United States

Department of

Agriculture

Civil Rights 

Implementation 

Team

September 1997

Implementation 

of the Civil Rights

Action Team Report

at USDA

An Interim Progress Report 
BLANK PAGE—Inside Front Cover
1 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

Implementation 

of the Civil Rights Action

Team Report at USDA

An Interim Progress Report

Contents

Message from Secretary Dan Glickman ........................................................ 2

Executive Summary ....................................................................................... 3

Status of Implementation, by Recommendation ...................................... 7

Lack of Management Commitment to Civil Rights ...............................7

Program Delivery and Outreach .......................................................... 13

Work Force Diversity and Employment Practices .............................. 28

Organizational Structure of Civil Rights ............................................. 33

Abbreviations .............................................................................................. 39
Six months ago, USDA embarked on an ambitious effort to change 

the way we do business to ensure that every employee treats 

every customer and co-worker fairly and equitably, with dignity 

and respect.

Tens of thousands of staff hours later, we have come a long way toward

achieving that goal: We’re holding employees up and down our ranks personally accountable for being a part of the solution; instituting a zero-tolerance

reprisal policy to protect workers who stand up for their rights; changing our

foreclosure and lending policies to root out discrimination; settling proven

cases of wrongdoing, and moving to investigate and resolve others; reaching

out more to underserved populations; and hiring a full-time cadre of civil

rights advocates for our legal team.

And that is only a partial list of our accomplishments. 

I am proud of how far we have come in six short months, but amid all this

progress, one thing is clear: We have a long way to go. 

This report serves as a reality check. It gives us a better understanding of

just how much time, effort, commitment and leadership it’s going to take —

from every USDA employee, from Congress, and from the agriculture community — to institutionalize the changes underway. 

We will not fix a decades-old problem overnight. But we are taking steps

every day toward putting a history of discrimination behind us, and turning

USDA into the federal civil rights leader. USDA will reach that day, not

because of the leadership of a few people, but because the vast majority of

our employees take this effort seriously. 

This is my 6-month progress report on the implementation of the 92 recommendations contained in “Civil Rights at the United States Department of

Agriculture — A Report by the Civil Rights Action Team.”

I work every day with committed public servants — across the country and

in Washington — who take great pride in America, its ideals, and the work of

“the people’s department.” Their commitment will prevail, and we will succeed in building a USDA that reflects and respects our country’s diversity, a

USDA that can best serve agriculture and our Nation in the 21st Century.

Dan Glickman

2 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

Message from Secretary

Dan Glickman

?O@K W2@@@@@@@@@6K? ?O&@@@@@@@@@@@@6K? O2@@@@@@@@@@@@@@@@@@ ?O2@@@@@@@6K W2@@@@@@@@@@@@@@@@@@@@ ?O2@@@@@@@@@@@6X ?W&@@@@@@@@@@@@@@@@@@@@@@@ ?W2@@@@@@@@@@@@@@1 O&@@@@@@@@0Mf?I'@@@@@@@L? W&@@@@@@@@@@@@@@@@ W2@@@@@@@(M?hV'@@@@@@1? ?W&@@@@@@@@@@@@@@@@@ ?W&@@@@@@@(Yhe?V'@@@@@@L W&@@@@@@@@0M?I'@@@@@ W&@@@@@@@0Y?hfN@@@@@@1 ?O2@@@@? ?O&@@@@@@(M?fN@@@@@ 7@@@@@@(M? ?3@@@@@@ ?W2@@@@@5? ?W2@@@@@@@0Yg?@@@@@ ?J@@@@@@(Y ?N@@@@@@L? O&@@@@@@H? W&@@@@@@(Mh?@@@@@ W&@@@@@(Y? 3@@@@@1? ?O2@@@@@@@@5 ?W&@@@@@@(Y?h?@@@@@ ?W&@@@@@(Y N@@@@@@? ?W2@@@@@@@@@(Y W&@@@@@@(YheJ@@@@@ W&@@@@@(Y? ?@@@@@@? O&@@@@@@@@@0Y? ?W&@@@@@@(Y?he7@@@@5 7@@@@@(Y ?@@@@@@? ?O2@@@@@@@@@@0M? W&@@@@@@(Yhf@@@@@H ?J@@@@@(Y? ?@@@@@@?hf?O2@@@@@@@@@@0M? ?W&@@@@@@(Y?hf@@@@@? W&@@@@(Y ?@@@@@@?he?W2@@@@@@@@@@0M? W&@@@@@@(Y @@@@@? 7@@@@@H? ?@@@@@5?heO&@@@@@@@@@0M? ?W&@@@@@@(Y?hf?J@@@@5? ?J@@@@@5 ?@@@@@H?hO2@@@@@@@@@0M? ?7@@@@@@(Y ?7@@@@H? W&@@@@(Y ?@@@@@hO2@@@@@@@@@0M? J@@@@@@(Y? ?@@@@@ ?W&@@@@@H? ?@@@@@gO2@@@@@@@@@0M? ?W&@@@@@(Y ?@@@@@ ?7@@@@@5 ?@@@@@fW2@@@@@@@@(M W&@@@@@(Y? J@@@@5 J@@@@@(Y ?@@@@@e?O&@@@@@@@@0Y? ?W&@@@@@(Y 7@@@@H 7@@@@@H? J@@@@@?O2@@@@@@@@0M? ?7@@@@@(Y? @@@@@? ?J@@@@@5 7@@@@@@@@@@@@@@(M? J@@@@@(Y ?J@@@@5? W&@@@@(Y @@@@@@@@@@@@@@0Y ?W&@@@@@H? ?7@@@@H? 7@@@@@H? @@@@@@@@@@@@0M W&@@@@@5 ?@@@@@ ?J@@@@@5 @@@@@@@@@@(M 7@@@@@(Y J@@@@5 W&@@@@(Y @@@@@@@@@0Y? ?J@@@@@(Y? 7@@@@H 7@@@@@H? ?J@@@@@@@(M? W&@@@@@H @@@@@? ?J@@@@@5 W&@@@@@@(Y 7@@@@@5? ?J@@@@5? ?7@@@@(Y ?O&@@@@@@(Y? ?J@@@@@(Y? ?7@@@@H? J@@@@@H? ?W2@@@@@@@(Y ?7@@@@@H ?@@@@@ 7@@@@5 W&@@@@@@@@H? J@@@@@5? J@@@@5 ?J@@@@@HhW26K ?W&@@@@@@@@5 7@@@@(Y? 7@@@@H W&@@@@5?g?W&@@@@? W&@@@@@@@@@H ?J@@@@@H ?J@@@@@? 7@@@@@H?g?7@@@@5?hf?W&@@@@@@@@@@? ?7@@@@5? ?7@@@@5? ?W2@@@@@@@ ?J@@@@@5hJ@@@@@H?hfW&@@@@@@@@@@@? J@@@@@H? J@@@@@H? W&@@@@@@@@

?7@@@@@Hg?W&@@@@@ 7@@@@@@@@@@@5? ?W&@@@@5 7@@@@5 ?W&@@@@@@@@@ ?@@@@@5?gW&@@@@@5 @@@@@(Y@@@@@H? ?7@@@@@H ?J@@@@@H W&@@@@@@@@@@ J@@@@@H?g7@@@@@(YheW2@@@@@@(YJ@@@@@ J@@@@@5? ?7@@@@5? ?W&@@@@@@@@@@@ 7@@@@5g?J@@@@@(Y?h?W&@@@@@@(Y?7@@@@@ 7@@@@@H? J@@@@@H? W&@@@@@@@@@@@@ ?J@@@@@HgW&@@@@@Hhe?7@@@@@@(Ye@@@@@5 @@@@@5 7@@@@5 7@@@@@@@X@@@@@ ?7@@@@5?f?W&@@@@@5?heJ@@@@@@(Y?e@@@@@H ?J@@@@@H ?J@@@@@H ?J@@@@@(MB@@@@@@ J@@@@@H?f?7@@@@@(Y?h?W&@@@@@(Ye?J@@@@@? ?7@@@@@? ?7@@@@5? W&@@@@(Ye@@@@@5hf?W2@@@ 7@@@@5gJ@@@@@(YheW&@@@@@(Y?e?7@@@@@? J@@@@@5? J@@@@@H? 7@@@@@H??J@@@@@HhfW&@@@@ ?J@@@@@Hf?W&@@@@(Y?h?W&@@@@@(Yf?@@@@@5? 7@@@@@H? 7@@@@5 ?J@@@@@5e?7@@@@5?hf7@@@@@L? ?7@@@@@?fW&@@@@@HheW&@@@@@(Y?f?@@@@@H? @@@@@5 ?J@@@@@H W&@@@@(YeJ@@@@@H?hf@@@@@@1? ?@@@@@5?f7@@@@@5?h?W&@@@@@(YgJ@@@@@ ?J@@@@@H ?7@@@@5? 7@@@@@H?e7@@@@5 3@@@@@@L J@@@@@H?e?J@@@@@(Y?hW&@@@@@(Y?g7@@@@5 ?7@@@@@? J@@@@@H? ?J@@@@@5e?J@@@@@H N@@@@@@1 7@@@@@fW&@@@@@Hh?W&@@@@@(Yh@@@@@H ?@@@@@5? 7@@@@5 ?7@@@@@He?7@@@@@? ?@@@@@@@ W-X? ?J@@@@@5f7@@@@@5?hW&@@@@@(Y?g?J@@@@@? ?@@@@@H? ?J@@@@@H J@@@@@5?eJ@@@@@5? ?3@@@@@@L?hf?W&@)X ?7@@@@@He?J@@@@@(Y?g?W&@@@@@(Yh?7@@@@5? J@@@@@ W&@@@@5? 7@@@@(Y?e7@@@@@H? ?N@@@@@@1?hfW&@@@1 ?@@@@@@?eW&@@@@(Yh?7@@@@@@H?h?@@@@@H? 7@@@@@ 7@@@@@H? ?J@@@@@He?J@@@@@5 3@@@@@@?hf7@@@@@ J@@@@@5?e7@@@@@H?hJ@@@@@@5heJ@@@@@ @@@@@5 ?J@@@@@5 ?7@@@@5?e?7@@@@@H N@@@@@@?he?J@@@@@@ 7@@@@@H??J@@@@@5h?W&@@@@@(Yhe7@@@@5 @@@@@H ?7@@@@(Y J@@@@@H?eJ@@@@@5? ?3@@@@@?he?7@@@@@@ @@@@@@e?7@@@@(YhW&@@@@@(Y?he@@@@@H @@@@@? J@@@@@H? 7@@@@5e?W&@@@@@H? ?V'@@@5?heJ@@@@@@5 @@@@@5eJ@@@@@H?h7@@@@@(Yhe?J@@@@@? ?J@@@@@? 7@@@@5 ?J@@@@@He?7@@@@@5 V4@0Y?h?W&@@@@@@H ?J@@@@@H?W&@@@@5h?J@@@@@(Y?he?7@@@@5? ?7@@@@@? ?J@@@@@H ?7@@@@5?eJ@@@@@(Y ?7@@@@@@@? ?7@@@@@??7@@@@@HhW&@@@@@Hhf?@@@@@H? ?@@@@@@? W&@@@@5? J@@@@@H?e7@@@@@H? J@@@@@@@5? ?@@@@@@?J@@@@@5?g?W&@@@@@5?hfJ@@@@@ ?@@@@@@? 7@@@@@H? 7@@@@5e?J@@@@@5 ?W&@@@@@@@H? ?@@@@@5?7@@@@@H?g?7@@@@@(Y?hf7@@@@5 ?@@@@@@? ?J@@@@@5 @@@@@HeW&@@@@@H ?7@@@@@@@@ J@@@@@HJ@@@@@5hJ@@@@@(Y @@@@@H ?@@@@@@? ?7@@@@@H ?J@@@@5?e7@@@@@5? J@@@@@@@@5

7@@@@@?7@@@@@Hg?W&@@@@(Y?hf?J@@@@@? ?@@@@@@? J@@@@@5? ?7@@@@H??J@@@@@@H? 7@@@@@@@@H @@@@@@?@@@@@5?gW&@@@@@H ?7@@@@5?fW2@@@@6K ?@@@@@@? 7@@@@(Y? J@@@@@eW&@@@@@5 ?J@@@@@@@@@? @@@@@@@@@@@@H?g7@@@@@5? J@@@@@H?e?W&@@@@@@@@? ?@@@@@@? ?J@@@@@H 7@@@@5e7@@@@@(Y ?7@@@@@@@@5? ?J@@@@@?@@@@@5g?J@@@@@(Y? 7@@@@5fO&@@@@@@@@@L ?@@@@@@L ?7@@@@5? ?J@@@@@H?J@@@@@@H? J@@@@@@@@@H? ?7@@@@@?@@@@@HgW&@@@@@H ?J@@@@@HeW2@@@@@@@@@@@1 ?@@@@@@1 J@@@@@H? ?7@@@@@?W&@@@@@5 ?W&@@@@@@@@@ ?@@@@@@@@@@@5?g7@@@@@5? ?7@@@@@?e7@@@@@@@@@@@@@ ?3@@@@@@L?hf7@@@@5 ?@@@@@@T&@@@@@(Y ?7@@@@@@@@@@ ?@@@@@@@@@@@H?f?J@@@@@(Y? ?@@@@@5??J@@@@@@@@@@@@@@ ?N@@@@@@1?he?J@@@@@HeO2@@@@ ?@@@@@V@@@@@@(Y? J@@@@@@@@@@5 ?@@@@@@@@@@@gW&@@@@@H J@@@@@H?W&@@@@@@@@@@@@@5 @@@@@@@LheW&@@@@5?W2@@@@@@ J@@@@@?@@@@@(Y 7@@@@@@@@@@Hh?O2@6X ?@@@@? J@@@@@@@@@@5g7@@@@@5? 7@@@@5?W&@@@@@@@@@@@@@@H 3@@@@@@)K?h7@@@@@YO&@@@@@@@ 7@@@@@@@@@@@H? ?J@@@@@@@@@@@?e?W2@@@@@@@@1 @@@? 7@@@@@@@@@@Hf?J@@@@@(Y? ?J@@@@@HW&@@@@@@@@@@@@@@5?e@@6X V'@@@@@@@6K?f?J@@@@@@@@@@@@@@@@ @@@@@@@@@@@5 ?7@@@@@@@@@@5?eW&@@@@@@@@@5 ?7@@@? @@@@@@@@@@5?f?7@@@@(Y ?7@@@@@W&@@@@@@X@@@@@@@@H??J@@@)X? ?N@@@@@@@@@@6?@KO&@@@@@@@@@@@@@@@@ ?J@@@@@@@@@@(Y J@@@@@@@@@@@H??W&@@@@@@@@@@H J@@@@? @@@@@@@@@@H?fJ@@@@@H? ?@@@@@@@@@@@@@>@@@@@@@@5eW&@@@@)? @@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@5 ?7@@@@@@@@@@H? ?W&@@@@@?@@@@@eW&@@@@@@@@@@@?f?O26X? W26?@? 7@@@@? @@@@@@@@@@f?W&@@@@5 J@@@@@?@@@@@@>@@@@@@@@@H?W&@@@@@H? ?I'@@@@@@@@@@@@@@@@@@@@@@@@@@@@H ?@@@@@@@@@@5 ?7@@@@@@@@@@@5e7@@@@@@@@@@@5?e?O2@@@)X ?W&@@@@? @@@@@? @@@@@@@@@5f?7@@@@@H 7@@@@@@@@@@@V@@@@@@@@@@?W&@@@@@@ V'@@@@@@@@@@@@@@@@@@@@@@@@@@5? ?@@@@@@@@@(Y J@@@@@(Y@@@@@H?J@@@@@@@@@@@0Y??W2@@@@@@1 W&@@@@@? ?J@@@@@? @@@@@@@@@HfJ@@@@@5? ?J@@@@@@@@@@@@X@@@@@@@@@5?7@@@@@@@ ?V4@@@@@@@@@@@@@@@@@@@@@@@@@H? ?@@@@@@@@(Y? 7@@@@@HJ@@@@@??7@@@@@?hW&@@@@@@@@ ?W&@@@@@@W@K ?7@@@@@? @@@@@@@@@?f7@@@@(Y? ?7@@@@@@@@@@@>@@@@@@@@@0YJ@@@@@@@5 ?I4@@@@@@@@@@@@@@0M?@@@@@5 J@@@@@@@(Y ?J@@@@@5?7@@@@5?J@@@@@5?g?W&@@@@@@@@@ W&@@@@@@@@@@@? J@@@@@5? @@@@@@@@5?e?J@@@@@H ?@@@@@@@@@@@>@@@@@@@@@eW&@@@@@@@H ?@@@@@@?f?J@@@@@H ?W&@@@@@@(Y? ?7@@@@@H?@@@@@H?7@@@@(Y?gW&@@@@@@@@@@hf?O@Khe?W&@@@@@@@@@@@@? ?W&@@@@@H? @@@@@@@@H?e?7@@@@5? J@@@@@@@@@@V@@@@@@@@@5?W&@@@@@@@@? J@@@@@5?f?7@@@@@? O&@@@@@@(Y J@@@@@5?J@@@@@?J@@@@@Hg?O&@@@@@@@@@@5heW2@@@@@?h?7@@@@@@@@@@@@@? ?7@@@@@5 @@@@@@@5fJ@@@@@H? 7@@@@@@@@@@@@@@@@@@@@HW&@@@@@@@@@? 7@@@@@H?fJ@@@@@5? W2@@@@@@@@H?h?W26K? W2@@@?g7@@@@@H?7@@@@5?7@@@@5?f?W2@@@@@@@@@@@@H?W2@6Ke?W&@@@@@@?hJ@@@@@@@@@@@@@@? J@@@@@@H @@@@@@@Hf7@@@@5 @@@@@@@@@@@@@@@@@@@@@W&@@@@@@@@@5? ?J@@@@@5g7@@@@@H? ?W&@@@@@@@@@heW&@@@@hf?W&@@@@?f?J@@@@@5e@@@@@H?@@@@@H?fW&@@@@@@@@@@@@@?W&@@@@@?W&@@@@@@@?h7@@@@@@@@@@@@@@? 7@@@@@5? 3@@@@@5?e?J@@@@@H ?J@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@H?e?W2@@@6K ?7@@@@@Hg@@@@@5 W&@@@@@@@@@@h?O&@@@@@hfW&@@@@@?fW&@@@@@H?J@@@@@??@@@@@g7@@@@@@@@@@@@@@T&@@@@@@?7@@@@@@@@?g?J@@@@@@@@@@@@@@@?f?O@K ?J@@@@@@H? N@@@@@H?e?7@@@@5? ?7@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@fW&@@@@@@6Khf@@@@ J@@@@@5?g@@@@@H ?O&@@@@@@@@@@@g?O2@@@@@@@he?W&@@@@@@?f7@@@@@5??7@@@@@??@@@@@f?J@@@@@@@@X@@@@@V@@@@@@@@?@@@@@@@@@?g?7@@@@@@@@@@@@@@@?e?W2@@@@? W&@@@@@5 ?3@@@5fJ@@@@@H? J@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@e?W&@@@@@@@@@6Xh?J@@@@ 7@@@@(Y?g@@@@@? ?W2@@@@@@@@@@@@@L?e?W2@@@@@@@@@he?7@@@@@@@?e?J@@@@@(Y??@@@@@5?J@@@@@fW&@@@@@@(R@@@@@@@@@@@@@@@@@@@@@@@@@?gJ@@@@@@@@@@@@@@@@?eW&@@@@@? 7@@@@@(Y ?V4@0Yf7@@@@5 7@@@@@@@@@@@@@@(Y@@@@@@@@@@(Y@@@@@eW&@@@@@@@@@@@)K?gW&@@@@ ?J@@@@@Hg?J@@@@@? O&@@@@@@@@@@@@@@)KeO&@@@@@@@@@@heJ@@@@@@@@?eW&@@@@@He?@@@@@H?7@@@@@e?W&@@@@@@(YJ@@@@@@@@@@@@@@@@@@@@@@@@@?g7@@@@@@@@@@@@@@@5??O&@@@@@@? ?J@@@@@@H? ?J@@@@@H @@@@@V'@@@@@@@(Y?@@@@@@@@@(YJ@@@@@L?7@@@@@@@@@@@@@@6K?e?O&@@@@@ W&@@@@5?g?7@@@@@?hfO2@@@@@@@@(?'@@@@@@@@@@@@@@@@@@@@@h?W&@@@@@@@@?e7@@@@@5?e?@@@@@e@@@@@@eW&@@@@@@(Y?7@@@@@@@@@@@@@@@@@@@@@@@@@?f?J@@@@@@@@@@@@@@@@HW2@@@@@@@@? W&@@@@@5 ?7@@@@@? ?J@@@@@?N@@@@@@0Y??3@@@@@@@(Y?7@@@@@)X@@@@@@@@@@@@@@@@@@@@@@@@@@@5 7@@@@@H?g?@@@@@@LheO2@@@@@@@@@(Y?N@@@@@@@@@@@@@@@@@@@@@hW&@@@@@@@@@??J@@@@@@H?eJ@@@@@e@@@@@@?O&@@@@@@(Y?J@@@@@@@@@@@@@@@@@@@@@@@@@@Lf?7@@@@@@@@@@@@@@@@W&@@@@@@@@@? O@?@K? 7@@@@@(Y J@@@@@5? ?7@@@@5??@@@0Mf?V'@@@@@(Ye3@@@@@@@@@@@@(MI4@@@@@@@@@@@@@@@@@@H ?J@@@@@5h?3@@@@@)K?f?O2@@@@@@@@@@@0Ye?3@@@@@@@@@@@@@@@@@@@@g?W&@@@@@@@@@5?W&@@@@@5f7@@@@5e@@@@@@@@@@@@@@(Ye7@@@@@@@@@@@@@@@@@@@(Y@@@@@1fJ@@@@@@@@@@@X@@@@@@@@@@@@@@@@? O2@@@@@@@@@@@@@@6K ?J@@@@@@H? 7@@@@@H? J@@@@@H?hfV4@@@0Y?eN@@@@@@@@@@@(Ye?I'@@@@@@@@@@@@@@@5? ?7@@@@(Yh?N@@@@@@@@@@6?2@@@@@@@@@@@(Mf?V'@@@@@@@@@@@@@@@@@@@L?fO&@@@@@@@@@@HW&@@@@@(Yf@@@@@He@@@@@@@@@@@@@(Y?e@@@@@@@@@@@@@@@@@@@(Y?@@@@@@L??W&@@@@@@@@@@V@@@@@@@@@@@@@@@@@Lhf?O2@@@@@@@@@@@@@@@@@@@@@@6K? W&@@@@@5 @@@@@5 7@@@@5 ?@@@@@@@@@@(Y?fV4@@@@@@@@@@@@@(Y? J@@@@@H?he3@@@@@@@@@@@@@@@@@@@@@@0Y?gV'@@@@@@@@@0M?@@@@@@)KeO2@@@@@@@@@@@@W&@@@@@@H?f@@@@@?e3@@@@@@@@@@@(Yf@@@@@@@@@@X@@@@@@@(Ye@@@@@@)KO&@@@@@@@@@@5?3@@@@@@@@@@@@@@@@)X?hO2@@@@@@@@@@@@@@@@@@@@@@@@@@@@6Khf?W&@@@@@(Y ?J@@@@@H ?J@@@@@H ?3@@@@@@@@(YhI4@@@@@@@@@@(Y 7@@@@5hfV'@@@@@@@@@@@@@@@@@@@0M?h?V4@@@@@@0M?e3@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@5f@@@@@@@?eN@@@@@@@@@@(Y?e?J@@@@@@@@(R@@@@@@@@H?e3@@@@@@@@@@@@@@@@@@(Y?N@@@@@@@@@@@@@@@@@)KfO2@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@6K?hO&@@@@@@H? ?7@@@@5? ?7@@@@@? ?V'@@@@@@(Y?heI4@@@@@@@0Y? ?J@@@@@Hhf?V'@@@@@@@@@@@@@@@@0M? N@@@@@@@@@@@@@@@@(Y@@@@@@@@@@@(Yf?@@@@@5?e?3@@@@@@@@(Yf?7@@@@@@@0Y?@@@@@@@5fN@@@@@@@@@@@@@@@@@@He?3@@@@@@@@0Y@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@6K?fO2@@@@@@@5 J@@@@@H? J@@@@@5? V'@@@@(Y ?I4@0M ?7@@@@5? V'@@@@@@@@@@@@@0M? ?3@@@@@@@@@@@@@@(Y?@@@@@@@@@@(Y?e?W&@@@@@H?e?V'@@@@@@0Y?f?@@@@@@@f@@@@@@(Yf?3@@@@@@@@@@@@@@@@5?e?V4@@@@@0Me3@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@0?4@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@(Y 7@@@@@ 7@@@@(Y? ?V4@@0Y? J@@@@@H? ?V4@@@@@@@@@@0M? ?V'@@@@@@@@@@@@(Y??@@@@@@@@@@Hf?7@@@@@@gV4@@@0M?g?3@@@@@@f@@@@@(Y?f?V'@@@@@@@@@@@@@@(Y? V'@@@@@@@@@@@@@@@@@@@@@@@0M?heI4@@@@@@@@@@@@@@@@@@@@@@@@@(Y? @@@@@@ ?J@@@@@H 7@@@@5 I@?@M? V4@@@@@@@@@@0Ye?3@@@@@@@@5?f?@@@@@@5 ?V4@@0M?f?I4@0YhV'@@@@@@@@@@@@@H ?V'@@@@@@@@@@@@@@@@@@0M? I4@@@@@@@@@@@@@@@@@@@@(Y ?J@@@@@5 ?7@@@@5? ?J@@@@@H I4@@@@@@0Mf?V'@@@@@@0Y?f?3@@@@@H ?V4@@@@@@@@@@@5? V4@@@@@@@@@@@@@0M? I4@@@@@@@@@@@@@@@@@(Y? ?@@@@@@H J@@@@@H? ?7@@@@5? ?I40M?hV4@@@0M?g?N@@@@5? I'@@@@@(Y? I4@@@@@@@0M? ?I4@@@@@@@@@@@@@0Y @@@@@? 7@@@@5 ?@@@@@H? 3@@@H? ?V4@@@0Y ?I4@@@@@@@@@0M ?7@@@@5? ?J@@@@@H J@@@@5 V4@@ ?I@?@M J@@@@@H? ?7@@@@@? 7@@@@H 7@@@@@ J@@@@@5? ?J@@@@@? @@@@@@ 7@@@@@H? ?7@@@@5? @@@@@@ ?J@@@@@5 ?@@@@@H? @@@@@5 ?7@@@@(Y J@@@@5 ?J@@@@@H J@@@@@H? 7@@@@H ?7@@@@@? ?W&@@@@5 ?J@@@@@? ?@@@@@@? ?7@@@@@H ?7@@@@@? ?@@@@@@? J@@@@@5? ?@@@@@5? ?@@@@@@?hf?W&@@@@@H? ?@@@@@H? ?@@@@@@?hf?7@@@@@5 J@@@@@ ?@@@@@@LhfJ@@@@@(Y 7@@@@@ ?@@@@@@1he?W&@@@@@H? @@@@@5 ?3@@@@@@heW&@@@@@5 @@@@@H ?N@@@@@@L?g?O&@@@@@(Y @@@@@? @@@@@@)Xf?W2@@@@@@(Y? ?J@@@@@? @@@@@@@)K?eO&@@@@@@(Y ?7@@@@@? 3@@@@@@@@@@@@@@@@@@(Y? ?3@@@@5? V'@@@@@@@@@@@@@@@@(Y ?V'@@(Y? ?V'@@@@@@@@@@@@@@(Y? V40Y V'@@@@@@@@@@@@(Y ?V'@@@@@@@@@@0Y? V4@@@@@@@0M? I4@@@0M?
In February 1997, Secretary of Agriculture Dan Glickman accepted the findings of a team that listened to customers and employees from across the

U.S. to find out how well USDA was serving the people and how well they

treated their employees. The findings of their efforts were reported in “Civil

Rights at the United States Department of Agriculture — A Report by the

Civil Rights Action Team.”

Based on the findings, the Department made a commitment to take action

on all 92 recommendations of the Civil Rights Action Team (CRAT). An

Acting Assistant Secretary of Agriculture for Administration was appointed

and was charged with implementing the recommendations of the CRAT — a

first step in making USDA a leader in civil rights. 

Under the guidance of the Assistant Secretary of Agriculture for

Administration’s (ASA) office, more than 300 USDA employees have

worked to make the recommendations into realities. Much of their work is

complete and actions are now in the hands of agencies, legislators, customers, and employees. 

To better address the needs of employees and customers, recommendations were grouped into one of four categories:

■ Lack of Management Commitment to Civil Rights

■ Program Delivery and Outreach

■ Workforce Diversity and Employment Practices

■ Organizational Structure of Civil Rights

This report reflects the Department’s progress.

3 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

Executive Summary
Snapshot of Action

Below is a snapshot of the status of recommendations. Of the 92 recommendations, an action plan has been completed for 45 recommendations, 43 more

are scheduled to be completed by October 31, 1997, and work on four recommendations will require more time to put processes or policies in place for

results. The process of changing policy is sometimes lengthy. While the

Department is interested in getting civil rights policies in place quickly, it is

also committed to implementing policies and procedures that will be long

lasting, responsive to everyone, and that fit into the operations of USDA.

Every effort has been made not to add more bureaucracy to the system. The

advantage to this approach is that civil rights is part of every USDA program

and part of personnel policies. The disadvantage is that it takes longer to see

results on some recommendations.

Progress Chart Key 

Actions of Civil Rights Implementation Team (CRIT) complete and 

policies in place. (10)

Actions of CRIT complete and action required by another group or 

by USDA agency before results are realized. (35)

CRIT work in progress—work expected to be complete by 

October 31, 1997. (43)

Action for recommendation will require longer to complete, however,

progress has been made in establishing a process to respond to 

the recommendation. (4)

43

3 6 7 8 12

18 19 20 24

25 26 27 28 29 30

42

52 53 54 55 56 57 58 59 60

64 65 66 67 68 71

73 74 75 76 79 80 83

1 2

13 14 16 17 21 22 23

31 32 33 34 35 36

37 38 39 40 41 44 45 46 47 48

49 50 51

61 62 63 69 70 72

77 78 81 82 84

85 86 87 88 89 90 91 92

15

4 5 9 10 11

4 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

The chart below shows of the status of each civil rights recommendation.
Highlights

This report gives the status of implementation of each recommendation, but

there are some activities which are especially noteworthy.

■ It is a condition of employment that every employee treat every co-worker

and customer fairly and equitably, and with dignity and respect.

■ As of July 31, 1997, USDA has a new reprisal policy — zero tolerance for

reprisals against employees who file civil rights complaints — and a policy

of immediately adjusting hostile or volatile work place conditions.

■ For the first time — beginning October 1, 1997 — agency heads will have

performance standards for civil rights and will be rated by the ASA on their

civil rights accomplishments.

■ Resolving the backlog of Equal Employment Opportunity (EEO) discrimination complaints is one of USDA’s highest priorities. As of September 3,

1997, USDA closed or settled 354 of the 1,504 cases that were in the backlog as of April 1, 1997.

■ In April 1997, a new foreclosure policy was instituted to ensure that violations of borrowers’ civil rights did not result in customers losing their

farms. All foreclosures were halted in cases where complaints of discrimination were on file. 

■ An independent review team was created to review the status of some

4,449 pending foreclosures. As of September 11, 1997, the team had

reviewed 2,768 cases and had halted further action on 115 foreclosures

pending investigation of possible civil rights violations. The rest, where

there was no finding of discrimination, are proceeding through foreclosure.

■ The Office of Civil Rights investigative unit, which had been disbanded in

1983, is being re-staffed to investigate and resolve the backlog of program

discrimination complaints.

■ While progress hasn’t been as fast as expected, USDA has closed 115 of

the active formal program complaints (since January 1997). As of

September 3, 1997, there were 872 active formal program delivery discrimination cases on file. Since April 1997, USDA has agreed to five major

financial settlements — totaling more than $2 million — with farmers who

were discriminated against. Four of the settlements were for loans and the

fifth was for disaster program benefits.

5 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT
■ On August 22, 1997, the Secretary established an Office of Outreach,

located in the office of the ASA to lead and coordinate proactive outreach

efforts throughout all of USDA. This office will serve customers USDA

has not served well in the past.

■ In July, 1997, the Secretary named a 30-person National Commission on

Small Farms. This commission will develop a national strategy for small

farms and ranches that will help ensure economic viability and address the

rapid decline in the numbers of minority farmers and ranchers.

■ To help stem the loss in the number of minority farms, work is underway

to establish a voluntary registry of minority farms. Working with community-based organizations, USDA intends to build the registry using USDA

Service Centers.

■ To help strengthen civil rights skills of USDA employees, training policy

and multi-year training modules are being prepared to address: sensitivity

and diversity, EEO laws and policies, program outreach, sexual harassment,

complaint process, and special emphasis programs. In addition, all USDA

employees will be required to attend annual civil rights training. The first

training is scheduled for November 1997.

■ Several of the CRAT recommendations are being addressed by draft legislative amendments or new legislative proposals including the bill

Representative Eva Clayton (D-NC) introduced, H.R. 2185 — “USDA

Accountability and Equity Act of 1997 — a bill to establish equitable service for customers and equal opportunity for employees of the United

States Department of Agriculture.”

6 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT
7 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Lack of Management Commitment to Civil Rights

Recommendation 3

Status of Implementation 

by Recommendation 

Lack of Management Commitment to Civil Rights

To ensure civil rights accountability at USDA, delegate to the Assistant

Secretary for Administration (ASA) full authority — in practice as well

as on paper — over all civil rights issues at USDA. The ASA may further

delegate civil rights authority through the Mission Area Assistant and

Under Secretaries to Agency Heads to administer civil rights programs.

Status of Implementation 

This recommendation was implemented on May 16, 1997, with the issuance

of Secretary’s Memorandum 1010-4. Implementing this recommendation

assures civil rights accountability at USDA. The ASA now has full authority

over civil rights. This includes the authority to rate the Agency Heads on their

performance of civil rights functions. Through the exercise of these authorities, the ASA can ensure civil rights accountability in USDA that results in

the fair and equitable treatment of all customers and employees, fewer complaints of discrimination and reprisal, and a significant improvement in the

timely processing of formal and informal complaints. This authorization will

be institutionalized when the ASA’s office reorganization is approved.

Delegate to the ASA the authority to rate Agency Heads on their civil

rights performance elements. The ASA will provide feedback to the

Secretary on the civil rights performance of the Subcabinet.

Status of Implementation

Beginning October 1, 1997, the ASA will rate Agency Heads on their civil

rights performance elements. USDA’s civil rights goals, objectives, and performance measures are being integrated into the performance standards of

Agency Heads. Specific standards for each Agency Head — as opposed to

generic standards — will be in place by October 1, 1997, to hold Agency

Heads accountable.

Revise the present Performance Review Board (PRB) process for measuring performance of senior executives in civil rights, and implement an

objective process designed to measure accomplishments based on specific

goals and objectives. Hold Subcabinet members, Agency Heads, and

senior officials accountable for implementing results-oriented affirmative

employment and civil rights implementation plans.

Recommendation 1

Recommendation 2
Status of Implementation 

PBRs review the performance of Senior Executive Service (SES) employees.

A comprehensive plan has been developed to identify USDA’s civil rights

goals and objectives, to develop performance measures, and to integrate them

into the performance standards of Agency Heads. Goals for accountability,

employment, program delivery, and procurement have been prepared, and

tasks and performance measures required to measure accomplishments

towards achieving these goals have been developed. These will be incorporated into the PRB guidelines.

The Secretary should revise and reissue USDA’s civil rights policy to

include specific, measurable goals and objectives in program delivery

and employment that will provide guidance for senior officials on what

they are expected to accomplish. The Secretary will hold the Subcabinet

and Agency Heads accountable for adherence to the civil rights policy.

Status of Implementation 

Part of recommendation 4 was implemented with the issuance of Secretary’s

Memorandum 4300-7, Civil Rights Policy Statement, February 28, 1997.

When these recommendations are fully implemented, USDA will have institutionalized an effective process to hold Agency Heads accountable for

achieving specific results in civil rights. This will establish a level of accountability that has never before existed at USDA.

To assure accountability, adopt and enforce a policy that the Department

will take the appropriate adverse or disciplinary action against any manager found guilty of reprisal against any USDA employee or customer.

Investigate all allegations of reprisal, and abuses of power, and where

allegations appear meritorious, immediately remove the official from

managerial duties, pending full investigation.

Status of Implementation 

A new reprisal policy was issued July 31, 1997. In cases of suspected reprisal

arising from EEO complaints, each mission area will establish a three-person

panel made up of one union or employee representative, one manager or personnel staff member, and one impartial member who will conduct an inquiry

into the claim. Within 45 days, this panel may make binding recommendations to adjust the employee’s workplace or environment to reduce tension

and may also recommend that the mission area consider disciplinary action. 

For reprisal cases not arising from an EEO complaint each mission area

will establish an office to hear allegations at the headquarters and, as appropriate, at the field level. In addition, Departmental Policy Manual 752-1,

“Reprisal Actions Against Employees and Others,” requires statistical reporting of reprisal complaints and disciplinary measures; the report will be available to all USDA employees. The effectiveness of the reprisal panels will be

evaluated on or before December 31, 1998.

8 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Lack of Management Commitment to Civil Rights

Recommendation 4

Recommendation 5
9 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Lack of Management Commitment to Civil Rights

Streamline procedures to allow agencies to quickly take the appropriate

adverse and disciplinary actions against employees who fail to provide

programs and services in compliance with all applicable civil rights laws

and regulations, or who discriminate against or harass USDA customers

or employees.

Status of Implementation 

Procedures have been streamlined. When discrimination is found as a result

of an employment or program complaint, the Office of Civil Rights will

notify the Agency Head and direct that appropriate disciplinary action be

taken. The Office of Civil Rights will monitor agency compliance and if the

agency’s discipline is not deemed appropriate, the Office of Civil Rights will

consult with the Office of Human Resources Management (OHRM) to determine an appropriate action.

The Office of Civil Rights will soon begin tracking complaints and respondents by name. This will allow the Office of Civil Rights to identify locations

or individuals where persistent problems exist and to take appropriate corrective action.

The Secretary, USDA’s Subcabinet, and Agency Heads must set an example of accountability and commitment for the Department by ensuring

that their immediate staffs reflect the desired diversity that the Secretary

is establishing for the Department as a whole. 

Status of Implementation 

“The Secretary’s Workforce Diversity Plan for Political Appointees,” has been

drafted. The plan calls for:

■ Diversity among political appointees;

■ A results-oriented civil rights commitment and accountability of political appointees at the Subcabinet and Agency Head levels for meeting

the civil rights goals and objectives, as reflected in the revised

Affirmative Employment and Recruitment Program (AERP); 

■ Establishment of a performance appraisal system that ensures maximum accountability of the Subcabinet and the Agency Heads for carrying out the AERP goals and objectives; and 

■ A training and development program for current and future political

appointees, so they will acquire the skills and knowledge necessary to

effectively manage a diverse workforce. 

This plan will be reviewed quarterly and will provide operational guidance

and feedback to the Secretary, Subcabinet, and Agency Heads. The Director

of OHRM, in coordination with the USDA White House Liaison, will be

responsible for updating and implementing the objectives of the plan. 

Recommendation 6

Recommendation 7
10 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Lack of Management Commitment to Civil Rights

Include in the Department’s Strategic Plans required under the

Government Performance and Results Act (GPRA) as well as in agency

plans, goals as outlined in the Secretary’s policy statement to improve

workforce diversity and civil rights. Affirmative Employment Plans and

Civil Rights Implementation Plans must also reflect the Secretary’s

goals. Set specific goals for minority and women-owned business participation in all program delivery, procurement, export, and business development activities.

Status of Implementation 

This recommendation is being implemented in concert with recommendations

3, 4, 9, and 10. 

The Department’s strategic plans will include measurable goals for workforce diversity, as well as goals for the participation of minority and womenowned businesses.

Plans should establish reporting requirements to periodically collect data

from USDA field offices to measure program delivery to minority,

women, and small and limited-resource farmers.

Status of Implementation

Work is progressing on implementing this recommendation in concert with

recommendations 3, 4, 8, and 10 to establish these reporting requirements.

Plans should include well-defined areas of responsibility and accountability. Performance standards and elements for Agency Heads and all

senior officials should reflect the specific goals and objectives as identified in the Department’s and agencies’ strategic plans.

Status of Implementation 

This recommendation is being implemented in concert with recommendations

3, 4, 8, and 9 to include well-defined areas of responsibility and accountability in the performance standards for Agency Heads and all senior officials.

Identify the core competencies and skills required to effectively manage

people and serve customers, including recruitment and management of a

diverse workforce and serving diverse customers. Require all promotions

and selectees into managerial positions to demonstrate those competencies. Use employee and peer review surveys to assess managerial competence, provide feedback, and develop performance improvement plans

for managers where needed.

Recommendation 8

Recommendation 9

Recommendation 10

Recommendation 11
Recommendation 14

Status of Implementation 

USDA will adopt the 22 basic leadership competencies developed by the

Office of Personnel Management (OPM) as the basis for all supervisory, managerial, and executive selection, training, and development. An upward and

peer feedback program has been drafted, with an implementation plan outlining technical requirements and costs necessary for program administration.

Require and provide ongoing training for all managers to enhance their

people skills, including managing a diverse workforce. Develop criteria to

measure effectiveness, provide specific timeframes for managers to

improve, and require Agency Heads to remove from managerial positions those whose performance fails to meet the criteria.

Status of Implementation 

USDA’s training policy will require competency-based training for supervisors and managers and establish a framework to evaluate training effectiveness and impact.

The Department of Justice (DOJ) should investigate allegations of

abuse of authority by the Office of Inspector General and Forest

Service Law Enforcement.

Status of Implementation

A decision memorandum has been prepared outlining several options available to implement this recommendation. 

The Secretary should direct the Forest Service to discontinue the practice

of using its Law Enforcement staff to investigate Forest Service employees.

Status of Implementation 

On September 2, 1997, the ASA directed the Under Secretary for Natural

Resources and Environment to stop using Forest Service (FS) Law

Enforcement and Investigations officers to investigate FS employees for noncriminal misconduct or other minor employee misconduct. Any proposed investigation by FS of FS employees for alleged criminal conduct will require the

advance approval of the OIG, the FS Chief, and the Under Secretary for

Natural Resources and Environment. In addition, the Chief and Under

Secretary were directed to involve USDA’s Director of the Office of Civil

Rights as appropriate if discrimination is involved.

11 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Lack of Management Commitment to Civil Rights

Recommendation 12

Recommendation 13
The DOJ should advise the Secretary on the role and functions of the

OGC at USDA as it relates to civil rights. The Secretary should take

appropriate action to ensure that OGC has the capacity to provide the

Department with the quality of legal assistance required for civil rights.

Status of Implementation 

To ensure civil rights accountability within the Office of the General Council

(OGC), a new division has been established and the selection of the new

Associate General Counsel for Civil Rights is pending. The attorneys in this

section will specialize in civil rights law and will provide USDA with the

expertise it needs to make certain that employment and program delivery

activities are conducted in accordance with civil rights laws, regulations, and

statutes. Additionally, OGC will soon adopt an AERP to add diversity to its

workforce, so OGC employees can better understand and serve minority, limited-resource, and women farmers. 

12 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Lack of Management Commitment to Civil Rights

Recommendation 15
13 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

Status of Implementation 

by Recommendation

Program Delivery and Outreach

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 18

To assure that local delivery of USDA credit programs is fair and equitable, work with the President and Congress to obtain the authority to

make personnel selections and manage the Farm and Foreign

Agricultural Services (FFAS) and Rural Development (RD) mission areas

to ensure accountability down the line, from the Secretary to the State

and county levels.

Status of Implementation 

An outreach effort has been outlined to identify potential political appointee

candidates from under-represented groups to fill vacant positions. An analysis

will be prepared about the civil rights impact of pending appointments, especially as it relates to under-represented groups. These efforts will ensure representation of under-represented groups at all levels of USDA, especially where

USDA’s top staff can set an example that the entire Department can follow. 

Modernize the FSA State and county committee system by converting all

county non-Federal FSA positions, including county executive directors,

to Federal status; changing the committee selection process; and removing county committees from any farm loan determinations.

Status of Implementation 

Legislative language to implement this recommendation has been incorporated into H.R. 2185, “A bill to establish equitable service for customers and

equal opportunity for employees of the United States Department of

Agriculture,” which was introduced July 17, 1997, by Representative Eva

Clayton. The proposed legislation will convert approximately 10,400 permanent and 2,800 temporary county committee employees to Federal positions.

In addition, provisions are included to expand county committee membership

where necessary for under-represented groups and to change farm loan processing to a Federal function.

Conduct a complete review of county committees and county office staffs

to determine whether nepotism, conflict of interest, and/or discrimination in program delivery exist.

Status of Implementation 

Guidelines have been developed for the Farm Service Agency (FSA) to conduct

the reviews, and a monitoring group has been established under the ASA to

independently oversee the process. The monitoring team will ensure the review

Recommendation 16

Recommendation 17
14 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

is conducted in a thorough, unbiased manner. Reports from the monitoring subgroup and FSA will be provided to the ASA by the end of 1997. Corrective

actions will be taken as problems are identified. The review will be done on a

sampling basis — with the sample expanded where warranted.

Establish a system to assure timely and equitable handling of loan applications by county offices, including review and concurrence by FSA and

Rural Development State Directors within 30 days of any adverse decision that affects a member of a defined socially disadvantaged group.

Status of Implementation 

A policy being developed by FSA and RD will be institutionalized. At the

same time, work is underway to develop a data base to track the loan- making

process as to timeliness, reasons for rejection, and participation rates by various minority groups. Implementation of this recommendation should ensure

that all minority applicants for farm credit loans will be treated fairly and will

have better access to Departmental programs.

Require independent review of all pending foreclosures to determine

whether discrimination in USDA programs contributed to foreclosure

action.

Status of Implementation 

In April 1997, the Director of the Office of Civil Rights established an independent team to review all FSA pending foreclosures. Of the 4,500 pending foreclosures, the team has reviewed 2,768 and, as of September 11, 1997, halted

further action on 115 cases awaiting investigation for possible civil rights violations or further review.

Require that all pending foreclosures or actions leading to foreclosure be

halted until all appeals of any formal civil rights complaints have been

completed.

Status of Implementation:

In April 1997, the Department issued FSA Field Notices 114 and 117 which

clarified the policy ensuring that discrimination is not a factor in any USDA

farm loan foreclosure. The policy:

■ Froze all loans that had already been called due or accelerated until the

independent review team has made a determination;

■ Established an independent review team to examine loans facing foreclosure to make sure that discrimination or inequitable treatment is not

a factor before any foreclosure action is taken (recommendation 20);

Recommendation 19

Recommendation 20

Recommendation 21
Recommendation 23

15 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

■ Assured borrowers that USDA would continue to apply its loan servicing programs to all accounts;

■ Assured borrowers that USDA would not accelerate any loans or call

any loans due until the independent team had reviewed the account

and found no evidence of discrimination or inequitable treatment; and

■ Established that FSA must process new loan applications from borrowers with pending discrimination complaints. Additionally, if an

FSA loan officer is alleged to have discriminated against the prospective borrower, the application will be assigned to another loan officer.

If the new loan is refused, the applicant must be advised both in a

face-to-face meeting and in writing.

Act on all existing program discrimination complaints within the next

120 days. Resolve those that can be resolved and bring all others to the

point of adjudication within those 120 days.

Status of Implementation 

In April 1997, the Office of Civil Rights established a team to examine and

resolve the backlog of program complaints. After the team began work, it discovered that almost all the cases lacked investigations and, therefore, it was

unable to complete work within the original goal of 120 days. It also found

that the investigative unit of the Office of Civil Rights had been disbanded in

1983. In July 1997 the new Director of the Office of Civil Rights began hiring contract investigators and recruiting for permanent and temporary investigators. Since January 1997, the Office of Civil Rights has closed 115 of the

more than 800 formal program complaints. There have been five major financial settlements, totaling more than $2 million, with farmers who were discriminated against. Four of the settlements were for loans and the fifth

concerned disaster program benefits.

Require that an agency’s civil rights office elevate a program discrimination

complaint to the next higher level when no action has been taken within the

time limit. When a delay occurs at the next higher level, the agency’s civil

rights office should apply the adverse inference rule and direct the agency

to immediately act on the complaint in favor of the customer. 

Status of Implementation 

This recommendation is being implemented in concert with recommendations

24 and 25. The adverse inference rule is included in the new program discrimination complaints process.

Recommendation 22
16 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Establish one program appeals system for all Mission Areas at USDA.

Hold all litigation until the appeals process is complete.

Status of Implementation 

The system for processing program discrimination complaints is being

redesigned. The new system provides various options for different types of

cases, for example, mediation, hearing, or investigation, and will result in most

complaints being brought to closure within 180 days. The system calls for the

coordination of appeals and discrimination complaints, so that an adverse

appeal decision will not be implemented while a discrimination complaint is

being processed. An operational manual and a regulation setting forth key

aspects of the system are being drafted. Customer input has been and will continue to be solicited. A key component of the new system is an education and

awareness campaign, so customers know how to file a discrimination complaint and USDA employees know what to do when they receive one.

The National Appeals Division Director shall consider the impact of the

NAD appeals process on the civil rights of farmers and coordinate the

program appeals process with the Department’s program discrimination

complaints process.

Status of Implementation 

The recommendation is being implemented in concert with recommendations

23 and 24. The discrimination complaints process and the National Appeals

Division (NAD) appeals process are being coordinated through the development of the program discrimination complaints process.

Require that the National Appeals Division and informal agency program appeals processes comply with established legal timelines and

establish timelines in cases where they are not required by law. When

NAD does not comply with these timelines and the Hearing Officer has

ruled in favor of the customer, the Hearing Officer’s ruling shall stand.

Status of Implementation 

An appeals deadline policy is being drafted. The policy would require agencies, including NAD, to comply with timelines and to implement appeals and

discrimination complaint decisions in a timely manner. The policy sets uniform timelines, when appropriate, for appeals processes of different USDA

agencies. Implementation of the policy also requires discrimination complaint

decisions to be implemented within 10 working days. Agencies will no longer

implement adverse appeals decisions when the customer has a pending discrimination complaint. Consequently, the policy ensures that agencies will

meet timelines and that timely implementation will be a factor in managers’

and employees’ performance standards.

Recommendation 24

Recommendation 25

Recommendation 26
Recommendation 28

Recommendation 29

Hold all managers accountable for carrying out the final decisions of the

National Appeals Division and within 10 working days of their issuance.

Status of Implementation 

Under the new program discrimination complaints process, agencies will be

required to carry out final decisions within 10 days.

To establish a baseline for the number of minority farms, USDA should

support a voluntary registry of minority farms. This would help USDA set

goals to halt land loss and to monitor the loss of minority-owned farms.

Status of Implementation 

The Secretary is establishing a voluntary registry of minority-owned lands,

through the USDA Service Centers, to document the amount of farmland

owned by minorities. The registry will establish a baseline of minority farmland ownership which can be monitored over time. It will be available to

CBOs, educational institutions, and government agencies helping minorities

with land retention and acquisition. The voluntary registry form has been

designed and is currently going through the clearance process. It will be

issued in Spanish and English and will be distributed to CBOs and other

organizations to ensure that the registry form is widely publicized and accessible to all.

To assure that the U.S. Census of Agriculture accurately counts minority

farms, National Agricultural Statistics Service (NASS) has added a number of

additional lists of minority farm operators to the mailing list for the 1997 census. Also, minority operators included in the 1992 census were contacted to

identify farmers who were missed in the 1992 census. As part of the 1997

census, a procedure has been designed which will estimate the number of

Native American farm operators on every reservation — instead of counting a

reservation as one farm, as was done in the 1992 census.

Fully implement a “Debt for Nature” program as authorized in the 1996

Farm Bill and prior legislation.

Status of Implementation 

A memorandum has been drafted to direct the Agency Heads of FSA and

Natural Resources Conservation Service (NRCS) to fully implement the

“Debt for Nature” program. These two agencies have agreed to cooperate on

joint administration of the program and have prepared a budget proposal to

cover debt cancellation conservation contracts and to inventory property conservation easements and transfers.

By ensuring that all minority farmers understand and have access to this

program, many of them will be able to maintain a viable farming operation

when they sign up for the debt cancellation for the conservation feature of

this program.

17 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 27
18 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Establish and empower a Special Task Force to determine a process for

providing remediation to farmers who have been discriminated against

by USDA. Priority should go to farmers who have lost or are about to

lose their land because of discrimination. 

Status of Implementation 

Pending.

Allow farmers who have received debt write-downs to continue eligibility

for operating loans. 

Status of Implementation 

Legislative language to implement this recommendation has been incorporated into H.R. 2185. USDA will work to ensure that farmers continue to

have access to credit, while adequate safeguards are in place to protect the

integrity of financial programs. Factors to be considered involve the Federal

Debt Collection Act and outstanding recommendations from the General

Accounting Office.

Allow completion of lease back/buy back agreements extended for lack of

funds during the 3 years previous to elimination of the program on April

4, 1996, where the farm and home plan did show that the operation

would cash-flow.

Status of Implementation 

Legislative language to implement this recommendation has been incorporated

into H.R. 2185. It provides authority for the Secretary to finance a farm loan

(to the extent practical, at the same terms as farm ownership loans) for individuals who had a lease back/buy back agreement during fiscal years 1994-96;

had applied in a timely manner for a farm ownership loan during fiscal years

1994-96; have been denied financing due to lack of funds; and can demonstrate that the farm will generate sufficient income to repay the loan.

Allow incorporation of anticipated tax liability in the terms of debt

write-downs.

Status of Implementation 

The Secretary wanted to ensure that State and county office employees consider anticipated tax liability when calculating debt restructure; therefore, an

FSA procedural notice (FSA Notice FC-119) was issued on May 28, 1997,

that provided guidelines on how to consider the tax liability for debt writedown. However, in H.R. 2185, Rep. Eva Clayton proposes to amend the

Consolidated Farm and Rural Development Act so the debt write-down is not

considered as income for tax purposes. Because this is a tax matter, the

Secretary will work with the Treasury Department on this issue.

Recommendation 30

Recommendation 31

Recommendation 32

Recommendation 33
19 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Allow eligibility for 502 single-family housing program direct loans without a credit history if applicants can demonstrate they have been able to

live independently and pay rent and utility bills in a timely manner.

Status of Implementation 

Changes have been made to the Direct Single-Family Housing Field Office

Handbook (HB-1-3550) to ensure that applicants have every opportunity to

provide the Rural Housing Service (RHS) with documentation of an acceptable credit history, especially when there is a lack of credit history on a credit

report. Enhancements were made to several areas of the handbook. These

provided useful reminders, examples, and clear policy statements to ensure

that customers’ full credit history is taken into consideration when determining their ability to repay a single-family housing loan. On May 19, 1997,

these changes became effective and were issued in revised handbook pages to

all RD staff in a procedural notice. The agency also provided training to its

field staff during July 1997. 

Implementing this recommendation will mean that more limited-resource

customers will be eligible for rural housing loans. Applicants previously

denied loans because of lack of credit history will now have an opportunity to

participate in the home ownership program.

Allow EQIP cost-share payments in the same year conservation practices

are completed.

Status of Implementation 

Draft legislation to implement these recommendations has been incorporated

into H.R. 2185.

The “pay-as-you-go” provision of the Omnibus Budget Reconciliation Act

(OBRA) of 1990 requires offsets for direct spending, and acceptable offsets

will need to be found.

Appoint a diverse commission to develop a national policy on small farms.

Status of Implementation

On July 16, 1997, the Secretary established a National Small Farm

Commission to develop a national strategy for small farms and ranches. The

30-member Commission held public hearings in Memphis, TN; Sioux Falls,

SD; Washington, DC; and Sacramento, CA, and is scheduled to report back

to the Secretary by September 30, 1997. Following the release of the

Commission’s report, the Secretary’s office will set up and oversee an interagency team to develop a Departmental plan for incorporating and institutionalizing the Commission’s recommendations through existing programs and, if

necessary, new programs.

Recommendation 34

Recommendation 35

Recommendation 36
20 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Establish an Office of Outreach in a program mission area to coordinate program delivery outreach efforts throughout USDA. Assign responsibility for

the Outreach and Technical Assistance to Socially Disadvantaged Farmers

(2501) to this new office to assure Department-wide implementation.

Status of Implementation 

The Secretary has signed a memorandum to establish a Departmental Office

of Outreach in the Office of the ASA. The personnel package, which included

the delegation of authority and position descriptions for the office, has been

developed. A director, who has been selected and will be announced soon,

will coordinate program delivery efforts throughout USDA. Locating the

Office of Outreach under the ASA gives it the visibility and stature needed to

send a strong signal of USDA’s commitment to strengthening outreach to all

underserved customers.

Develop a strategic outreach plan, as part of USDA’s strategic plan, for

which Agency Heads will be held accountable through the Civil Rights

performance standard.

Status of Implementation 

A USDA strategic outreach plan for fiscal years 1997-2002 was drafted and

submitted to the Chief Financial Officer for help in coordinating a target peer

review. The plan will be incorporated into USDA’s Departmental

Administration’s Strategic Plan. A Secretary’s transmittal memorandum has

been drafted to Subcabinet officials, directing them to incorporate the goals

and objectives of the plan into the outreach components of agency plans. The

impact of implementing this recommendation is to provide a common vision

and outreach objectives under which all USDA agencies will operate.

Establish in each agency an outreach liaison position to coordinate and

direct outreach programs in conjunction with the new USDA Office of

Outreach. The agency coordinator must be responsible for monitoring

outreach goals and accomplishments to underserved customers.

Status of Implementation 

A Secretary’s Memorandum has been drafted requiring each Agency Head to

establish an outreach liaison.

Recommendation 37

Recommendation 38

Recommendation 39
21 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Establish State and National Outreach Councils, comparable to the

USDA Food and Agriculture Council (FAC), to coordinate outreach

efforts of all USDA agencies with State and local-level program delivery.

Require that Outreach Councils establish partnerships with communitybased organizations and 1890, 1994, and 1862 land-grant institutions,

HACU, and the Research and Employment Access Programs Initiative to

enhance program and service delivery to underserved communities.

Status of Implementation

A memorandum has been prepared to expand the responsibilities of the State

and National FACs to include the Outreach Advisory Councils to coordinate

USDA outreach efforts with State and local program delivery efforts.

Establish a partnership between USDA and the Department of the

Interior to develop a strategic outreach plan to address the needs of

American Indian agriculture and land conservation.

Status of Implementation

A memorandum has been prepared directing the ASA and the National FAC

to charge the Office of Outreach to work with the U.S. Department of the

Interior in setting up a joint task force with tribal governments. The task force

will develop a USDA strategic outreach plan for identifying and addressing

the agriculture and land conservation needs of American Indians. The

National FAC will help develop the plan.

Require land-grant institutions and major CSREES, ARS, ERS, FS, and

NRCS programs to identify and give priority to the research and educational needs of the socially disadvantaged.

Status of Implementation 

Several actions have been developed to ensure that USDA agencies make the

research and educational needs of underserved customers a priority. Mission

areas will be directed to designate an individual in USDA research, educational, technical assistance agencies, and land grant universities who will

ensure that the needs of socially disadvantaged and limited-resource customers are given priority. A proposal is being written for one of the mission

areas to sponsor an annual national conference that will foster a dialogue on

research, educational, and technical needs of limited-resource and underserved customers. Implementation of this recommendation will ensure that

the research, educational, and technical assistance needs of socially disadvantaged and limited-resource customers are surfaced and given serious consideration in the priority-setting process.

Recommendation 40

Recommendation 41

Recommendation 42
USDA should thoroughly examine funding of institutions of higher education to determine if 1890 and 1994 land-grant institutions are receiving

equitable support to assist USDA in carrying out its mission. The

Department should adjust its budget recommendations and consider

other statutory or regulatory changes required to eliminate any disparate funding of land-grant institutions.

Status of Implementation 

Two legislative actions are proposed as amendments to Title 8 of the Federal

Agriculture Improvement and Reform (FAIR) Act of 1996 to move toward

more equitable funding for the minority-serving land grant institutions. These

items are included as part of the Administration’s reauthorization package for

the research and education title of the 1996 farm bill. One amendment that

would increase resources available to the 1890 institutions contains matching

requirements for formula funds (Evans-Allen research and 1890 Extension

funds), with the amount of the match phased in over a 4-year period. The proposed legislation also includes two options for assuring that the 1890 institutions will not be penalized for failure to meet their match. A second proposed

amendment extends eligibility to the 1890 and 1994 minority-serving institutions for participation in the specially funded 3(d) extension programs and

eligibility to all accredited colleges and universities, including Hispanic-serving institutions, to apply for competitive 3(d) programs. Implementing this

recommendation will strengthen USDA’s ties and provide more equitable

funding to the minority-serving land grant institutions.

Fully fund the Outreach and Technical Assistance to Socially

Disadvantaged Farmers (2501) program at $10 million annually.

Status of Implementation

The legislative language to implement this recommendation has been incorporated into H.R. 2185.

The “pay-as-you-go” provision of the OBRA of 1990 requires offsets for

direct spending, and acceptable offsets for any increase in direct spending

must be found.

Extend and fully fund the Extension Indian Reservation program at $8

million annually.

Status of Implementation 

The legislative language to implement this recommendation has been incorporated into H.R. 2185.

The “pay-as-you-go” provision of the OBRA of 1990 requires offsets for

direct spending, and acceptable offsets for any increase in direct spending

must be found.

22 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 43

Recommendation 44

Recommendation 45
Increase EQIP funding from $200 million to $300 million and target the

increase for assistance to minority and limited-resource farmers, ranchers, and Indian nations.

Status of Implementation

The legislative language to implement this recommendation has been incorporated into H.R. 2185. A team is also exploring non-legislative options for

implementing this recommendation.

Fully fund the farm ownership and farm operating loan programs at $85

million and $500 million, respectively.

Status of Implementation

The legislative language to implement this recommendation has been incorporated into H.R. 2185. The “pay-as-you-go” provision of the OBRA of 1990

requires offsets for direct spending, and acceptable offsets for any increase in

direct spending must be found.

Require that a higher percentage of farm ownership and farm operating direct loan funding be targeted to minorities and socially disadvantaged groups.

Status of Implementation

Legislative language has been drafted for inclusion in the Department’s

omnibus legislative package to amend existing legislation to ensure program

resources, at a minimum, will be expended to reflect the diversity in population of the specific State or county. This change will allow management the

flexibility of targeting additional resources, since the legislation will not specify either the actual percentage or the methodology for determining the rate.

Dedicate one-third of the Fund for Rural America to serving the needs of

socially disadvantaged customers.

Status of Implementation

A plan has been developed and is under review to use one-third of the Fund

for Rural America for “Resources 2000,” a 2-year campaign to reach and

meet the needs of rural, socially disadvantaged communities and the people

who live there. The main thrust of “Resources 2000” is to reach and make a

difference in a set of specially selected communities that are the “poorest of

the poor.”

Target $100 million annually from Rural Utilities Service Water and

Waste Disposal Grant Program to Federally recognized Indian Tribes.

Status of Implementation 

A funding proposal has been drafted to target up to $100 million of the total

appropriated funds to federally recognized Indian tribes. 

23 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 46

Recommendation 47

Recommendation 48

Recommendation 49

Recommendation 50
Target $50 million of RHS funds annually for the Farm Worker

Housing Program.

Status of Implementation 

A funding proposal has been drafted to target up to $50 million for farm

worker housing. Implementing this recommendation will increase and direct

funds and programs to socially disadvantaged groups and communities. 

Require consideration of underserved communities in USDA Service

Center location decisions.

Status of Implementation 

The National FAC will issue a Departmental directive to the State FACs

directing them to revise their USDA Service Center implementation plans to

consider underserved communities in Service Center location decisions.

Guidelines are being established to standardize criteria used to identify underserved communities.

Establish satellite offices where necessary to reach underserved customers.

Status of Implementation 

The National FAC will issue guidelines for State FACs to use in establishing

offices where needed to reach underserved customers. 

Establish full-time USDA Service Centers on Tribal lands.

Status of Implementation

The National FAC will issue a directive to the State FACs to establish and

evaluate full-time USDA Service Centers on tribal lands. The consultative

process will be used with the American Indian tribes to help in determining

Service Center locations on tribal lands. The National FAC will monitor the

State FACs’ implementation of the directive and its guidelines.

Ensure that all USDA Service Centers are accessible to people with 

disabilities.

Status of Implementation 

The ASA will issue a directive requiring USDA agencies to complete a selfevaluation to determine the degree to which USDA Service Center programs

are in compliance with guidelines issued by the DOJ. The directive will also

instruct agencies to bring programs into compliance. The Office of Civil

Rights will monitor those that are not in compliance. Criteria for recognizing

outstanding efforts will be included in determining USDA’s Honor Awards

Program selections.

24 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 51

Recommendation 52

Recommendation 53

Recommendation 54

Recommendation 55
Streamline program regulations and application forms to make USDA

programs more easily accessible to all customers. Require USDA county

offices to assist socially disadvantaged customers in understanding

requirements and completing forms.

Status of Implementation

Guidelines have been drafted to streamline program regulations and application forms. Additionally, the team compiled an extensive list of all forms,

related program regulations, program name, and agency responsible for the

program. The list is being evaluated before further action is taken.

Strengthen the training program for FSA county committees and county

office staff on all programs, with special emphasis on civil rights issues

and outreach responsibilities.

Status of Implementation

A policy requiring annual civil rights training and training modules are being

developed to implement standardized civil rights training for USDA beginning FY 1998 for a 3-year cycle. Six major areas have been identified and

will be included in the civil rights training curriculum: Sensitivity and

Diversity, EEO Laws and Policies, Program Outreach (Title VI), Sexual

Harassment, Complaint Process (Title VII), and Special Emphasis Programs.

The Director of the Office of Civil Rights and the Director of OHRM will be

responsible for the delivery, design, and evaluation. 

Provide and document Title VI training for all volunteers and new field,

State, and Service Center employees on an annual basis.

Status of Implementation

This recommendation is being implemented in concert with recommendation

57. A design team has gathered input from representatives of agencies —

NRCS, FSA, RD, and Food and Consumer Service (FCS) — with significant

program delivery and outreach responsibilities. The pilot training is set for

January 1998, with the actual training scheduled for April 1998. 

Make all USDA educational and technical assistance services and publications available to customers in languages appropriate to the community being served. Use appropriate media outlets to distribute

information to underserved communities.

Status of Implementation

A USDA regulation has been prepared that requires Agency Heads to develop

and implement communications plans that serve diverse and special-needs

audiences. To assist agencies and field staff in working with diverse and special-needs customers, a team has also drafted a field communications guide.

25 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 56

Recommendation 57

Recommendation 58

Recommendation 59
When this recommendation is fully implemented, the communications needs

of diverse and special-needs customers will be better served and USDA staff

will be better equipped with resources to serve these groups.

Establish an initiative to address the needs of farm workers that could be

addressed through USDA programs.

Status of Implementation 

A plan for conducting listening sessions concerning farm worker issues has

been drafted. Lists of panel members, farm workers groups, and others to

attend have been developed. The listening sessions will provide much of the

information the panel will use to develop an initiative. The team has also proposed a Farm Worker Coordinator position in the Office of Outreach. The

Secretary has also proposed a joint working group made up of USDA and

Department of Labor officials to maintain an ongoing dialogue on farm

worker issues.

Enforce the requirement that those who use “restrictive-use pesticides”

keep records of the application of their products.

Status of Implementation

A team is examining options to expand cooperative agreements for the

Federal pesticide record keeping program with all states and territories by the

end of FY 1998.

Immediately provide pesticide information to health care providers treating pesticide-related illnesses.

Status of Implementation

A $3.5 million increase in the Cooperative, State, Research, Education, and

Extension Service (CSREES) budget has been requested, which includes a

maintenance cost of $1.75 million to update the Extension Toxicology

Network (EXTOXNET) data base to make information on pesticides readily

available and to provide training to health care providers. A partnership

between the American Medical Association (AMA) and USDA has also been

proposed.

Require USDA to use this information to prepare comprehensive annual

pesticide use reports, as mandated in the 1990 and 1996 farm legislation. 

Status of Implementation 

A funding request has been prepared that seeks a $2 million increase in the

NASS budget to enhance future pesticide use surveys. The “pay-as-you-go”

provision of the OBRA of 1990 requires offsets for direct spending, and

acceptable offsets for any increase in direct spending must be found.

26 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 60

Recommendation 61

Recommendation 62

Recommendation 63
Enforce the Environmental Justice Executive Order at USDA. 

Status of Implementation

A Departmental regulation is being developed to address the needs of farm

workers as they relate to environmental justice. A policy statement is also

being developed for complying with Executive Order 12898 on environmental justice. Environmental justice will be incorporated into the National

Environmental Protection Act (NEPA) process and into all program delivery.

Outreach and training will be enhanced. Evaluation, oversight, and reporting

methods will be developed to ensure that environmental justice policy is

being implemented. 

Reassert the commitment of USDA to the goal of increasing involvement

of small and disadvantaged businesses in USDA programs.

Status of Implementation

Performance standards and criteria have been identified to strengthen the

evaluation of managers’ efforts to support small business participation.

Several pilot initiatives have been proposed that will streamline regulations

and simplify the execution of small business contracts. A Departmental regulation was developed to establish a clearance process to identify greater

opportunities for small business set-asides. In addition, a wide range of technical assistance materials for use by small businesses have been developed.

27 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Program Delivery and Outreach

Recommendation 64

Recommendation 65
28 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

Status of Implementation 

by Recommendation

Workforce Diversity and Employment Practices

Review all SES designations, beginning with FSA, to determine if positions are appropriately designated as career-reserved or general.

Status of Implementation 

The team has reviewed the designations for all occupied and allocated vacant

SES positions in USDA. Results are being prepared for follow-up discussions

with Under and Assistant Secretaries and Agency Heads.

Hold all managers accountable for a diverse pool of applicants for all

vacancy announcements and target outreach and recruitment of underrepresented groups as identified in the agency Affirmative Employment

Plans (AEPs).

Status of Implementation 

A team prepared and completed the AERP regulations, Personnel Bulletin

330-3, “Core Competencies for Agency Recruiters and Outreach

Representatives”; and Personnel Bulletin 335-1, “Multi-grade Positions.”

The regulations integrate equal opportunity recruitment and all affirmative

employment programs; reemphasize equal opportunity outreach, recruitment,

and affirmative employment requirements by cross-referencing with new

OHRM requirements; and hold managers and supervisors accountable

through the performance appraisal system. October 1, 1997, is the target

effective date for the AERP.

Personnel Bulletin 330-3 identifies two levels of required competencies: a

basic level for those who recruit infrequently and a higher level for those who

recruit on a recurring basis. It also requires agencies to certify that recruiters

and outreach representatives, meet core competencies; and it permits USDA’s

OHRM to evaluate agencies compliance practices. It was distributed to

Agency Heads and Departmental Personnel Manual holders in August 1997.

Recruiters and outreach representatives are scheduled to be certified by

August 25, 1998.

Personnel Bulletin 335-1, which became effective August 18, 1997,

requires agencies to provide consistent information on career ladders to all

applicants; ensures that job openings are advertised in multi-grade increments; and requires career ladders be published in an agency’s Merit

Promotion Plan and cannot change for one year. 

STATUS BY RECOMMENDATION Workforce Diversity and Employment Practices

Recommendation 66

Recommendation 67
Require all USDA employees to have civil rights training annually.

Status of Implementation

An annual civil rights training policy has been drafted and a training plan

developed that will implement standardized civil rights training for USDA

beginning in FY 1998. Six major areas have been identified and will be

included in the training curriculum: Sensitivity and Diversity, EEO Laws and

Policies, Program Outreach (Title VI), Sexual Harassment, Complaint

Process (Title VII), and Special Emphasis Programs. The roles and responsibilities of the Director of the Office of Civil Rights and the Director of

OHRM in the implementation of training have been identified. 

Civil rights training is scheduled for November 1997 using satellite broadcast. The Office of Civil Rights will monitor and track the annual civil rights

training. 

Publicize and recognize those managers and agencies that have made significant accomplishments in workforce diversity.

Status of Implementation

Criteria for recognizing individuals, groups and managers for outstanding

efforts in workforce diversity has been drafted. The draft will be taken to

OHRM to incorporate the criteria into USDA’s Honor Awards Program.

Direct the Forest Service to end the use of surplus lists.

Status of Implementation 

On June 11, 1997, the Acting ASA directed the Under Secretary for Natural

Resources and Environment to:

■ Suspend directed reassignments of employees identified as “surplus”

under the FS Employee Placement System (EPS);

■ Have FS propose to the National Federation of Federal Employees

(NFFE) that they reopen their collective bargaining agreement provisions which are the basis for the EPS; and

■ Analyze the current EPS in terms of the effect on diversity and its relationship to complaints and representational activities. 

FS suspended directed reassignments on June 16, 1997, began negotiations

with NFFE, and has completed the requested analysis.

29 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Workforce Diversity and Employment Practices

Recommendation 68

Recommendation 69

Recommendation 70
Evaluate the role and function of the Special Emphasis Program

Managers (SEPM) in accomplishing USDA’s civil rights goals and objectives. The valuable resources dedicated to support SEPM could be used

more effectively. Presently they are limited to the annual Special

Emphasis activities as their primary function.

Status of Implementation

A team conducted interviews with Departmental SEPMs to determine how

they perceived their function and responsibilities. The team determined that

under the new civil rights structure at USDA, the SEPMs would also serve as

desk officers to interface with specific agencies. Implementing this recommendation will make the SEPMs more effective and responsive to agencies’ needs.

Develop and implement retention programs to ensure a diverse workforce. 

Status of Implementation

This recommendation was implemented in August 1997 with the issuance of

Personnel Bulletin 250-3, “Work Life Survey Guidelines,” and Personnel

Bulletin 250-4, “Agency/Department Exit Interview Guidelines.”

Personnel Bulletin 250-3 requires agencies to conduct periodic work life surveys aimed at assessing conditions in the workplace and identifying problems.

Agencies must report results to the OHRM.

Personnel Bulletin 250-4 requires agencies to provide a questionnaire to permanent full-time employees who are separating from the agency or the

Department. The questionnaires will be designed to alert management to concerns within the workforce and take the appropriate action to correct problems.

To substantially reduce the backlog of EEO complaints, offer mediation,

arbitration, or similar alternative dispute resolution (ADR) processes to

employees who filed a formal EEO complaint before January 1, 1997. The

use of ADR shall be the employee’s choice; however, binding arbitration

will be used only if agreed to by both the employee and management.

Status of Implementation 

The Backlog Resolution Team’s effort to reduce the backlog of 1,504

employment discrimination complaints has resulted in 354 cases being closed

— 252 by settlement and 102 by decision and other action as of September 3,

1997. About 200 additional cases have been referred to the Federal Mediation

and Conciliation Service for mediation. The Backlog Resolution Team officially closed its operations on July 31, 1997 but it will continue settlement

efforts in those cases having a reasonable chance of being resolved — 674

cases were identified where mediation was possible. Where it appears that an

agency has unreasonably refused to settle the case, USDA’s Director of the

Office of Civil Rights will sign a settlement agreement in lieu of the agency.

All unresolved cases will continue in the EEO process. The ASA has directed

that a small, ephemeral task force be established to further explore the resolution of EEO complaints.

30 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Workforce Diversity and Employment Practices

Recommendation 71

Recommendation 72

Recommendation 73
31 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Workforce Diversity and Employment Practices

All EEO resolution agreements shall have terms that (1) relate to the

nature of the complaints; (2) address causal factors; (3) are conducive to

timely implementation; and (4) contain implementation time frames. To

ensure accountability, “no fault” settlements shall be used only in cases

where all the parties to the dispute agree that it is appropriate.

Status of Implementation 

A new policy on EEO settlement agreements has been drafted. The USDA

draft policy holds Agency Heads accountable for full and timely implementation of EEO settlements, and directs them to empower their civil rights directors to intervene and sign agreements on behalf of the agency when

necessary. The draft policy further directs that “no fault” agreements shall not

be used to shield acts of discrimination, and holds Agency Heads accountable

for vigorously addressing misconduct and discrimination by their managers.

The Director of the Office of Civil Rights has drafted guidelines for agencies

and the Office of Civil Rights staff to implement the Secretary’s policy.

To ensure an effective and timely EEO complaints process on a permanent basis, conduct an independent review of USDA’s existing EEO system, assess the areas of deficiency, and redesign or repair the system.

Status of Implementation

An analysis of the EEO complaints process, led by an independent contractor

that specializes in process reengineering, began in July, 1997. The analysis

will result in specific recommendations to repair the system.

Initiate a continuing and coordinated USDA-wide workforce planning

and recruitment process.

Status of Implementation

Personnel Bulletin 250-1, “Workforce Planning,” scheduled to be issued in

early October, requires agencies to coordinate strategic planning, recruitment

efforts, affirmative employment program plans, and other strategies to ensure

a highly skilled and diverse workforce. Personnel Bulletin 250-2, “Human

Resources Management Evaluation Program,” requires agencies to review

workforce plans and human resource management programs to emphasize

responsibility and accountability, and ensure that diversity is an integral part

of the Department’s workforce and programs. A new staff will be established

in the OHRM to oversee these functions. In addition, a memorandum of

understanding has been drafted which establishes a research and scholar

exchange program and addresses under-representation of Asian Pacific

Americans in USDA’s workforce.

Recommendation 74

Recommendation 75

Recommendation 76
The Secretary should be more involved in the management and selection

of the SES cadre within USDA.

Status of Implementation 

The Office of Personnel Management (OPM) approved the USDA Senior

Executive Service Candidate Development Program (SESCDP) Plan on

August 20, 1997. USDA officials had hoped to immediately announce a new

SESCDP. However, since OPM has just revised the Executive Core

Qualifications (ECQs) and the Leadership Competencies that form the basis

for the ECQs, USDA is currently working with OPM to modify the USDA

plan to use the new standards. The program is expected to be announced this

fall, with the first class starting this winter.

32 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Workforce Diversity and Employment Practices

Recommendation 77
33 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

Status of Implementation 

by Recommendation

Organizational Structure of Civil Rights 

STATUS BY RECOMMENDATION Organizational Structure of Civil Rights

Consolidate the Department’s civil rights functions under one Office of

Civil Rights that reports directly to the ASA. Immediately fill the top

position in that office with a career SES individual with demonstrated

skills in civil rights management, communications and outreach, partnership building with other USDA agencies, and leadership.

Status of Implementation

In March 1997, the civil rights offices under the Office of Operations and all

the offices under the Policy Analysis and Coordination Center — Civil Rights

were consolidated under the new Office of Civil Rights. Secretary’s

Memorandum 1010-4, dated May 16, 1997, officially outlined the restructuring of Departmental Administration, including the establishment of the Office

of Civil Rights, headed by a Director who reports directly to the ASA, and

the consolidation of all civil rights offices under the Office of Civil Rights.

Internal customers — employees, managers, and agencies — and external

customers alike now have one point of contact on civil rights program, and

equal employment opportunity matters.

Organize the new USDA Civil Rights Office with separate employment

and program civil rights components that report under separate lines

of supervision.

Status of Implementation 

This recommendation is being implemented as part of the overall reorganization of the Office of Civil Rights. Since March 1997, the Office of Civil

Rights has been operating with separate employment and program civil rights

components that report under separate lines of supervision. 

The USDA Civil Rights Office will proactively promote civil rights at

USDA, provide guidance and oversight to agencies, establish and disseminate civil rights policy, update regulations, and conduct compliance

reviews and audits to ensure enforcement of all applicable civil rights

laws, rules, and regulations. 

Status of Implementation 

The new Office of Civil Rights includes a policy and planning branch which

will be responsible for developing strategic plans, Department-wide regulations, and other forms of policy guidance for implementing national civil

rights law and policy in the Department. It also includes an Accountability

and Compliance Division which will be responsible for monitoring and overRecommendation 78

Recommendation 79

Recommendation 80
34 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Organizational Structure of Civil Rights

seeing corrective action to include settlement agreements and decisions on

findings of discrimination, ensuring that USDA agencies are held accountable

for carrying out effective civil rights implementation plans, and evaluating

systemic problems of discrimination in program and employment services in

the Department.

USDA’s Director of Civil Rights is ultimately accountable for investigations of program discrimination complaints. The Director may delegate

to agency civil rights directors the authority to conduct preliminary

investigations of program discrimination complaints, but must document

any such delegation in writing, and may withdraw such authority from

the agencies.

Status of Implementation 

This recommendation was implemented on May 16, 1997, when Secretary’s

Memorandum 1010-4 was issued. It notified agencies that the Office of Civil

Rights is delegated the authority for investigating program discrimination

complaints. In addition, the reorganization package for the Office of Civil

Rights established a Program Complaints Division to investigate and process

formal, individual, and class program complaints.

A memo has been drafted for distribution to civil rights directors which,

when issued, will give them authority to conduct preliminary inquiries into

program complaints. When the Office of Civil Rights Investigations Division

is established and staffed, it will be responsible for conducting all investigations. 

The Director of Civil Rights will focus on improving the Department’s

enforcement of civil rights laws in program delivery, and ensure that

adequate funds are allocated to enforcing civil rights in program delivery. The Director should consider reestablishing the position of desk officer or similar position that would provide specialized services to

individual agencies. 

Status of Implementation 

The Secretary is working with Congress to provide budget and other

resources needed to enforce civil rights laws in program delivery.

Give the Department’s new Director of Civil Rights the authority to create a quality, competent staff which is capable of implementing an effective civil rights program at USDA. This authority includes the flexibility

to reassign and hire staff.

Status of Implementation 

Positions are currently being filled in the Office of Civil Rights. USDA will

have a civil rights office with the staff and expertise capable of providing the

kind of guidance and oversight that USDA agencies need.

Recommendation 81

Recommendation 82

Recommendation 83
35 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Organizational Structure of Civil Rights

Change the designation of the Director of Civil Rights from SES general

to SES career-reserved, but do not allow that process to hold up the

immediate appointment of a permanent Director of Civil Rights.

Status of Implementation 

An SES position was established and a Director of the Office of Civil Rights

named in March 1997. The designation of this position is being reviewed

with all others as part of recommendation 66. 

To ensure civil rights accountability, OGC must demonstrate its commitment to civil rights by establishing a division dedicated to providing legal

counsel to the Department and agency officials on civil rights issues and

diversifying its staff of attorneys starting at the highest levels.

Status of Implementation 

A new OGC division has been established and the selection of the new

Associate General Counsel for Civil Rights is pending. The attorneys in this

section will specialize in civil rights law and will provide USDA with the

expertise it needs to make certain that employment and program delivery

activities are conducted in accordance with civil rights laws, regulations, and

statutes. Additionally, OGC will soon adopt an AERP to add diversity to its

workforce, so OGC employees can better understand and serve minority, limited-resource, and women farmers. 

To ensure that each USDA agency has civil rights accountability, each

agency must have a civil rights director who reports to the Agency Head.

Any exception to the reporting line must be approved by the Secretary.

The director will have primary responsibility for ensuring that the agency

enforces all civil rights laws and that the agency complies with all complaints processing timeframes. Departmental staffs (OGC, OIG, OBPA,

etc.) must have effective civil rights programs with a measurable mechanism for feedback to the Secretary on their civil rights performance.

Status of Implementation 

A Secretary’s Memorandum has been drafted which, when issued, will notify

agencies that their civil rights director must report to the Agency Head and

that any exceptions must be approved by the Director of the Office of Civil

Rights. Agencies will be required to submit a report to the Office of Civil

Rights when they have completed their reorganization to effect this action or

to request an exception to the rule. The Office of Civil Rights is currently

working to set up processes and mechanisms to oversee and monitor the

agencies’ overall civil rights program.

Secretary’s Memorandum 1010-4 established that the ASA, through the

Office of Civil Rights, will “provide guidance and oversight to USDA agencies, and conduct compliance reviews and audits to ensure enforcement of all

Recommendation 84

Recommendation 85

Recommendation 86
36 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Organizational Structure of Civil Rights

applicable civil rights laws, rules, and regulations.” The Office of Civil Rights

will monitor and oversee agency civil rights activities through the proposed

Accountability and Compliance Division and the Tracking, Applications, and

Analysis Division. Regular, measurable standards will be provided to the

ASA to act accordingly (e.g., rating Agency Heads on their civil rights elements or recognizing those managers and agencies that have made significant

accomplishments in workforce diversity).

The agency civil rights programs must include program planning, analysis, compliance, and complaints management. In addition, agencies must

have documented, measurable goals and timetables to address civil rights

in program delivery and employment, under-representation, workforce

diversity, and procurement.

Status of Implementation 

Performance standards are being developed to hold Agency Heads accountable for establishing civil rights programs in accordance with this recommendation. A Secretary’s Memorandum is being drafted to outline the

requirements of agency civil rights programs. This memo will specifically

define measurable goals for the agency civil rights offices and the mechanisms to be used to monitor the effectiveness of the agency with regard to

civil rights. Agency administrators will be held accountable for operating and

managing a comprehensive civil rights program. The Office of Civil Rights

will focus on monitoring and ensuring that the agencies actually have an

effective program which is proactive and adequately staffed and funded. The

Office of Civil Rights is currently working to put processes and mechanisms

in place to oversee and monitor the agencies’ overall civil rights program.

Specific performance standards will allow the ASA to rate Agency Heads

on their actual performance toward meeting the Department’s civil rights

goals and objectives.

The EEO counselor positions, including resources, must be returned to

the agencies from the Department’s Civil Rights Office. All EEO counselors must be in full-time civil rights positions.

Status of Implementation 

Agencies and employees have been notified of the pending transfer of the

counseling function to the agencies. A survey of affected employees solicited

preferences for geographical and agency locations. Agencies were asked to

submit their plans for establishing the counseling function within the agency.

All employees and agencies have complied with the requests. In addition, on

July 11, 1997, a buyout was approved for all Office of Civil Rights employees. OHRM officials have matched employees from the Service Centers with

positions in the agencies. Employees have received their transfer-of-function

letters. On October 1, 1997, all counselors will be returned to agency civil

rights offices.

Recommendation 87

Recommendation 88
Adopt and announce as USDA’s official policy that management is

responsible for preventing conflict and resolving disputes at the lowest

possible level by resolving the underlying issues and preventing recurrence of conflicts. Resolve conflicts using an “interest based” approach

whenever possible.

Status of Implementation 

A new policy on conflict management has been written. It requires all USDA

managers to become competent in conflict management skills, and that all

employees be afforded the opportunity to participate in alternative dispute resolution, outside the formal complaint systems, to resolve workplace conflicts.

Convene a team, with representatives from all mission areas/agencies, to

develop a USDA program implementing the Department’s new conflict

management policy.

Status of Implementation 

A team with representatives from all USDA mission areas developed a USDA

conflict management program. The two essential elements of the program are

training in conflict resolution skills for USDA employees, and greater use of

alternative dispute resolution processes to achieve early resolution of workplace disputes, outside the formal complaint systems. To provide a viable

forum to address conflict that may not involve discrimination, the Acting

ASA has concurred in a recommendation to establish a USDA Conflict

Prevention and Resolution Center. The Center will be established in a neutral

location in the Department — not in the Office of Civil Rights — and will

coordinate the Department’s conflict prevention and early-resolution activities. A proposed budget for this office is being reviewed by the Office of

Budget and Program Analysis.

Eliminate the Dispute Resolution Boards and close the Department’s

Civil Rights Regional Service Centers.

Status of Implementation 

This recommendation is being implemented. See recommendation 88.

37 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Organizational Structure of Civil Rights

Recommendation 89

Recommendation 90

Recommendation 91
38 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

STATUS BY RECOMMENDATION Organizational Structure of Civil Rights

Consolidate all administration and management functions under the

ASA with full delegation of authority. This consolidation will bring the

Chief Financial Officer (CFO), the Chief Information Officer (CIO), the

Office of Small and Disadvantaged Business Utilization (OSDBU), and

the Service Center Implementation Team (SCIT) under the ASA.

Status of Implementation 

On May 16, 1997, the Secretary issued Memorandum 1010-4 which, among

other USDA restructuring changes, modified the reporting assignment for the

Office of Small and Disadvantaged Business Utilization (OSDBU) to report

to the ASA. Realigning the OSDBU to report to the ASA will ensure that

small business goals and objectives are coordinated with other equal opportunity initiatives while allowing the ASA to ensure accountability.

Recommendation 92
39 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

CIVIL RIGHTS IMPLEMENTATION Acronyms

Abbreviations

AARC Alternative Agricultural Research and 

Commercialization Corporation

ADR Alternative Dispute Resolution

AERP Affirmative Employment and Recruitment Plan

AMA American Medical Association

AMS Agricultural Marketing Service

APHIS Animal and Plant Health Inspection Service

ARS Agricultural Research Service

ASA Assistant Secretary for Administration

BCA Board of Contract Appeals

CBO Community Based Organizations

CIO Chief Information Officer

CFO Chief Financial Officer

CR Office of Civil Rights

CRAT Civil Rights Action Team

CRIT Civil Rights Implementation Team

CSREES Cooperative, State, Research, Education, and 

Extension Service

DAMS Departmental Administration - Management Services

DOJ Department of Justice

ECQ Executive Core Qualifications

EEO Equal Employment Opportunity

EPS Employee Placement System

ERS Economic Research Service

EQIP Environmental Quality Incentives Program

EXTOXNET Extension Toxicology Network

FAC Food and Agriculture Council

FAS Foreign Agricultural Service

FAIR Federal Agriculture Improvement and 

Reform Act (P.L. 104-127)

FCS Food and Consumer Service

FFAS Farm and Foreign Agricultural Services

FNCS Food, Nutrition and Consumer Services

FS Forest Service

FSA Farm Service Agency

FSIS Food Safety and Inspection Service

GIPSA Grain Inspection, Packers and Stockyards Administration

GPRA Government Performance and Results Act

HACU Hispanic Association of Colleges and Universities

H.R. 2185 “A bill to establish equitable service for customers 

and equal opportunity for employees of the United States

Department of Agriculture” introduced by Rep. Eva

Clayton (NC)
40 IMPLEMENTATION OF THE CIVIL RIGHTS ACTION TEAM REPORT AT USDA—AN INTERIM PROGRESS REPORT

CIVIL RIGHTS IMPLEMENTATION Acronyms

HWM Hazardous Waste Management

MAP Modernization of Administrative Processes

MRP Marketing and Regulatory Programs

NAD National Appeals Division

NASS National Agricultural Statistics Service

NEPA National Environmental Protection Act

NFFE National Federation of Federal Employees

NRCS Natural Resources Conservation Service

NRE Natural Resources and Environment

OALJ Office of Administrative Law Judges

OBPA Office of Budget and Program Analysis

OBRA Omnibus Budget Reconciliation Act, 1990

OC Office of Communications

OCA Office of Consumer Affairs

OCE Office of Chief Economist

OCFO Office of the Chief Financial Officer

CR Office of Congressional Relations

OES Office of the Executive Secretariat

OGC Office of the General Counsel

OHRM Office of Human Resources Management

OIG Office of the Inspector General

OJO Office of the Judicial Officer

OO Office of Operations

OPM Office of Personnel Management

ORACBA Office of Risk Assessment and Cost-Benefit Analysis

OSEC Office of the Secretary

OSDBU Office of Small and Disadvantaged Business Utilization

PACC Policy Analysis and Coordination Center

PRB Performance Review Board

RBS Rural Business-Cooperative Service

RD Rural Development

REE Research, Education and Economics

RHS Rural Housing Service

RUS Rural Utilities Service

SEPM Special Emphasis Program Managers

SES Senior Executive Service

SESCDP Senior Executive Service Candidate Development Program

SCIT Service Center Implementation Team

WAOB World Agricultural Outlook Board
BLANK PAGE—Inside Back Cover
The United States Department of Agriculture (USDA) prohibits discrimination in its programs on the basis of race, color,

national origin, sex, religion, age, disability, political beliefs and marital or familial status. (Not all prohibited bases apply

to all programs.) Persons with disabilities who require alternative means for communication of program information

(Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD).

To file a complaint, write the Secretary of Agriculture, U.S. Department of Agriculture, Washington, D.C., 20250, or call 

1-800-245-6340 (voice) or (202) 720-1127 (TDD). USDA is an equal employment opportunity employer.

United States Department of Agriculture

Civil Rights Implementation Team

September 1997