Federal Affirmative Action:

Better EEOC Guidance and Agency Analysis of Underrepresentation Needed

GGD-91-86: Published: May 10, 1991. Publicly Released: May 16, 1991.

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Pursuant to a congressional request, GAO reviewed the federal affirmative employment program, focusing on: (1) the Equal Employment Opportunity Commission's (EEOC) major workforce data requirements for agency multiyear affirmative employment plans; and (2) agency compliance with requirements.

GAO found that: (1) 27 of 35 agencies, employing 98 percent of the federal workforce, complied with the EEOC requirement to identify major occupations in their multiyear affirmative employment plans, but the criteria for selecting those occupations varied; (2) although EEOC required each agency to submit summary analyses by grade groupings for its total workforce, it did not require data or analysis of major occupations by grade level and, as a result, agencies did not identify and address representation disparities that existed between upper and lower grades of major occupations; (3) EEOC approved 17 agency plans that did not include the required workforce analysis of major occupations, in an attempt to prevent further delays of otherwise appropriate affirmative employment plans; (4) agencies cited personnel changes in agency equal employment opportunity (EEO) offices and the inaccessibility of EEO data as the main reasons for late submissions of plans; (5) although the 18 agencies that complied with EEOC major occupation reporting requirements provided actual workforce numbers or percentages of employees in their major occupations, additional analyses of data could help to develop representation indexes and estimates of the number of individuals needed to attain full representation in major occupations; (6) major occupation data by grade level was needed to identify and to help eliminate those barriers that prevented the upward movement of individuals within major occupations; and (7) the compilation of representative information by common occupations could facilitate EEO information sharing among agencies.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: EEOC should strengthen the emphasis of the federal affirmative employment program on improving minority and female representation in upper grade levels by analyzing the time agencies took to prepare and EEOC to approve affirmative employment plans, develop standards for completing these processes, and hold agencies and EEO officials accountable for meeting the standards.

    Agency Affected: Equal Employment Opportunity Commission

    Status: Closed - Implemented

    Comments: EEOC has analyzed the amount of time agencies have taken to prepare and submit affirmative employment plans and the time it took EEOC to approve these plans. EEOC has developed new procedures for ensuring timely submission and approval of agency plans.

    Recommendation: EEOC should strengthen the emphasis of the federal affirmative employment program on improving minority and female representation in upper grade levels by withholding plan approval until all required data and analyses are included.

    Agency Affected: Equal Employment Opportunity Commission

    Status: Closed - Not Implemented

    Comments: Standard internal operating procedures have been developed and implemented ensuring required agency data has been included in accomplishment reports and plans prior to approval. If data is not included in agency submissions, the report or plan will be rejected with a deadline for submission of the missing data provided in the EEOC response.

    Recommendation: EEOC should strengthen the emphasis of the federal affirmative employment program on improving minority and female representation in upper grade levels by expanding agency data collection and analysis requirements to include major occupation workforce data by grade level or grade groupings and the systematic use of representation indexes to analyze workforce data and estimate the number of people needed to attain full representation.

    Agency Affected: Equal Employment Opportunity Commission

    Status: Closed - Not Implemented

    Comments: EEOC has not responded to this recommendation. Expanded agency data collection and analysis requirements to include major occupation workforce data were to be addressed in a draft management directive on Equal Employment Opportunity and Affirmative Employment for Minorities, Women, and People With Disabilities. However, the management directive remains in draft and there are no current plans to finalize and publish it, according to the Federal Sector Programs Director.

    Recommendation: EEOC should strengthen the emphasis of the federal affirmative employment program on improving minority and female representation in upper grade levels by including in its revised directive better guidance on what constitutes a major occupation.

    Agency Affected: Equal Employment Opportunity Commission

    Status: Closed - Implemented

    Comments: EEOC has not responded to this recommendation. Revised guidance on what constitutes a major occupation was to be addressed in a draft management directive on Equal Employment Opportunity and Affirmative Employment for Minorities, Women, and People With Disabilities. However, the management directive remains in draft and there are no current plans to finalize and publish it, according to the Federal Sector Programs Director.

    Recommendation: EEOC should strengthen the emphasis of the federal affirmative employment program on improving minority and female representation in upper grade levels by: (1) compiling major occupation workforce data by agency; (2) identifying agencies with full EEO representations and successful affirmative employment strategies; and (3) sharing this information with other agencies with common occupations.

    Agency Affected: Equal Employment Opportunity Commission

    Status: Closed - Implemented

    Comments: EEOC has not fully responded to this recommendation. EEOC does not routinely compile workforce data on major occupations. Collecting this information was provided for in a draft management directive on Equal Employment Opportunity and Affirmative Employment for Minorities, Women, and People With Disabilities. However, the management directive remains in draft and there are no current plans to finalize and publish it, according to the Federal Sector Programs Director. The director said, however, that some analysis of representation rates in specific major occupations occurs during on-site technical visits to individual agencies.

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