies and a
strategic plan overview that basically consisted of excerpts from
these 15 agencies' plans rather than an agencywide plan reflecting
overarching goals and objectives. 

From our review of all four plans, it was not evident that ESA
provided guidance or direction to its four offices on what should be
included in their plans.  We found that the plans were uneven in
their coverage of the six strategic plan elements called for by the
Results Act, with one office's plan omitting several elements.  For
example, the plans for WHD and OLMS addressed all of the elements;
however, the OWCP plan did not address the strategies that would be
used to achieve the goals, the key external factors that could affect
the achievement of the goals, or the evaluations to be used to
establish goals or that would be used to monitor progress. 

By using a decentralized approach, ESA may have missed opportunities
to improve coordination among its four program offices and ensure
that the programs are able to achieve their goals.  For example,
there appeared to be several common themes across the four offices'
plans in terms of

  -- strategic goals, such as better serving customers;

  -- strategies to achieve those goals, such as reliance on
     technology or the development of data systems to increase
     program efficiency; and

  -- key external factors that could affect the achievement of those
     goals, such as reduced resources or diverse stakeholders with
     differing views. 

Because ESA did not prepare an overall plan or provide information
that acknowledged these commonalities, ESA may not be in a position
to address these common themes strategically and facilitate the
achievement of each of the offices' goals. 

Similarly, there were commonalities in at least one of the offices'
plans--OWCP.  However, OWCP's plan appeared to be a compilation of
strategic goals developed by the three programs it oversees rather
than an overall plan for OWCP as a whole.  OWCP stated in its plan
that "individual teams were responsible for developing strategic
plans for each of the three compensation programs it
operated--Federal Employees' Compensation Act, Black Lung, and
Longshore and Harbor Workers' Compensation." Perhaps as a result of
this approach, OWCP's plan contained similar goals for each of the
three programs it oversees instead of delineating a single goal. 
OWCP's plan contains the following goals related to improving
customer service: 

  -- "[Ensure] injured FECA [Federal Employees' Compensation Act]
     workers are served by a fair, swift, and people-oriented
     compensation system."

  -- "Insure fair, swift, cost effective and people-oriented services
     for Black Lung customers."

  -- "Provide a secure, effective, efficient and prompt compensation
     and service delivery system for the Longshore Program."

We recognize that strategic planning is a challenge that is made more
difficult when, as with ESA, an organization has diverse functions,
is authorized under several separate pieces of legislation, and has
programs that traditionally have operated fairly autonomously. 
However, to derive the value and benefit of a strategic planning
process, Labor may want to consider whether the development of an
ESA-level plan would enhance its planning efforts.  Such a plan could
use common programmatic themes as a foundation to help ESA make
policy decisions in terms of direction and operations of its
programs, to evaluate whether the programs are achieving intended
results, and to increase coordination among its program operations. 

Numerous statutes govern the various missions of ESA's offices.  We
found that the strategic goals laid out in the office plans reflect
specific requirements or general purposes of statutes, or are not
based on specific statutes but are desirable performance goals.  For
example, WHD's goal to increase customer satisfaction with the
services provided is not based on a specific statute but is a
desirable performance goal. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :4

The Department of Labor commented on a draft of this letter.  Labor
does not substantially disagree with our observations about the
strategic plans.  The new Secretary of Labor takes the strategic
planning process seriously, acknowledges that Labor has a lot to
learn about the process, and expects the later versions of its plans
to be significantly improved. 

Only one of the three component units--OSHA--provided specific
comments on the draft.  OSHA stated our observations were insightful
and agreed with many of them.  In addition, OSHA characterized its
comments as "less a rebuttal than an explanation of the approaches
taken in formulating OSHA's Strategic Plan." Labor did not provide
comments on the ETA and ESA portions of our letter but stated that
both agencies will consider our input when revising their strategic
plans.  Labor also stated that ESA was preparing an agency-level
strategic plan overview in accordance with the guidelines under the
Results Act. 


---------------------------------------------------------- Letter :4.1

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 Minority Leader of the House of
Representatives; the Ranking Minority Members of your Committees; 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) 512-7014 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; Charles A.  Jeszeck and Sigurd R.  Nilsen,
Assistant Directors; Lori Rectanus, Senior Evaluator; Robert Crystal,
Assistant General Counsel; and Julian P.  Klazkin, Senior Attorney. 

Carlotta C.  Joyner
Director, Education and
 Employment Issues

Enclosures - 3


OBSERVATIONS ON ETA'S DRAFT
STRATEGIC PLAN
=========================================================== Appendix I


   PLAN ADDRESSES MOST ELEMENTS IN
   THE RESULTS ACT
--------------------------------------------------------- Appendix I:1

The Employment and Training Administration's (ETA) draft strategic
plan addresses five of the six elements required by the Results Act,
but it does not contain the required information on program
evaluation.  Furthermore, other elements are incomplete or could be
improved.  The draft plan could be improved by providing a more
descriptive mission statement, indicating the extent to which
evaluations were used in preparing the plan and how they will be used
to measure progress, acknowledging the role of other organizations in
the employment and training area and indicating how the combined
efforts will be coordinated, and recognizing the importance of
reliable and integrated data systems in assessing program
implementation and performance. 


      MISSION STATEMENT COULD BE
      MORE DESCRIPTIVE
------------------------------------------------------- Appendix I:1.1

The draft strategic plan states that "ETA's mission is to provide
critical support to the public sector and the private sector response
to changes in the labor market, ensuring that Americans have access
to the information and resources they require to successfully manage
their job lives and that U.S.  businesses have access to the skilled
workers and training resources they need to compete successfully in a
global economy." ETA's mission statement does not clearly include all
aspects of its responsibilities.  Instead, ETA's mission statement
focuses on its role in providing information to workers and employers
to facilitate efficient labor exchange activities--surely one of
ETA's responsibilities, but only one aspect of its mission.  In
addition, its reference to providing information and resources so
that Americans can successfully manage their working lives makes the
mission statement process oriented rather than results oriented.  The
mission statement could be both broader--referring to ETA's role of
improving incomes for workers through job training and maintaining
the incomes of dislocated workers as they search for new jobs--and
cover more of the activities in which ETA is involved, such as job
training for new and dislocated workers and income maintenance for
unemployed workers. 

The vision statement included in ETA's draft strategic plan is a more
comprehensive articulation of its mission and could be used as a
basis to improve the mission statement.  The vision statement
provides that ETA "promotes more efficient, effectively functioning
U.S.  labor markets by providing high quality job training,
employment, and income maintenance services through State and local
workforce development systems." Modifying this statement to include a
more results-oriented focus, such as to help individuals obtain jobs,
would improve its basis as a mission statement. 


      STRATEGIC GOALS COVER THE
      RANGE OF ETA
      RESPONSIBILITIES
------------------------------------------------------- Appendix I:1.2

The ETA draft strategic plan contains five strategic goals that
appear to cover the range of ETA's responsibilities, with a focus on
long-term goals.  The goals cited in the plan are: 

  -- "Improve systems to enhance and leverage investments in service
     delivery for youth, adults and employers, and to improve the
     functioning of labor markets."

  -- "Assure that America's youth, particularly at-risk youth,
     acquire the knowledge, skills and abilities they need to earn a
     decent living."

  -- "Provide adult unemployed, disadvantaged and dislocated workers
     the services which will help them find and hold good jobs at
     decent wages with career potential."

  -- "Employers 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."

  -- "In partnership with employees and their representatives,
     achieve greater operating efficiency, provide better services at
     reduced costs and increase customer satisfaction."

The second and third goals clearly articulate populations to be
assisted, the kind of assistance ETA can provide, and the outcomes
desired, such as youths earning a decent living, and unemployed,
disadvantaged, and dislocated workers finding and holding good jobs
at decent wages with career potential.  These two goals are expressed
in a manner that allows for future assessment of whether they are
being achieved.  The first and fourth goals appear to be process
oriented, specifying the achievement of interim steps believed to be
necessary to achieve certain goals, such as improving systems to
enhance service delivery, and having employers value ETA's work.  The
fifth goal deals with internal ETA operating efficiency and customer
satisfaction. 

ETA could improve its strategic plan by developing strategic
objectives that are results oriented.  The strategic objectives
currently in the plan appear to be strategies to achieve goals rather
than objectives.  For example, the strategic goal that ".  .  . 
America's youth, particularly at-risk youth, acquire the knowledge,
skills and abilities they need to earn a decent living" contains
objectives that are essentially strategies for achieving that goal,
such as: 

  -- "through Job Corps, provide alternative education and job skills
     preparation in a safe living and learning environment, for
     disadvantaged, low income youth who dropped out of school or who
     are at risk of dropping out of school."

  -- "through Job Training Partnership Act [JTPA] year-round, summer
     and pilot and demonstration programs, provide alternative
     education and job skills preparation for youth who dropped out
     of school or who are at risk of dropping out of school."

Developing more focused, measurable objectives would enhance the
usefulness of the plan in communicating what ETA hopes to achieve. 


      STRATEGIES DESCRIBE HOW
      GOALS WILL BE ACHIEVED
------------------------------------------------------- Appendix I:1.3

Overall, ETA's draft strategic plan outlines the various strategies
needed to achieve its goals.  The strategic goals, combined with the
strategies listed in the plan, provide a fairly comprehensive
description of how ETA plans to achieve its goals.  However, the
draft strategic plan does not provide a schedule for initiating and
completing its strategies as discussed in OMB Circular A-11. 
Furthermore, the draft plan does not discuss how ETA will communicate
strategic goals throughout the organization.  Also, the plan could be
strengthened to better indicate how ETA will hold managers and staff
accountable for achieving these goals.  Its discussion on management
accountability states that ETA will "implement managerial systems . 
.  .  and strengthen the relationship between performance and
personnel evaluation systems," but it is not clear how managerial
accountability will be achieved through this strategy. 


      RELATIONSHIP TO ANNUAL PLAN
      DESCRIBED
------------------------------------------------------- Appendix I:1.4

The ETA draft plan includes a brief discussion of the relationship of
the strategic plan to its annual performance plan.  It describes this
relationship through a series of examples of performance goals that
are likely to be included in the annual performance plan.  Although
examples of performance goals are not required, it is a positive step
toward articulating how ETA will measure progress.  We recognize that
ETA's annual performance plan is being developed and that the
performance indicators listed in its current strategic plan may
change.  In that regard, we identified several areas in which we
believe ETA could improve its presentation of information.  For
instance, the examples cited in the plan generally are process
oriented, such as expanding the number of states that demonstrate and
pursue one-stop system-building principles.  This may be an important
aspect of building a better service delivery system, but outcome
measures that focus on the end results, such as reemployment at
higher wages, would appear to be a more meaningful measure of
performance. 

Overall, ETA's articulation of performance measures would be improved
by including more results-oriented measures to ensure that ETA can
assess the extent to which it has achieved its goals, both long-term
and annual.  For example, the plan includes output measures that do
not focus on what the goal is to achieve; instead, they are process
oriented, such as increasing the number of agencies participating in
state and local centers, increasing the number of job vacancy
listings available on Internet, and increasing students' perception
of safety at Job Corps centers.  The plan could focus on results by
including more measures, such as those included under the job
training objective--entered employment rate, follow-up employment
rate, average wage at placement, and follow-up weekly earnings. 


      KEY EXTERNAL FACTORS
      INDICATED
------------------------------------------------------- Appendix I:1.5

ETA's draft strategic plan describes, in general, the factors outside
the agency's scope and responsibility that could negatively affect
its ability to achieve its strategic goals.  Although these factors
were not explicitly linked to a particular goal in accordance with
OMB Circular A-11, the draft plan does describe how certain external
factors could affect the various entities and individuals involved in
the nation's employment and training system, which in turn could
affect ETA's programs, activities, and resources.  Examples of these
factors included pending legislation to consolidate and reform the
nation's employment and training programs, changes in the economy
that could affect the demand for employment and reemployment
assistance, and resource availability. 


      ROLE OF EVALUATIONS NOT
      ADEQUATELY ADDRESSED
------------------------------------------------------- Appendix I:1.6

The plan did not include a discussion of how evaluations were used in
preparing the plan as well as a schedule for future evaluations as
required by Circular A-11.  Rather, the plan states that ETA will
reassess its program requirements to ensure that needed information
to measure performance is collected and available timely. 

Although a large number of studies on employment training have been
conducted or are under way, ETA made no reference to these studies in
its plan.  For example, the Department of Labor has funded numerous
studies of its programs over the years, such as the long-term study
of JTPA results,\2 and we have issued a number of reports on
federally funded employment training programs under ETA's purview and
the problems resulting from the multiple employment training programs
spread across 15 federal departments and independent agencies.  In
addition, many other studies have been conducted of the assistance
provided to dislocated workers under JTPA, the Trade Adjustment
Assistance program, and the unemployment insurance system.  In
addition, another study, aimed at analyzing the net impact of Job
Corps, is under way. 


--------------------
\2 Abt Associates, Inc., The National JTPA Study:  Impacts, Benefits,
and Costs of Title II-A (Bethesda, Md.:  Abt Associates, Inc., Mar. 
1994). 


   GOALS ARE CONSISTENT WITH
   STATUTORY RESPONSIBILITIES
--------------------------------------------------------- Appendix I:2

The goals set out in ETA's plan reflect requirements of law or are
consistent with the law.  The first goal is consistent with the
purpose of JTPA as well as that 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. 

Under titles III and IX of the Social Security Act (42 U.S.C.  501,
1101), ETA 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 JTPA (29 U.S.C.  1651) and other acts.  Youth,
adults, and specific groups can receive assistance through grants to
states under JTPA. 


      CROSSCUTTING ACTIVITIES NOT
      DESCRIBED
------------------------------------------------------- Appendix I:2.1

The ETA plan does not acknowledge a key aspect of the nation's
federally funded employment training system--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, one of which is ETA.  However, because ETA omitted the
fact that many of the nation's job training programs are outside its
purview, its plan does not discuss how its programs fit in with the
nation's broader job training strategy.  While the draft plan notes
that the prospect of new legislation could provide a new policy
framework, this is not expanded upon nor are its implications
acknowledged elsewhere in the plan. 

The plan could also be improved by including a discussion of
cooperative efforts with other agencies.  For example, ETA and the
Department of Education jointly administer the school-to-work
program.  However, reviewing these two strategic plans does not give
one a sense that there was coordination in developing the plans
because their strategies and measures or indicators are generally
different.  For example, the Education draft plan cites as a core
strategy, to "engage high schools, postsecondary institutions, and
adult high schools in building school-to-work systems by sponsoring a
national information center, creating networks that include
educators, employers and other key stakeholder groups, and sponsoring
efforts to align postsecondary admissions policies with new methods
of assessing high school student performance." ETA's plan does not
include a similar strategy.  But it does include a strategy to
"support the development, testing, dissemination, and showcasing of
successful efforts to serve out-of-school youth in a STW
[school-to-work] framework," which is not included in Education's
plan.  Both ETA and Education delineated measures that reflect the
focus of the agencies' roles in the program.  Education's plan
focuses on curriculum and number of students participating, whereas
ETA's also includes a focus on skill attainment, unemployment, and
starting wage rate.  A cooperative effort by ETA and Education in
developing measures would ensure that all the outcomes of the program
are identified and measured. 

ETA also needs to strengthen its discussion of the impact that
recently passed welfare reform legislation is likely to have on the
structure and delivery of employment training programs at the state
and local levels as well as at on other federal agencies, such as the
Department of Health and Human Services.  In developing strategies to
best serve those individuals transitioning from welfare to work, ETA
will need to coordinate extensively with state and federal
organizations providing services to these individuals to ensure that
the appropriate mix of services is provided. 


   PRODUCING RELIABLE PERFORMANCE
   INFORMATION IS A MANAGEMENT
   CHALLENGE
--------------------------------------------------------- Appendix I:3

A major management challenge is to produce reliable information to
assess program implementation and performance.  ETA has multiple data
systems that are not integrated.  In its plan, ETA cites different
data sources and systems, some of which are not yet developed. 
However, the plan does not include a discussion of ETA's strategies
for ensuring that these sources and systems provide the type of
information it will need to assess programs. 

On the basis of previous work, we know that ETA produces a
significant amount of information on its programs and undertakes
numerous evaluations to monitor and assess program implementation and
performance.  However, the value of ETA's data could be improved if
the different evaluation systems were coordinated.  For example, Job
Corps and JTPA both have process- and results-oriented measures
associated with their programs.  And both programs are focused on
training economically disadvantaged individuals and helping them
obtain jobs at decent wages.  But the specific indicators used by the
two programs are different.  For example, JTPA uses employment rates
and weekly earnings at 13 weeks following program termination as a
measure of program performance and Job Corps uses placement rates,
average wage, and job training-employment match at a specific point
as a measure.  If the programs used similar indicators, ETA would be
able to provide an overall common measure of the extent to which its
job training programs are achieving common goals and to allow it to
compare the relative effectiveness of different strategies. 

Another important issue is the need for ETA to obtain information on
long-term program outcomes such as job retention.  We recognize the
difficulty of developing and collecting such information.  However,
the ultimate value of employment and training programs is in their
ability to help individuals obtain and retain jobs.  In that regard,
the results of our 1996 study showed that while there were some
positive effects of JTPA in the years immediately following training,
there were no significant effects on participant earnings and
employment rates after 5 years.\3

Also, our past work has shown that ETA faces a major challenge in
obtaining reliable data.  For the Job Corps, the reported information
did not provide a complete and accurate picture of program activities
and results.  For example, our survey of employers who were reported
as hiring Job Corps participants showed that about 15 percent of the
placements in our sample were potentially invalid:  A number of
employers reported that they had not hired students reported placed
at their businesses, and other employers could not be found.\4


--------------------
\3 Job Training Partnership Act:  Long-Term Earnings and Employment
Outcomes (GAO/HEHS-96-40, Mar.  4, 1996). 

\4 Job Corps:  High Costs and Mixed Results Raise Questions About
Program's Effectiveness (GAO/HEHS-95-180, June 30, 1995). 


OBSERVATIONS ON OSHA'S DRAFT
STRATEGIC PLAN
========================================================== Appendix II


   OSHA'S DRAFT STRATEGIC PLAN
   CONTAINS MOST ELEMENTS IN THE
   RESULTS ACT
-------------------------------------------------------- Appendix II:1

OSHA's draft strategic plan includes all but one of the six elements
delineated in the Results Act.  The plan's long-term goals are
succinct and logically linked to the mission statement.  Our review
of the three other elements--approaches to achieve goals,
relationship between long-term goals and annual goals, and key
factors--indicate that these could benefit from more information,
clarity, and context.  The use of evaluations is not discussed in the
strategic plan.  The following is our analysis of the plan's major
components. 


      PLAN'S MISSION STATEMENT IS
      CLEAR AND SUCCINCT
------------------------------------------------------ Appendix II:1.1

OSHA's stated mission in its strategic plan is to "assure so far as
possible every working man and woman in the Nation safe and healthful
working conditions." Its vision statement expands on this, stating
that OSHA envisions itself to be a "world class leader in
occupational safety and health by making America's workplaces the
safest in the world." OSHA's mission statement clearly and succinctly
describes why it exists and, in conjunction with supporting
narrative, explains what it does and how it performs its work.  For
example, the plan states that its mandate involves OSHA's application
of a set of tools (standards development, enforcement, and compliance
assistance) that enable employers to maintain safe and healthful work
places.  Supporting information emphasizes OSHA's shared commitment
with workers and employers to fulfill its mission. 


      GOALS CONSISTENT WITH OSHA'S
      MISSION
------------------------------------------------------ Appendix II:1.2

The goals in OSHA's strategic plan cover its main functions and
operations and are consistent with several of our past agency
reviews.  In addition, the goals are more outcome oriented than those
contained in earlier drafts of OSHA's strategic plan.  The goals are
as follows: 

  -- "Assure safe and healthful working conditions for all workers,
     as evidenced by fewer hazards, reduced exposures, and fewer
     injuries, illnesses, and fatalities

  -- "Change workplace culture to increase employer and worker
     awareness of, commitment to, and involvement in safety and
     health

  -- "Secure public confidence through excellence in the development
     and delivery of OSHA's programs and services."

OSHA's goals are directly related to its mission of a safe and
healthful work place and are consistent with the results from our
past work.  Two of our previous reports discuss the benefits of work
place safety and health programs and employee involvement.\5 In
addition, three other reports stress the importance for OSHA to
develop a greater service orientation while carrying out its
mission.\6

In a recently issued report,\7 we presented the results of our
examination of early progress under the Results Act toward
results-oriented goal setting and performance measurement in selected
federal regulatory agencies, including OSHA.  In that report, we
found only one of OSHA's strategic goals to be results oriented "to
some extent" and the remaining two "to little or no extent." Using
our criteria from this report, we consider the current goal
of--"assure safe and healthful working conditions for all workers, as
evidenced by fewer hazards, reduced exposures and fewer injuries,
illnesses and fatalities"--to be results oriented (for example,
"reducing injuries") as well as measurable ("counting the reduced
number of injuries and illnesses").  However, the performance
measures associated with this goal seem to apply only to certain
types of industries and would not include all workers.  The second
goal, "change workplace culture to increase employer and worker
awareness of, commitment to, and involvement in safety and health" is
considered to be "somewhat results oriented." It is considered
somewhat results oriented because it is not clear how OSHA plans to
measure commitment or involvement. 

Some of the associated performance measures contained in OSHA's
strategic plan are clearly outcome oriented.  For example, OSHA's
first goal, related to safe and healthful working conditions for
workers, includes specific results, such as (1) reducing three of the
most prevalent types of work place injuries and illnesses by 20
percent, (2) reducing injury and/or illness rates in at least five
high-hazard industries by 20 percent, and (3) decreasing the total
number of fatalities in the construction industry by 20 percent. 

On the other hand, some of the performance measures are ambiguous,
posing measurement and interpretation problems.  For example, the
plan includes a measure specifying that all proposed regulations and
initiatives contain a worker involvement component, but it does not
define the elements of such a component.  Similarly, the plan states
that by fiscal year 2002, OSHA will ensure that 50 percent of the
employers who are targeted for or request an OSHA intervention will
have implemented an effective safety and health plan, but it does not
discuss the components of such effective plans nor how they would be
assessed for their effectiveness. 

The agency's strategic plan also includes performance measures that
are essentially strategies for achieving the goals rather than
measures.  For example, measures such as "develop and deliver
training to workers and employers in the skills necessary for
effective worker involvement in safety and health" and "develop and
disseminate occupational safety and health training and reference
materials targeted to small business employers and workers" are
strategies for reaching the strategic goals rather than indicators of
progress toward achieving those goals. 


--------------------
\5 Occupational Safety and Health:  Options for Improving Safety and
Health in the Workplace (GAO/HRD 90-66BR Aug.  24, 1990) and
Occupational Safety and Health:  Worksite Safety and Health Programs
Show Promise (GAO/HRD 92-68, May 19, 1992). 

\6 OSHA:  Potential to Reform Regulatory Enforcement Efforts
(GAO/T-HEHS-96-42, Oct.  17, 1995), Department of Labor Rethinking
the Federal Role in Worker Protection and Workforce Development
(GAO/T-HEHS-95-125, Apr.  4, 1995), and Workplace Regulation: 
Information on Selected Employer and Union Experiences
(GAO/HEHS-94-138, June 30, 1994). 

\7 Managing for Results:  Regulatory Agencies Identified Significant
Barriers to Focusing on Results (GAO/GGD-97-83, June 24, 1997). 


      LINK BETWEEN STRATEGIES AND
      ACHIEVEMENT OF GOALS UNCLEAR
------------------------------------------------------ Appendix II:1.3

Under the Results Act, approaches or strategies should describe the
way an agency intends to accomplish its goals and objectives.  These
strategies should briefly describe the operational process, staff
skills, and technologies as well as the human, capital, information,
and other resources needed.  OSHA's plan presents a broad discussion
of the array of strategic tools that it will rely on to achieve its
goals.  However, the strategic plan focuses on describing particular
strategies rather than articulating a clear link between the
individual strategies and the achievement of the plan's goals. 

OSHA's strategic plan states that it will increasingly use "data
driven approaches to direct its resources away from safer workplaces
towards more hazardous ones" and will "address the most prevalent
types of workplace injuries and illnesses and .  .  .  high hazard
industries.  .  .  identified through site specific injury and
illness data." Such improved targeting, by facilitating more
efficient use of scarce enforcement resources, can contribute to
reduced work place hazards, injuries, illnesses, and fatalities as
specified in the plan's strategic goals.  Improved targeting is also
consistent with results presented in our past work.  To the extent
that stakeholders also perceive improved targeting as more equitable
and credible, it can also influence public confidence through better
service delivery and change work place culture by increasing employer
commitment to health and safety.  Yet, the plan does not discuss any
of these potential links.  The plan could also be enhanced by
highlighting the necessary linkages between different strategic tools
that can make their use more effective.  For example, the plan's
discussion of its information technology and problem analysis
strategies does not include how these strategies (for example,
improved data collection) can facilitate its enforcement strategy
(for example, better inspection targeting). 

OSHA's strategic plan does not include a schedule for initiating or
completing significant actions, as called for in OMB Circular A-11,
part 2.  For example, OSHA's plan specifies that it will promulgate a
rule on safety and health programs in the work place.  But the plan
does not provide any schedule for initiating or completing this
action nor the level of resources deemed necessary.  Similarly, the
plan states in its problem analysis section that it will use the data
collected in an ongoing manner as part of its own initiatives to
guide its program operations to determine the appropriate mix of
interventions and strategic tools to use.  However, the plan does not
contain a description of these data collection efforts, any schedule
for their implementation, nor the resources needed for completion. 

OSHA's draft strategic plan also does not address another area called
for in OMB Circular A-11, part 2--the process for communicating goals
and objectives throughout an agency and for assigning accountability
to managers and staff for achievement of objectives.  OSHA's
strategic plan does specify that it will rely on Labor management
cooperation, employee participation, and the development of
management and information systems to assist OSHA staff in achieving
the agency's strategic goals.  However, while these initiatives may
contribute to communicating goals and objectives throughout the
agency and foster staff involvement, the plan is not clear about how
these initiatives will facilitate the assigning of accountability to
management for achieving objectives. 


      ANNUAL PERFORMANCE GOALS NOT
      SPECIFICALLY DEFINED
------------------------------------------------------ Appendix II:1.4

OSHA's strategic plan states that OSHA will develop annual
performance plans, based on the strategic plan's goals and
objectives, that will define the specific programmatic activities to
be accomplished such as identification of the standards to be
addressed during that year and the national and local emphasis
programs to be implemented.  The agency also expects that the annual
plans will have a cumulative impact on achieving the strategic plan's
overall goals and objectives.  The plan, however, does not
specifically define the annual performance goals, and there is a
general lack of detail in identifying the appropriate data and
measures OSHA will use to monitor progress on its strategic goals. 
OSHA acknowledges this lack of specificity, mentioning the general
data limitations regarding safety and health, the agency's need for
improved data and measurement systems, and its need to collect the
baseline data for those appropriate measures against which future
performance will be tracked. 

In response to these problems, the plan states that OSHA will review
a number of different data and information sources as part of the
development of its annual performance plans.  These annual efforts
will be coordinated with OSHA's data initiative that will be fully
implemented by fiscal year 1998.  The plan also states that resources
will be devoted in the early years of the plan to identifying
appropriate performance measures and collecting the baseline data
necessary for their use.  Although it is not explicit, this wording
suggests that OSHA will begin to track interim measures of progress
prior to fiscal year 2002.  Such actions can facilitate the
assessment of progress toward the strategic plan's goals during the
early years of the plan and are consistent with the Results Act. 


      EXTERNAL FACTORS COULD
      INFLUENCE ACHIEVEMENT OF
      GOALS
------------------------------------------------------ Appendix II:1.5

OSHA's strategic plan presents a comprehensive discussion of the
factors that could influence the achievement of its strategic goals
and the way it measures the impact of its efforts.  As OSHA notes,
agency performance in improving worker safety and health can be
significantly affected by general economic conditions, such as
layoffs; workforce demographics, such as employing
non-English-speaking workers; changes in the economy's job mix, for
example, a shift from manufacturing to service-based employment; and
governmental budget decisions (for example, the fiscal year 1996
shutdown).  Even its data collection efforts are constrained by
external requirements like the Paperwork Reduction Act and
difficulties associated with the use of data from the Bureau of Labor
Statistics.  Finally, OSHA notes that a key component of its
strategic plan is the inclusion of partner, stakeholder, and customer
needs and requirements, although, in some cases, conflict between
these parties may make inclusion or consensus difficult. 

The strategic plan does not convey the degree to which achievement of
OSHA's goals would be affected by these external factors and the
degree to which these factors may limit OSHA's ability to commit
itself to making significant progress toward its goals.  In some
instances, these outside factors may seriously impede or even
overcome OSHA's good faith efforts to implement its strategy or may
render OSHA's performance measures unsuitable. 


      ROLE OF EVALUATION NOT
      INCLUDED IN STRATEGIC PLAN
------------------------------------------------------ Appendix II:1.6

OSHA's strategic plan neither describes program evaluations that were
used in preparing the strategic plan nor refers to future program
evaluations that go beyond analysis of measured performance,
assessment of the external environment, and the needs of its
stakeholders.  In our view, evaluations could play a particularly
helpful role for OSHA in gauging its performance and achieving its
goals, given the often limited availability of data for performance
measures and the presence of serious external factors that could
confound agency program and measurement efforts.  For example,
evaluations can be used to directly measure agency performance and to
develop improved outcome performance indicators, particularly given
that many of the agency's specified performance measures would not be
in place until fiscal year 2002. 


   STATUTORY RESPONSIBILITIES
-------------------------------------------------------- Appendix II:2

OSHA administers the Occupational Safety and Health Act of 1970 (29
U.S.C.  651).  The purposes delineated in this act are generally
reflected in the goals in OSHA'S plan, which are as follows: 

  -- "Assure safe and healthful working conditions for all workers,
     as evidenced by fewer hazards, reduced exposures, and fewer
     injuries, illnesses, and fatalities

  -- "Change workplace culture to increase employer and worker
     awareness of, commitment to, and involvement in safety and
     health

  -- "Secure public confidence through excellence in the development
     and delivery of OSHA's programs and services."

The first goal reflects purposes declared in the 1970 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. 


   CROSSCUTTING ISSUES
-------------------------------------------------------- Appendix II:3

OSHA's strategic plan identifies, as a key component, the inclusion
and consideration of its partner, stakeholder, and customer needs and
requirements.  Although OSHA has met with some key stakeholders while
developing its draft plan (including Office of Management and Budget
(OMB) and congressional staff), the plan does not indicate the input
OSHA has received from these groups.  For example, while OSHA has met
with representatives from among the 25 state-operated health and
safety programs, the plan does not indicate the input OSHA solicited
and received on its strategic goals or on any other part of the plan. 
The strategic plan states that the 25 state-operated OSHA programs
are "integral partners in OSHA's mission of assuring the safety and
health of the Nation's workers." OSHA's plan also states that the
objectives, strategic measures, and strategic tools chosen to guide
OSHA's achievement of the three strategic goals may not reflect the
focus and emphasis for each state program.  However, the plan reports
that the goals are reflective of broad generic aspirations for the
nationwide occupational safety and health effort, and as such
establish the parameters against which the status of the 25 states
will be measured.  Greater consultation with the state-operated
health and safety programs during the development of the strategic
plan, rather than in a later, "subsidiary process" might lead to
superior strategic goals for OSHA and possibly more inclusive
national standards that would facilitate program effectiveness in
both the federal- and state-operated OSHA programs. 

The plan also acknowledges the importance of coordinating with
agencies that may have related missions and authorities.  The plan
notes that OSHA has in place a number of memorandums of understanding
with federal agencies that administer other laws that affect work
place conditions.  For example, the Department of Transportation has
legal authority for rail, air, and water safety and regulates many
conditions that affect workers in those industries.  The plan also
states that as the administration of these laws changes, OSHA will
continue to modify its memorandums of understanding to minimize
administrative overlap. 


   MAJOR MANAGEMENT CHALLENGES
-------------------------------------------------------- Appendix II:4

As we have identified in past reports,\8 and as OSHA has
acknowledged, a major management issue it faces in conducting its
mission is the development of data and information management systems
that can facilitate the measurement and tracking of OSHA's
performance.  The strategic plan acknowledges the central importance
of this issue, including as one of its strategic measures the full
implementation of the information systems necessary to collect OSHA
data and the capacity to analyze its performance measures. 

OSHA continues to face a major challenge in developing the data
sources and measures necessary to track progress toward its
performance goals.  As the plan points out, OSHA depends on data from
a number of other agencies that must accommodate information needs
beyond those of OSHA.  Many external factors may also impede OSHA
from collecting the necessary data, and from developing meaningful
measures themselves, including external constraints on its
information collection efforts, such as legislative and budgetary
developments.  In many of these cases, the careful use of evaluation
can assist OSHA's efforts, but it may not be sufficient for it to
make progress toward its goals. 


--------------------
\8 See Occupational Safety and Health:  Changes Needed in the
Combined Federal-State Approach, (GAO/HEHS-94-10, Feb.  28, 1994) and
Occupational Safety and Health:  Assuring Accuracy in Employer Injury
and Illness Records (GAO/HRD-89-23, Dec.  30, 1989). 


ESA'S STATUTORY RESPONSIBILITIES
========================================================= Appendix III

Four offices within the Employment Standards Administration (ESA)
carry out the following laws:  the Fair Labor Standards Act (29
U.S.C.  201) and the Contract Work Hours and Safety Standards Act (29
U.S.C.  327), 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; 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; and the
Labor-Management Reporting and Disclosure Act (29 U.S.C.  400) and
related laws, which are carried out by the Office of Labor Management
Standards (OLMS).  In addition, the Office of Federal Contract
Compliance Programs (OFCCP) enforces statutory and nonstatutory
nondiscrimination and affirmative action requirements for federal
contractors. 

WHD's goals are not based on specific statutory requirements, but are
desirable performance goals.  These goals are to (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."

The goals of the Office of Workers' Compensation Programs are to (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 2, 3, 4, 7, 8, and 13 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 5, 9, 10, and 14 deal with the Black Lung Program, and
are not based on a specific statutory requirement.  Goals 6, 7, 11,
and 12 all relate to the Longshore and Harbor Workers' Compensation
Program.  (As noted, goal seven also relates to FECA.) Although none
of the goals is required by law, each is consistent with the
Longshore Act. 

OLMS' goals are to (1) "[p]rotect union financial integrity by
enforcing safeguards established under LMRDA [Labor-Management
Reporting and Disclosure Act] and related laws"; (2) "[r]esolve
member complaints concerning union officer elections, union
trusteeships, and other matters pertaining to safeguards for union
democracy under the LMRDA and related laws and supervise remedial
union officer elections as required by law"; (3) "[e]nsure that
reports required of unions and others are available for public
disclosure in accordance with the requirements of the LMRDA and
related laws"; and (4) "[e]nsure protections for transit employees
and the timely release of Federal transit grant funds by
expeditiously certifying statutory employee protection arrangements."

All four of OLMS' goals reflect statutory requirements.  The first
three reflect Labor's responsibility to carry out LMRDA.  More
specifically, the first goal reflects Labor's statutory
responsibility to issue necessary rules and regulations to "prevent
the circumvention or evasion" by labor organizations of LMRDA's
reporting requirements, which include the submission of annual
financial condition reports.  Fines may be assessed against those who
violate the reporting requirements.  (29 U.S.C.  431(b), 438, 439.)
See 29 U.S.C.  464, 482, for the statutory requirement relating to
the second goal and 29 U.S.C.  435 for the statutory requirement
relating to the third goal.  The fourth goal, which involves
coordination between the Secretaries of Labor and Transportation,
reflects a statutory requirement that appears in a transportation
statute.  (49 U.S.C.  5323(a)(1)(D), 5333.)

OFCCP's goals are to (1) ensure compliance by federal contractors
with equal employment opportunity and affirmative action
requirements; (2) secure voluntary compliance by federal contractors
with equal employment opportunity requirements; and (3) produce
high-quality compliance reviews, complaint investigations, and
compliance assistance.  The first two goals reflect both statutory
and nonstatutory requirements that apply to federal contractors.  The
statutory requirements come from statutes that explicitly impose
requirements on federal contractors and Labor--for example, section
503 of the Rehabilitation Act of 1973 (29 U.S.C.  793), which
explicitly requires federal contractors to take affirmative action to
employ and advance in employment qualified handicapped individuals
and directs Labor to take necessary enforcement action.  The
nonstatutory requirements come from Executive Order 11246, as
amended, which explicitly imposes upon federal contractors
nondiscrimination and affirmative action requirements based on race,
color, religion, sex, or national origin and directs Labor to enforce
the requirements.  The third goal is not based on a specific
statutory requirement, but is a general management goal. 

*** End of document. ***