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    Subject Term: "Disadvantaged persons"

    10 publications with a total of 25 open recommendations
    Director: Kay Brown
    Phone: (202) 512-7215

    1 open recommendations
    Recommendation: To help improve tribes' ability to maintain safe, stable, and permanent care for children, the Secretary of Health and Human Services should direct the Children's Bureau to explore the reasons for low tribal participation and identify actions to increase this participation in the title IV-E Guardianship Assistance Program.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS agreed with this recommendation. The agency noted that some tribal-state agreements might predate 2008, when GAP was established. HHS also said that regional office staff participate annually in joint planning for the title IV-B and IV-E programs with their respective states and tribes and that participation in GAP is a topic covered in joint planning activities. In addition, HHS said that regional office staff are available to assist states and tribes with discussions about GAP participation when tribal-state agreements are renegotiated and that technical assistance is available to tribes, if needed. According to HHS, the agency plans to add information to the Children's Bureau website about direct federal funding for tribal title IV-E agencies and about tribal-state partnership agreements and plans to distribute issue briefs on GAP and best practices for tribal-state agreements. We agree that HHS has the planning process, technical assistance resources, and regional staff in place to discuss GAP participation with title IV-E state and tribal agency officials. However, our review found that tribal participation in GAP remains low, which suggests that HHS needs to identify actions to increase participation in this program. We believe that the additional actions HHS plans to take - providing information on the Children's Bureau website about direct funding and distributing issue briefs on GAP and best practices for tribal - state partnerships and agreements - could support tribes' participation in GAP either by helping tribes to directly operate a title IV-E program or to negotiate a tribal-state agreement that includes a provision for GAP participation. Because some tribes reported challenges at the state level to participating in GAP and several tribes reported that the state where they are located does not participate in the program, we encourage HHS to engage title IV-E state agency officials in discussions about tribal participation in GAP during the annual review of the their title IV-E state plan. HHS could identify ways that regional office staff might help state agencies resolve any challenges to GAP participation that tribes experience at the state level. HHS has taken several steps over the past few years to help tribes with their title IV-E programs, including hiring a tribal coordinator to facilitate communication between regional offices and tribal title IV-E agencies. Taking additional steps to ensure that tribes have the opportunity to participate in GAP could go a long way toward helping tribes gain more resources for children under their care and better support tribes' efforts to care for children exiting foster care to permanent homes.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    7 open recommendations
    Recommendation: To help foster and unaccompanied homeless youth better navigate the college admissions and federal student aid processes, the Secretaries of Education and HHS should jointly study potential options for encouraging and enabling child welfare caseworkers, McKinney-Vento homeless youth liaisons, and other adults who work with these youth to more actively assist them with college planning.

    Agency: Department of Education
    Status: Open

    Comments: In 2017, Education reported that it is continuing its efforts to address the recommendation. In May 2016, Education, working with the Department of Health and Human Services, issued a Foster Youth Transition Toolkit, which addresses both financial aid and college admissions processes. The toolkit was written for youth in or formerly in foster care rather than for professionals who serve these youth. Education noted that it had also posted a Homeless Youth Fact sheet for teachers and other professionals on its website in July. Education said that it will continue to work with HHS and the National Association for the Education of Homeless Children and Youth about college admissions and federal student aid processes for foster and unaccompanied homeless youth. Education also plans to conduct a technical assistance webinar for McKinney-Vento homeless youth liaisons and to provide technical assistance for other programs. Making such information available on Education's website is an encouraging step, as are plans to conduct webinars for professionals who work with homeless youth. We look forward to the implementation of these plans. However, we continue to believe that HHS and Education should consider ways to encourage more active college planning efforts among professionals who work with homeless and foster youth that consider professional staff's competing goals and priorities and multiple responsibilities.
    Recommendation: To help foster and unaccompanied homeless youth better navigate the college admissions and federal student aid processes, the Secretaries of Education and HHS should jointly study potential options for encouraging and enabling child welfare caseworkers, McKinney-Vento homeless youth liaisons, and other adults who work with these youth to more actively assist them with college planning.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS, working with the Department of Education, issued a Foster Youth Transition Toolkit in May 2016 which encourages current and former foster youth to pursue college and addresses both financial aid and college admissions processes. The toolkit was written for youth in or formerly in foster care, and HHS considers it a resource for unaccompanied homeless youth as well as for the adults who serve these youth. Making such information available through this joint publication is an encouraging step. However, child welfare caseworkers, school homelessness liaisons, and other professionals who work with homeless and foster youth have competing goals and priorities and multiple responsibilities. To encourage and facilitate college planning and admissions efforts, Education and HHS would need to carefully consider professional staff's workloads, responsibilities, and training needs, among other issues, and develop some options for encouraging college planning efforts among professionals in these programs who work with homeless and foster youth. HHS did not provide an update for FY 2017.
    Recommendation: To help foster and unaccompanied homeless youth, as well as adults who assist these youth, better navigate the federal student aid process and obtain information about college resources, the Secretary of Education, in consultation with the Secretary of HHS, should create webpages directed to homeless and foster youth so they can more easily find tailored and centralized information about available federal and other resources, such as Pell Grants, Chafee Education and Training Voucher Program (Chafee ETV Vouchers), and waivers for college admission tests.

    Agency: Department of Education
    Status: Open

    Comments: In 2017, Education reported that it is continuing its efforts to address the recommendation. In addition to having a webpage about foster youth, Education noted that in April 2016 it had created a new webpage with resources for homeless children and youth. In July 2016, Education developed and posted online a Foster Care Transition Toolkit and a Fact Sheet on federal student aid for homeless youth that is available through its resources webpage. The development and posting of these materials on the agency's website offers helpful resources to foster and homeless youth; however, Education should also make it easier for these youth, who often lack adult support, to find these documents easily--such as by referring to them on the page that says who is eligible for federal student aid--without lengthy searching of the Website.
    Recommendation: To help college financial aid administrators more effectively implement eligibility rules for unaccompanied homeless youth, the Secretary of Education should make available an optional worksheet or form that college financial aid administrators can voluntarily use to document unaccompanied homeless youth status or encourage the use of existing forms that are available.

    Agency: Department of Education
    Status: Open

    Comments: Education agreed that it would be helpful to make forms developed by outside organizations knowledgeable about homelessness issues available for financial aid administrators to use for documenting the status of unaccompanied homeless youth. Education also said that it plans to highlight the availability of these forms and provide guidance at its annual conference and in updates to the Federal Student Aid Handbook. Education noted that it will not endorse the use of a specific form but that it will highlight forms that already exist that may be useful to financial aid administrators. In 2017, Education reported that it is continuing its efforts to address the recommendation. We look forward to Education making such forms available for college financial aid administrators so that they can more effectively implement eligibility rules for unaccompanied homeless youth.
    Recommendation: To help homeless youth more easily access federal student aid, the Secretary of Education should clarify its guidance to financial aid administrators and students about whether financial aid administrators should accept any unaccompanied homeless youth determination provided by McKinney-Vento homeless liaisons or other authorized officials even if a student is not in high school or receiving program services.

    Agency: Department of Education
    Status: Open

    Comments: In 2017, Education reported that it is continuing its efforts to address the recommendation. In June 2016, Education posted questions and answers about federal student for homeless youth on its website and in July, the agency posted a fact sheet about Homeless Youth on its webpage for teachers and other professional staff. However, neither document states whether financial aid administrators should accept any unaccompanied homeless youth determination provided by McKinney-Vento liaisons or authorized officials even if a student is not in high school or receiving program services. In July 2016, Education issued guidance for the McKinney-Vento program specifying that a local liaison may continue to provide verification of a youth's homelessness status for federal student aid purposes for as long as the liaison has access to the information necessary to make such a determination for a particular youth. The guidance also stated that local homelessness liaisons should ensure that all homeless high school students receive information and counseling on college-related issues. Education said that it will also hold a technical assistance webinar for McKinney-Vento Education for Homeless Children and Youths Program liaisons. In the 2017-18 Application and Verification Guide for financial aid administrators, Education clarified circumstances under which authorized officials may provide documentation of unaccompanied homelessness for a person who is no longer officially receiving services. The updated guide also noted that local homelessness liaisons may write subsequent year letters of verification for unaccompanied homeless youth through age 23 for whom they have the necessary information to write such letters and that this documentation is acceptable for verifying unaccompanied homelessness. The agency should also update the question and answer factsheet on federal student aid for homeless students so that the information on unaccompanied homeless youth determinations is presented consistently in these key documents.
    Recommendation: To enhance access to federal student aid for unaccompanied homeless youth, the Secretary of Education should consider developing a legislative proposal for congressional action to simplify the application process so that once a student has received an initial determination as an unaccompanied homeless youth, the student will not be required to have that status re-verified in subsequent years but attest to their current status on the Free Application for Federal Student Aid, unless a financial aid administrator has conflicting information.

    Agency: Department of Education
    Status: Open

    Comments: In 2017, Education reported that it is continuing its efforts to address the recommendation. In July 2016, Education said that the department had proposed further simplification of the FAFSA in its fiscal year 2017 budget proposal. Education stated that it will also consider the feasibility of a legislative proposal to not require re-verification of homelessness after a student has received an initial determination. Such a legislative proposal would enhance access to federal student aid for unaccompanied homeless youth.
    Recommendation: To simplify program rules for Chafee ETV vouchers and improve access to these vouchers for former foster youth ages 21 and 22, the Secretary of HHS should consider developing a legislative proposal for congressional action to allow foster youth to be eligible for the Chafee ETV voucher until age 23 without also requiring that they start using the voucher before they turn 21.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS's budget request for fiscal year 2018 does not contain a legislative proposal to improve access to Chafee vouchers for former foster youth ages 21 and 22. In July 2016, HHS noted that it had made a proposal for mandatory programs to improve foster youth's access to vouchers for title IV-E Chafee programs in the Administration for Children and Families' fiscal year 2017 budget request. However, the agency explained that the proposal's purpose is to extend eligibility for Chafee Foster Care Independence Program (CFCIP) services to youth up to age 23 in jurisdictions that have extended foster care to age 21. According to HHS, the budgetary proposal does not affect the Chafee Vouchers. A legislative proposal to simplify program rules for Chafee ETV vouchers would support improving access to these vouchers for former foster youth ages 21 and 22.
    Director: J. Christopher Mihm
    Phone: (202) 512-6806

    1 open recommendations
    Recommendation: To build upon the Department of Housing and Urban Development and the Rental Policy Working Group's efforts to improve coordination of rental assistance, the Secretary of the Department of Housing and Urban Development, in consultation with the Rental Policy Working Group, should work with states and localities to develop an approach for compiling and reporting on the collective performance of federal, state, and local rental assistance programs. Such an effort may begin with one or more pilots to test approaches before they are considered for wider application.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: In July 2017, a HUD official said HUD is still working to respond to the GAO recommendation. He said HUD is currently in the planning stages for updating the existing "Picture of Subsidized Housing" database to add the Low Income Housing Tax Credit (LIHTC) and HOME programs and that including LIHTC and HOME will give a more complete picture of governmental assistance since LIHTC is often combined with other subsidies and HOME funds are often put into state housing trust funds and issued together with funding from state revenue sources.
    Director: Kay Brown
    Phone: (202) 512-7215

    2 open recommendations
    Recommendation: To improve the consistency of assistance provided to tribes, the Secretary of Health and Human Services should take steps to provide consistent title IV-E guidance to tribes across its regional offices.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: In May 2015, HHS hired a tribal coordinator who will work in the Office of the Associate Commissioner of the Children's Bureau. The tribal coordinator's primary functions will include facilitating communication across the regions and with tribes to share experiences and information, so as to ensure greater consistency and clarity. While this hire represents an initial step towards improving communication with tribal title IV-E agencies, more time is needed for the tribal coordinator to implement policies and procedures that will ensure consistent title IV-E guidance to tribes across HHS regional offices. In May 2017, the agency reported that tribal coordinator position was ultimately elevated to the Office of the ACYF Commissioner and became the Commissioner's representative to the Tribes. We await documentation on any guidance provided to the regional offices that would help with consistency.
    Recommendation: To improve the timeliness of assistance provided to tribes, the Secretary of Health and Human Services should establish procedures to ensure reviews of draft title IV-E plans are conducted by regional office staff in a timely manner.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: As of May 2017, HHS stated that it does not anticipate taking action in response to this recommendation because of its existing protocols for communicating with and responding to tribal title IV-E grantees. We maintain that establishing procedures, including but not limited to timeframes for responses, would help ensure that tribes receive timely feedback from regional offices regarding their draft title IV-E plans.
    Director: Dave Wise
    Phone: (202) 512-2834

    3 open recommendations
    Recommendation: To promote and enhance federal, state, and local NEMT coordination activities, the Secretary of Transportation, as the chair of the Coordinating Council, should convene a meeting of the member agencies of the Coordinating Council and complete and publish a new or updated strategic plan that, among other things, clearly outlines a strategy for addressing NEMT and how it can be coordinated across federal agencies that fund NEMT service.

    Agency: Department of Transportation
    Status: Open

    Comments: The Federal Transit Administration (FTA) concurred with this recommendation. As of November 2016, FTA stated that Administrator-level members of the Coordinating Council on Access and Mobility (CCAM) met in July 2016 to begin the process of developing a strategic plan. A follow-up meeting of the same group is planned for December 2016. According to FTA, it is anticipated this meeting will result in agreement on a strategic plan framework and that interagency working groups will begin implementation of the framework in early 2017. Based on the minutes of the July 2016 CCAM meeting, emerging themes identified for the strategic plan included improved access to medical care and to better coordinate transportation planning, particularly integrating transportation planning into healthcare planning. This recommendation will be kept open pending finalization of the strategic plan framework and how it relates to NEMT.
    Recommendation: To promote and enhance federal, state, and local NEMT coordination activities, the Secretary of Transportation, as the chair of the Coordinating Council, should convene a meeting of the member agencies of the Coordinating Council and finalize and issue a cost-sharing policy and clearly identify how it can be applied to programs under the purview of member agencies of the Coordinating Council that provide funding for NEMT.

    Agency: Department of Transportation
    Status: Open

    Comments: FTA concurred with this recommendation. As of November 2016, FTA stated that Administrator-level members of the Coordinating Council on Access and Mobility met in July 2016 to begin the process of developing a strategic plan. A follow-up meeting of the same group is planned for December 2016. According to FTA, it is anticipated the December meeting will result in agreement on a strategic plan framework and that interagency working groups will begin implementing the plan in early 2017. FTA expects development of a cost-sharing policy and proposed model will be an objective in the strategic plan. We plan to keep this recommendation open pending completion of the strategic plan framework and further information related to implementing this recommendation.
    Recommendation: To promote and enhance federal, state, and local NEMT coordination activities, the Secretary of Transportation, as the chair of the Coordinating Council, should convene a meeting of the member agencies of the Coordinating Council and using the on-going work of the Health, Wellness, and Transportation working group and other appropriate resources, (1) identify the challenges associated with coordinating Medicaid and VA NEMT programs with other federal programs that fund NEMT, (2) develop recommendations for how these challenges can be addressed while still maintaining program integrity and fraud prevention, and (3) report these recommendations to appropriate committees of Congress. To the extent feasible, the Coordinating Council should implement those recommendations that are within its legal authority.

    Agency: Department of Transportation
    Status: Open

    Comments: FTA said they concurred in part with this recommendation. FTA announced the selection of 19 Rides to Wellness Demonstration and Innovative Coordinated Access and Mobility pilot projects, totally about $7.3 million, in September 2016. According to FTA, seven of the 19 projects have a NEMT focus. In addition, during 2016 FTA conducted outreach sessions in various cities throughout the United States to discuss partnership opportunities between the health and transportation industries. FTA stated that a new series of NEMT-specific listening sessions is now underway and additional sessions are planned for 2017. The purpose of these sessions is to identify challenges related to NEMT coordination that will be addressed by Coordinating Council on Access and Mobility (CCAM) working groups in the future. CCAM is also in the process of developing a strategic plan framework. FTA anticipates agreement on this framework in December 2016. The Fixing America's Surface Transportation (FAST) Act requires CCAM to develop and publish a strategic plan. FTA anticipates issues related to this recommendation will be developed through 2020. We plan to keep this recommendation open to further monitor CCAM and FTA progress and the extent challenges are identified and addressed related to better coordinating Medicaid and VA NEMT with other NEMT programs in the federal government, through the strategic plan framework or other actions resulting from the listening sessions.
    Director: Daniel Bertoni
    Phone: (202) 512-7215

    2 open recommendations
    Recommendation: As part of initiatives currently under way to improve agency information on claims with appointed representatives and detect potential fraud associated with representatives, the Commissioner of the Social Security Administration should consider actions to provide more timely access to data on representatives and enhance mechanisms for identifying and monitoring trends and patterns related to representation, particularly trends that may present risks to program integrity. Specifically, SSA could (1) Identify additional data elements, or amendments to current data collection efforts, to improve information on all appointed representatives, including those under contract with states and other third parties; (2) Implement necessary policy changes to ensure these data are collected. This could include enhancing technical systems needed to finalize SSA's 2008 proposed rules that would recognize organizations as representatives; and (3) Establish mechanisms for routine data extracts and reports on claims with representatives.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA reported that it is approaching the conclusion of the first phase of a new initiative, called Registration, Appointment and Services for Representatives (RASR). This initiative aims to register all appointed representatives and improve relevant business processes and data collection. SSA reported that it had to postpone the first release of RASR, originally targeted for December 2016, due to some systems issues. SSA stated that it has not yet set a new target date for the first release. SSA stated that this new application will enhance data collection and management of representatives' information and that it will help make strides toward better oversight and improved data analysis and reporting. We will consider closing this recommendation when these efforts are completed.
    Recommendation: To address risks associated with potential overpayments to representatives and protect claimant benefits, the Commissioner of the Social Security Administration should take steps to enhance coordination with states, counties, and other third parties with the goal of improving oversight and preventing and identifying potential overpayments. This coordination could be conducted in a cost-effective manner, such as issuing guidance to states and other third parties on vulnerabilities for overpayment; sharing best practices on how to prevent overpayments; or considering the costs and benefits, including any privacy and security concerns, of providing third parties controlled access to portions of the eFolder to facilitate the detection of potential overpayments.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA stated that it added a section to a new form--Form SSA-1698, Fee Agreement for Representation before the Social Security Administration--that claimants and representatives can use to enter into fee agreements. According to SSA, this form requires the disclosure of fees that the representative will receive from a third party and the amount of those fees. SSA expects this form to be in use upon OMB approval. Similar language already exists in another form--Form SSA-1560-U4, Petition to Obtain Approval of a Fee for Representing a Claimant before the Social Security Administration--that claimants and representatives can use for fee petitions. SSA stated that these forms are (and will be) included in the folder of evidence that adjudicators may review before determining whether and how much to authorize in fees. According to SSA, disclosure and approval of any third party fees, with potential adjustment of the fee, by both the claimant and SSA should help prevent excessive fees. While the proposed change to the form may help improve transparency of fee arrangements, the potential for a representative to receive a payment from SSA and also receive a payment from a state or other third party still exists. Unless SSA and the state or other third party share information on their payments or have policies and procedures in place to prevent such cases, representatives could still receive both SSA and state payments that total more than the SSA-authorized fee. In order to address this vulnerability, we continue to believe that SSA should enhance coordination or issue guidance to states and other third parties about this vulnerability, which could include SSA sharing best practices for preventing these types of overpayments. For example, one state requires contracted organizations to submit copies of their signed form 1696 (Appointment of Representative) so the state could verify the representative checked the appropriate box for payment.
    Director: Brown, Kay E
    Phone: (202) 512-7215

    1 open recommendations
    Recommendation: To encourage broader adoption and evaluation of promising approaches and address impediments to the use of the career pathways approach among TANF agencies, HHS should, in consultation with Congress, identify potential changes that would address the lack of incentives for states and localities to adopt promising approaches and then develop and submit a legislative proposal outlining those changes.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: In June 2015, HHS noted that the agency's fiscal year 2016 budget includes a proposal to increase incentives for states to implement or strengthen subsidized employment programs and notes the Administration's willingness to work with Congress to improve the TANF program's effectiveness in accomplishing its goals. Additionally, HHS reported that it continues to provide technical assistance and disseminate research to help encourage TANF agencies to adopt or strengthen employment-focused approaches. While we commend these efforts, we continue to believe it is important for HHS, in consultation with Congress, to identify potential changes that would address the lack of incentives for states and localities to adopt promising approaches and develop and submit a legislative proposal outlining those changes. As of October 2017, we have not received any additional status updates on this recommendation from HHS.
    Director: Wise, David J
    Phone: (202)512-3000

    1 open recommendations
    Recommendation: To establish accountability for meeting the programs' goal of increasing the participation of traditionally underrepresented groups in the highway construction workforce, the Secretary of Transportation should direct the FHWA Administrator to create and implement an oversight mechanism that (1) holds states accountable for meeting federal training criteria and (2) clearly stipulates how FHWA will assess state program effectiveness, including what type of program achievement data states are to submit and how such data will be used. This oversight mechanism should include assessing the effectiveness of its division offices in overseeing state activities.

    Agency: Department of Transportation
    Status: Open

    Comments: FHWA has taken steps to implement an oversight mechanism that may address this recommendation. FHWA officials anticipate completing their work in response to this recommendation in mid- to late 2017.
    Director: Iritani, Katherine M
    Phone: (206)287-4820

    2 open recommendations
    Recommendation: To enhance the provision of dental care to children covered by Medicaid and CHIP, and to help ensure that HHS's Insure Kids Now Web site is a useful tool to help connect children covered by Medicaid and CHIP with participating dentists who will treat them, the Secretary of HHS should establish a process to periodically verify that the dentist lists posted by states on the Insure Kids Now Web site are complete, usable, and accurate, and ensure that states and participating dentists have a common understanding of what it means for a dentist to indicate he or she can treat children with special needs.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: HHS has reported taking steps to improve the data on the Insure Kids Now website, including establishing an ongoing system to check that data are in the correct format and conducting validation surveys. HHS has also reported that CMS will provide technical assistance to low performing States and develop mechanisms to better identify providers that serve children with special health care needs. As of September 2017, CMS has not indicated that it has communicated with states and providers on what it means for a dentist to indicate he or she can treat children with special needs. We will leave this recommendation open until the agency takes steps to ensure that states and participating dentists have a common understanding of what it means for a dentist to indicate he or she can treat children with special needs.
    Recommendation: To enhance the provision of dental care to children covered by Medicaid and CHIP, and to help ensure that HHS's Insure Kids Now Web site is a useful tool to help connect children covered by Medicaid and CHIP with participating dentists who will treat them, the Secretary of HHS should require states to verify that dentists listed on the Insure Kids Now Web site have not been excluded from Medicaid and CHIP by the HHS-OIG, and periodically verify that excluded providers are not included on the lists posted by the states.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: As of September 2017, CMS has not indicated the agency has required states to ensure that excluded providers are not listed on the Insure Kids Now website and has not indicated that the agency has taken steps to periodically verify that excluded providers are not listed. CMS has said that it relies on states to provide accurate lists of eligible dentists and that data issues prevent the agency from independently verifying that excluded providers are not included on the Insure Kids Now website. We continue to believe that CMS should require states to ensure that excluded providers are not listed on the website and periodically verify that excluded providers are not included on the lists posted by the states, so that the website does not present inaccurate information about providers available to serve Medicaid-covered children.
    Director: Shames, Lisa R
    Phone: (202)512-2649

    5 open recommendations
    Recommendation: To better ensure sufficient oversight and management direction are provided to guide USDA's civil rights efforts, to make responsibility for improvement clear, and to make USDA's performance more transparent, Congress may wish to consider making USDA's Assistant Secretary for Civil Rights subject to a statutory performance agreement.

    Agency: Congress
    Status: Open

    Comments: As of September 2013, action on a new farm bill is pending and it is not known whether Congress will make the Assistant Secretary subject to a performance agreement.
    Recommendation: To better ensure sufficient oversight and management direction are provided to guide USDA's civil rights efforts, to make responsibility for improvement clear, and to make USDA's performance more transparent, Congress may wish to consider establishing a USDA civil rights oversight board.

    Agency: Congress
    Status: Open

    Comments: As of September 2013, action on a new farm bill is pending and it is not known whether Congress will establish a USDA civil rights oversight board.
    Recommendation: To improve USDA efforts to address civil rights issues and the participation of minority farmers and ranchers in USDA programs, the Secretary of Agriculture should prepare and implement an improvement plan for resolving discrimination complaints that sets time frame goals and provides management controls for resolving complaints from beginning to end.

    Agency: Department of Agriculture
    Status: Open

    Comments: USDA has not fully implemented this recommendation. As of August 2012, USDA had developed a plan to improve resolution of discrimination complaints, and the Office of the Assistant Secretary for Civil Rights (OASCR) had implemented many of the plan's actions, such as placing priority on processing program complaints facing the statute of limitations. However, USDA had more work to do on (1) establishing an electronic records management system; (2) implementing the Lean Six Sigma (LSS) process; (3) conducting pilot efforts to explore establishing new time frame goals for intake, investigation, and adjudication activities to resolve employee and program complaints; and (4) providing documentation of new policies, procedures, guidance, and training needed to determine if new management controls cover the entire process for resolving complaints. As of September 2013, OASCR's electronic complaints management systems allow OASCR to scan in, store, and retrieve multiple records in a searchable environment. OASCR undertook a review of the program complaint process through LSS, and based on the results, extended the scope of the review to include the employment complaint process. OASCR implemented core changes through LSS that identify efficiencies to reduce time frames. OASCR has established time frame goals for processing program complaints; however, it has yet to establish them for investigating and adjudicating employment complaints. Time frame goals for the entire employment complaint resolution process would have to be final before management controls can be made final.
    Recommendation: To improve USDA efforts to address civil rights issues and the participation of minority farmers and ranchers in USDA programs, the Secretary of Agriculture should develop and implement a plan to ensure the accuracy, completeness and reliability of ASCR's databases on customer and employee complaints, and that provides for independent validation of ASCR's data quality.

    Agency: Department of Agriculture
    Status: Open

    Comments: USDA has not fully implemented this recommendation. As of August 2012, the Office of the Assistant Secretary for Civil Rights' (OASCR) efforts to ensure data reliability of the iComplaints employee complaints database included a comprehensive set of business rules, a data integrity tool, and a quality review management module. Also, OASCR had developed and was implementing a plan to check the accuracy of the data entered for every program complaint in the Program Complaints Management System (PCMS). However, OASCR had not provided all of the documentation needed to assess whether its planned efforts contain key elements to ensure the accuracy, completeness, and reliability of the iComplaints and PCMS databases. For example, OASCR officials had neither provided documentation showing that the office developed departmental policy to ensure the consistent use of iComplaints and PCMS nor training to ensure the completeness of data in PCMS. As of September 2013, OASCR officials provided standard operating procedures (SOPs) for processing program complaints, which include numerous steps to ensure the consistent use of PCMS. OASCR officials also provided SOPs for processing employment complaints; however, the SOPs have not been finalized for the investigation and adjudication phases of the processing and are therefore insufficient to ensure the consistent use of iComplaints. OASCR officials did provide documentation showing that OASCR has established a formal training program to ensure that OASCR and USDA civil rights practitioners are trained in the proper use of PCMS and iComplaints. In addition, the PCMS Data Integrity Team is working to correct discrepancies found as of October 2012. This effort is 85 percent complete.
    Recommendation: To improve USDA efforts to address civil rights issues and the participation of minority farmers and ranchers in USDA programs, the Secretary of Agriculture should develop a results-oriented department-level strategic plan for civil rights at USDA that unifies USDA's departmental approach with that of ASCR and the newly created Office of Advocacy and Outreach and that is transparent about USDA's efforts to address the concerns of stakeholders.

    Agency: Department of Agriculture
    Status: Open

    Comments: USDA has not fully implemented this recommendation. As of August 2012, the Office of the Assistant Secretary for Civil Rights (OASCR) had not updated its strategic plan since our report was issued in October 2008. From October 1, 2009, to November 20, 2011, OASCR was placed under Departmental Management and during that time was not required to develop or update its own strategic plan, according to OASCR officials. Since November 20, 2011, OASCR has reported directly to the Secretary and has been working to develop its own strategic plan. On July 31, 2012, we obtained a revised draft of OASCR's strategic plan that covers fiscal years 2011-2015. This draft still has a number of shortcomings. For example, it (1) focuses primarily on the activities OASCR plans and does not unify OASCR's approach with the Office of Advocacy and Outreach, other USDA agencies, or the department as a whole; (2) does not describe the viewpoints and interests of USDA's external stakeholders, such as community-based organizations; and (3) does not fully address other key issues identified in our report, such as measuring performance to gauge progress, using performance information for identifying performance gaps and making program improvements, and identifying external and internal factors that can influence the achievement of its long-term goals. As of September 2013, OASCR had, by November 2012, finalized and published its strategic plan for fiscal years 2011-2015. The published plan includes some time frame goals for processing program and employment complaints, but these goals are incomplete. The published plan also includes some minor editorial changes, but otherwise, it was almost identical to the draft plan we reviewed in July 2012 and still has the same shortcomings that we identified at that time.