Equal Employment Opportunity:
DHS Has Opportunities to Better Identify and Address Barriers to EEO in Its Workforce
GAO-09-639, Aug 31, 2009
Under MD-715, federal agencies are to identify and eliminate barriers that impede free and open competition in their workplaces. EEOC defines a barrier as an agency policy, principle, or practice that limits or tends to limit employment opportunities for members of a particular gender, race, ethnic background, or disability status. According to EEOC's instructions, many employment barriers are built into the organizational and operational structures of an agency and are embedded in the day-to-day procedures and practices of the agency. In its oversight role under MD-715, EEOC provides instructions to agencies on how to complete their barrier analyses and offers other informal assistance. Based on agency submissions of MD-715 reports, EEOC provides assessments of agency progress in its Annual Report on the Federal Workforce, feedback letters addressed to individual agencies, and the EEO Program Compliance Assessment (EPCA).
DHS has generally relied on workforce data and has not regularly included employee input from available sources to identify "triggers," the term EEOC uses for indicators of potential barriers. GAO's analysis of DHS's MD-715 reports showed that DHS generally relied on workforce data to identify 13 of 15 triggers, such as promotion and separation rates. According to EEOC, in addition to workforce data, agencies are to regularly consult a variety of sources, such as exit interviews, employee groups, and employee surveys, to identify triggers. Involving employees helps to incorporate insights about operations from a frontline perspective in determining where potential barriers exist. DHS does not consider employee input from such sources as employee groups, exit interviews, and employee surveys in conducting its MD-715 analysis. Data from the governmentwide employee survey and DHS's internal employee survey are available, but DHS does not use these data to identify triggers. By not considering employee input on DHS personnel policies and practices, DHS is missing opportunities to identify potential barriers. Once a trigger is revealed, agencies are to investigate and pinpoint actual barriers and their causes. In 2007, through its departmentwide barrier analysis, DHS identified four barriers: (1) overreliance on the Internet to recruit applicants, (2) overreliance on noncompetitive hiring authorities, (3) lack of recruitment initiatives that were directed at Hispanics in several components, and (4) nondiverse interview panels. GAO's analysis of DHS's 2007 and 2008 MD-715 reports showed that DHS has articulated planned activities to address identified barriers, has modified nearly all of its original target completion dates by a range of 12 to 21 months, and has not completed any planned activities; although officials reported completing other activities in fiscal year 2007 and 2008 associated with its EEO program. Nearly half of the planned activities involve collaboration between the civil rights and human capital offices. DHS said that it modified the dates because of staffing shortages. In order to ensure that agency programs are effectively and efficiently implemented, it is important for agencies to implement internal control activities, such as establishing and tracking implementation goals with timelines. This allows agencies to pinpoint performance shortfalls and gaps and suggest midcourse corrections. DHS has not developed project plans with milestones beyond what is included in its MD-715 report and its Human Capital Strategic Plan. These documents include only the anticipated outcomes and target completion dates, not the essential activities needed to achieve the outcome. Identifying the critical phases of each planned activity necessary to achieve the intended outcome with interim milestones could help DHS ensure that its efforts are moving forward and manage any needed midcourse corrections, while minimizing modification of target dates. DHS uses a variety of means to oversee and support components, including providing written feedback on draft reports to components that are required to prepare their own MD-715 reports, conducting program audits, and convening a council of EEO directors from each of the components.
- Review Pending
- Closed - implemented
- Closed - not implemented
Recommendations for Executive Action
Recommendation: The Secretary of the Department of Homeland Security should direct the Officer for Office of Civil Rights and Civil Liberties (CRCL) to develop a strategy to regularly include employee input from such sources as the Federal Human Capital Survey (FHCS) and DHS's internal survey in identifying potential barriers to EEO.
Agency Affected: Department of Homeland Security
Status: Closed - Implemented
Comments: DHS' 2010 Management Directive 715 (MD-715) report includes a strategy to regularly include employee input from employee sources. For example, DHS' MD-715 report includes a section titled "EEO Plan To Eliminate Identified Barrier." One of the planned activities is to develop and implement an exit survey with target dates by which the exit survey would be implemented, and when the results of the survey would begin to be used to influence workplace policies. The report also describes a planned activity to use the employee viewpoint survey (EVS) to identify changes needed to improve employee satisfaction. Within four months of the publication of the EVS, DHS officials would begin to work to develop a plan for changes based on the results. According to DHS officials, the EVS will be conducted annually and the results of the EVS and the exit surveys will be used to identify potential barriers to EEO.
Recommendation: The Secretary of the Department of Homeland Security should direct the Officer for CRCL and the Chief Office of the Human Capital (CHCO) to identify essential activities and establish interim milestones necessary for the completion of all planned activities to address identified barriers to EEO.
Agency Affected: Department of Homeland Security
Comments: DHS's FY 2010 MD-715 report does identify essential activities and establishes milestones for the completion of the activities to address identified EEO barriers. We will review the FY 2011 MD-715 report, due at the end of January 2012, to ensure that DHS is working towards these milestones and plans. During a July 2010 teleconference, officials from DHS's Office of Civil Rights and Civil Liberties (CRCL) said that they are working with DHS components to include interim milestones in their Management Directive-715 reports and that such milestones will be included DHS's FY 2010 MD-715 report, which was due on January 31, 2011.