Recommendation: As part of the Equal Employment Opportunity Commission's plans to implement a new data system, the Chair of the Equal Employment Opportunity Commission should assess the feasibility of developing the agency's capacity to systematically analyze retaliation charge data, including the protected activities associated with these charges. (Recommendation 1)

Agency: Equal Employment Opportunity Commission
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Department of Agriculture should direct the Assistant Secretary for Civil Rights to publicize promising practices for Title IX compliance on its websites for their university grantees. (Recommendation 1)

Agency: Department of Agriculture
Status: Open

Comments: USDA agreed with the recommendation. In its March 2020 formal comment letter, the department stated that it will ensure promising practices information is posted to websites for the Office of the Assistant Secretary for Civil Rights (OASCR) and the National Institute of Food and Agriculture. Additionally, a notice will be sent to universities to ensure they are aware the information is available, along with specifics regarding access to the same.

Recommendation: The Secretary of Energy should direct the Director of the Office of Economic Impact and Diversity to publicize promising practices for Title IX compliance on its websites for their university grantees. (Recommendation 2)

Agency: Department of Energy: Office of the Secretary
Status: Open

Comments: DOE agreed with the recommendation. In its February 2020 formal comment letter, the department stated that the Office of Civil Rights and Diversity (OCRD) has identified promising practices on an ongoing basis in its Title IX compliance review reports. OCRD will develop and publicize a promising practices guide on its website for reference by university grantees. The estimated completion date is June 1, 2020. GAO will review this action once it receives documentation from DOE.

Recommendation: The Secretary of the Department of Health and Human Services should direct the Director for the Office for Civil Rights to publicize a stand-alone list of promising practices for Title IX compliance on its websites for their university grantees. (Recommendation 3)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: HHS agreed with the recommendation. In its February 2020 formal comment letter, the department stated the Office for Civil Rights will incorporate effective practices from materials posted on its website and external sources in a stand-alone list of effective practices to help universities comply with Title IX. The Office for Civil Rights will also draw from its Title IX enforcement work to update the effective practices list on an ongoing basis.

Recommendation: The Secretary of Energy should direct the Director of the Office of Economic Impact and Diversity to finalize and publish Title IX complaint procedures, consistent with DOJ's regulations. (Recommendation 4)

Agency: Department of Energy: Office of the Secretary
Status: Open

Comments: DOE agreed with the recommendation. In its February 2020 formal comment letter, the department stated that the Office of Civil Rights and Diversity (OCRD) has developed a draft outline of complaint procedures. OCRD is benchmarking these procedures against NASA and NSF external civil rights complaint procedures. OCRD will finalize and publish Title IX complaint procedures, consistent with the Department of Justice's regulations. The estimated completion date is October 31, 2020.

Recommendation: The Secretary of the Department of Agriculture should direct the Assistant Secretary for Civil Rights to finalize and publish revised Title IX complaint procedures. (Recommendation 5)

Agency: Department of Agriculture
Status: Open

Comments: USDA agreed with the recommendation to finalize and publish Title IX complaint procedures. According to the department's March 2020 formal comment letter, USDA's Departmental Regulation (DR) 4330-002, Nondiscrimination in Program and Activities Receiving Federal Financial Assistance from USDA, addresses processing Title IX administrative complaints filed with the Department in any program or activity receiving financial assistance from USDA. The Departmental Regulation (DR) 4330-002 was revised in 2019 and is currently in the clearance process for publication.

Recommendation: The Secretary of the Department of Agriculture should direct the Assistant Secretary for Civil Rights to clarify on its website that individuals on USDA-funded grants can file Title IX complaints through the Assistant Secretary for Civil Rights—including clarifying who is considered "customers." (Recommendation 6)

Agency: Department of Agriculture
Status: Open

Comments: USDA agreed with this recommendation. According to the department's March 2020 formal comment letter, USDA's Office of the Assistant Secretary for Civil Rights (OASCR) will add language on its website to make clear recipients of USDA-funded grants are included in the definition of a customer and, as such, may file Title IX complaints through OASCR. Additionally, the requested information will be added to the Frequently Asked Questions section on OASCR' s website.

Recommendation: The Secretary of the Department of Health and Human Services should direct the Director for the Office for Civil Rights to assess the feasibility of receiving and reviewing concerns of sex discrimination—including sexual harassment—and communicating to individuals on agency-funded grants the option to notify the agency of these concerns, outside of the Title IX complaint process. (Recommendation 7)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: HHS agreed with the recommendation. In its February 2020 formal comment letter, the department stated that outside of the Title IX enforcement process, the Office for Civil Rights updated its sex discrimination web pages to inform persons on how to file complaints of discrimination directly to the Office for Civil Rights, including complaints of sexual harassment. The Office for Civil Rights has also incorporated information about Title IX rights and obligations in outreach material used on university campuses, including information addressing sexual harassment.

Recommendation: The Secretary of Energy should direct the Director of the Office of Economic Impact and Diversity to assess the feasibility of receiving and reviewing concerns of sex discrimination—including sexual harassment—and communicating to individuals on agency-funded grants the option to notify the agency of these concerns, outside of the Title IX complaint process. (Recommendation 8)

Agency: Department of Energy: Office of the Secretary
Status: Open

Comments: DOE agreed with the recommendation. In its February 2020 formal comment letter, the department stated that the Office of Civil Rights and Diversity (OCRD) will evaluate the feasibility of receiving and reviewing concerns of discrimination, including sexual harassment, outside of the Title IX complaint process described in DOE's Title IX regulations, as well as communicating this option to individuals on DOE funded grants. The estimated completion date is December 31, 2020.

Recommendation: The Administrator of NASA should assess the feasibility of receiving and reviewing concerns of sex discrimination—including sexual harassment—and communicating to individuals on agency-funded grants the option to notify the agency of these concerns, outside of the Title IX complaint process. (Recommendation 9)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with the recommendation. According to the agency's February 2020 formal comment letter, NASA plans to assess the feasibility of receiving and reviewing concerns of sex discrimination and harassment and communicating to individuals on agency-funded grants the option to notify the agency of these concerns. In conducting the feasibility assessment, NASA will benchmark with agencies that currently have the capability to receive and review concerns of sex discrimination, including sexual harassment. NASA will also examine internal resources to ensure successful implementation. NASA estimates completion by September 20, 2020.

Recommendation: The Secretary of the Department of Agriculture should direct the Assistant Secretary for Civil Rights to assess the feasibility of receiving and reviewing concerns of sex discrimination—including sexual harassment—and communicating to individuals on agency-funded grants the option to notify the agency of these concerns, outside of the Title IX complaint process. (Recommendation 10)

Agency: Department of Agriculture
Status: Open

Comments: USDA agreed with this recommendation. According to the department's March 2020 formal comment letter, USDA is to direct the Office of the Assistant Secretary for Civil Rights (OASCR) to assess the feasibility of receiving and reviewing concerns of sex discrimination (including sexual harassment) and including language in agency-funded grants on the option to notify the agency of harassment issues outside of the Title IX complaint process. The Office of the Mission Area Liaison within OASCR will assess the feasibility of creating a tracking system to capture inquiries and concerns outside of the Title IX complaint process. If feasible, the system will serve as a risk assessment tool to identify issues, potential violations, trends, risks, and areas prime for focused compliance review, according to USDA's formal comment letter.

Recommendation: The Secretary of the Department of Health and Human Services should direct the Director for the Office for Civil Rights and the Director of NIH to develop and implement formal procedures for sharing relevant information about Title IX (compliance reviews, violations, and complaints) and sex discrimination concerns, including sexual harassment. For example, HHS components should internally share information regarding findings of Title IX violations, concerns of sex discrimination, including sexual harassment, and Title IX compliance review reports. (Recommendation 11)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: HHS agreed with the recommendation. In its February 2020 formal comment letter, the department stated that the Office for Civil Rights and NIH will review the current procedure for sharing information, and development and implement (as necessary) formal procedures for sharing relevant information about Title IX and sexual harassment concerns. Furthermore, an action plan to address the recommendation will be provided in the department's 180-day letter response to Congress.

Recommendation: The Secretary of Energy should establish goals and an overall plan to assess all of the agency's sexual harassment prevention efforts for their university grantees, including methods to regularly monitor and evaluate its sexual harassment prevention policies and communication mechanisms (e.g. Title IX or sex discrimination websites). (Recommendation 12)

Agency: Department of Energy: Office of the Secretary
Status: Open

Comments: DOE agreed with the recommendation. In its February 2020 formal comment letter, the department stated that the Office of Civil Rights and Diversity will conduct research into best practices for harassment prevention efforts for university grantees and benchmark with other federal agencies. The estimated completion date for establishment of goals is January 31, 2021 and the estimated completion date for establishment of an overall plan is August 31, 2021.

Recommendation: The Secretary of the Department of Health and Human Services should establish goals and an overall plan to assess all of the agency's sexual harassment prevention efforts for their university grantees, including methods to regularly monitor and evaluate its sexual harassment prevention policies and communication mechanisms (e.g. Title IX or sex discrimination websites). (Recommendation 13)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: HHS agreed with the recommendation. In its February 2020 formal comment letter, the department stated that NIH has created goals for all NIH grantee sexual harassment prevention efforts, as noted in GAO's report. NIH will develop a plan to assess progress towards achieving those goals, including methods to regularly monitor and evaluate policies and communication methods. To the extent Title IX enforcement and outreach efforts may prevent sexual harassment, the Office for Civil Rights will develop a plan for leveraging enforcement efforts and outreach communications to help HHS grantees implement prevention efforts. HHS will submit an action plan that fully address department efforts regarding this recommendation in its 180-day letter response to Congress.

Recommendation: The Administrator of NASA should establish goals and an overall plan to assess all of the agency's sexual harassment prevention efforts for their university grantees, including methods to regularly monitor and evaluate its sexual harassment prevention policies and communication mechanisms (e.g. Title IX or sex discrimination websites). (Recommendation 14)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA agreed with the recommendation. According to the agency's February 2020 formal comment letter, NASA accepts its responsibility to establish policies and communication mechanisms to help university grantees to prevent sexual harassment, and the agency is committed to ongoing monitoring and evaluation of these efforts. At the same time, NASA judges that the most effective way to discharge these responsibilities is to adopt the approach now being developed by the National Science and Technology Council. NASA will establish goals, plans, and methods pursuant to this recommendation by adopting the policies and approaches developed through the interagency process. The estimated completion is to be determined based on timelines and milestones established by the Office of Science and Technology Policy's Safe and Inclusive Research Environments Subcommittee Subcommittee.

Recommendation: The Director of NSF should establish goals and an overall plan to assess all of the agency's sexual harassment prevention efforts for their university grantees, including methods to regularly monitor and evaluate its sexual harassment prevention policies and communication mechanisms (e.g. Title IX or sex discrimination websites). (Recommendation 15)

Agency: National Science Foundation
Status: Open

Comments: NSF agreed with the recommendation. According to the agency's February 2020 formal comment letter, NSF is embarking on an assessment process to improve its policies and practices continually in order to achieve the goal of safe and inclusive research environments.

Recommendation: The Secretary of the Department of Agriculture should establish goals and an overall plan to assess all of the agency's sexual harassment prevention efforts for their university grantees, including methods to regularly monitor and evaluate its sexual harassment prevention policies and communication mechanisms (e.g. Title IX or sex discrimination websites). (Recommendation 16)

Agency: Department of Agriculture
Status: Open

Comments: USDA agreed with this recommendation. According to the department's March 2020 formal comment letter, USDA will consider developing language to include in university grantees' terms and conditions regarding allegations of sexual harassment. Additionally, the Office of the Assistant Secretary for Civil Rights (OASCR) will reach out to other agencies within the Title IX Quarterly Working Group to assess best practices for monitoring and evaluating sexual harassment prevention policies and communication mechanisms. Finally, USDA will increase its communication with university grantees and increase oversight through compliance reviews.

Recommendation: In consultation with DOE, HHS, NASA, NSF, and USDA, the Assistant Attorney General for the Department of Justice should direct the responsible Civil Rights Division sections to fully adopt two federal interagency leading practices—agree on agency's roles and responsibilities and develop mechanisms to monitor, evaluate, and report results of collaborative efforts, for its Quarterly Title IX STEM discussion group. (Recommendation 17)

Agency: Department of Justice: Office of the Assistant Attorney General for Administration
Status: Open

Comments: DOJ generally agreed with the recommendation. According to the department's February 2020 formal comment letter, the Civil Rights Division (CRT) is prepared to delineate agencies' roles and responsibilities within the Quarterly Title IX STEM Discussion Group and is willing to develop an enhanced process for evaluating, monitoring, and reporting on the group's collaborations in enforcing Title IX that is achievable within DOJ's current resource allocation, or if more resources become available.

Recommendation: The Executive Director of OCWR, in collaboration with relevant managers, should establish a policy that requires a schedule of tasks to be developed, documented, and updated throughout the lifetime of IT system projects. (Recommendation 1)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: The agency agreed with the recommendation. OCWR officials stated that they will be implementing a policy to ensure that project planning steps, including a schedule of tasks, will be included and documented for future IT projects.

Recommendation: The Executive Director of OCWR should identify and assess risks in establishing and maintaining a permanent records retention program, and develop policies and procedures to ensure that risks are properly addressed. (Recommendation 2)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: The agency agreed with the recommendation. OCWR officials stated that they have hired a contractor to assist with various risk management activities related to OCWR's permanent records retention program, including identifying and assessing risks and developing policies and procedures to address any risks.

Recommendation: The Executive Director of OCWR should identify desired performance results, develop performance measures that demonstrate the degree to which the desired results were achieved, and report progress toward those results in OCWR's annual reports. (Recommendation 3)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: The agency agreed with the recommendation. OCWR officials stated that they are reassessing desired performance results, developing new performance measures to monitor progress towards those results, and will clearly report OCWR's progress in future annual reports.

Recommendation: The Executive Director of OCWR should collect relevant data through a survey or other mechanisms, and use the information to evaluate the effectiveness of education and outreach efforts and the extent to which they are reaching all covered legislative branch populations. (Recommendation 4)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: The agency agreed with the recommendation. According to OCWR officials, they are working with congressional oversight committees and covered legislative branch offices to obtain data through surveys or other methods that will enable them to evaluate the effectiveness and coverage of OCWR's education and outreach efforts.

Recommendation: The Executive Director of OCWR should integrate IT planning and implementation into the agency's strategic planning process. (Recommendation 5)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: The agency agreed with the recommendation. OCWR officials stated that they intend to revise the agency's strategic plan, including integrating IT planning and implementation into the strategic planning process, after they gain more experience with the new procedures required by the Congressional Accountability Act (CAA) Reform Act of 2018.

Recommendation: The Executive Director of OCWR should incorporate key strategic human capital management practices, such as developing strategies to recruit and retain staff with mission-critical skills, into the strategic planning process. (Recommendation 6)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: The agency agreed with the recommendation. OCWR officials reported that they hired a contractor to better incorporate key management practices, such as developing strategies for recruiting and retaining staff with mission-critical skills, into OCWR's human capital plan and strategic planning process.

Recommendation: The Department of Education's Assistant Secretary for Civil Rights should determine the extent to which Title IX coordinators at the K-12 level are aware of and using the tools recommended in OCR's existing guidance and any barriers preventing their use of this guidance, and use this information in OCR's efforts to encourage them to work with athletics administrators on ensuring equal athletic opportunities. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: In November 2018, the Office for Civil Rights sent an e-mail to its Regional Directors to inform them of GAO's report, remind them of the importance of coordination between Title IX coordinators and athletics administrators, and encourage them to look for opportunities in their investigations and compliance work to examine the role of Title IX coordinators at the K-12 level. Agency officials also said they sent a letter to Title IX coordinators reminding them of the tools available to them under Title IX. While these are important first steps, as we noted in our report, we continue to believe the systemic approach we recommended is necessary. We are working with Education to obtain updated information, and will close the recommendation if Education demonstrates that any of these steps results in obtaining new information about the extent to which K-12 Title IX coordinators are aware of and using existing Title IX tools, and any barriers they face in doing so, and that they have used this information to inform their work with Title IX coordinators.

Recommendation: The Chair of the EEOC should develop a timeline to complete the planned effort to clean Integrated Mission System data for a one-year period and add missing industry code data. (Recommendation 1)

Agency: Equal Employment Opportunity Commission
Status: Open

Comments: As part of an effort to overhaul its IMS data system, EEOC has begun developing an Employer Master List that will provide a source of employer information, including industry codes, but EEOC told us that it has not yet completed this effort. It anticipates this system will be more fully developed by spring 2020. It is important for EEOC to collect sufficient information through its Employer Master List and use it to analyze charge data by industry.

Recommendation: The Director of OFCCP should analyze internal process data from closed evaluations to better understand the cause of delays that occur during compliance evaluations and make changes accordingly. (Recommendation 2)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: In June 2019, OFCCP officials reported that OFCCP's procedures outlined in the Active Case Enforcement Directive (DIR 2011-01) caused delays in case closures, but OFCCP did not indicate that this conclusion resulted from the recommended analysis of internal process data from closed evaluations. OFCCP officials reported that the agency's aged case rate-defined as a case which is open for more than 730 days and has not been referred for further enforcement-has dropped from 27.7 percent in fiscal year 2017 to 20.9 percent in fiscal year 2019. However, it did not report on changes in case outcomes. In September 2019, OFCCP officials told us they continue to look for ways to address delays with effective policies that make the agency more efficient. We maintain that OFCCP should determine the root causes of delays based on data analysis of actual evaluations to demonstrate that its policy changes are accurately targeting the causes of these delays.

Recommendation: The Director of OFCCP should assess the quality of the methods used by OFCCP to incorporate consideration of disparities by industry into its process for selecting contractor establishments for compliance evaluation. It should use the results of this assessment in finalizing its procedures for identifying contractor establishments at greatest risk of noncompliance. (Recommendation 4)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: In its agency response to our November 2017 report, OFCCP officials reported that the agency was exploring the use of U.S. Census Bureau and administrative data to refine its selection process to focus on industries with a greater likelihood of noncompliance. In January 2019, DOL officials reported that DOL had revised its scheduling methodology to include industries with the highest rates of violations. OFCCP published the scheduling list in March 2019 and its field offices started scheduling cases in May 2019. OFCCP stated it will continue to monitor results from this revised scheduling methodology to determine its effectiveness. It will be important for OFCCP to refine these methods based on its experiences with them. This new process is a step toward focusing efforts on industries at greater risk of potential noncompliance with nondiscrimination or affirmative action requirements. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Director of OFCCP should evaluate the current approach used for identifying entities for compliance review and determine whether modifications are needed to reflect current workplace structures and locations or to ensure that subcontractors are included. (Recommendation 5)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: In fiscal year 2019, OFCCP evaluated its current approach for identifying subcontractors for review. OFCCP stated that the current approach does not reliably include subcontractors in the pool from which contractors are scheduled because there is no government or public database that captures the complete universe of subcontractors and other important data. In June 2019, OFCCP submitted revisions to its process to the Office of Management and Budget (OMB) for approval. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Director of OFCCP should evaluate the Functional Affirmative Action Program to assess its usefulness as an effective alternative to an establishment-based program, and determine what improvements, if any, could be made to better encourage contractor participation. (Recommendation 6)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: OFCCP has taken steps to encourage contractors to use the FAAP program without fully evaluating it as an alternative to the establishment-based program. Evaluating the FAAP could help OFCCP improve its ability to achieve its objectives and may provide broader insight for OFCCP's overall enforcement approach. We will consider closing this recommendation when these efforts are complete.

Recommendation: To improve leadership's commitment to preventing and responding to incidents of sexual harassment, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to develop a strategy for holding individuals in positions of leadership accountable for promoting, supporting, and enforcing the department's sexual harassment policies and programs.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with our recommendation and stated that leadership accountability is essential to the success of the department's efforts to prevent sexual harassment. In February 2018, DOD took action toward addressing this recommendation and released an update to DOD Instruction 1020.03, Harassment Prevention and Response in the Armed Forces, that directs the Director, Office of Diversity Management and Equal Opportunity (ODMEO), to ensure that DOD components' harassment prevention and response programs incorporate, at a minimum, compliance standards for promoting, supporting, and enforcing polices, plans, and programs. The updated instruction also directs the Commandant, Defense Equal Opportunity Management Institute (DEOMI), to tailor training materials to servicemember professional development levels and associated leadership duties and responsibilities. As of February 2020, DOD had not completed development of the compliance standards or training materials. We will monitor DOD actions on this issue.

Recommendation: To improve implementation of the department's sexual harassment policies and programs, the Secretary of Defense should direct the service secretaries to verify or track military commanders' compliance with existing requirements that commanders periodically determine their organizational health and functioning effectiveness by periodically assessing their equal opportunity climate through "command climate" assessments.

Agency: Department of Defense
Status: Open

Comments: DOD has updated its guidance on sexual harassment, including a requirement for sharing the results of command climate assessments with the next higher level of command, but has not yet implemented an oversight mechanism to verify and track commanders' compliance with requirements to conduct such assessments. DOD concurred with this recommendation and stated that it would implement the recommendation through revisions to its guidance. According to DOD, a 2013 memorandum from the Secretary of Defense on sexual assault prevention and response outlined requirements addressing leadership accountability for preventing sexual harassment. The memorandum included a requirement that the results of command climate surveys be provided to the next level up in the chain of command, and it directed service chiefs, through their respective military department secretaries, to develop methods to assess the performance of commanders in establishing command climates of dignity and respect. The Secretary of Defense also issued a memorandum addressing prevention and response of sexual harassment in 2014, and DOD updated its guidance on sexual harassment in 2015. In 2016, DOD stated that further revisions to guidance were forthcoming to provide a framework for oversight of sexual harassment. This framework, among other things, would address standards for holding leaders accountable for promoting, supporting, and enforcing sexual harassment policies. DOD issued a new DOD Instruction 1020.03, Harassment Prevention and Response in the Armed Forces, in February 2018 but has not implemented an oversight framework as of February 2020. We will continue to monitor DOD's actions.

Recommendation: To enhance oversight of the department's program to help prevent and to address incidents of sexual harassment involving servicemembers, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to ensure that the Office of Diversity Management and Equal Opportunity develops and aggressively implements an oversight framework to help guide the department's efforts. At a minimum, such a framework should contain long-term goals, objectives, and milestones; strategies to accomplish goals; criteria for measuring progress; and results-oriented performance measures to assess the effectiveness of the department's sexual harassment policies and programs. Such a framework should also identify and include a plan for ensuring that adequate resources are available to carry out the office's oversight responsibilities.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with our recommendation and stated that as part of its revised guidance it proposed to strengthen and institutionalize the responsibilities and authorities needed for successful implementation of the department's sexual harassment policies. In February 2018, DOD took action toward addressing this recommendation and issued an update to DOD Instruction 1020.03, Harassment Prevention and Response in the Armed Forces, that directs the Director, Office of Diversity Management and Equal Opportunity, to ensure that DOD components' harassment prevention and response programs incorporate , at a minimum, (1) long-term goals, objectives, and milestones; (2) results-oriented performance measures to assess effectiveness; and (3) compliance standards for promoting, supporting, and enforcing policies, plans, and programs. As of February 2020, DOD has not developed and aggressively implemented an oversight framework, as we recommended. We will continue to monitor DOD's actions.