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Testimony: 

Before the Subcommittee on Coast Guard and Maritime Transportation, 
Committee on Transportation and Infrastructure, House of 
Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Tuesday, April 27, 2010: 

Coast Guard: 

Civil Rights Directorate's Action Plans to Improve Its Operations 
Could Be Strengthened by Implementing Several Aspects of Project 
Planning and Implementation Practices: 

Statement of Laurie Ekstrand, Director: 
Strategic Issues: 

GAO-10-571T: 

GAO Highlights: 

Highlights of GAO-10-571T, a testimony before the Subcommittee on 
Coast Guard and Maritime Transportation, Committee on Transportation 
and Infrastructure, House of Representatives. 

Why GAO Did This Study: 

Allegations of management weaknesses, unsecured personal information, 
and employee dissatisfaction have been made against U.S. Coast Guard’s 
Civil Rights Directorate (CRD). To address these allegations, the 
Director of CRD commissioned an external review of civil rights 
operations. In February 2009, the review made 53 recommendations to 
improve the civil rights operations. CRD developed action plans to 
address these recommendations. As requested, GAO reviewed (1) how 
Coast Guard’s action plans align with EEOC’s elements of a model equal 
employment opportunity program (2) how Coast Guard developed and 
reviewed its action plans, and (3) the extent to which Coast Guard’s 
action plans align with generally accepted project management 
practices. To conduct this work GAO reviewed documentation from CRD, 
EEOC, internal control standards, and literature on project 
management. We also interviewed CRD officials. 

What GAO Found: 

Of the Equal Employment Opportunity Commission’s (EEOC) six equal 
employment opportunity program model elements, CRD’s action plans 
focus mainly on the first—agency leadership. Of the 29 action plans 
developed and implemented by CRD to address the 53 recommendations in 
the recent external review, almost half center on the leadership 
element. For example, one action plan involved scheduling training for 
headquarters and field staff. 

CRD took several steps to develop and review action plans to address 
recommendations from the external review, such as developing a 
functional review team, assigning project officers, meeting with the 
Commandant and agency leadership, and consulting the agency financial 
officer. However, CRD did not consistently document key decisions 
related to the development and review of the action plans as 
recommended in federal internal control standards. As a result, CRD 
lacks transparency and accountability to stakeholders. Lack of 
documentation also impedes the ability to track progress, make mid-
course corrections, and illustrate to stakeholders that it is 
effectively solving these issues. According to CRD officials, their 
priority was to complete the action plans in a timely manner rather 
than ensure that development and review processes were documented. 

GAO reviewed four of CRD’s action plans in relation to generally 
accepted project management practices to determine the extent to which 
recommended practices were followed. The recommended practices are: 
(1) identifying measurable performance goals, (2) defining specific 
tasks, (3)identifying the person(s) accountable, (4) identifying 
interim milestones and checkpoints, (5) identifying the needed 
resources, (6)consulting stakeholders, and (7) defining how to 
evaluate success. The selected action plans showed some elements of 
the project management practices, such as identifying accountable 
individuals, but fell short in relation to other elements. 
Specifically, performance goals were identified in the form of a 
product, such as development of a manual, rather than in relation to a 
desired outcome, such as demonstrating an increase in the number of 
staff who know how to properly safeguard personal information. All 
four action plans we reviewed lacked plans for evaluating their 
success. CDR officials stated that they were more focused on 
completing the plans rather than evaluating them, but early evaluation 
can identify and guide mid-course corrections to ensure positive 
change. 

What GAO Recommends: 

GAO recommends that the Department of Homeland Security direct the 
Commandant of the Coast Guard to take the following actions: (1) going 
forward, ensure internal controls are in place to maintain the 
documentation necessary to facilitate oversight, (2) establish 
measurable performance goals for the action plans, and (3) define an 
evaluation plan for each action plan. DHS concurred with all GAO 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-10-571T] or key 
components. For more information, contact Laurie Ekstrand at (202) 512-
6806 or ekstrandl@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the approach the Civil Rights 
Directorate (CRD) of the U.S. Coast Guard has taken to improve the 
operations of its civil rights program. According to CRD, their 
mission is to foster and maintain a model workplace which supports 
mission execution. To accomplish this mission, CRD manages the Coast 
Guard Equal Employment Opportunity (EEO) program for civilian 
employees and the Equal Opportunity (EO) program for its military 
members. In advancement of these programs, CRD provides services such 
as an intake, mediation, and review process for military and civilian 
complaints for all Coast Guard personnel. 

Under a prior Director, two separate external reviews of the civil 
rights operations made recommendations for improvement related to the 
CRD's organizational structure, complaint processes, and program 
effectiveness. More recently, allegations of management weaknesses, 
unsecured personal information, and employee dissatisfaction have been 
made against CRD. The current CRD Director commissioned a third 
external review and evaluation in September 2008 to improve the 
operations of the civil rights program. In February 2009, Booz Allen 
Hamilton (BAH) completed this review and made 53 recommendations, 
which were similar to those of the previous reports.[Footnote 1] The 
Director of CRD subsequently developed action plans to address these 
recommendations. 

As requested, my testimony today will describe (1) how Coast Guard's 
action plans align with the elements of a model equal employment 
opportunity program, (2) how Coast Guard developed and reviewed its 
action plans, and (3) the extent to which Coast Guard's action plans 
align with generally accepted project management practices. 

To address all of the objectives, we reviewed the 2009 BAH report and 
recommendations and selected CRD action plans and supporting 
documentation to address the recommendations. In addition, to identify 
how Coast Guard's action plans focus on the elements of a model EEO 
program, we reviewed the Equal Employment Opportunity Commission's 
(EEOC) Management Directive-715 (MD-715), which established the 
elements.[Footnote 2] In the absence of an EO framework of model 
elements, and given that CRD stated they apply the EEO model elements 
to all Coast Guard personnel, including military, we have used the EEO 
model elements framework to organize the actions plans. 

To describe how the Coast Guard developed and established a project 
management process for its action plans, we obtained documentation 
from CRD officials on their organizational structure and review 
processes and interviewed CRD officials to supplement the 
documentation. To determine the extent to which Coast Guard's action 
plans are aligned with generally accepted project management 
practices, we reviewed prior GAO reports[Footnote 3] and the 
Government Performance and Results Act (GPRA) of 1993,[Footnote 4] and 
also conducted an external literature review to identify elements of 
successful project planning and implementation. Subsequently, we 
identified and adapted seven practices that are associated with 
generally accepted project management practices.[Footnote 5] We 
analyzed the extent to which selected action plans contained seven 
practices associated with generally accepted project management 
practices. We also reviewed our prior work on the Coast Guard's 
modernization program[Footnote 6] for context regarding the Civil 
Rights Directorate's restructuring action plan. We conducted semi-
structured interviews with Coast Guard officials responsible for the 
design, implementation, and approval of action plans to address the 
recommendations. 

As part of our assessment, we selected and reviewed four action plans 
that are related to key issues identified in the external review. For 
example, the first three action plans relate to improving the 
consistency of EO/EEO service delivery throughout Coast Guard--a major 
issue identified in the third party review.[Footnote 7] The selected 
plans encompass actions on 13 of the 53 recommendations and address 
major concerns with CRD's operations. We selected the following action 
plans: 

* Completing a New Personally Identifiable Information (PII) Handbook; 

* Restructuring Civil Rights Operations; 

* Revising the EO Manual; and: 

* Training to Address Office Climate. 

We conducted this performance audit from November 2009 through April 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

In brief, nearly half of the action plans align with strengthening the 
demonstrated commitment from leadership. Leadership commitment is an 
essential element of a model EEO program. While action plans and 
leadership commitment are critical, only effective implementation of 
solutions will resolve the CRD's long-standing issues. According to 
CRD officials, their priority was to address the recommendations and 
complete the planning and implementation of action plans in a timely 
manner. Although CRD established a planning and process management 
control group and focused on implementing and completing the action 
plans quickly, in many cases the CRD action plans lack documentation 
important to internal controls, and these plans could be improved by 
defining measurable outcome goals and plans for evaluation of action 
plan results. Without internal controls, such as timely and reliable 
documentation, CRD weakens transparency to stakeholders and loses a 
historical record of its implementation approach. Based on our review 
of the selected action plans, we recommend that, going forward, CRD: 
(1) ensure internal controls are in place to maintain the 
documentation necessary to facilitate oversight and course corrections 
as plans are designed and implemented, (2) establish measurable 
performance goals for the action plans to support the management 
decision as to the completion status of the action plans, and (3) 
define an evaluation plan for each action plan to assess the degree to 
which the plan yielded the intended outcomes. 

Background: 

The Coast Guard is one of the five armed forces of the United States 
and the only military organization within the Department of Homeland 
Security. Coast Guard is charged with carrying out 11 statutory 
missions with approximately 50,000 personnel: 42,000 active duty 
military and 8,000 civilians.[Footnote 8] 

CRD's mission is to foster and maintain a model EO/EEO workplace that 
supports mission execution. CRD's principal functions are to 
facilitate the Coast Guard's (1) EEO program for its civilian 
employees and (2) EO program for its military members. Under the EEO 
program, CRD is responsible for ensuring Coast Guard compliance with 
the federal statutes prohibiting employment discrimination as well as 
EEOC's regulations and directives, including MD-715, which explains 
the basic elements necessary to create and maintain a model EEO 
program. Under the EO program, while military members are not covered 
by the antidiscrimination statutes and EEOC regulations and 
directives, Coast Guard policy provides that military equal 
opportunity policies are generally based upon principles set forth in 
civilian EEO policy, including affording military members with 
discrimination complaint procedures that mirror the EEO process to the 
extent possible. 

CRD is led by a Director who reports to the Commandant of the Coast 
Guard and is responsible for all EEO/EO activities within the Coast 
Guard. The Chief of the Office of Policy, Planning, and Resources 
reports directly to the Director of the CRD and serves as the acting 
Director in the Director's absence. The Office of Policy, Planning, 
and Resources also acquires, allocates, and oversees resources for CRD 
in compliance with the Chief Financial Office's policies. The Chief of 
the Office of Civil Rights Operations reports to the Director of CRD 
and oversees and manages all full-time 45 Coast Guard civil rights 
service providers through three Civil Rights Regional offices. 

Figure 1: Organizational Chart of the Civil Rights Directorate: 

[Refer to PDF for image: Organizational Chart] 

Top level: 
Director, Civil Rights Directorate: 
* Executive Assistant. 

Second level, reporting to Director, Civil Rights Directorate: 
* Chief, Office of Policy, Planning, and Resources; 
* Chief, Office of Civil Rights Operations: 
- Solutions and Complaints Staff. 

Third level, reporting to Chief, Office of Policy, Planning, and 
Resources: 
* Policy and Procedures Division; 
* Planning and Resource Management Division. 

Third level, reporting to Chief, Office of Civil Rights Operations: 
* Civil Rights, Region 1, Washington, D.C.
* Civil Rights, Region 2, Portsmouth, Va. 
* Civil Rights, Region 3, Alameda, Calif. 

Source: GAO presentation of Coast Guard information as of September 
30, 2009. 

[End of figure] 

As stated previously, EEOC's MD-715 provides guidance to federal 
agencies to identify the basic elements necessary to create and 
maintain a model EEO program. EEOC instructions state that an agency 
should review its EEO and personnel programs, policies, and 
performance standards against six elements to identify where their EEO 
program can become more effective. The six essential elements EEOC 
describes for a model EEO program are: 

* Demonstrated commitment from agency leadership, 

* Integration of EEO into the agency's strategic mission, 

* Management and program accountability, 

* Proactive prevention of unlawful discrimination, 

* Efficiency, and: 

* Responsiveness and legal compliance.[Footnote 9] 

Agency Leadership Is the Primary EEOC Model Program Element Addressed 
by Coast Guard Action Plans: 

Over one-third of the 2009 recommendations dealt with agency 
leadership issues, as did the recommendations of the prior reviews. 
CRD developed 29 action plans to address the recent 53 
recommendations, with 13 focusing on leadership. Table 1 shows a 
summary of the distribution of these action plans across EEOC's six 
model elements.[Footnote 10] 

Table 1: Distribution of CRD Action Plans across EEOC's Model Elements: 

EEOC's model elements: Demonstrated Commitment from Agency Leadership; 
Number of action plans aligned with model element[A]: 13. 

EEOC's model elements: Integration of EEO into Agency's Strategic 
Mission; 
Number of action plans aligned with model element[A]: 5. 

EEOC's model elements: Management and Program Accountability; 
Number of action plans aligned with model element[A]: 2. 

EEOC's model elements: Proactive Prevention of Unlawful Discrimination; 
Number of action plans aligned with model element[A]: 0. 

EEOC's model elements: Efficiency; 
Number of action plans aligned with model element[A]: 4. 

EEOC's model elements: Responsiveness and Legal Compliance; 
Number of action plans aligned with model element[A]: 1. 

Source: GAO analysis based on EEOC's model elements and action plan 
alignment. 

[A] Four of the 29 action plans did not align with any of EEOC's model 
elements. 

[End of table] 

The priority given by CRD to address agency leadership is based on the 
most recent recommendations they received and is also consistent with 
the focus of earlier third-party recommendations provided to the Coast 
Guard on EO/EEO issues.[Footnote 11] According to EEOC, the leadership 
element of a model program includes allocating sufficient resources to 
the EEO program, such as personnel with training and experience, staff 
with relevant knowledge and skills, adequate data collection and 
analysis systems, and training programs for all employees. Issuing an 
effective EEO program policy statement and ensuring that all employees 
are informed of EEO programs are also part of the demonstrated 
commitment element. Examples of the action plans that focus on 
demonstrated commitment from agency leadership include: 

* Develop a comprehensive training program for Civil Rights Service 
Providers; 

* Schedule Office of Civil Rights headquarters and field-level senior 
staff for the Center for Creative Leadership North America Leadership 
workshops; and: 

* Task regional managers with identifying skills and managing the 
training needs of their staffs. 

Although CRD Established Processes to Develop and Review Selected 
Action Plans, Documentation of Key Decisions and Outcomes Needs 
Improvement: 

CRD took several steps to develop and review action plans to address 
recommendations from the most recent external review, such as 
developing a functional review team, assigning project officers, 
meeting with the Commandant and agency leadership, and consulting the 
agency financial officer. CRD officials stated that they organized 
with a sense of urgency to address the recommendations and complete 
their planning and implementation of action plans. The key players in 
the planning and implementation of action plans were: 

* Functional Review Team: According to CRD staff, a team of senior CRD 
staff, called the "Tiger Team," was created to serve as the functional 
review team. This team aimed to effectively and efficiently address 
the recommendations with limited resources. Members of the Tiger Team 
included the Director of CRD, the executive assistant, the Chief of 
the Office of Policy and Planning, and Chief of the Office of Civil 
Rights Operations. The Tiger Team guided the development of the action 
plans and also reviewed and approved the implementation of the action 
plans. The Tiger Team formulated strategies to implement action plans, 
assigned project officers, set deadlines for project officers to 
complete action plans, and reviewed documentation submitted by project 
officers to support their position that an action plan was complete. 

* Project Officers: Project officers, appointed by the Tiger Team, 
were responsible for providing weekly updates to the Tiger Team and 
for overseeing the execution of the action plans. CRD told us that the 
project officers were chosen based on their job responsibilities and 
knowledge of the subject matter. The project officers reported to the 
Tiger Team through an appointed lead project officer. 

* Commandant: CRD staff told us that the Director and executive 
assistant met regularly with the Commandant to provide updates and 
receive feedback on the action plans. According to CRD staff, during 
these meetings the Commandant provided guidance on the action plans 
and helped formulate the decision on time frames to complete the 
action plans. 

* Agency Leadership: Coast Guard leadership, including the Commandant, 
was involved mainly with the action plan to restructure civil rights 
operations. The Commandant charged the Leadership Council, an advisory 
body of the Coast Guard's senior leadership,[Footnote 12] with 
evaluating CRD's organizational structure, human resource practices, 
and needs related to their EEO program, diversity, and climate, among 
other related responsibilities. CRD briefed the Leadership Council 
twice and the council provided guidance and feedback to CRD on aspects 
of the restructuring action plan. 

* Coast Guard's Restructuring Team: The Commandant's Intent Action 
Order Reorganization Review Team is an intra-agency body that reviews 
organizational restructuring proposals for compliance with rules of 
engagement and conformity to overall Coast Guard organizational rules 
and policies. The review team's approval was necessary for CRD to 
restructure its operations; CRD completed a checklist that was 
required to gain the review team's approval. 

* Coast Guard Directorates: CRD staff also met with senior officials 
in other directorates for feedback on action plans that related to 
their respective offices. For example, the Director and executive 
assistant met with Planning, Resources, and Procurement Directorate 
staff to review all the action plans for financial implications and to 
receive status updates from CRD on the execution of the action plans. 
The Planning, Resources, and Procurement Directorate staff advised the 
Commandant on the budget implications of the proposed action plans and 
recommended budget-related decisions. Although the Chief Financial 
Officer did not have approval responsibilities, he received periodic 
status updates from CRD on the execution of the action plans. CRD 
officials also stated that the Engineering and Logistics Directorate 
and the Command, Control, Communications, Computers and Information 
Technology Directorate reviewed the restructuring action plan. 

CRD Did Not Consistently Document Key Decisions Related to the 
Development and Review of the Action Plans: 

When developing and reviewing the action plans, CRD did not maintain 
documentation as recommended in federal internal control standards. 
[Footnote 13] As a result, CRD lacks transparency and accountability 
to stakeholders. Lack of documentation also impedes the ability to 
track progress, make midcourse corrections, and illustrate to 
stakeholders that it is effectively solving these issues. According to 
the internal control standards, accurate and timely documentation of 
actions and events is necessary for the management of an organization 
and for making effective decisions. 

CRD was not able to provide documentation for recording minutes and 
decisions made at internal meetings, meetings with the Commandant, 
briefings to the Leadership Council, or meetings related to the action 
plans. They primarily tracked the action plans and the status of their 
completion through the functional review recommendation sheet. In 
addition, they used memos and e-mails to document some decisions and 
as a way to delegate responsibility. 

* The Functional Review Recommendation (FRR) Spreadsheet: The FRR 
spreadsheet was the primary tool that CRD used to update the 
Commandant and CRD leadership on action plan development and 
implementation. The Tiger Team designed the FRR spreadsheet using the 
Commandant's guidance on important elements to track. For each 
recommendation, this spreadsheet included the responsible project 
officer, actions taken, the priority of the action plan, deadlines, 
days until deadlines, and completion status. After receiving status 
notes from the project officers through the CRD executive assistant, 
the lead project officer would update the FRR sheet by deleting 
previous entries in the "Action Taken" columns. As a result, CRD only 
has documentation of the most recent actions taken and in the future 
will not be able to assess the effectiveness of their approach to the 
action plans.[Footnote 14] Decisions or directions from the Commandant 
as a result of these status reviews were not recorded. 

* Memos: CRD used memos to document some decisions, such as the 
rationale behind restructuring the directorate, the assignment of a 
modernization officer to oversee the logistics of CRD's modernization, 
the Commandant's approval of resources for training, staffing, and 
other program support, and the assignment of a PII privacy officer to 
ensure that safeguards are in place for proper handling of complaint 
records. 

* E-mails: CRD used e-mails to document when meetings were held and 
who was invited to meetings. CRD provided e-mails as the sole 
documentation of certain actions related to the planning and 
implementation of the action plans, such as the designation of tasks 
to staff, outreach to stakeholders, and submission of action plan 
status updates. 

CRD officials stated that their priority was to complete the action 
plans in a timely manner rather than assure that development and 
review processes were documented. However, without timely and reliable 
documentation of decisions and actions, CRD cannot communicate or 
provide a historical track of its approach to the action plans. 
Ultimately, this lack of documentation may weaken CRD's transparency. 
When an organization is undergoing change, as is the case with CRD and 
Coast Guard, transparency becomes even more important as it can 
increase the staff's confidence in the changes. 

According to CRD officials, the CRD executive assistant--an integral 
part of the action plan implementation process--serves at CRD on a 
rotating basis and will leave the position in June of 2010. Without 
documentation of the decisions made in the design, implementation, and 
review of the action plans, the knowledge the official has may leave 
with him. 

Documentation of decisions may also allow CRD to demonstrate to Coast 
Guard leadership and other stakeholders its progress in addressing 
long-standing issues identified in the two previous external reviews 
of CRD. Both the reviews of CRD highlighted issues related to the 
office's organizational structure, complaint process, and 
effectiveness, among other issues. Clear documentation is necessary so 
that the directorate can track progress, make midcourse corrections, 
and illustrate to stakeholders that it is effectively solving long-
standing issues. 

The following are examples of the types of records that CRD could have 
maintained: 

* Documentation of the action plan development process and its 
products, such as minutes from the internal CRD meetings. Minutes from 
these meetings could have included concerns that were raised, 
decisions that were made, follow-up issues, and individuals in 
attendance. Decisions from the Commandant, Leadership Council, and 
other directorates should also have been documented. 

* Documentation of the review process, such as the individuals tasked 
with reviewing the action plans, dates when completed action plans 
were approved or denied, and criteria for approving the completion of 
the action plans. 

* Historical record of the weekly status updates of the action plans 
on the FRR spreadsheet, without which CRD officials may not be able to 
determine if they are on track to meet their goals or course-correct 
if necessary. They also cannot use this historical record to fine-tune 
action planning in the future. 

Selected Action Plans Implemented Some Project Planning Practices, but 
Did Not Fully Implement Other Practices: 

According to the Project Management Institute, a project plan is used 
to guide the execution and the internal controls for a project. The 
plan documents planning assumptions, project decisions, approved 
scope, cost, and schedules.[Footnote 15] Among other benefits, this 
facilitates communication among stakeholders. The following seven 
practices are adapted from generally accepted project management 
practices: 

1. Identifying measurable performance goals; 

2. Defining specific tasks to complete the action plan; 

3. Identifying the person(s) accountable for completing the tasks to 
complete the action plan; 

4. Identifying interim milestones/checkpoints to gauge the completion 
of the action plan; 

5. Identifying the needed resources to complete the action plan; 

6. Consulting stakeholders; and: 

7. Defining how to evaluate the success of completing the action plan. 
[Footnote 16] 

We reviewed the following four action plans that are related to key 
issues identified in the external review. These action plans encompass 
13 of the 53 recommendations that were made to CRD. 

* Complete a New PII Handbook. This action plan was intended to create 
a PII handbook. To do so, CRD needed to complete a number of complex 
tasks including developing Standard Operating Procedures for personal 
and confidential information, developing a records management system 
for EEO/EO-related records, instituting a privacy and records 
management program, and assigning a privacy officer in Coast Guard 
headquarters. 

* Train Senior Staff to Address Office Climate. This action plan was 
intended to improve the interpersonal dynamics of CRD's senior staff. 
Elements of the action plan included using workshops to help senior 
staff understand their own and others' underlying interests and 
concerns, guiding the Director, Deputy Director, and senior staff to 
pursue more collaborative methods of working with each other, and 
strengthening leadership effectiveness in group dynamics. 

* Restructure Civil Rights Operations. This action plan was intended 
to centralize the management of the EEO/EO services. Formerly, the 
civil rights service providers who receive EEO/EO complaints were 
geographically dispersed and reported to their command leader within 
the geography in which they were located. In the centralized 
structure, full-time civil rights service providers report to three 
civil rights regional managers, each responsible for a multistate 
region. As the regional managers report to CRD rather than Field 
Commanders, they are in the direct line of command of CRD headquarters. 

* Revise the EO Manual. This action plan was intended to address the 
recommendation to revise the manual and add content that addresses the 
roles of field and headquarters personnel throughout the complaint 
process and the appropriate statutory references and citations. CRD 
contracted this undertaking to a third party to complete while 
providing the oversight intended to achieve a standardized 
administration of complaints throughout the commands. 

Action Plans Only Partially Identified Measurable Performance Goals 
and Did Not Define How to Evaluate the Success of Completing a Plan: 

We analyzed the four selected action plans to determine the extent to 
which generally accepted project management practices have been 
integrated in their development and implementation process. Table 2 
shows the results of our assessment of the extent to which each action 
plan implemented the practices. For purposes of our analysis, fully 
means all of the conditions of the project management practices were 
met, partially means the criteria did not meet all of the conditions 
of the project management practice, and did not implement means CRD 
did not provide evidence to meet any of the conditions of the project 
management practice or the evidence provided was inadequate. 

Table 2: GAO Assessment of CRD's Action Plan Alignment with Generally 
Accepted Project Management Practices: 

Action taken to address recommendation: Create PII Handbook; 
Identified measurable performance goals: Partially; 
Defined specific tasks to complete the action plan: Fully; 
Identified the person(s) accountable for executing the tasks to 
complete the action plan: Fully; 
Identified interim milestones/checkpoints to gauge the completion of 
the action plan: Partially; 
Identified the needed resources to complete the action plan: Did not 
implement; 
Consulted stakeholders: Fully; 
Defined how to evaluate the success of completing the action plan: Did 
not implement. 

Action taken to address recommendation: Training to Address Office 
Climate; 
Identified measurable performance goals: Partially; 
Defined specific tasks to complete the action plan: Did not implement; 
Identified the person(s) accountable for executing the tasks to 
complete the action plan: Fully; 
Identified interim milestones/checkpoints to gauge the completion of 
the action plan: Partially; 
Identified the needed resources to complete the action plan: Partially; 
Consulted stakeholders: Did not implement; 
Defined how to evaluate the success of completing the action plan: Did 
not implement. 

Action taken to address recommendation: Restructuring Civil Rights 
Operations; 
Identified measurable performance goals: Partially; 
Defined specific tasks to complete the action plan: Fully; 
Identified the person(s) accountable for executing the tasks to 
complete the action plan: Fully; 
Identified interim milestones/checkpoints to gauge the completion of 
the action plan: Partially; 
Identified the needed resources to complete the action plan: Fully; 
Consulted stakeholders: Fully; 
Defined how to evaluate the success of completing the action plan: Did 
not implement. 

Action taken to address recommendation: Revising the EO Manual; 
Identified measurable performance goals: Partially; 
Defined specific tasks to complete the action plan: Fully; 
Identified the person(s) accountable for executing the tasks to 
complete the action plan: Fully; 
Identified interim milestones/checkpoints to gauge the completion of 
the action plan: Fully; 
Identified the needed resources to complete the action plan: Fully; 
Consulted stakeholders: Partially; 
Defined how to evaluate the success of completing the action plan: Did 
not implement. 

Source: GAO analysis of CRD action plans. 

[End of table] 

Identifying Measurable Performance Goals. All the selected action 
plans describe an output goal, such as revising the EO manual or 
attending training, but do not identify measurable objectives or 
identify the intended results of completing the action plans. In order 
to fully meet the criteria, CRD needed to define an outcome goal for 
each of the selected action plans that had measurable objectives 
against which actual achievements can be compared. For example, 
conducting training to address office climate is an output goal, but 
also establishing an outcome goal, such as improving the results of 
CRD's organizational assessment survey--a measure of personnel 
attitudes across Coast Guard--would more fully measure the success of 
the action plan in achieving its intent. 

Defined Specific Tasks to Complete the Action Plan. Three of the four 
action plans defined specific tasks to complete the action plan; 
however, the action plan related to attending training to address 
CRD's office climate did not. CRD's senior officials attended six 45-
minute training sessions over the course of two months. CRD officials 
stated that since this action plan was undertaken, a training manager 
has been appointed to plan longer-term training for CRD. 

Identified the Person(s) Accountable for Completing the Action Plan. 
All four selected action plans fully implemented the project planning 
practice of identifying a person or persons accountable for completing 
the action plan. CRD designated a project officer, or person 
accountable for the completion of the action plan, at the beginning of 
the action plan implementation process. Each project officer was 
responsible for updating the lead project officer on the week's 
progress, as part of the process CRD had established. 

Identified Interim Milestones and Checkpoints to Gauge the Completion 
of the Action Plan. The contract to revise the EO manual was the only 
action plan that fully implemented checkpoints and milestones to gauge 
the completion of the manual. The remaining three action plans, 
creating the PII handbook, restructuring civil rights operations, and 
training to address office climate, used their weekly status reporting 
system to judge process. Establishing milestones for the action plans 
before or during the planning process would have allowed CRD not only 
to judge weekly progress, but also to benchmark where weekly progress 
stood against where they intended. Further, CRD did not keep a record 
of the weekly status reports or checkpoints; instead, they replaced 
the prior week's status with the newest status, thus reducing their 
ability to track the action plans' long-term progress. 

Identified the Needed Resources to Complete the Action Plan. The 
action plan to create a PII handbook was the only plan that did not 
identify the needed resources to complete the specific action plan. 
Although CRD officials stated that all of the action plans were 
reviewed by Coast Guard directorates responsible for Budget, 
Information Technology, and Infrastructure to determine needed 
resources, CRD was unable to provide documentation of any of the 
directorate reviews. Training to address office climate partially 
implemented this practice. CRD provided documentation of the financial 
cost of training; however, the documentation did not discuss any other 
training resources, such as staff time and equipment or training 
materials. The other two selected action plans, restructuring civil 
rights operations and revising the EO manual, fully implemented the 
practice of identifying all of the needed resources to complete action 
plans. CRD used approved funding and staffing requests to document the 
identification of resources needed for both of these action plans. 

Consulted Stakeholders. For two of the selected action plans, creating 
the PII handbook and restructuring civil rights operations, CRD 
provided documentation demonstrating that they consulted the 
stakeholders they deemed relevant--civil rights service providers and 
unions respectively.[Footnote 17] One of the action plans, related to 
training to address office climate, did not have any documentation of 
stakeholder consultation. According to CRD officials, the action plan 
to revise the EO manual will consult all directorates once it is 
complete. We assessed this action plan as partially implemented 
because the end users of the manual were not consulted while the 
manual was being drafted. 

Evaluated the Success of Completing the Action Plan. None of the 
selected action plans that we reviewed identified how CRD would 
evaluate the success of completing the action plan. CRD officials 
stated that they were primarily focused on completing the action plans 
to address the recommendations to improve the EO/EEO program, and if 
they had more time, they would have planned to evaluate the action 
plans. This planning practice--planning to evaluate success--is linked 
to the earlier planning practice of identifying performance goals. 
Outcome measures as performance goals, as opposed to output measures, 
would provide the basis for evaluating the success of the action plans 
in achieving the intended improvements in CRD. While it is too early 
to evaluate the effectiveness of the action plans, strategizing about 
how they would be evaluated is a key step in identifying any necessary 
midcourse corrections and ensuring that change will go in the right 
direction. 

Conclusions and Observations: 

Nearly half of the CRD action plans address issues focused on agency 
leadership. Coast Guard has received recommendations for addressing 
these issues in previous years but the issues continue to be 
identified by external reviews as needing improvement. Although the 
current CRD action plans are intended to address these longstanding 
issues, effective implementation of the action plans is key to 
achieving measurable outcomes and making progress to resolve long-
standing issues. 

CRD established an internal organization and process to address all 
the recommendations for improvement. When developing and implementing 
action plans, it is important to incorporate a systematic approach to 
documenting decisions, outcomes, and actions. Without reliable 
documentation, CRD cannot demonstrate the clear purpose, planning, 
actions, and outcomes of its efforts. In addition, documentation 
provides an opportunity for transparency and facilitates the transfer 
of knowledge when employees leave the office to serve in other roles, 
which is especially important in military organizations. 

Generally accepted project planning practices include identifying 
measurable objectives and the intended results of completing action 
plans. Although all of the selected action plans identified output 
goals, the plans consistently lacked evidence of planning in relation 
to outcomes. Without measurable performance goals, CRD cannot know if 
an action plan achieves its intended goals. Additionally, the 
application of generally accepted project management practices 
facilitates the evaluation of success and completion of the action 
plan. By not systematically evaluating success, CRD risks using time 
and resources ineffectively. More importantly, it also could be more 
difficult for CRD to know when it has arrived at its overall intended 
goal--achieving a productive and effective EEO/EO program that will 
work to ensure a workplace free from discrimination. 

Recommendations for Executive Action: 

We recommend that the Secretary of the Department of Homeland Security 
direct the Commandant of the Coast Guard to take the following three 
actions: 

* Going forward, ensure internal controls are in place to maintain the 
documentation necessary to facilitate oversight and course corrections 
as plans are designed and implemented. 

* Establish measurable performance goals for the action plans to 
support the management decision as to the completion status of the 
action plans. 

* Define an evaluation plan for each action plan to assess the degree 
to which the plan yielded the intended outcomes. 

Agency Comments: 

We provided a draft of this testimony to the Secretary of the 
Department of Homeland Security for review and comment. In written 
comments, which are reprinted in appendix V, the Director of DHS's 
Departmental GAO/OIG Liaison Office concurred with our 
recommendations. Coast Guard also provided technical comments, which 
we incorporated as appropriate. 

Mr. Chairman, this concludes my prepared statement. I would be pleased 
to respond to any questions that you or other Members of the 
Subcommittee might have. 

Contact and Staff Acknowledgments: 

For further information about this testimony, please contact Laurie E. 
Ekstrand on (202) 512-6806 or by email esktrandl@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this statement. Individuals making 
key contributions to this testimony included William J. Doherty, 
Assistant Director, Amber G. Edwards, analyst-in-charge, Karin 
Fangman, Robert Gebhart, Juliann Gorse, David Maurer, Tamara F. 
Stenzel, and Gregory Wilmoth. 

[End of section] 

Appendix I: Third-Party Recommendations to the Coast Guard's Civil 
Rights Directorate: 

Recommendation number: 1; 
Recommendation: Equal Opportunity Review--Design and implement metrics 
to measure process efficiency and for valuing benefits of Equal 
Opportunity Review process. Develop and implement a mechanism to track 
and report these metrics against performance targets. 

Recommendation number: 2; 
Recommendation: Equal Opportunity Manual Revision--To provide 
specificity regarding the purpose, format, and structure of Equal 
Opportunity reviews. 

Recommendation number: 3; 
Recommendation: Training Requirements--Assess Office of Civil Right's 
current training program and develop a training suite for Civil Rights 
Service Providers, supervisors, and managers that is tailored to the 
specific audience. 

Recommendation number: 4; 
Recommendation: Workload Analysis--Maximize workflow efficiencies and 
workforce planning by basing staffing decisions and training 
requirements on valid and reliable data. This would include developing 
a Work Breakdown Structure (WBS) that delineates the discrete work 
elements of Office of Civil Rights operations. 

Recommendation number: 5; 
Recommendation: Conduct a training needs assessment of the U.S. Coast 
Guard civil rights organization to assess current training programs 
and knowledge gaps. This assessment should also consider regulatory 
requirements, business drivers, and the skills and abilities of Civil 
Rights Service Providers. 

Recommendation number: 6; 
Recommendation: Use facilitated workshops to help Office of Civil 
Rights senior staff members to understand their own and other 
stakeholders' underlying interests and concerns and thereafter to 
focus on those interests rather than on stated positions and demands. 

Recommendation number: 7; 
Recommendation: Through coaching sessions, guide the Director, Deputy 
Director, and senior staff to pursue more collaborative methods of 
working with each other. This could be accomplished through the 
strategic planning process and other Office of Civil Rights 
initiatives such as the Management Directive-715 Report. 

Recommendation number: 8; 
Recommendation: Conduct a skills inventory of current staff to measure 
skills versus organizational need, and to identify skill sets required 
for the job. 

Recommendation number: 9; 
Recommendation: Conduct a skills assessment to identify core 
competencies by assessing existing job descriptions and key skills 
required to support each programmatic function. Refine job vacancy 
announcements to ensure that candidates have the required skills. 

Recommendation number: 10; 
Recommendation: Skills Assessment--Determine whether an adequately 
skilled civil rights workforce is available, trained, and prepared to 
achieve the Office of Civil Rights and U.S. Coast Guard's civil rights 
objectives. 

Recommendation number: 11; 
Recommendation: Develop a Training Course for Equal Opportunity Review 
team members on various data collection methods and the process of 
applying statistical techniques to analyze, describe, and evaluate 
trend data. 

Recommendation number: 12; 
Recommendation: Ensure that all Civil Rights Service Providers receive 
training on intake and complaint processing at both the Informal and 
Formal stages. This would include training designed to ensure that 
Civil Rights Service Providers understand their role of neutrality 
throughout the counseling process. 

Recommendation number: 13; 
Recommendation: Training--Provide Strategic Plans and Resources 
Management Team Lead with additional training in budget development 
and justifications. 

Recommendation number: 14; 
Recommendation: Ensure Office of Civil Rights Budget Personnel undergo 
training in statutory and regulatory obligations of the office. 

Recommendation number: 15; 
Recommendation: Assess and take appropriate action regarding Equal 
Opportunity Review Team participants training needs. 

Recommendation number: 16; 
Recommendation: Restructure U.S. Coast Guard Civil Rights Operations--
This restructuring can be accomplished by placing the Field Civil 
Rights Service Providers under the direct oversight of the Director of 
Office of Civil Rights with Area Equal Opportunity Managers reporting 
to the Director instead of directly to Field Commanders. 

Recommendation number: 17; 
Recommendation: Convert the Instructional Systems Specialist position 
currently residing in the Policy and Plans Division to an Operations 
Manager position reporting to the Deputy. This position would, among 
other duties, be responsible for operations management and training 
requirements oversight. 

Recommendation number: 18; 
Recommendation: Transition training oversight responsibilities from 
the Policy and Plans Division to a newly created Operations Manager 
(reporting to the Deputy) who will manage all aspects of OCR training 
processes. 

Recommendation number: 19; 
Recommendation: Create a Senior Advisor Position--This position will 
provide programmatic guidance to the Director. 

Recommendation number: 20; 
Recommendation: Designate Privacy and Records Manager--Assign to CG-
00H one GS-14 billet. 

Recommendation number: 21; 
Recommendation: Leverage 0-6 Deputy Responsibility--Responsible for 
operational and nonstatutory activities including budgeting, resource 
management, strategic planning, and oversight. Align the Strategic 
Plans and Resource Management Team and the Policy and Plans Division 
under the Deputy. 

Recommendation number: 22; 
Recommendation: Establish a solid-line reporting relationship of field 
Civil Right Service Providers--have all Civil Rights Service Providers 
report to the Director. 

Recommendation number: 23; 
Recommendation: Develop an integrated strategic plan to better enable 
the organization to execute and deliver on its mission. This strategic 
plan should incorporate input from key stakeholders, be well 
communicated to employees, and cascaded across Office of Civil Rights 
and throughout the Field to ensure consistency of focus across all 
areas of the U.S. Coast Guard civil rights organization. 

Recommendation number: 24; 
Recommendation: Move CG-00H-3 Program Analyst billet to CG-00H-2--to 
assist with Equal Opportunity Reviews. 

Recommendation number: 25; 
Recommendation: Move Administrative Specialist from CG-00H-2 to CG-00H-
4--to assist with administrative functions. 

Recommendation number: 26; 
Recommendation: Standard Operating Procedures--Develop Standard 
Operating Procedures for CG-00H-3 to handle all aspects of budget 
requests for Office of Civil Rights. 

Recommendation number: 27; 
Recommendation: Revise the Equal Opportunity Manual to include 
statutory references and citations so that a reader can cross-
reference relevant statutory language with the guidance provided. In 
addition, add content that addresses the roles of Field and Office of 
Civil Rights personnel throughout the complaint process. 

Recommendation number: 28; 
Recommendation: Institute a privacy and records management program--
based on Department of Homeland Security policies and procedures. 

Recommendation number: 29; 
Recommendation: Redesign the Equal Opportunity Review process to 
increase the value and effectiveness of this function. 

Recommendation number: 30; 
Recommendation: Strategic Planning--Ensure that each division develops 
a strategic plan that feeds into the Director's overall strategic plan. 

Recommendation number: 31; 
Recommendation: Develop Standard Operating Procedures for handling 
Personally Identifiable Information and Confidential information. 

Recommendation number: 32; 
Recommendation: Develop a records management system that describes, 
for each type of record, where it should be retained, the various 
classifications of records, the applicable policies, and how the 
complaint records should be maintained. 

Recommendation number: 33; 
Recommendation: Equal Opportunity Manual Revision--Enter detailed 
Instruction for handling Personally Identifiable Information. Also, 
revise the Equal Opportunity Manual such that it provides a step-by-
step process to determine whether the release of documents is 
appropriate. 

Recommendation number: 34; 
Recommendation: Institute a mandatory annual training requirement for 
supervisors and managers through which participants are taught their 
responsibilities with respect to Equal Employment Opportunity and 
affirmative employment. Provide refresher training in a computer-based 
format that can be used in any location. 

Recommendation number: 35; 
Recommendation: Develop a business case for Equal Opportunity Reviews. 
This analysis should consider the specific reasons for an established 
number of Equal Opportunity Reviews, the rationale for particular site 
selections, quantifiable measures of success, available dedicated 
resources, and any other strategic or regulatory drivers that would 
necessitate Equal Opportunity Reviews. 

Recommendation number: 36; 
Recommendation: Equal Opportunity Reviews--redesign position 
requirements for individuals participating in the Equal Opportunity 
Review process to reflect the specific skills and abilities required 
to conduct substantive analysis and high-level technical writing. 

Recommendation number: 37; 
Recommendation: Revise the U.S. Coast Guard service-specific portion 
of the Defense Equal Opportunity Management Institute Equal 
Opportunity Advisors Program to include training by civilian Equal 
Employment Opportunity Commission certified trainers who would provide 
instruction in the areas of Equal Employment Opportunity Counseling 
and complaint processing. This training curriculum would include, 
among other topics, instruction in basic Equal Employment Opportunity 
Counseling and other related activities, such as writing reports of 
counseling, identifying issues, conducting inquiries, and pursuing 
resolution options. 

Recommendation number: 38; 
Recommendation: Training Program--Professionalized Equal Employment 
Opportunity Counseling training program to include mandatory training 
required by Equal Employment Opportunity Commission, including the 
eight-hour Refresher and the 32-hour training requirement for new 
federal Equal Employment Opportunity Counselors. In addition, require 
counselors to fulfill a bi-annual training requirement by taking an 
Interviewing Techniques, Conflict Resolution, or Facilitation course. 

Recommendation number: 39; 
Recommendation: Equal Opportunity Manual--Revise the Equal Opportunity 
Manual such that it effectively serves as the guiding document for 
enterprise-wide civil rights operations. 

Recommendation number: 40; 
Recommendation: Standard Operating Procedures--Develop Comprehensive 
Standard Operating Procedures to standardize Office of Civil Rights 
operations. This would include Standard Operating Procedures for each 
team/division within the Office of Civil Rights and the compilation of 
an accessible master volume. 

Recommendation number: 41; 
Recommendation: Perform gap analysis to determine where the current 
staff meet core competencies and identify where competency gaps exist 
by comparing the core competencies required to support the Office of 
Civil Rights roles with the results of the skills inventory of the 
current staff. 

Recommendation number: 42; 
Recommendation: Determine whether current program functions are 
statutorily required or necessary to support the Office of Civil 
Rights mission and to determine resource needs. 

Recommendation number: 43; 
Recommendation: Hire or contract for final agency decision (FAD) 
analysts. 

Recommendation number: 44; 
Recommendation: Create a Separate spend plan for Training Needs 
Assessment. 

Recommendation number: 45; 
Recommendation: Identify "strategic initiatives"--that would be 
drivers of the Office of Civil Rights strategy as well as that of U.S. 
Coast Guard. These initiatives should then be prioritized for funding 
and implementation in any given fiscal year based on their expected 
impact. 

Recommendation number: 46; 
Recommendation: Use Office of Civil Rights Strategic Plan to advocate 
for resource requirements by demonstrating how performance goals align 
with budget requests. 

Recommendation number: 47; 
Recommendation: Recruit and hire full-time experienced Equal 
Employment Opportunity Counselors and Civil Rights Service Providers 
and discontinue the use of collateral duty staff. 

Recommendation number: 48; 
Recommendation: Assess CG-00H-4 funding needs. 

Recommendation number: 49; 
Recommendation: Use the Official U.S. Coast Guard Blog to refute 
misinformation and protect the credibility of the U.S. Coast Guard 
workforce. 

Recommendation number: 50; 
Recommendation: Establish an Official U.S. Coast Guard Blog to convey 
key message and to minimize confusion and misinformation. 

Recommendation number: 51; 
Recommendation: Disable access to negative unofficial blog sites at 
U.S. Coast Guard work locations. 

Recommendation number: 52; 
Recommendation: Strengthen leadership effectiveness in group dynamics 
and find tools to address effectiveness. 

Recommendation number: 53; 
Recommendation: Ensure that individuals are held accountable for acts 
of insubordination. 

Source: GAO presentation of Booz Allen Hamilton recommendations to CRD. 

[End of table] 

[End of section] 

Appendix II: Summary of the Equal Employment Opportunity Commission 
Model Elements: 

Equal Employment Opportunity Commission model elements: Demonstrated 
commitment from agency leadership; 
Summary: Commitment to equal opportunity should be embraced by agency 
leadership and communicated through the ranks from the top down. Among 
other things, an agency shall provide sufficient staffing and 
resources to operate the Equal Employment Opportunity (EEO) program in 
an effective manner. For example, staff and resources should also be 
sufficient to enable accurate collection and analysis of data and 
other employment factors, including applicant information, to enable 
the efficient identification of barriers. This will necessarily 
require staff beyond the EEO office, particularly information 
management/services. 

Equal Employment Opportunity Commission model elements: Integration of 
EEO into the agency's strategic mission; 
Summary: This model element provides that the agency's EEO program 
should be organized and structured in such a manner as to maintain a 
work place that is free from discrimination in any of its management 
policies, practices or procedures and supports the agency's strategic 
mission. Agency leadership should fully utilize EEO staff as a 
consultant prior to making decisions which effect workplace 
opportunities. The EEO Director should be a regular participant in 
senior staff meetings and regularly consulted on workplace issues and 
not solely delegated to responding to discrimination complaints. 

Equal Employment Opportunity Commission model elements: Management and 
program accountability; 
Summary: This model element provides that agencies should hire, 
develop, and retain supervisors and managers who have effective 
managerial, communication, and interpersonal skills in order to 
supervise most effectively in a workplace with diverse employees and 
avoid disputes arising from ineffective communications. Also, the 
agency should meaningfully evaluate managers and supervisors on 
efforts to ensure equality of opportunity for all employees. 

Equal Employment Opportunity Commission model elements: Proactive 
prevention of unlawful discrimination; 
Summary: This model element provides that as part of its ongoing 
obligation to prevent discrimination on the bases of race, color, 
national origin, religion, sex, age, reprisal and disability, and to 
eliminate barriers that impede free and open competition in the 
workplace, an agency must conduct a self-assessment on at least an 
annual basis to monitor progress, identify areas where barriers may 
operate to exclude certain groups, and develop strategic plans to 
eliminate identified barriers. 

Equal Employment Opportunity Commission model elements: Efficiency; 
Summary: This model element provides that an agency must evaluate its 
EEO complaint resolution process to ensure it is efficient, fair, and 
impartial. It also provides that an agency's complaint process must 
provide for neutral adjudication; consequently, the agency's EEO 
office must be kept separate from the legal defense arm of the agency 
(i.e., the Office of General Counsel) or other agency offices having 
conflicting or competing interests. 

Equal Employment Opportunity Commission model elements: Responsiveness 
and legal compliance; 
Summary: This model element provides that the head of the agency or 
agency head designee shall certify to the Equal Employment Opportunity 
Commission (EEOC) that the agency is in full compliance with the EEO 
laws and EEOC regulations, policy guidance, and other written 
instructions. It also provides that all agencies shall report their 
EEO program efforts and accomplishments to the EEOC and respond to 
EEOC directives and orders, including final orders contained in 
administrative decisions, in accordance with instructions, time 
frames, and deadlines. 

Source: GAO summary of EEOC's Model Elements. 

[End of table] 

[End of section] 

Appendix III: Excerpt from Coast Guard Civil Rights Directorate 
Functional Review Recommendation Sheet: 

Recommendation number: 16; 

BAH recommendation: Restructure U.S. Coast Guard Civil Rights 
Program – This restructuring can be accomplished by placing the Field 
Civil Rights Service Providers under the direct oversight of the 
Director of Office of Civil Rights with Area Equal Opportunity 
Managers reporting to the Director instead of directly to Field 
Commanders; 
Project officer: Project officer 1; 
Most recent action taken: Restructuring plan has been developed to 
align with the Coast Guard’s proposed Modernization Plan. This plan 
will include efforts to streamline the Office of Civil Rights (OCR) 
reporting restructures; 
Primary	due date: 4/20/2009; 
Days before due: -271; 
Status: Work in progress. 

BAH recommendation: Present modernization to Strategic Transformation 
Team; 
Project officer: Project officer 2; 
Most recent action taken: [Empty]; 
Primary	due date: [Empty]; 
Days before due: [Empty]; 
Status: Complete. 

BAH recommendation: Present to Commanding Officers; 
Project officer: Project officer 1; 
Most recent action taken: 3/16: Video teleconference scheduled with 
Commandant and Area Commanders on 3/19; 
Primary	due date: [Empty]; 
Days before due: -312; 
Status: Work in progress. 

BAH recommendation: Present to Leadership Council; 
Project officer: Project officer 1; 
Most recent action taken: [Empty]; 
Primary	due date: [Empty]; 
Days before due: [Empty]; 
Status: Complete. 

BAH recommendation: Obtain approval and implement; 
Project officer: Project officer 3; 
Most recent action taken: [Empty]; 
Primary	due date: [Empty]; 
Days before due: -307; 
Status: Work in progress. 

Source: GAO presentation of CRD information. 

[End of section] 

Appendix IV: Summary of Generally Accepted Project Management 
Practices: 

Project planning practice: Identifying measurable performance goals; 
Summary: This practice defines the project's goals, describing how 
they will be achieved and defines measures of performance. The 
Government Performance Results Act of 1993 (GPRA) defines performance 
goals and measures with the intention of improving the effectiveness, 
accountability, and service delivery of federal programs[A] This 
framework informs federal practice and describes measures as either 
output or outcome measures. Outcomes describe the intended result of 
carrying out the activity while outputs describe the level of activity 
that will be provided over time including the characteristics 
established as standards for the activity, such as timeliness. 

Project planning practice: Defining specific tasks to complete the 
action plan; 
Summary: This practice identifies and documents the specific 
activities that must be performed in order to complete the project. 
This aids project completion by facilitating such activities as 
identifying the resource requirements, developing an appropriate time 
table for completion, and necessary stakeholder involvement in the 
project. 

Project planning practice: Identifying the person(s) accountable for 
completing the tasks to complete the action plan; 
Summary: This practice identifies and documents who is assigned and 
responsible for the completion of project tasks. This aids project 
completion by facilitating internal controls and reporting processes. 

Project planning practice: Identifying interim milestones/checkpoints 
to gauge the completion of the action plan; 
Summary: This practice identifies and documents interim milestones and 
checkpoints to gauge the completion of the project. A milestone is a 
significant event in the project that marks the completion of a 
deliverable or phase. A checkpoint is a point at which the status 
check is performed. This aids project completion by identifying not 
only the distance the team has traveled toward completing the project, 
but the direction traveled. 

Project planning practice: Identifying the needed resources to 
complete the action plan; 
Summary: This practice identifies and documents the determination of 
what resources (people, equipment, materials, and money) are needed to 
complete an action plan. This aids project completion by assuring that 
resource availability can be assured or alternate plans established to 
reach the goal of the action plan. 

Project planning practice: Consulted stakeholders; 
Summary: This practice identifies stakeholders--individuals and 
organizations that are involved in or may be affected by project 
activities--and ensures that they are included in developing and 
executing the project plan allowing them contribute appropriately. 
This aids project completion by ensuring that employees understand and 
are committed to the goals. 

Project planning practice: Defined how to evaluate the success of 
completing the action plan; 
Summary: This practice establishes and documents quantifiable criteria 
that must be met for the project to be considered successful. Prior 
GAO work[B] on designing evaluations discusses the importance of 
evaluating actions because it is a safeguard against using time and 
resources ineffectively. Evaluating the success of completing the 
action plan also increases the likelihood that a person, a team, or an 
agency will know when an action is complete and one has arrived at the 
intended goal, which should be attaining the results the action plans 
were intended to accomplish. 

Source: GAO analysis. 

[A] Government Performance and Results Act of 1993 (GPRA), Pub. L. No. 
103-62, 107 Stat. 285 (Aug. 3, 1993). 

[B] GAO, Designing Evaluations, GAO/PEMD-10.1.4, (Washington, D.C.: 
May 1991). 

[End of table] 

[End of section] 

Appendix V: Comments from the Department of Homeland Security: 

U.S. Department or Homeland Security: 
Washington, DC 20528: 

April 21, 2010: 

Ms. Laurie Ekstrand: 
Director, Strategic Issues: 
Government Accountability Office: 
Washington, D.C. 20548: 

Dear Ms. Ekstrand: 

Thank you for the opportunity to comment on the draft report GAO-10-
571T "Coast Guard: Civil Rights Directorate's Action Plan to Improve 
Its Operations Could Be Strengthened By Implementing Several Aspects 
of Project Planning and Implementation Practices." 

The Department of Homeland Security and the Coast Guard concurs with 
the draft report's recommendations and will work to incorporate sound 
project management principles in future corrective plans. We agree 
that improved metrics will better enable the program to measure 
success. The Coast Guard looks forward to continuing to refine its 
project management efforts to ensure that they meet the requirements 
of sound project planning and implementation. 

The following is our response to the recommendations. 

Recommendation #1: Ensure internal controls are in place to maintain 
the documentation necessary to facilitate oversight and course-
correction as plans are designed and implemented. 

Response: Concur. To institutionalize the practice, the Coast Guard 
will imbed internal control functions into staff responsibilities. 

Recommendation #2: Establish measurable performance goals for the 
action plans to support the management decision as to the completion 
status of the action plans. 

Response: Concur. The Coast Guard will develop desired outcomes and 
measurable success factors, and incorporate them into projects of this 
magnitude. 

Recommendation #3: Define an evaluation plan for each action plan to 
assess the degree to which the plan yielded the intended outcomes. 

Response: Concur. Consistent with recommendation #2. the Directorate 
will develop a template to incorporate the practice in business 
processes. 

Thank you for the opportunity to provide comments to the draft report. 

Sincerely, 

Signed by: 

Jerald E. Levine: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Footnotes: 

[1] Booz Allen Hamilton, U.S. Coast Guard Office of Civil Rights 
Program Review, 2009. See appendix I for a list of the 53 
recommendations to CRD. 

[2] MD-715 provides policy guidance and standards for establishing and 
maintaining effective affirmative programs of equal employment 
opportunity under § 717 of Title VII of the Civil Rights Act of 1964, 
as amended, and effective affirmative action programs under section 
501 of the Rehabilitation Act of 1973, as amended. See, 42 U.S.C. § 
2000e-16 and 29 U.S.C. § 791. We did not evaluate the extent to which 
CRD's action plans met the criteria for EEOC model elements. 

[3] GAO, Motor Carrier Safety: The Federal Motor Carrier Safety 
Administration Has Developed a Reasonable Framework for Managing and 
Testing Its Comprehensive Safety Analysis 2010 Initiative, [hyperlink, 
http://www.gao.gov/products/GAO-08-242R] (Washington, D.C.: Dec. 20, 
2007); and GAO, Standards for Internal Control in the Federal 
Government, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.: 
November 1999). Internal control standards provide the overall 
framework for establishing and maintaining internal controls in the 
federal government. 

[4] Government Performance and Results Act of 1993 (GPRA), Pub. L. No. 
103-62, 107 Stat. 285 (Aug. 3, 1993). 

[5] Project Management Institute, A Guide to the Project Management 
Body of Knowledge (PMBOK), First Edition (1996). We adapted the 
original language from PMBOK for the purposes of the GAO testimony. 

[6] GAO, Coast Guard: Observations on the Genesis and Progress of the 
Service's Modernization Program, [hyperlink, 
http://www.gao.gov/products/GAO-09-530R] (Washington, D.C.: Jun. 24, 
2009). 

[7] There are other action plans related to key issues identified in 
the external review that are not included in our review. 

[8] Coast Guard's 11 missions are: (1) Ports, waterways, and coastal 
security, (2) Drug interdiction, (3) Aids to navigation, (4) Search 
and rescue, (5) Living marine resources, (6) Marine safety, (7) 
Defense readiness, (8) Migrant interdiction, (9) Marine environmental 
protection, (10) Ice operations, and (11) Other law enforcement. See, 
§ 888 of the Homeland Security Act of 2002 (Pub. L. No. 107-296, 116 
Stat. 2135, 2249 (2002)). 

[9] See appendix II for a summary of the six model elements. 

[10] The EEOC categories of model elements are not mutually exclusive 
and can be subject to interpretation. 

[11] None of the action plans focus on proactive prevention of 
unlawful discrimination because no recommendations were made 
concerning this element. This does not imply that there should be 
plans focusing on proactive prevention or that the Coast Guard Civil 
Rights Directorate does not need to improve proactive prevention. 

[12] The Leadership Council consists of the Commandant, Vice 
Commandant, Commanders (Atlantic and Pacific Areas), the Chief of 
Staff, and the Master Chief Petty Officer of Coast Guard. 

[13] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[14] See appendix III for an excerpt from the Functional Review 
Recommendation Implementation Spreadsheet. 

[15] Project Management Institute, A Guide to the Project Management 
Body of Knowledge, First Edition (1996). 

[16] See appendix IV for a summary of the generally accepted project 
management practices. 

[17] We did not speak with the civil rights service providers and 
unions to obtain their views on CRD's consultation. 

[End of section] 

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