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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
July 2011:
Coast Guard:
Civil Rights Directorate Can Enhance Workforce Restructuring Efforts:
GAO-11-718:
Contents:
Letter:
Results In Brief:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Briefing Slides Presented to Congressional Requesters:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: Contact and Staff Acknowledgments:
Abbreviations:
BAH: Booz Allen Hamilton:
CRD: Civil Rights Directorate:
CRSP: Civil Rights Service Provider:
EO: Equal Opportunity:
EEO: Equal Employment Opportunity:
EEOC: Equal Employment Opportunity Commission:
MD: Management Directive:
USCG: United States Coast Guard:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 18, 2011:
Congressional Requesters:
The United States Coast Guard's (USCG) Civil Rights Directorate's
(CRD) principal functions are to provide Equal Opportunity (EO)
services to its approximately 50,000 active duty military, and Equal
Employment Opportunity (EEO) services to its 8,000 civilian employees.
We reported in April 2010[Footnote 1] that CRD had taken action to
help resolve its management challenges, such as dissatisfaction among
USCG personnel and to improve its civil rights program, primarily
guided by recommendations resulting from a 2009 Booz Allen Hamilton
(BAH) study that CRD commissioned.[Footnote 2] Among these
recommendations were that CRD centralize its organizational structure
and institute a full-time equal employment workforce, which BAH
expected would help significantly enhance program components, such as
organizational cohesion. According to CRD officials, they implemented
these recommendations in July 2009, and at the time of our last review
continued to build on the organizational restructuring.
In response to BAH recommendations, in July 2009 CRD:
* Reorganized its field operations to deliver civil rights services by
specialists through a centrally managed national structure divided
into three national regions headed by regional managers. Regions are
further divided into 14 subordinate zones. (see appendix I for a
geographical representation of CRD's workforce structure).
* Staffed the civil rights regions and zones with full-time field
Civil Rights Service Providers (CRSPs) and discontinued the use of
part-time (collateral duty) personnel.
* Established a centralized reporting structure for all CRSPs to
report to three regional civil rights managers who in turn report
directly to CRD headquarters, rather than the previous practice of
reporting to a local command structure.
CRD relies on a blended workforce of full-time military and civilian
CRSPs to provide USCG personnel with EO/EEO counseling, complaint
investigation/processing, and EO/EEO training. CRD uses the same
discrimination complaint processing procedures for military personnel
as it does for civilians, except, unlike civilian employees, military
personnel do not have standing at the Equal Employment Opportunity
Commission (EEOC). However, military personnel may appeal their
complaints to the Department of Homeland Security.
Because of the importance of the role that CRSPs have in implementing
CRD's civil rights program, and your interest in how the current
structure enables CRD to meet the needs of USGC personnel, you
requested that we determine what CRD has done to help ensure that the
reorganization of its workforce improves civil rights services. In
particular, we examined workforce structure changes related to:
* The reorganization of field operations (e.g., use of full-time
staff, rather than collateral-duty staff,[Footnote 3] geographic
distribution of USCG personnel, staff workload, and ratios of civil
rights service providers to USCG personnel in different regions and
zones where USCG personnel serve), and:
* CRSP's qualifications (i.e., work experience, educational
requirements, performance standards and qualifications, and training).
On May 18, 2011, we briefed your staff on CRD's efforts to ensure that
the reorganization of its workforce has led to improvement and on
challenges CRD continues to face. This report transmits materials used
at the briefing and reprinted in Appendix I.[Footnote 4]
This briefing is part of your larger request, for which a report will
be issued later this year. That report will address (1) how CRD's
performance goals and metrics compare with the standards in the
Government Performance Results Act, and other related sources that
provide guidance; and, (2) how CRD's program compares to the EEOC
model program, as described in the EEOC's Management Directive (MD)
715.[Footnote 5]
To evaluate CRD's efforts to help ensure that the reorganization of
its workforce has improved civil rights services, we examined CRD
documentation about organizational restructuring, field operations,
and workforce qualifications. We analyzed CRD formal and informal
civilian and military complaint data, staffing ratios of CRSPs to USGC
personnel, and the CRD Alignment Billet Plan to identify factors that
CRD considers in determining staffing ratios and staff allocations.
[Footnote 6] To determine CRD professional qualifications for CRSPs,
we analyzed CRD's training development plan and training data. We
interviewed CRD officials responsible for the design and
implementation of workforce restructuring and field operations. We
also conducted semistructured interviews with 7 of 40 CRSPs, who
provide EO services to USCG military and EEO services to USCG civilian
personnel.[Footnote 7] We interviewed them to obtain their
perspectives on their roles as CRSPs, CRD workforce restructuring, and
professional qualifications. We selected CRSPs from across CRD's
geographic zones who were assigned prior to the July 2009
reorganization so that they could offer perspectives on the former and
the current organizational structures. We interviewed both civilian
and military CRSPs, and we selected two civilian CRSPs who had been in
the military. Because respondents were selected based on a
nonprobability sample, the results cannot be generalized to all CRSPs.
We also interviewed EEOC officials and reviewed EEOC guidance and
documentation related to field operations and workforce
qualifications.[Footnote 8] For background information, we reviewed
the 2009 BAH report and its recommendations related to restructuring
CRD field operations and CRSP qualifications, and the 2009 BAH
Workload Analysis of CRD field personnel. Lastly, we reviewed our
prior testimony[Footnote 9] for context regarding CRD's organizational
restructuring action plan as well as a past GAO study on internal
control.[Footnote 10]
We assessed the reliability of staffing, training, and complaint data
that CRD provided by verifying that the data fields for the data were
consistent with our data requests, and determined that the data were
sufficiently reliable for the purposes of this report. However, we
determined that the data and systems that CRD uses for tracking,
monitoring, and reporting CRSP training data were not reliable. We
obtained and analyzed training records from CRD for each CRSP to
determine if basic annual training requirements were being
met.[Footnote 11] Some of the records provided were missing data or
incomplete. We are making a recommendation based on this observation.
We conducted this performance audit from November 2010 to July 2011 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.
Results In Brief:
CRD has improved its civil rights services in certain respects, but
additional potential enhancements remain:
* CRD continues to centralize its workforce, but lacks a disciplined
and documented strategic approach for making staffing allocation
decisions. In November 2009, BAH performed a workforce analysis of
CRSPs' tasks, and determined that CRD needed 37 CRSPs in addition to
the 41 staff already in place at that time. BAH also recommended that
CRD devise a strategic growth plan to determine geographic staff
allocations and to ensure that high-priority positions are considered.
CRD officials said they were in agreement with BAH's assessment, and
were working to increase the CRSP workforce.
Nonetheless, CRD has not developed a disciplined and documented
strategic approach that would promote transparency in decision making,
and include criteria about geographic placements of CRSPs; nor has it
identified the relative importance of priorities, including criteria
for placing additional staff among its regions and zones. For example,
in reviewing CRD's staffing allocation data plan for staffing 12 of
the 37 positions that BAH recommended, the rationale was not clear for
placing CRSPs in certain geographic locations rather than in others.
CRD officials told us they rely on several factors included in BAH's
Workload Analysis in making geographic staffing allocation decisions,
such as distance CRSPs travel to provide training or counseling; the
number of civilian personnel in the zone; and the ratio of CRSPs to
USCG personnel in a zone. CRD officials said they also rely on their
management knowledge and judgment, noting that these are intangibles
that a workforce analysis cannot fully capture. To a lesser extent,
they stated they relied on complaint data to identify zones with
higher levels of complaints, because overall, complaint levels have
been relatively low across their regions for military and civilian
personnel. These can be appropriate considerations when making
staffing decisions. However, without a disciplined and documented
strategic approach, transparency is not promoted and knowledge is not
institutionalized. Further, without such an approach, CRD can not be
assured that staffing allocation decisions are targeting the most
pressing needs, and that civil rights issues of USCG are being
addressed.
* CRD has taken steps to ensure that CRSPs are qualified to provide
civil rights services, but has not been able to ensure that they meet
basic training requirements, due to data and system reliability
shortfalls. Regarding required training, to ensure quality counseling
throughout the federal sector, EEOC MD-110 mandates an initial 32
hours of training and 8 hours of continuing training annually for all
EEO service providers, which include CRSPs.[Footnote 12]
To address the skill gaps in CRD's workforce noted in the November
2009 BAH report, CRD established a Training Development Plan that
identifies training for CRSPs by level,and began developing a system
to track mandatory and recommended CRSP training data. Other steps CRD
took include establishing performance standards for CRSPS, organized
annual regional and biennial annual headquarters conferences, and
encouraging CRSPs to participate in professional training courses and
EO/EEO conferences.
We identified data reliability gaps in CRD's current training tracking
system that may prevent CRD from determining if CRSPs met minimum EEOC
training requirements. Our analysis of the CRSP Master Training Record
System, which consists of three spreadsheets containing regional CRSP
training data, revealed inconsistencies in the recording of CRSP
training data and incomplete records for 12 of 40 CRSPs, as of April
2011.[Footnote 13] We also found that the Master Training Record
System lacks internal controls such as a data verification process,
and system documentation. Further, based on the interviews we
conducted with 7 of 40 CRSPs, we determined there were inconsistent
processes for managing and tracking training information. Federal
internal control standards require that documents used to manage a
program or operation are to be properly managed and maintained.
Internal controls help to ensure that all transactions are completely
and accurately recorded.[Footnote 14]
CRD officials acknowledged that training data shortfalls exist because
they had focused on other priorities, and limited resources prevented
them from developing a centralized CRSP training system and processes
in the past. CRD officials stated that in addition to the Master
Training Record System, they can confirm that CRSPs have met training
requirements by requesting certification directly from CRSPs.[Footnote
15] However, relying on requests for certification from CRSPs is a
less efficient and effective means of verifying training than through
a centralized system.
To address shortfalls in data reliability and their processes, CRD
officials told us they are in the process of building a centralized
Web-based system, to ensure accuracy and consistency of CRSPs training
data. They anticipated this system being available in June 2011.
However, CRD officials were not able to provide us with planning
documentation that described the structure of this system, such as
design specifications, or specific milestones for its development and
implementation.
Conclusions:
CRD has made progress toward improving its civil rights program.
Further, CRD has made progress centralizing its workforce structure
and in using criteria to make staff allocation decisions. A level of
informed managerial discretion is important in making decisions
related to human capital and staffing needs. However, as its workforce
analysis plan recommended, it is important that CRD have a more
formalized and documented approach, or use consistent criteria in
decision making regarding staff allocations and prioritization of USCG
needs. Without such a plan, transparency is not promoted and knowledge
is not institutionalized. Further, without such an approach, CRD can
not be assured that staffing allocation decisions are targeting the
most pressing needs, and that civil rights issues of USCG are being
addressed.
Similarly, CRD has taken steps to improve CRSP's qualifications and
training, but without reliable data and systems to manage CRSP
training data, CRD lacks an efficient and effective means of verifying
that CRSPs meet basic EEOC training requirements, which plays a role
in its annual MD-715 submission to EEOC. More importantly, if CRSPs
are not meeting basic EEOC training requirements, it could impact the
quality of civil rights services provided to USCG personnel. CRD
officials informed us they are in the process of developing a
centralized system to ensure accuracy and consistency of CRSP training
data, but without documentation of system specifications and
milestones for the development and implementation of this system, it
is not clear that the new system will be able to achieve its intended
purposes when launched.
Recommendations for Executive Action:
We recommend that the Secretary of Homeland Security direct the
Commandant of the Coast Guard to take the following two actions:
* To promote transparency in decision making, develop a disciplined
and documented strategic approach that includes criteria for making
geographic staffing allocation decisions, which would include helping
identify the highest priorities for placing additional staff among its
regions and zones.
* Implement a centralized system for CRSP training records that
provides design specifications with associated implementation
milestones and that aligns with internal control standards for data
tracking, monitoring, and reporting.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Secretary of Homeland
Security for review and comment. In written comments, which are
reprinted in appendix II, DHS generally concurred with our findings,
conclusions, and recommendations, and provided additional information
about CRD's accomplishments and program activities in progress.
However, DHS disagreed with certain information. Specifically, DHS
concurred with our first recommendation related to developing a
disciplined and documented strategic approach that includes criteria
for making geographic staffing allocation decisions. However, DHS
disagreed with our characterization of the basis for CRD's strategic
decision making, listing several documents it provided to us showing
the analyses CRD undertook to aid decision making about staffing
allocations, and determining priorities for placing staff. We
acknowledge that CRD provided various documents for review during the
course of our work. However, CRD did not provide sufficient detail
about how it used this information in determining staffing
allocations. For example, CRD's billet placement plan identifies
particular zones as, for example, 'High Priority,' or 'Not as High';
however, it lacks any indication of how the number of complaints,
distances CRSPs travel, or other factors were considered in
establishing the different staffing priority levels. Further, CRD
officials provided complaint data that covered two fiscal years, but
there was no indication or analysis as to if or how this data was used
to determine staffing or make workload projections. Additionally, in
response to our request for evidence regarding staffing allocations
during the time of our work, we did not receive the memos, the digest,
or the May 2011 internal document that CRD cited as a summarization of
the factors considered in making staffing-allocation decisions. To the
extent that these documents help CRD establish a disciplined and
systematic decision-making process, we encourage the agency's use of
this information in support of its efforts to address our
recommendation. As we stated in our report, without such a process,
transparency is not promoted and knowledge is not institutionalized.
Therefore, we believe our recommendation remains valid until there is
further evidence of a disciplined and systematic decision-making
process for allocating staff.
DHS also agreed with our second recommendation to implement a
centralized system for CRSP training records that provides design
specifications with associated implementation milestones, and that
aligns with internal control standards for data tracking, monitoring
and reporting. However, DHS disagreed with our application of EEOC's
MD-110, which identifies minimum training standard for all CRSPs,
stating that the standard only applies to the subset of CRSPs who
perform EEO counseling.[Footnote 16] However, CRSP data that CRD
provided from its CRSP Master Training Record System for our analysis
showed no indication of a difference in training requirements between
CRSPs who are EEO counselors, and CRSPs who are not. As stated in the
report, based on our review of CRSP training records, the data
provided to us did not verify that the MD-110 requirement was met for
all CRSPs. DHS also disagreed with our assessment that reliability
gaps in CRD's current training tracking matrix may prevent the
Directorate from validating minimum training requirements, stating
that it has other means for determining if training requirements were
met, such as contacting CRSPs directly to verify compliance with
training requirements. However, as stated in our report, this approach
is a less efficient and effective means of verifying training
requirements than through a centralized system. CRD described the
plans underway to develop and implement a Web-based application--the
Training Management Tool--that would enable CRD regional managers to
validate training completion on a real-time basis. To the extent that
this Web-based application provides the capacity to accurately track,
monitor and report CRSP training information, we believe use of such a
tool could be responsive to our recommendation. DHS also provided
technical comments, which we incorporated as appropriate.
We will send copies of this report to the Secretary of Homeland
Security and other interested parties. The report also will be
available at no charge on GAO's Web site at [hyperlink,
http://www.gao.gov].
If you or your staff have any questions concerning this report, please
contact Yvonne D. Jones at (202) 512-6806 or jonesy@gao.gov. Contact
points for our Office of Congressional Relations and Public Affairs
may be found on the last page of this report. GAO staff who made major
contributions to this report are listed in Appendix III.
Signed by:
Yvonne D. Jones:
Director, Strategic Issues:
List of Requesters:
The Honorable John L. Mica:
Chairman:
The Honorable Nick J. Rahall, II:
Ranking Member:
Committee on Transportation and Infrastructure:
House of Representatives:
The Honorable Bennie Thompson:
Ranking Member:
Committee on Homeland Security:
House of Representatives:
The Honorable Frank A. LoBiondo:
Chairman:
The Honorable Rick Larsen:
Ranking Member:
Subcommittee on Coast Guard and Maritime Transportation:
Committee on Transportation and Infrastructure:
House of Representatives:
The Honorable Elijah Cummings:
House of Representatives:
[End of section]
Appendix I: Briefing Slides Presented to Congressional Requesters:
GAO Briefing to Congressional Requesters:
Coast Guard: Civil Rights Directorate Can Enhance Workforce
Restructuring Efforts:
May 18, 2011:
Table of Contents:
* Background - Slides 3-4;
* Objective - Slide 5;
* Scope and Methodology — Slides 6-7;
* Results in Brief — Slide 8;
* Issue 1 — Slides 9-12;
* Issue 2 - Slides 13-19;
* Conclusions — Slide 20;
* Recommendations — Slide 21;
* Appendix I — Slide 22;
* Appendix II — Slide 23;
* Appendix Ill — Slides 24-25.
Background:
The United States Coast Guard's (USCG) Civil Rights Directorate (CRD)
principal functions are to provide Equal Opportunity (EO) services to
its approximately 50,000 active duty military and Equal Employment
Opportunity (EEO) services to its approximately 8,000 civilian
personnel.
CRD's military and civilian Civil Rights Service Providers (CRSPs)
provide these services in the form of EO/EEO counseling, complaint
investigation/processing, and EO/EEO training.
In late 2008, CRD commissioned an external review and evaluation of
CRD's plans to improve its provision of civil rights services. In
February 2009, Booz Allen Hamilton (BAH) completed its review, and
made several recommendations related to CRD workforce organization,
including a centralized reporting structure, use of full-time CRSPs,
and workforce training.
To address the BAH recommendations, in July 2009, CRD:
* reorganized its field operations into three regions that are further
subdivided into 14 zones, based on existing staff allocations (see
appendix I for the geographical reorganization of CRD's workforce
structure);
* staffed national regions and zones with full-time field CRSPs and
discontinued the use of collateral duty staff; and
* established a centralized reporting structure for all CRSPs to
report directly to CRD, rather than the previous practice of reporting
to a local command structure.
Objective:
Identify what the USCG's CRD has done to help ensure that the
reorganization of its workforce improves the provision of civil rights
services. More specifically, evaluate workforce structure changes
related to the following:
* Issue 1: The reorganization of field operations (e.g., use of full-
time
staff rather than collateral duty staff,[Footnote 17] geographic
distribution of USCG personnel, staff workload, and ratios of civil
rights service providers to USCG personnel in different regions and
zones where USCG personnel serve), and
* Issue 2: CRSP's qualifications (i.e., work experience, educational
requirements, performance standards and qualifications, and training).
Scope and Methodology:
To address this objective, we:
Examined:
* Documentation from CRD about organizational restructuring, which CRD
began implementing in 2009, field operations, and workforce
qualifications from July 2009 to March 2011.
* Two 2009 Booz Allen Hamilton (BAH) Reports:[Footnote 18]
- one that addressed recommendations on restructuring of the CRD field
operations, which CRD commissioned and used to develop action plans to
improve its civil rights operations, and,
- the other, a workload analysis of CRD field personnel, which
according to CRD officials, is being used to develop a rationale for
staffing decisions.
* Guidance from the Equal Employment Opportunity Commission (EEOC)
related to workforce qualifications.
Analyzed:
* Complaint data (fiscal year 2010), staffing ratio data (as of April
2011), and CRD's geographical realignment plan (October 2010); and
* Training development plan (as of December 2009) and training data
(calendar year 2010)
Interviewed:
* CRD officials and CRSPs about organizational restructuring, field
operations, and workforce qualifications; and;
* EEOC officials about workforce qualifications and best practices for
EEO field operations and organizational structures.
We assessed CRD data and found them sufficiently reliable for the
purposes of this report, except for data and systems that CRD uses for
tracking, monitoring, and reporting CRSP training data. We are making
a recommendation based on this observation.
We conducted this performance audit from November 2010 through May
2011, 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 objective.
We believe that the evidence obtained provide a reasonable basis for
our findings and conclusions based on our audit objective.
Results in Brief:
CRD continues to build on its workforce reorganization, but lacks a
disciplined and documented strategic approach that would promote
transparent K in decision making, and include criteria about
geographic placements of CRSPs; nor has CRD identified the highest
priorities for placing additional staff among its regions and zones.
* CRD agreed with the results of BAH's 2009 Workload Analysis, which
included a recommendation that CRD develop a strategic growth plan to
aid decision making for field staff allocation.
* However, CRD's current staffing plan for allocating CRSPs to
specific geographic areas lacks a disciplined strategic approach to
developing a strategic growth plan that would include, for example,
documented rationale and criteria for staff allocation.
CRD has taken steps to improve CRSP qualifications, but lacks reliable
data and systems to assure compliance with minimum training
requirements.
*CRD made improvements in CRSP qualifications by, among other things,
setting performance standards, establishing a training development
plan, and organizing regional and headquarters conferences.
* CRD lacks reliable CRSP training data and systems to assure
compliance with minimum EEOC training requirements.
Issue 1: CRD Continues to Build on its Workforce Reorganization:
CRD retained BAH to perform a workload analysis for workforce planning
purposes. By considering CRSP tasks, BAH determined that:
* In addition to the 41 staff in place at the time, CRD needed an
additional 37 field CRSPs for tasks, such as complaint processing and
training, if CRD is to improve services.[Footnote 19]
* CRD should devise a strategic growth plan to determine geographic
staff allocations to help ensure that high priority factors, such as
complaints processing and assessment and training needs, are used in
decision making about staff allocations.
* CRD's strategic plan should include factors that capture the
variations across zones such as the number of complaints per zone,
number of personnel supported, average distance between commands, mix
of civilian and military personnel supported, geographic size of each
zone, and the existence of adequate supervisory leadership.
CRD agreed with BAH's workload analysis, and developed an allocation
plan for distributing the 37 additional positions geographically as
they become authorized, 4 of which were authorized in 2010, and 12
which have been authorized for 2011.
Issue 1: CRD Lacks a Documented Strategic Approach to Support Staffing
Allocation Decisions:
However, based on our review of documents and data CRD provided as
well as discussions with CRD officials, we found no evidence that CRD
took a disciplined and documented approach in considering the relative
importance of factors that BAH cited as high priorities in CRD's staff
allocation decisions (see appendix III for CRD's current and proposed
staff allocation).[Footnote 20] For example,
* CRD did not provide us with a documented rationale or criteria for
its decision to staff the 12 new positions in certain geographic
locations over others. In April 2010, we recommended that CRD ensure
that internal controls were in place to maintain documentation
necessary to facilitate oversight.[Footnote 21] CRD agreed with our
recommendation and said that it would imbed internal control functions
into staff responsibilities to maintain the documentation to oversee
and correct plans as they are designed and implemented.
* CRD did not have a documented methodical approach to determine how a
variety of factors that BAH cited as priorities, such as complaint
levels or civilian and military personnel levels, which vary from zone
to zone, impact the decision to allocate the 12 new positions to
particular regions or zones (see appendix IV for supporting detail on
variations across zones such as USCG personnel and complaint levels).
According to CRD officials, they relied on the following factors to
make staff allocation decisions:
* the distance CRSPs have to travel to provide training or counseling,
* the ratio of CRSPs to personnel, and,
* maintaining the mix of military and civilian CRSPs to support USCG's
blended military and civilian workforce.
CRD officials also relied on their professional judgment and knowledge
of the specific geographical locales. To ensure continuity, CRD gives
additional consideration to placements of civilian CRSP positions in
zones where only military CRSPs are serving.[Footnote 22]
To a lesser extent, CRD officials stated that they relied on complaint
data per zone, because overall, complaint levels have been relatively
low across the regions for military and civilian personnel.
Management's judgment is one of many important factors in making human
capital and equal opportunity program decisions, but federal
governmentwide internal control standards require that major
management decisions be documented and readily available for
examination.[Footnote 23]
As BAH's workload analysis plan recommended, and based on our previous
work, it is important that CRD has a disciplined, well-documented
strategic approach for decision making regarding staff allocations and
prioritization of needs.[Footnote 24] This type of planning is very
important in:
* determining the critical skills and competencies that will be needed
to achieve current and future programmatic results; and;
* developing strategies that are tailored to address gaps in number,
deployment, and alignment of human capital approaches for all critical
skills and competencies that need attention.
This approach to workforce planning may also help CRD use factors such
as the number of formal and informal complaints per zone or the
existence of adequate supervisory leadership.
Without such a disciplined and documented strategic approach,
knowledge is not institutionalized, and CRD cannot be assured that
staffing allocation decisions are resulting in targeting the most
pressing needs, and that civil rights issues of USCG are being
addressed.
Issue 2: CRD Has Taken Steps to Improve CRSP Qualifications:
In the February 2009 BAH study commissioned by CRD, BAH made several
recommendations for CRD to manage all aspects of CRSP training
activities and to ensure that CRSPs have required skills and training.
As part of the justification for CRD restructuring, the CRD Director
outlined the need for:
* skilled and experienced full-time civil rights professionals; and;
* a training inventory to ensure CRSP credentials are kept current.
Additionally, to ensure quality counseling throughout the federal
sector, EEOC Management Directive (MD) 110 requires an initial 32
hours of training and 8 hours of continuing training annually for all
EEO service providers, which include CRSPs.[Footnote 25]
Based on our review of CRD documentation and discussions with CRD
officials, CRD took the following steps to improve CRSP professional
qualifications and training:
* established performance standards for CRSPs;
* established a Training Development Plan identifying a suite of
EO/EEO training courses for different levels of CRSPs;
* organized annual regional and biennial headquarters conferences;
* encouraged CRSP's to participate in professional training courses and
EO/EEO industry conferences; and;
* initiated the development of a system, CRSP Master Training Record
System, to track CRSP training data.
Issue 2: CRD Lacks Reliable Data and Systems to Assure Compliance with
Minimum Training Requirements:
CRD officials told us that all CRSPs met the annual EEOC training
requirements.
However, based on our analysis of data from the CRSP Master Training
Record System, 12 of the 40 CRSPs, as of April 2011, had incomplete
records for the required 8 hour EEO Counselor annual refresher
training in 2010.[Footnote 26]
Based on the data CRD provided, we also identified significant gaps in
the CRSP training data:
* incomplete CRSP data in one regional report,
* inconsistent recording of CRSP data across three separate regional
reports,
* inaccurate summaries of regional data, and,
* undated documentation.
Information systems should include internal controls and reliability
procedures.
The federal government's internal control standards state that:
* documents used to manage a program or operation are to be properly
managed and maintained.
* Transactions should be promptly recorded to maintain their relevance
and value to management in controlling operations and making
decisions. Internal controls help to ensure that all transactions are
completely and accurately recorded.
* A variety of controls can be used in information processing to help
ensure the validation and verification of data maintained in
centralized systems. For example, edit checks can be conducted on data
entered for information processing.[Footnote 27]
Based on past GAO work, data verification and validation are necessary
to ensure that users can have confidence in the reported performance
information.[Footnote 28]
The CRSP Master Training Record System lacks internal controls such as:
* data verification - an assessment of data completeness, accuracy,
and consistency; and,
* system documentation — system flowcharts, design specifications,
user manuals, and documentation of the process for submitting,
maintaining, and reporting CRSP training data.
Previously, monitoring and tracking of CRSP training rested with CRD
regional managers who certified to CRD Headquarters that CRSPs had
completed their EEOC training requirements.
Until January 2011, CRD had no automated and centralized system for
tracking, monitoring, and reporting CRSP training data. CRSP training
data are currently located in an interim tool (three separate
spreadsheets containing regional CRSP training data).
Based on the interviews we conducted with 7 of 40 CRSPs, we determined
there were inconsistent processes for tracking and managing training
information.[Footnote 29] This includes inconsistent notifications for
required training and different regional approaches to tracking
training requirements.[Footnote 30]
According to CRD officials, because of other priorities and limited
resources, CRD did not begin developing a centralized process and
system for tracking and monitoring training records until January 2011.
To address the shortfalls in their Master Training Record System, such
as those we identified, CRD officials said they are developing a Web-
based system designed to centralize CRSP training data, and that this
system would be available in June 2011.
At the time of our review, CRD did not have a planning document that
described the structure of this system, including system flowcharts,
design specifications, or a user manual. However, according to CRD
officials, once the new Web-based system is fully implemented, CRD
should be able to ensure the accuracy of CRSP training data.
Based on CRD's belief that training provides CRSPs with knowledge,
skills, and abilities to perform civil rights functions, the quality
of civil rights services provided to USCG personnel may be diminished
if CRSPs are not meeting basic EEOC training requirements.[Footnote 31]
However, without reliable training data and systems, CRD cannot be
fully assured that all of its CRSPs have completed mandatory EEO
Counselor training requirements. This type of information plays a role
in certifying to EEOC through the annual MD-715 submission that
CRSPs have met basic EEOC training requirements.[Footnote 32]
CRD officials stated that in addition to the Master Training Record
System, CRD could confirm that CRSPs have met training requirements by
requesting certification directly from CRSPs. However, relying on
requests for certification from CRSPs is a less efficient and
effective means of verifying training than through a centralized
system.
Conclusions:
* Issue 1: CRD has made progress in using criteria to make staff
allocation decisions, but without a formalized staffing approach, CRD
can not be assured that staffing allocation decisions are targeting
the most pressing needs and that civil rights issues of USCG are being
addressed.
* Issue 2: CRD has taken steps to improve CRSPs' qualifications and
training, but without reliable data and systems to manage CRSP
training data, CRD lacks an efficient and effective means of verifying
that CRSPs meet basic EEOC training requirements. If CRSPs are not
meeting basic EEOC training requirements, it could impact the quality
of civil rights services provided to USCG personnel. CRD officials
informed us they are in the process of developing a centralized system
to ensure accuracy and consistency of CRSP training data, but without
documentation of system specifications and milestones for the
development and implementation of this system, it is not clear that
the new system will be able to achieve its intended purposes when
launched.
Recommendations for Executive Action:
GAO recommends that the Secretary of Homeland Security direct the
Commandant of the Coast Guard to take the following two actions:
* to promote transparency in decision making, develop a disciplined
and documented strategic approach that includes criteria for making
geographic staffing allocations decisions, which would help identify
the highest priorities for placing additional staff among its regions
and zones; and;
* implement a centralized system for CRSP training records that
provides design specifications with associated implementation
milestones and that aligns with internal control standards for data
tracking, monitoring, and reporting.
Appendix I:
Figure 1: Geographical Reorganization of CRD Services, as of March
2011:
[Refer to PDF for image: illustrated U.S. map]
United States Coast Guard:
Civil Rights Directorate:
Region 1:
Zone 1:
Maine;
Massachusetts;
New Hampshire;
Rhode Island;
Vermont.
Zone 2:
Connecticut;
New Jersey;
New York.
Zone 3:
Delaware;
Maryland;
Pennsylvania.
Zone 4:
District of Columbia;
Northern Virginia.
Region 2:
Zone 5:
Southern Virginia.
Zone 6:
Georgia;
Kentucky;
North Carolina;
South Carolina;
Tennessee.
Zone 7:
Florida;
Puerto Rico.
Zone 8:
Alabama;
Arkansas;
Louisiana;
Mississippi;
Missouri.
Zone 9:
Colorado;
Kansas;
Nebraska;
New Mexico;
North Dakota;
Oklahoma;
South Dakota;
Texas.
Zone 10:
Indiana;
Illinois;
Iowa;
Michigan;
Minnesota;
Ohio;
West Virginia.
Region 3:
Zone 11:
Arizona;
California;
Nevada;
Utah.
Zone 12:
Alaska.
Zone 13:
Idaho;
Montana;
Oregon;
Washington.
Zone 14:
Hawaii.
Source: GAO analysis of CRD data.
[End of figure]
Appendix II: CRD's Current and Proposed Allocation of Additional CRSP
Staff:
Table 1: USCG Personnel and Civil Rights Service Providers by Region
and Zone, as of April 2011:
CRD region/zone: CRDHQ;
Total USCG personnel per geographic zone: 0;
Current CRSPs: 0;
CRD's allocation of remaining proposed billets: 0;
Allocation of 12 authorized billets (FY 2011)[A]:3.
CRD region/zone: Region 1, HQ[B];
Total USCG personnel per geographic zone: 0;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 1.
CRD region/zone: Region 1, zone 1;
Total USCG personnel per geographic zone: 3,491;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 0;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 1, zone 2;
Total USCG personnel per geographic zone: 5,445;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 1;
Allocation of 12 authorized billets (FY 2011)[A]: 1.
CRD region/zone: Region 1, zone 3;
Total USCG personnel per geographic zone: 2,181;
Current CRSPs: 2;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 1.
CRD region/zone: Region 1, zone 4;
Total USCG personnel per geographic zone: 3,930;
Current CRSPs: 2;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 2, Region HQ;
Total USCG personnel per geographic zone: 0;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 4;
Allocation of 12 authorized billets (FY 2011)[A]: 3[C].
CRD region/zone: Region 2, zone 5;
Total USCG personnel per geographic zone: 4,888;
Current CRSPs: 4;
CRD's allocation of remaining proposed billets: 4;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 2, zone 6;
Total USCG personnel per geographic zone: 3,965;
Current CRSPs: 2;
CRD's allocation of remaining proposed billets: 3;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 2, zone 7;
Total USCG personnel per geographic zone: 5,764;
Current CRSPs: 4;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 2, zone 8;
Total USCG personnel per geographic zone: 3,306;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 2, zone 9;
Total USCG personnel per geographic zone: 2,311;
Current CRSPs: 1;
CRD's allocation of remaining proposed billets: 3;
Allocation of 12 authorized billets (FY 2011)[A]: 1.
CRD region/zone: Region 2, zone 10;
Total USCG personnel per geographic zone: 2,765;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 3, Region HQ;
Total USCG personnel per geographic zone: 0;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 0;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 3, zone 11;
Total USCG personnel per geographic zone: 5,904;
Current CRSPs: 2;
CRD's allocation of remaining proposed billets: 3;
Allocation of 12 authorized billets (FY 2011)[A]: 1.
CRD region/zone: Region 3, zone 12;
Total USCG personnel per geographic zone: 2,509;
Current CRSPs: 3;
CRD's allocation of remaining proposed billets: 1;
Allocation of 12 authorized billets (FY 2011)[A]: 1.
CRD region/zone: Region 3, zone 13;
Total USCG personnel per geographic zone: 3,485;
Current CRSPs: 2;
CRD's allocation of remaining proposed billets: 2;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
CRD region/zone: Region 3, zone 14;
Total USCG personnel per geographic zone: 1,211;
Current CRSPs: 45;
CRD's allocation of remaining proposed billets: 33;
Allocation of 12 authorized billets (FY 2011)[A]: 12.
CRD region/zone: Total4;
Total USCG personnel per geographic zone: 51,155;
Current CRSPs: 2;
CRD's allocation of remaining proposed billets: 0;
Allocation of 12 authorized billets (FY 2011)[A]: 0.
Source: GAO analysis of CRD data.
[A] CRD received authorization for 12 billets in fiscal year 2011
(this is in addition to 4 billets CRD received in fiscal year 2010).
CRD officials told us they use the terms billet and position
interchangeably to refer to a full-time staff person.
[B] According to CRD officials, regional CRSPs provide civil rights
services for USCG personnel in zones within their region on an as-
needed basis.
[C] CRD officials told GAO that they are in process of splitting
Region 2 into two regions, and they are going to staff the Region 4 HQ
with two billets.
[End of table]
Appendix III: Variations Across Zones That Could Influence Allocating
Additional CRSP Staff:
Figures 1-3 illustrate variations across zones in the number of
military and civilian USCG personnel supported, and the number of
formal and informal complaints. Other variables not depicted include
travel necessary to provide training and counseling.
Figure 1: USCG Military and Civilian (Including Nonappropriated Fund
Employees) Personnel by Zone (as of April 2011):
[Refer to PDF for image: stacked vertical bar graph]
Zone: 1;
Military: 2,953;
Civilian: 538.
Zone: 2;
Military: 1,668;
Civilian: 777.
Zone: 3;
Military: 1,221;
Civilian: 960.
Zone: 4;
Military: 2,158;
Civilian: 1,772.
Zone: 5.
Military: 3,507;
Civilian: 1,381.
Zone: 6.
Military: 3,186;
Civilian: 779.
Zone: 7;
Military: 5,124;
Civilian: 640.
Zone: 8;
Military: 2,901;
Civilian: 405.
Zone: 9;
Military: 1,980;
Civilian: 331.
Zone: 10;
Military: 2,297;
Civilian: 468.
Zone: 11;
Military: 5,196;
Civilian: 708.
Zone: 12;
Military: 2,097;
Civilian: 412.
Zone: 13;
Military: 3,213;
Civilian: 272.
Zone: 14;
Military: 1,031;
Civilian: 180.
Source: GAO analysis of CRD data.
[End of figure]
Figure 2: Fiscal Year 2010 Formal Complaints by Zone:
[Refer to PDF for image: stacked vertical bar graph]
Zone: 1;
Military: 1;
Civilian: 2.
Zone: 2;
Military: 0;
Civilian: 0.
Zone: 3;
Military: 0;
Civilian: 2.
Zone: 4;
Military: 2;
Civilian: 13.
Zone: 5.
Military: 2;
Civilian: 10.
Zone: 6.
Military: 2;
Civilian: 10.
Zone: 7;
Military: 3;
Civilian: 2.
Zone: 8;
Military: 0;
Civilian: 1.
Zone: 9;
Military: 1;
Civilian: 4.
Zone: 10;
Military: 2;
Civilian: 2.
Zone: 11;
Military: 0;
Civilian: 1.
Zone: 12;
Military: 0;
Civilian: 1.
Zone: 13;
Military: 0;
Civilian: 0.
Zone: 14;
Military: 2;
Civilian: 0.
Source: GAO analysis of CRD data.
[End of figure]
Figure 3: Fiscal Year 2010 Informal Complaints by Zone:
[Refer to PDF for image: stacked vertical bar graph]
Zone: 1;
Military: 3;
Civilian: 2.
Zone: 2;
Military: 0;
Civilian: 2.
Zone: 3;
Military: 2;
Civilian: 4.
Zone: 4;
Military: 1;
Civilian: 9.
Zone: 5.
Military: 6;
Civilian: 20.
Zone: 6.
Military: 4;
Civilian: 7.
Zone: 7;
Military: 4;
Civilian: 3.
Zone: 8;
Military: 0;
Civilian: 3.
Zone: 9;
Military: 7;
Civilian: 6.
Zone: 10;
Military: 3;
Civilian: 3.
Zone: 11;
Military: 8;
Civilian: 10.
Zone: 12;
Military: 0;
Civilian: 2.
Zone: 13;
Military: 1;
Civilian: 1.
Zone: 14;
Military: 4;
Civilian: 1.
Source: GAO analysis of CRD data.
[End of figure]
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[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
July 1, 2011:
Yvonne Jones:
Director, Strategic Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Re: Draft Report GA0-11-718. "Coast Guard: Civil Rights Directorate
Can Enhance Workforce Restructuring Efforts"
Dear Ms. Jones:
Thank you for the opportunity to review and comment on this draft
report. The U.S. Department of Homeland Security (DHS) appreciates the
U.S. Government Accountability Office's (GAO's) work in planning and
conducting its review and issuing this report.
The Department is pleased to note the report's positive acknowledgment
that the United States Coast Guard's (USCG's) Civil Rights Directorate
(CRD) has made progress toward improving its civil rights program. The
USCG also notes the operational successes listed below, which
highlight the positive effect of workforce restructuring on Coast
Guard civil rights service delivery.
* A reduction by 27 percent in the number of days required to
investigate civilian complaints compared with the former structure.
* A reduction by 40 percent in the number of days required to
investigate military complaints of discrimination compared with the
former structure.
* A complete elimination in 2009 of the substantial workload of
military complaints for which no decision had been rendered (affecting
complaints which had arisen years earlier).
* Equal Employment Opportunity Commission (EEOC), officials have noted
the Coast Guard's favorable compliance level with Management Directive
(MD)-715, especially progress under what they classify as leadership
(i.e., the Director reporting to the agency head, and involvement
including appropriate resourcing support by leadership).
These successes comport directly with the six elements of a model
civil rights program as defined in EEOC MD-715.
Although the USCG generally concurs with GAO's findings and
conclusions, it disagrees with (1) GAO's characterization of the basis
for CRD strategic decisions, (2) application of MD-110, and (3)
assessment that reliability gaps in the CRD's current training
tracking matrix may prevent the Directorate from validating minimum
training requirements.
The draft report contained two recommendations directed to DI-IS. As
discussed below, OHS concurs with both recommendations. Specifically,
GAO recommended the Secretary of Homeland Security direct the
Commandant of the Coast Guard take the following actions:
Recommendation 1: To promote transparency in decision making, develop
a disciplined and documented strategic approach that includes criteria
for making geographic staffing allocation decisions that would include
helping identify the highest priorities for placing additional staff
among its regions and zones.
Response: DHS concurs. The USCG agrees that using a disciplined and
documented strategic approach to making staffing allocation decisions
is important and that CRD has done this. Specifically, CRD provided
the GAO audit team numerous documents showing the analyses it
undertook and the high-priority factors it established in billet
placement.
Examples include:
* Staffing Ratios: A table depicting the current and future ratio of
Civil Rights Service Providers to U.S. Coast Guard workforce across 3
regions and 14 zones.
* Geography: A document depicting the geographic location of Coast
Guard's workforce, and coverage areas by region and zone (i.e., cross-
populated with the location of existing CRD staff). This document also
depicted another important factor that CRD took into consideration
specifically the distance Career Retention Screening Panels must
travel in order to service personnel within their areas of
responsibility.
* Workload Projection: A longitudinal analyses of informal and formal
complaint activity over successive years and by geography.
* Billet Placement Plan: An analysis dated October 30, 2010, entitled,
Geographical Alignment Billet Plan based on Workload Analysis:
Indication of 37 Billets, which depicts the overall schema for
placement of billets identified in the workload analysis. The plan
also depicts the priority designation for 12 billets already sourced.
In addition, many other CRD workforce reorganization-related documents
exist that illustrate USCG efforts to promote transparency, of which
GAO may not be fully aware. Examples include:
* Memo dated November 2010: Request Approval To Make Organizational
Adjustments.
* Memo dated December 14, 2010: Amendment To Organizational Adjustments
Request.
* Digest dated March 21 2011 : Civil Rights Program Position
Establishment.
* Memo dated March 31, 2011: Organization Modification Request.
In May 2011, CRD also created another internal document that further
summarizes its consideration of the foregoing factors, adds to the
related documentation already on file, and supplements USCG efforts to
promote transparency of its decision-making processes.
Recommendation 2: Implement a centralized system for CRSP training
records that provides design specifications with associated
implementation milestones and that aligns with internal control
standards for data tracking, monitoring, and reporting.
Response: DHS concurs. The USCG currently tracks Equal Employment
Opportunity (EEO) Counselor Training using an Excel spreadsheet. The
small number of personnel affected and infrequent training cycle time
facilitate ease of data collection via this method. In addition to the
Excel spreadsheet, upon approval and action by FORCECOM, the CRD plans
to utilize the Training Management Tool, the Coast Guard's enterprise-
wide training, qualification, and certification data reporting system.
When inclusion of EEO counselors is approved and implemented, this Web-
based application should enable CRD Regional Managers to validate
training completion within their staffs on a real-time basis, thus far
exceeding the requirement of annual assurance. Of note, the CRD
recently updated its EEO Counselor Training Spreadsheet and can
confirm that all EEO Counselors completed the required 8-hour EEO
Counselor annual refresher training.
Again, thank you for the opportunity to review and comment on this
draft report. Technical comments have been submitted under separate
cover. We look forward to working with you on future Homeland Security
engagements.
Sincerely,
Signed by:
Jim H. Crumpacker:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix III: Contact and Staff Acknowledgments:
GAO Contact:
Yvonne D. Jones, (202) 512-6806 or jonesy@gao.gov.
Staff Acknowledgments:
In addition to the contact named above, individuals making key
contributions to this report included Neil A. Pinney, Assistant
Director; Cheri Y. Truett, Analyst-In-Charge, Irina Carnevale; Robert
Gebhart; Angela Leventis; Lois Hanshaw; and Terry Richardson.
[End of section]
Footnotes:
[1] GAO, 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, [hyperlink,
http://www.gao.gov/products/GAO-10-571T] (Washington, D.C.: Apr. 27,
2010).
[2] Booz Allen Hamilton, U.S. Coast Guard Office of Civil Rights
Program Review, (2009).
[3] According to USCG, collateral duty is assigned to an individual by
the commanding officer, which is in addition to the individual's
primary duty. These duties are normally performed at the individual's
permanent duty station.
[4] The briefing slides in appendix I contain some updates made
subsequent to the May briefing to enhance technical accuracy.
[5] The Equal Employment Opportunity Commission's Management Directive
715, or 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.
[6] According to USCG, a billet is the authorization for a full-time
military person. While the parallel civilian term is referred to as a
position, CRD officials told us that they use the terms
interchangeably to refer to a full-time staff person.
[7] As of April 2011, there were 45 CRSP positions, of which 5 were
vacant.
[8] EEOC Management Directive (MD) 110 provides policy guidance that
describes in detail the procedures that must be followed when
processing complaints of discrimination filed by federal employees and
applicants for federal employment alleging employment discrimination
under 29 C.F.R. part 1614, as amended.
[9] [hyperlink, http://www.gao.gov/products/GAO-10-571T].
[10] 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).
[11] EEOC Management Directive (MD) 110.
[12] See Chapter 2 of EEOC MD-110.
[13] The February 2009 BAH report found similar deficiencies with CRSP
training records.
[14] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[15] In addition to training, CRD officials cited other ways, such as
management and EEOC review of CRSP complaint reports, to ensure
quality service.
[16] EEOC Management Directive (MD) 110 provides policy guidance that
describes in detail the procedures that must be followed when
processing complaints of discrimination filed by federal employees and
applicants for federal employment alleging employment discrimination
under 29 C.F.R. part 1614, as amended.
[17] According to USCG, collateral duty is assigned to an individual
by the commending officer and is in addition to the individual's
primary duty. These duties are normally performed at the individual's
permanent duty station.
[18] We did not conduct an independent assessment of BAH's work.
[19] BAH did not include the key tasks and required level of staffing
at the headquarters level in its analysis.
[20] CRD provided us documents, for example, on CRD's geographic
realignment as well as staffing, field operations, and complaint data.
[21] GAO, 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, [hyperlink,
http://www.gao.gov/products/GAO-10-571T] (Washington, D.C.: Apr. 27,
2010).
[22] According to CRD officials, military CRSPs serve a 4-year
rotational assignment, with a possible 2-year extension, while
civilian CRSPs have no such rotational requirement.
[23] 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).
[24] GAO, Human Capital: Key Principles for Effective Strategic
Workforce Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39]
(Washington, D.C.: December 2003) and GAO, A Model of Strategic Human
Capital Management, GAO-02-373SP (Washington, D.C.: March 2002).
[25] MD-110 provides policy guidance that describes in detail the
procedures that must be followed when processing complaints of
discrimination filed by federal employees and applicants for federal
employment alleging employment discrimination under 29 C.F.R. part
1614, as amended.
[26] The February 2009 BAH report found similar deficiencies with CRSP
training records.
[27] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[28] GAO, Performance Plans — Selected Approaches for Verification and
Validation of Agency Performance Information, [hyperlink,
http://www.gao.gov/products/GAO/GGD-99-139 (Washington, D.C.: July
19991.
[29] As of April 2011, there were 45 CRSP positions, of which 5 were
vacant.
[30] Because respondents were selected based on a nonprobability
sample, the results cannot be generalized to all CRSPs.
[31] In addition to training, CRD officials cited other ways, such as
management and EEOC review of CRSP complaint reports, to ensure
quality service.
[32] 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.
[End of section]
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