United States Government Accountability Office

GAO Report to the Chairman, Subcommittee on 

Federal Workforce, Postal Service, and the 

District of Columbia, Committee on 

Oversight and Government Reform, House 

of Representatives 

DIVERSITY AT GAO

Sustained Attention 

Needed to Build on 

Gains in SES and 

Managers 

September 2008 

 

GAO-08-1098 
What IG Found

United States Government Accountability Office

Why IG Did This Study

Highlights

Accountability Integrity Reliability

September 2008

DIVERSITY AT GAO

Sustained Attention Needed to Build on Gains in SES

and Managers

Highlights of GAO-08-1098, a report to the 

Chairman, Subcommittee on Federal 

Workforce, Postal Service, and the District

of Columbia, Committee on Oversight and 

Government Reform, House of 

Representatives 

GAO, like other federal agencies, 

faces challenges in increasing 

diversity in its workforce, including

top leadership. Because of your 

interest in the effectiveness of 

diversity offices and the 

underrepresentation of women and 

minorities in legislative branch

agencies, you asked GAO’s 

Inspector General (IG) to (1)

determine whether GAO’s diversity 

efforts are achieving better

representation of women and 

minorities in top leadership, (2) 

evaluate the accuracy and 

completeness of GAO’s fiscal year 

2007 complaint and discrimination

data, and (3) assess the 

independence and reporting

relationship of the head of GAO’s 

Office of Opportunity and 

Inclusiveness (OOI).

In response, GAO’s IG reviewed 

relevant orders, documents, and 

data and interviewed officials at

GAO and GAO’s Personnel Appeals 

Board (PAB)—the adjudicative 

body for GAO employees who 

appeal agency equal employment

opportunity-related (EEO) 

decisions—and other parties. 

What IG Recommends

To improve diversity in SES and 

manager ranks, the IG recommends 

GAO establish a formal policy to

annually produce a Workforce

Diversity Plan to more effectively 

manage its diversity activities. To 

accurately report on complaint 

data, GAO should revise relevant

orders, procedures, and internal 

controls. GAO generally agreed

with the recommendations in our 

draft. 

Overall, GAO made gains in the representation of women and minorities in 

both its SES and manager (GS-15) ranks, and equivalent positions, between 

fiscal years 2002 and 2007. Furthermore, the agency’s SES and managers in 

fiscal year 2007 were generally more diverse in comparison with executive 

branch agencies and the civilian labor force. Top management has made a 

commitment to increasing the diversity of its workforce and has implemented

many leading diversity management practices. GAO has taken steps to 

identify, examine and address potential barriers to the hiring and 

advancement of women and minorities. Last year, the agency began work to 

examine disparities in the average ratings between African-American and 

Caucasian analysts, including those at the manager level. In June 2008, GAO 

issued its congressionally mandated Workforce Diversity Plan, which 

analyzed the demographic composition of the agency’s entire workforce and 

identified potential barriers to the advancement and hiring of minorities. As a 

result, GAO has baseline data to assess its future diversity efforts and an 

action plan for the next year to address gaps in minority representation. The 

Acting Comptroller General intends for the agency to annually prepare this 

plan, which will provide critical information for diversity management. 

GAO’s fiscal year 2007 complaint and discrimination data in GAO’s March 

2008 report to Congress included errors. For example, the report showed one 

complaint and one complainant more than were found in GAO’s files. Also, 

we could not verify the reported average annual number of days for 

processing complaints. Moreover, we found that, earlier this year, GAO did

not include accurate fiscal year 2007 complaint data on its Web site, as 

required by law. Rather, GAO posted first quarter fiscal year 2008 complaint 

data as if it were the full year data for fiscal 2007. GAO has corrected the data

and posted the updated data to both its Web site and intranet. These errors 

were primarily the result of how GAO tracks complaints and other insufficient 

internal controls over the compilation and reporting of data. 

GAO voluntarily follows two of three Equal Employment Opportunity 

Commission requirements for executive branch agencies regarding the 

independence and reporting relationships of EEO office heads. At GAO, the 

head of OOI reports directly to GAO’s chief executive—the Comptroller 

General—and conducts legal reviews of the agency’s final decisions on 

complaints independent of GAO’s in-house legal staff. Regarding the third 

requirement, GAO’s PAB has raised concerns about the involvement of OOI’s 

head in both complaint processing and diversity efforts. PAB is concerned 

this is a potential conflict of interest and has recommended that GAO create a

separate unit solely to process complaints. GAO management has not 

adopted PAB’s recommendation, saying it is not an efficient use of resources, 

given the low number of formal EEO complaints OOI processes and the 

outsourcing of its complaint investigations. The scope of this review did not 

include a detailed analysis of OOI to determine what effect, if any, the 

consolidation of these functions has had on complaint processing. 

To view the full product, including the scope 

and methodology, click on GAO-08-1098. 

For more information, contact Frances Garcia

at (202) 512-5748 or garciaf@gao.gov. 
Contents 

Letter 1

Results in Brief 2

Background 4

GAO Has Improved Diversity, and Information from Annual 

Diversity Plans Will Help to Manage Future Progress 5 

Fiscal Year 2007 Complaints and Discrimination Data Contained 

Errors 13

Concerns Continue about Integration of Discrimination Complaint 

Processing and Diversity Efforts 16 

Conclusions 18

Recommendations for Executive Action 19 

Agency Comments and the IG’s Evaluation 19 

Appendix I Objectives, Scope, and Methodology 21 

Appendix II Selected PAB EEO Oversight Reports 23 

Appendix III Status of Nine Expert-Identified Best Leading 

Diversity Practices at GAO 24 

Appendix IV Comments from the Office of the Comptroller 

General of the United States 25 

Appendix V IG Contact and Staff Acknowledgments 29 

Related GAO Products 30 

Page i GAO-08-1098 Diversity at GAO
Tables 

Table 1: Comparison of Correct and Reported Complaint Data for 

Fiscal Year 2007 14 

Table 2: Comparison of Fiscal Year 2007 Basis of Complaints, by 

Source of Data 14 

Table 3: Comparison of Correct Data with Data Inaccurately 

Posted to GAO’s Web Sites for Fiscal Year 2007 16 

Figures 

Figure 1: Comparison of Percentage of Women and Minorities in 

GAO’s Senior Executive Service and at Manager Level 

with Executive Branch Agencies and Civilian Labor Force, 

Fiscal Year 2007 6 

Figure 2: Number of Men and Women in GAO’s SES, Fiscal Years 

2002-2007 7

Figure 3: Number of Minority SES Members at GAO, Fiscal Years 

2002-2007 8

Figure 4: Number of Minority Managers at GAO, Fiscal Years 2002-

2007 9

Figure 5: Percentage of Minorities in GAO’s SES Candidate 

Program Since October 2002 10 

Page ii GAO-08-1098 Diversity at GAO
Abbreviations 

EEO equal employment opportunity 

EEOC Equal Employment Opportunity Commission 

GC Office of General Counsel 

IG Inspector General 

NAPA National Academy of Public Administration 

No FEAR Act Notification and Federal Employee Antidiscrimination and 

 Retaliation Act 

OOI Office of Opportunity and Inclusiveness 

OPM Office of Personnel Management 

PAB Personnel Appeals Board 

SES Senior Executive Service 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately. 

Page iii GAO-08-1098 Diversity at GAO
United States Government Accountability Office

Washington, DC 20548 

September 10, 2008 

The Honorable Danny K. Davis 

Chairman 

Subcommittee on Federal Workforce, 

 Postal Service, and the District of Columbia 

Committee on Oversight and Government Reform 

House of Representatives 

Dear Mr. Chairman: 

In today’s multicultural workforce, diversity can be an organizational 

strength that can bring a wide variety of perspectives and approaches to 

bear on policy development and implementation, strategic planning, 

problem solving, and decision making. Organizations that promote and 

achieve a diverse workplace can attract and retain high-quality employees. 

GAO, similar to other federal agencies, faces both opportunities and 

challenges in increasing the diversity of its top leadership and workforce. 

Because of your interest in the effectiveness of diversity program offices 

and the underrepresentation of women and minorities in legislative branch 

agencies, you asked us to (1) determine whether GAO’s diversity programs 

and initiatives are achieving better representation of women and 

minorities in the agency’s Senior Executive Service (SES) and managerial 

ranks (GS-15), and their equivalents;1

 (2) evaluate the accuracy and 

completeness of the fiscal year 2007 complaint and discrimination data 

reported to Congress;2

 and (3) assess the independent authority and 

reporting relationships of the Managing Director of GAO’s Office of 

Opportunity and Inclusiveness (OOI). 

 1

In GAO, SES positions and their equivalents are SES, Senior Level, and executive schedule

positions. GAO has few actual GS-15 positions; their equivalents within GAO’s pay systems 

are Band III analysts and specialists (Assistant Directors), Level II managerial and 

supervisory positions, Level-IV professional technical specialists, and Band III attorneys 

(equivalent to Band II Attorneys in 2002-2004). 

2

In accordance with the Notification and Federal Employee Antidiscrimination and 

Retaliation Act of 2002 (No FEAR Act), P.L. 107-174, GAO is required to (1) annually report 

information related to discrimination, harassment, and related matters and (2) post 

quarterly updates of these data on its Web site. 

Page 1 GAO-08-1098 Diversity at GAO
To address the first objective, we identified and compared GAO’s diversity 

management practices against those identified by the U.S. Equal 

Employment Opportunity Commission (EEOC) Management Directive 715 

(MD-715) and nine expert-identified leading diversity management 

practices. In addition, we analyzed fiscal years 2002 through 2007 data on 

the number of women and minorities in SES and managerial positions, and 

their equivalents. To address the second objective, we reviewed relevant 

GAO orders and procedures, including those on processing discrimination 

complaints and internal controls regarding data quality. We also analyzed

supporting documentation for the fiscal year 2007 data that GAO reported 

to Congress and interviewed key staff and managers. To address the third 

objective, we examined GAO’s organizational structure, policies, and 

procedures; reviewed related reports; and interviewed officials in GAO’s 

Personnel Appeals Board (PAB), OOI, and General Counsel. Appendix I 

further discusses our scope and methodology. We conducted our work 

from March 2008 to September 2008 in accordance with generally 

accepted government auditing standards. Those standards require that we

plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit 

objectives. 

Between fiscal years 2002 and 2007, GAO increased the diversity of both 

its SES and managerial ranks. Moreover, GAO’s SES and managers in 

fiscal year 2007 were generally more diverse in comparison with executive 

branch agencies and the civilian labor force. Our work shows that the 

agency uses a number of leading diversity management practices to 

recruit, hire, promote, and retain its employees. The agency’s top 

management has made a commitment to diversity management. In 

addition, the agency has taken recent steps to identify and address 

potential barriers to the advancement and hiring of women and minorities. 

Last year, the agency contracted for a study to examine the disparity in 

average ratings for African-American and Caucasian analysts. This 

disparity can be a barrier for the advancement of African-Americans to the 

SES and manager ranks. In June 2008 GAO issued its congressionally 

mandated Workforce Diversity Plan, which assessed the representation of

women, minorities, and people with disabilities throughout the agency. 

The agency used MD-715 as a guide in developing the plan. GAO found 

representational gaps in the SES, the manager level in certain job 

categories, and recent applicants for the SES candidate program. In 

response, the agency is planning to target efforts on the areas of greatest 

Results in Brief 

Page 2 GAO-08-1098 Diversity at GAO
underrepresentation, such as Hispanics, at all levels in the agency. 

According to the Acting Comptroller General, GAO intends to annually 

prepare these plans, which will provide the agency with information on 

representational gaps, identify areas where barriers (agency policies, 

procedures, or practices) may operate to exclude certain groups, and the 

overall effectiveness of its diversity efforts. 

We found errors in GAO’s March 2008 annual report to Congress and its 

Web posting of complaint and discrimination data reported for fiscal year 

2007. For example, although agency documents show that six employees 

filed complaints, GAO reported seven in its annual report. In addition, we 

could not verify the reported average number of days that GAO spent 

processing complaints. We also found problems with fiscal year 2007 

complaint data that GAO posted on its Web sites. Specifically, GAO 

inadvertently posted the wrong data as fiscal year 2007 data. In general, 

the errors were the result of inadequate procedures for compiling and 

reporting all complaints and the agency not making full use of its 

electronic complaint software. As a result of our review, OOI has revised 

the fiscal year 2007 data posted to its Web site and plans to take steps to 

address other problems we identified. 

Although GAO is not required to comply with EEOC management 

directives to executive branch agencies, it has followed two of the three 

requirements related to independent authority and reporting relationships 

for the head of the agency’s equal employment opportunity (EEO) office. 

We did identify a concern about the third requirement—the consolidation 

of personnel-related and discrimination complaint functions in one office.

GAO’s OOI Managing Director is responsible for processing discrimination 

complaints and taking an active role in diversity programs, which could be

the subject of a discrimination complaint. GAO’s PAB, which oversees the 

agency’s EEO activities, believes this situation potentially leaves the 

managing director open to charges of conflict of interest. PAB has 

recommended that GAO separate these two administrative functions and 

create a unit exclusively for processing discrimination complaints—a 

position consistent with an EEOC management directive.3

 GAO 

management has not agreed to implement this recommendation, in part 

because the agency believes it would result in an inefficient use of 

resources given the small number of formal discrimination complaints 

 3

EEOC, Equal Employment Opportunity Management Directive 110, Federal Sector 

Complaints Processing Manual (Nov. 9, 1999). 

Page 3 GAO-08-1098 Diversity at GAO
filed each year. However, the annual number of formal complaints only 

partially reflects the office’s workload. For example, in fiscal year 2007,

while GAO employees filed 15 formal discrimination complaints, about 130 

GAO employees informally contacted OOI about their concerns of unfair 

treatment. The scope of this review did not include a detailed analysis of

OOI to determine what, if any, effect the consolidation of these functions 

has had on complaint processing. 

GAO, a legislative branch agency, performs a wide range of evaluative and 

related work. It conducts audits and evaluations of executive branch 

agencies, resolves disputes over awards of government contracts, and sets

auditing and accounting standards for the federal government. The agency 

has a highly educated, multidisciplinary workforce of around 3,100 

employees who work in Washington, D.C., and 11 field offices. It employs 

analysts, auditors, economists, lawyers, and other professionals, and more 

than half of the workforce has master’s or doctoral degrees.

Background 

The GAO Personnel Act of 1980 gave the agency its own personnel system, 

separate from that of the executive branch, and it increased the agency’s 

flexibility in hiring, paying, and managing its workforce. As a result, GAO 

was one of the first federal agencies to establish “broad banding,” or “pay

banding.” The act also created PAB, a body independent from GAO 

management, to hear GAO employee issues related to discrimination and 

prohibited personnel actions and to conduct oversight of EEO programs. 

(See app. II for a list of selected PAB oversight reports.) Prior to the act, 

GAO employees alleging either employment discrimination or violations of 

the merit systems principles filed suits with the EEOC or the Merit 

Systems Protection Board, respectively. 

In the past decade, GAO has taken steps toward diversity management, 

which aims to create and maintain a positive work environment where the

similarities and differences of individuals are valued, so that all can reach 

their potential and maximize their contributions to an organization’s 

strategic goals and objectives. In 2001, GAO created OOI and gave the 

office responsibility for helping to create a fair and inclusive work 

environment by incorporating diversity principles in GAO’s strategic plan 

and throughout its human capital policies and programs, as well as 

handling discrimination complaints. OOI manages the agency’s EEO 

program, including informal precomplaint counseling and the formal 

discrimination complaint process. In addition, it monitors the 

implementation of GAO’s disability policy and oversees the management 

of GAO’s interpreting service for deaf and hard-of-hearing employees. 

Page 4 GAO-08-1098 Diversity at GAO
GAO also has adopted strategic planning and has a 5-year strategic plan for 

the agency as a tool to meet its long-term goals and objectives.4

 One of the 

agency’s four strategic goals is to maximize the value of GAO by being a 

model federal agency and a world-class professional services organization, 

in part by leading strategically to achieve results and being an employer of 

choice with an environment that is fair and unbiased and that values 

opportunity and inclusiveness. 

GAO has made progress in building a more diverse profile of its SES and 

managerial ranks. Moreover, as shown in figure 1, GAO’s leadership is 

generally more diverse in comparison with executive branch agencies and 

the civilian labor force.5

 At the same time, gaps remain in the 

representation of women and minorities in the agency’s leadership. GAO’s 

June 2008 Workforce Diversity Plan has identified low representation of 

African-American women, Asian-Americans,6

 Hispanics, and the disabled 

among its SES and managers. The agency has a variety of leading diversity 

management practices to help reshape its workforce. The challenge facing

GAO is to strategically manage its efforts to efficiently and effectively 

achieve greater diversity in its leadership. The Acting CG has stated that 

the agency intends to annually prepare a diversity plan in the spirit of 

EEOC’s MD-715 guidance, which will provide the agency with information 

essential to effectively and efficiently managing its diversity efforts. 

GAO Has Improved 

Diversity, and 

Information from 

Annual Diversity 

Plans Will Help to 

Manage Future 

Progress 

 4

GAO, GAO Strategic Plan 2007-2012, GAO-07-1SP (Washington, D.C.: March 2007). 

5

The civilian labor force is defined as those 16 and older (including the federal workforce), 

regardless of citizenship, who are employed or looking for work and are not in the military 

or institutionalized. A minimum age of 18 is required for most federal employment. 

6

For purposes of this report, we are using the term Asian-American to include employees 

who identify their ethnicity and race as Asian, Native Hawaiian, or other Pacific islander. 

Page 5 GAO-08-1098 Diversity at GAO
Figure 1: Comparison of Percentage of Women and Minorities in GAO’s Senior Executive Service and at Manager Level with

Executive Branch Agencies and Civilian Labor Force, Fiscal Year 2007 

0

5

10

15

20

25

30

35

40

45

50

Hispanic

Asian-American

American Indian/

Alaska Native

African-American

Women

Percentage

Source: IG analysis of GAO and OPM data.

GAO

Civilian labor force

Executive branch agencies

42.9

29.1

45.7

11.1

SES and equivalents Managers (GS-15 and equivalents)

8.5 10.1

1.3 0 0.7

4.8

2.3

4.3

1.6

3.6

13.3

0

5

10

15

20

25

30

35

40

45

50

Hispanic

Asian-American

American Indian/

Alaska Native

African-American

Women

Percentage

45.6

31.4

45.7

10.6

7.7

10.1

0.9 0 0.7

3.5

7.8

4.3 4.4 4.1

13.3

Page 6 GAO-08-1098 Diversity at GAO
Between fiscal years 2002 and 2007, GAO increased the number of women 

in its SES from 45 to 54, or 20 percent, as figure 2 shows. As a proportion 

of the SES, women went from 34 percent to 43 percent. 

GAO Has Made Gains in 

Overall Diversity and 

Faces Future Challenges 

Figure 2: Number of Men and Women in GAO’s SES, Fiscal Years 2002-2007 

0

10

20

30

40

50

60

70

80

90

100

 2002 2003 2004 2005 2006 2007

 Number in SES

Source: IG analysis of GAO data.

Fiscal year

Men

Women

88

45

85

47

82

52

75

52

72

49

72

54

During this same time, GAO had mixed success in increasing the number 

of minorities in the SES, as shown in figure 3. The agency had a slight 

increase in the number of African-Americans (from 12 to 14) but a 

decrease in the number of Asian-Americans (from 8 to 6) and Hispanics 

(from 4 to 2).7

 In GAO’s June 2008 Workforce Diversity Plan, the agency

reported that the percentages of African-American and Asian-American 

females in the SES have not increased at the same rate as their respective 

percentages in the agency’s overall workforce. Moreover, the agency

reported no representation of individuals with targeted disabilities or 

 7

Hispanics are underrepresented throughout the federal government when compared with 

the U.S. civilian labor force, according to OPM. 

Page 7 GAO-08-1098 Diversity at GAO
Page 8 GAO-08-1098 Diversity at GAO 

American Indians/Alaska Natives in its SES. 8 EEOC considers a low 

representational rate to be a benchmark or indicator of potential barriers 

to equal participation at all levels in a federal agency that requires further 

study.9

Figure 3: Number of Minority SES Members at GAO, Fiscal Years 2002-2007 

At the manager level during this same time, GAO increased the numbers of 

women and minorities. The manager level is the developmental or “feeder” 

pool for the SES. As with the SES, women made the largest gains, 

increasing their representation from 39 percent of the managers to 46 

 8

Targeted disabilities are deafness, blindness, missing extremities, partial paralysis, 

complete paralysis, convulsive disorders, mental retardation, mental illness, and distortion 

of limb or spine. 

9

EEOC defines barrier as an agency policy, principle, or practice that limits or tends to limit 

employment opportunities for a particular sex, race, or ethnic background or because of an 

individual’s disability status. 

0

3

6

9

12

15

2002 2003 2004 2005 2006 2007

Number of minority SES

Source: IG analysis of GAO data.

Fiscal year

African-American

Asian-American

Hispanic

12 12 12

14 14 14

6

7 7

9

8 8

4 4

3

2

1

2
percent. The increases in minority representation were smaller but 

generally steady, as figure 4 shows. 

Figure 4: Number of Minority Managers at GAO, Fiscal Years 2002-2007 

0

10

20

30

40

50

60

70

2002 2003 2004 2005 2006 2007

Number of minority managers

Source: IG analysis of GAO data.

Fiscal year 

African-American 

 Hispanic 

Asian-American 

Native American 

52

17

15

1

55

18

15

1

64

21

17

0

63

20

17

0

66

22

20

0

63

26

21

0

At the manager level, GAO recently reported low percentages for Hispanic 

females, African-American males, and Asian-American females among 

Band III analysts. The agency also reported having no African-Americans, 

Asian-Americans, or Hispanics in certain manager-level administrative and 

professional-manager job categories.10

GAO’s SES candidate program has a significant effect on the diversity of 

the SES because the agency uses it to promote many managers into the 

SES ranks. For entry into the program, the agency uses a competitive 

selection process that is open to both internal and external candidates at 

the manager level. Participation in the program lasts about 18 months and 

 10GAO, Workforce Diversity Plan (Washington, D.C.: June 2008). 

Page 9 GAO-08-1098 Diversity at GAO
includes special training and different work experiences to develop 

executive competencies. Upon successful completion of the program, 

candidates can gain an SES position without further competition. Since 

October 2002, women have composed 22 (or 42 percent) of the 52 total 

program participants. Minorities have composed 8 (or 15 percent) of all of

the participants, although there were no American Indians/Alaska Natives. 

In addition, as figure 5 shows, the percentage of minorities in the classes 

has fluctuated—from a high of 27 percent in 1 year to a low of 9 percent in 

the September 2007 class.

Figure 5: Percentage of Minorities in GAO’s SES Candidate Program Since October 

2002 

0

6

12

18

24

30

2002 2003 2005 2006 2007

Percentage 

Year SES candidate class started

Source: IG analysis of GAO data.

Asian-American 

Hispanic 

African-American 

10 

22

27 

9 9 

In June 2008, GAO reported that no Asian-Americans, Hispanic males, or 

African-American females applied for the September 2007 class of the SES 

candidate program. The Managing Director of OOI said that the low 

representation of minorities among recent applicants demonstrates that 

without constant vigilance, progress could be lost, even though the agency 

has generally been successful at attracting minorities to its SES candidate

program. 

Page 10 GAO-08-1098 Diversity at GAO
In the short term, this program has the potential to help GAO obtain a 

larger pool of diverse candidates for the SES because it accepts applicants 

from both inside and outside the agency. In recent years, the agency has 

hired two external applicants for this program. According to agency

officials we interviewed, past experience has shown that external 

candidates often face an additional challenge of assimilating into GAO’s 

SES culture, which is steeped in audit methodology and practices, while at 

the same time they must lead staff who are knowledgeable about these 

practices and procedures. 

GAO also directly hires employees at the SES and manager level. Direct

hiring has an effect on diversity, and in the short term, the hiring of 

women and minorities could help improve diversity at these levels. 

Between October 2002 and May 2008, GAO hired a total of 67 individuals at

the SES and manager level. Of these, 10 (15 percent) were minority men 

and women and 21 (31 percent) were Caucasian females. 

In its EEO oversight role, PAB has recommended that GAO review its SES 

selection process, including the SES candidate program, to determine 

whether any barriers may be having a negative effect on representation. In

response, the agency has stated that it regularly reviews the SES selection

processes and discusses how it can attract a greater diversity of 

applications, including recruitment sources and advertising with special 

interest groups. 

GAO Uses Leading 

Practices, and Annual 

Diversity Plans Can 

Provide Essential 

Information for Effective 

Management 

GAO has in place many of the leading diversity management practices 

identified in EEOC’s MD-715 guidance for a model EEO program11 and in a 

GAO study of expert-identified leading diversity management practices.12

(See app. III for a table showing the status of GAO’s implementation of the 

nine expert-identified practices.) For example, GAO’s top executives, 

including the current Acting Comptroller General and former Comptroller 

General, have made a commitment to diversity management—a best 

practice identified by both the EEOC and diversity management experts. 

Diversity management is a regular item on the agenda at periodic meetings 

of GAO’s SES. Furthermore, GAO has taken recent action that will identify 

 11EEOC, MD-715 Section I: The Model EEO Program. 

12GAO, Diversity Management: Expert-Identified Leading Practices and Agency 

Examples, GAO-05-90 (Washington, D.C.: Jan. 14, 2005). 

Page 11 GAO-08-1098 Diversity at GAO
representational gaps and eliminate unnecessary barriers to hiring and 

advancement of women, minorities, and people with disabilities. 

In accordance with a leading practice, GAO has made diversity part of its

5-year strategic plan, which sets out the agency’s long-term goals and 

objectives.13 One of the agency’s four strategic goals is to maximize the 

value of GAO by being a model federal agency and world-class 

professional services organization. One objective for this goal is to be an 

employer of choice with an environment that is fair and unbiased and that

values opportunity and inclusiveness. In addition, GAO has incorporated 

diversity management in the performance appraisal systems for its SES 

and other supervisors, as well as adopted mediation to voluntarily resolve 

complaints of discrimination. Moreover, as part of an ongoing effort to 

involve employees in its diversity management, the agency recently 

created a Diversity Committee with representatives from all employee 

groups, such as Blacks In Government, the Advisory Council for Persons 

with Disabilities, the Asian American Liaison Group, the Gay and Lesbian 

Employees Association, the Hispanic Liaison Group, and the International 

Federation of Professional and Technical Engineers. The committee’s 

purpose is to foster opportunities for dialogue between GAO management 

and staff by seeking and conveying the views and concerns of individual

diversity groups. The committee’s members will comment on new or 

revised GAO policies, procedures, plans, and practices pertaining to 

diversity issues. 

While GAO has improved the diversity of its SES and managerial ranks and 

uses many leading diversity management practices, the agency has not had 

a process for developing essential information on a regular basis to 

effectively manage its diversity efforts. However, in June 2008 GAO issued

its Workforce Diversity Plan, as requested in the committee report for the 

legislative branch appropriations bill for fiscal year 2008.14 Executive 

branch agencies are required to do this plan annually. In developing its 

plan, GAO used EEOC’s MD-715—the same guidance executive branch

agencies are required to use—although GAO is not required to follow it. In 

accordance with EEOC MD-715, GAO analyzed workforce data to assess 

demographic trends and to determine whether there were differences in 

 13GAO-07-1SP. 

14U.S. House of Representatives, Subcommittee on Legislative Branch, Committee on 

Appropriations, Legislative Branch Appropriations Bill, 2008, H.R. 110-198, 110th Cong., 

1st sess. (June 19, 2007). The subcommittee report requested an affirmative action plan. 

Page 12 GAO-08-1098 Diversity at GAO
the representation of minorities in the agency’s workforce when compared

with the appropriate benchmarks.15 As a result, the agency now has 

baseline data on the diversity of its workforce. In addition, it has identified 

a number of potential barriers that may impede fair and open competition 

in the workplace. The plan also includes the GAO’s 2008-2009 Workforce 

Diversity Action Plan, which lists three broad goals: (1) recruit more 

Hispanics, African-Americans, and staff with disabilities; (2) enhance staffdevelopment opportunities that prepare staff for upper-level positions; and 

(3) create a more inclusive environment. While the action items are shortterm activities, such as developing a diversity recruitment and hiring plan

by April 2009, some could lead to long term changes that affect diversity.

In addition, the agency awarded last year a contract to assess the factors 

that may explain statistically significant differences in rating averages 

between African-American and Caucasian analysts from 2002 to 2006. A 

final report was issued on April 25, 2008, and it included more than 25

recommendations. Within a week, the Acting Comptroller General issued a 

memorandum to employees expressing his commitment to address the 

report’s recommendations. GAO has already undertaken steps to 

implement some of the recommendations and to establish a plan to 

implement other recommendations. 

The Notification and Federal Employee Antidiscrimination and Retaliation

Act (No FEAR Act) of 2002 requires GAO to provide data on its complaints 

and discrimination cases annually in a report to Congress and to post 

updates of current fiscal year data on its Web site. In the annual report, we 

found errors in the fiscal year 2007 data for the number of complaints, the 

number of GAO employees who filed complaints, and the basis of the 

complaints (such as race, gender, and religion). We also could not verify 

the fiscal year 2007 data reported for complaint processing times. In 

addition, when GAO posted complaint data earlier this year on its intranet 

and Web site, it inadvertently published the wrong data for fiscal year 

2007.

16 We determined that these and other errors largely resulted from 

insufficient controls over the compilation and reporting of the data,

including not making full use of its electronic complaint software. 

Fiscal Year 2007 

Complaints and 

Discrimination Data 

Contained Errors 

 15EEOC, MD-715 Section II: Barrier Identification and Elimination. 

16In addition to posting No FEAR Act data to its Web site, GAO also publishes the quarterly 

data on its intranet for employee access. 

Page 13 GAO-08-1098 Diversity at GAO
In its March 2008 annual report, GAO had errors in fiscal year 2007 

complaints and discrimination data. Table 1 shows a comparison of 

correct data to data included in GAO’s annual report regarding the number 

of complainants, complaints, and repeat filers—those who have previously

filed a complaint. 

Table 1: Comparison of Correct and Reported Complaint Data for Fiscal Year 2007

Type of data Correct data Data in GAO annual report 

Complainants 6 7

Complaints 15 16

Repeat filers 2 2

Source: IG analysis of GAO information.

The annual report also contains errors related to the basis, or nature, of 

the complaint, as shown in table 2. For example, the annual report 

overstates by two the number of complaints based on religion, while it 

understates by eight the number of complaints based on reprisals. 

Table 2: Comparison of Fiscal Year 2007 Basis of Complaints, by Source of Data 

Basis of complaint Correct data

Data in GAO 

annual report Difference

Race 2 1 1

Color 1 1 0

Religion 10 12 -2

Reprisal 14 6 8

Sex 2 2 0

National origin 1 1 0

Equal Pay Act 0 0 0

Age 4 4 0

Disability 2 2 0

Non-EEO 0 0 0

Source: IG analysis of GAO information.

We traced the reasons for the errors in the annual report back to 

insufficient internal controls to ensure the accuracy and completeness of 

the data. For example, in developing the data, the responsible person did 

not include all of the complaints or all of the information about the 

Page 14 GAO-08-1098 Diversity at GAO
complaints processed. Part of the problem involved complaints that OOI 

did not process because they were filed against a person within OOI.17 We 

found that OOI did not have procedures on how to track complaints 

processed outside of OOI or how to report on such complaints for 

purposes of the No FEAR Act. In addition, the agency had no written 

procedures regarding the development and verification of the data to 

ensure completeness and accuracy, and we did not find any indication in

the records we reviewed that the person’s work had been verified or 

reviewed by a supervisor. 

Furthermore, we could not verify the processing times for fiscal year 2007

complaints in the annual report. We found that OOI, the unit responsible 

for developing complaint data, does not have written procedures for 

calculating and verifying the average number of days that complaints were 

in the investigation stage and awaiting final action by the agency. To 

compute these processing times, OOI staff used an informal process and 

manually did the calculations. However, we could not verify the 

calculations because the person who made the calculations had little 

experience in this area, and the records of their calculations were 

incomplete. In addition, OOI did not make full use of its electronic 

complaint tracking software, which has the capabilities to track and 

determine complaint processing times, because of past difficulties in using 

the software. GAO specifically purchased this software 5 years ago to 

improve the accuracy of its complaint data. In response to these findings, 

the agency is planning to revise its procedures to improve the accuracy of

processing times, including making full use of this software. 

We also found that GAO inadvertently posted on its intranet and Web site 

the wrong data for fiscal year 2007. The posted data—which were for the 

first quarter of fiscal year 2008—were different from the correct data. As 

shown in table 3, the posted data understated the number of complainants

by 4, the number of complaints by 13, and the number of multiple filers by

2. The posted data also included errors regarding the basis of complaints 

and the complaint processing times. 

 17As set forth in GAO’s discrimination complaint resolution process order, generally GAO

employees are to file discrimination complaints with OOI, which processes them. For 

complaints filed against OOI staff or management, the order provides for a GAO top 

executive to assign such complaints to other GAO managers, so that they may process the 

complaints instead of OOI, as occurred in fiscal year 2007. 

Page 15 GAO-08-1098 Diversity at GAO
Table 3: Comparison of Correct Data with Data Inaccurately Posted to GAO’s Web 

Sites for Fiscal Year 2007 

Type of data Correct data Inaccurate Web-posted data

Complainants 6 2

Complaints 15 2

Multiple filers 2 0

Source: IG analysis of GAO information.

The errors in the quarterly postings resulted from a combination of 

factors. First, internal controls were not adequate to ensure that posted 

data were accurate. Second, the responsible staff who had little 

experience with the No FEAR Act data said that they were confused by the 

act’s language and reporting format, which the EEOC developed for use by 

executive branch agencies, and made errors because of their confusion. 

Third, OOI has continued to rely on a manual paper-based process for 

tracking and reporting all complaints and have made limited use of its 

electronic complaints tracking software. The manual process made it 

harder to accurately track the number of complaints and to determine 

processing times. As a result of our work, OOI has posted to its intranet 

and Web site the correct data for fiscal year 2007 and plans to revise its 

procedures for other problems we have identified. 

To ensure the fair and impartial processing of discrimination complaints, 

EEOC’s guidance on the federal sector EEO process for executive branch

agencies has three requirements regarding the reporting relationship and 

independence of the heads of agency EEO offices.18 Although GAO is not 

required to follow EEOC’s guidance, it adheres to two of the three 

requirements. Concerns have been expressed about the agency not 

following the third recommendation—keeping the EEO functions separate 

from the personnel function. PAB, in its EEO oversight capacity of GAO, 

has recommended that the agency create a separate unit solely to process 

discrimination complaints. 

Concerns Continue 

about Integration of 

Discrimination 

Complaint Processing 

and Diversity Efforts 

EEOC’s Management Directive 110, among other things, has three 

requirements for the head of agency EEO offices regarding reporting 

relationships and independence. First, to underscore the importance of 

equal employment opportunity to an agency’s mission and to ensure that 

the EEO Director is able to act with the greatest degree of independence,

 18EEOC, Management Directive 110. 

Page 16 GAO-08-1098 Diversity at GAO
it requires that the EEO Director report directly to the head of the agency.

Second, to enhance the credibility of the EEO office and the integrity of 

the EEO complaints process, it requires that the EEO fact-finding function

in general, and the legal sufficiency reviews of final agency decisions for 

discrimination complaints in particular, not be done by attorneys in a unit

that represents or defends the agency in such disputes. Third, to maintain 

the integrity of the EEO investigative and decision-making processes, the 

guidance requires that the EEO functions, especially investigations and 

decision making, must be kept separate from the personnel function to 

avoid conflicts of position or conflicts of interest, as well as the 

appearance of such conflicts. 

We found no problems with two requirements. The OOI Managing Director

reports directly to the Comptroller General, the head of GAO. In addition, 

the OOI Managing Director, who is an attorney, does legal sufficiency

reviews of final agency decisions and arranges for independent 

investigations. For the small number of complaints that OOI staff have not

directly processed, GAO’s Chief Administrative Officer assigns a manager 

to act on OOI’s behalf, while General Counsel assigns an attorney who is 

not in GAO’s Legal Services unit to assist the manager. Legal Services is 

part of GAO’s Office of General Counsel and serves as the agency’s inhouse legal counsel and represents the agency in legal disputes. 

PAB has reported about the potential for a real or apparent conflict of 

interest because the OOI Managing Director is responsible for overseeing

discrimination complaints while having a substantial role in GAO’s human 

capital activities, including diversity programs—which is a personnel 

function. PAB has pointed out that this situation does not conform to the 

EEOC directive, which states, “. . . the same agency official responsible for 

executing and advising on personnel actions may not also be responsible 

for managing, advising, or overseeing the EEO pre-complaint or complaint 

processes.” An illustrative example of a potential area of conflict is the 

OOI Managing Director’s role in reviewing employee performance ratings. 

He reviews selected ratings before they are final to identify any potential

EEO concerns, and he then discusses his concerns with the appropriate 

SES official. Therefore, if an employee were to file a discrimination 

complaint because of a rating, the OOI Managing Director would have

been involved in a review for potential EEO concerns and still would be 

responsible for the fair and impartial processing of the complaint. 

PAB has recommended that GAO create a separate complaint unit to 

process discrimination complaints exclusively and with no responsibility 

for personnel, or human capital, issues. GAO has stated that it does not 

Page 17 GAO-08-1098 Diversity at GAO
believe that creation of a separate unit is warranted due to the small 

number of discrimination complaints filed each year and that the 

appearance of any conflict of interest is mitigated by GAO contracting out 

its complaint investigations. PAB continues to believe that a structural 

separation between the two administrative functions is warranted. The 

scope of our review did not include a detailed analysis of OOI to determine 

what effect, if any, the consolidation of these functions has had on 

complaint processing. 

Moreover, the small number of formal complaints does not reflect the 

office’s workload, the majority of which involve informal contacts with the 

office and its efforts to resolve issues raised by GAO employees without 

the filing of a formal complaint. For example, in fiscal year 2007, GAO 

employees filed 15 discrimination complaints, while about 130 employees 

made informal contacts to OOI. These contacts concerned a range of 

issues, including appraisals, promotion, work assignments, harassment, 

work environment, feedback, communication, and training.

While the agency has made progress, the task ahead—further increasing 

the diversity of its leadership and workforce—is challenging. It will require 

a concerted effort that must be sustained over time. The small gains in 

minority representation in recent years will not be sufficient for achieving

a more diverse leadership. To move forward, GAO needs to establish as 

part of its long-term approach a written policy that requires the agency to

produce an annual plan that evaluates its workforce data and helps 

identify and remove unnecessary barriers to the advancement and hiring 

of women, minorities, and people with disabilities. The agency has taken a 

key step toward this end with its June 2008 Workforce Diversity Plan and 

the Acting Comptroller General’s stated intention to producing a diversity 

plan annually. Because of GAO’s transitional state with an Acting 

Comptroller General, we believe the agency needs to incorporate its 

intention into the order governing OOI’s responsibilities. By formally 

adopting the MD-715 annual review and evaluation process, GAO will be 

better able to evaluate the effects of its initiatives, use the evaluations as a 

basis for any strategic improvements, and hold agency leadership 

accountable. 

Conclusions 

In addition, GAO needs to improve its internal complaint processing 

procedures and the procedures related to compiling and reporting on 

those complaints. This will help to avoid recent problems and ensure that 

complaint data provided to others are accurate and reliable. 

Page 18 GAO-08-1098 Diversity at GAO
GAO may want to monitor the situation related to its decision not to create 

a separate unit for processing discrimination complaints. Some of the 

factors that the agency considered in its original decisions seem to have 

changed, and the agency does face some risk of real or apparent conflicts

of position or conflicts of interest. Further, the number of employees 

making informal contacts to OOI is substantial compared with the number 

of discrimination complaints. 

To acquire the information needed to make decisions for managing GAO’s 

diversity efforts and to achieve the intended results in the most timely and 

efficient manner, we recommend that the Acting Comptroller General take 

the following two actions: 

• Establish as agency policy the development of an annual diversity plan 

that includes the evaluation of the agency’s workforce, identifies and 

removes unnecessary barriers to advancement and hiring, and is 

comparable to the requirements outlined in EEOC’s MD-715. 

• Use information from its annual diversity plan to hold agency leadership 

accountable for the overall results of the agency’s diversity efforts. 

To improve the accuracy and completeness of the complaint and 

discrimination data reported to Congress and others, we recommend that 

the Acting Comptroller General take the following two actions: 

• Revise GAO’s complaint processing procedures order to clarify 

responsibility for tracking and reporting on the processing of complaints 

against a person within OOI. 

Strengthen internal controls for tracking, reviewing, and reporting on 

complaints. 

The Inspector General provided GAO with a draft of this report for review 

and comment. GAO generally agreed with our recommendations. 

Regarding the report’s four recommendations on GAO’s diversity planning 

efforts, the agency did not believe the report had given sufficient credit to

the agency’s foundation for long-term diversity planning and management. 

Based on further discussion of these comments and the clarification that 

management intends to continue producing an annual workforce diversity

plan in the spirit of EEOC’s MD-715 guidance, we believe that such an 

annual plan would address the intent of the draft report’s 

Recommendations for 

Executive Action 

Agency Comments 

and the IG’s

Evaluation 

Page 19 GAO-08-1098 Diversity at GAO
recommendations. As a result, we revised the final report to contain two 

agency planning recommendations to ensure that workforce diversity 

plans are developed at least annually and that they are used to help 

increase management accountability. Regarding the IG’s two 

recommendations on discrimination complaint data and reporting, the 

agency agreed to take steps to improve data quality and reporting and 

acknowledged taking steps to implement them. GAO also provided 

technical corrections that we have incorporated, as appropriate. GAO’s 

written comments appear in appendix IV. 

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 7 days from the 

report date. At that time, we will send copies to other interested 

congressional committees and GAO’s Acting Comptroller General. We will 

also make copies available to others on request.

If you or your staff have any questions about this report, please contact me 

at (202) 512-5748 or garciaf@gao.gov. Contact points for GAO’s Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. IG staff who made major contributions to this report are 

listed in appendix IV. 

Sincerely yours, 

Frances Garcia 

Inspector General 

GAO 

Page 20 GAO-08-1098 Diversity at GAO
Appendix I: Objectives, Scope, and Appendix I: Objectives, Scope, and Methodology 

Methodology 

GAO’s Inspector General reviewed GAO’s efforts to promote fair 

representation of women and minorities in its Senior Executive Service 

and other senior-level positions. Our objectives were to 

• determine whether GAO’s diversity programs and initiatives are achieving 

better representation of women and minorities in top leadership positions 

(i.e., Senior Level Executive and GS-15 positions, or their equivalent), 

• evaluate the accuracy and completeness of the fiscal year 2007 complaint 

and discrimination data reported to Congress, and

• assess the independent authority and reporting relationships of the 

Managing Director of GAO’s Office of Opportunity and Inclusiveness 

(OOI). 

To determine whether the GAO diversity-related programs and initiatives 

are achieving better representation of women and minorities in the Senior

Executive Service (SES) and managerial ranks (GS-15) and their 

equivalent positions, we primarily used (1) the U.S. Equal Employment 

Opportunity Commission Management Directive 715 (MD-715) checklist, 

which we modified to eliminate questions applicable only to executive

branch agencies; and (2) nine leading diversity management practices 

identified by experts in the field and discussed in GAO’s report Diversity 

Management: Expert-Identified Leading Practices and Agency 

Examples. Executive branch agencies are to use the MD-715 checklist 

annually to internally evaluate their performance for establishing and 

maintaining effective diversity programs, such as the essential elements of 

a model equal employment opportunity program. We used MD-715 and the 

GAO report on leading practices as criteria for our assessment because 

they provide policy guidance and standards for establishing and 

maintaining effective diversity programs. In addition, we obtained and 

analyzed data from GAO’s Chief Administrative Officer on women and 

minorities in the SES and manager and equivalent ranks for fiscal years 

2002 through 2007, data on GAO’s SES candidate program for fiscal year 

2002 through May 2008, and GAO’s hiring of SES and managers for fiscal 

year 2003 through May 2008. We also interviewed agency officials, such as 

the Chief Human Capital Officer and the OOI Managing Director, as well as

representatives from the firm that conducted the study on ratings 

disparities between African-American and Caucasian analysts and an 

employee group to obtain insight on the agency’s diversity management 

programs and initiatives. The scope of our audit was limited to GAO’s 

diversity programs in effect as of January 1, 2008.

Page 21 GAO-08-1098 Diversity at GAO
Appendix I: Objectives, Scope, and 

Methodology 

To evaluate the accuracy and completeness of the agency’s fiscal year 

2007 complaint and discrimination data and the information systems that 

produce that data, we reviewed GAO’s order and procedures on 

processing discrimination complaints and reviewed relevant files. Our 

assessment also included reviewing supporting documentation for the 

data reported in GAO’s annual report to Congress and posted on its 

intranet and Web site. In addition, we interviewed staff and managers in 

OOI and the Office of General Counsel (GC) to ascertain how complaint 

and discrimination data are collected, recorded, and reported. We further 

assessed the internal control systems GAO uses to process complaints, 

determine processing times, and develop the annual report and Web 

postings to ensure the quality of data.

To assess the independent authority and reporting relationships for GAO’s 

OOI Managing Director, we examined the agency’s organizational 

structure, policies, and procedures and reviewed GAO’s Personnel 

Appeals Board’s (PAB) reports on equal employment opportunity 

oversight. We also compared how GAO is currently organized to process 

discrimination complaints against how executive agencies are required to 

process such complaints, as described in EEOC Management Directive 

110. In addition, we interviewed the officials in PAB, OOI, and GC to 

discuss areas of concern for potential conflicts of interest. 

We conducted our work from March 2008 to September 2008 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

Page 22 GAO-08-1098 Diversity at GAO
Appendix II: Selected PAB EEO Oversight Appendix II: Selected P Reports AB EEO Oversight 

Reports 

The Employment of Hispanics at GAO. Washington, D.C.: January 29, 

2007.

1

The State of Equal Employment Opportunity at GAO in the 21st 

Century. Washington, D.C.: October 14, 2005. 

Study of GAO’s Office of Opportunity and Inclusiveness. Washington, 

D.C.: February 20, 2004. 

Minority Recruitment at GAO. Washington, D.C.: September 27, 2002. 

Selection Into the Senior Executive Service at GAO (1992-1997). 

Washington, D.C.: September 30, 1998. 

Follow-Up Report to GAO’s Discrimination Complaint Process and 

Mediation Program. Washington, D.C.: August 31, 1998. 

GAO’s Discrimination Complaint Process and Mediation Program. 

Washington, D.C.: September 29, 1995. 

 1

PAB reports can be located on its Web site, http://www.pab.gao.gov/oversight.php. 

Page 23 GAO-08-1098 Diversity at GAO
Appendix III: Status of Nine ExpertIdentified Best Leading Diversity Practices at Appendix III: Status of Nine Expert-Identified GAO 

Best Leading Diversity Practices at GAO 

Not yet adopted Level of adoption 

Expert-identified leading 

diversity management

practices

Do not 

anticipate 

adopting 

No decision

made, not in

use 

Will

adopt 

Plan under 

development

Written plan

complete 

Partially 

adopted

Fully 

adopted

Top leadership commitment ;

Diversity as part of an 

organization’s strategic plan 

;

Diversity linked to performance ;

Measurement ;

Accountability ;

Succession planning ;

Recruitment ;

Employee involvement ;

Diversity training ;

Source: IG analysis of GAO information.

Page 24 GAO-08-1098 Diversity at GAO
Appendix IV: Comments from the Office of the Appendix IV Comptroller General of the United States : Comments from the Office of 

the Comptroller General of the United States 

Page 25 GAO-08-1098 Diversity at GAO
Appendix IV: Comments from the Office of the

Comptroller General of the United States 

Page 26 GAO-08-1098 Diversity at GAO
Appendix IV: Comments from the Office of the

Comptroller General of the United States 

Page 27 GAO-08-1098 Diversity at GAO
Appendix IV: Comments from the Office of the

Comptroller General of the United States 

Page 28 GAO-08-1098 Diversity at GAO
Appendix V: I

A

G Contact and Staff 

cknowledgments 

Page 29 GAO-08-1098

Appendix V: IG Contact and Staff 

Acknowledgments 

Frances Garcia, (202) 512-5748 or garciaf@gao.gov

In addition to the contact named above, Cathy L. Helm (Assistant 

Director) and Keith Steck made significant contributions to this report. 

IG Contact 

Staff 

Acknowledgments 

Diversity at GAO
Related GAO Products Related GAO Products 

Human Capital: Workforce Diversity Governmentwide and at the 

Department of Homeland Security. GAO-08-815T. Washington, D.C.: 

May 21, 2008. 

U.S. Department of Agriculture: Management of Civil Rights Efforts 

Continues to Be Deficient Despite Years of Attention. GAO-08-755T. 

Washington, D.C.: May 14, 2008. 

Human Capital: Workforce Diversity Governmentwide and at the Small 

Business Administration. GAO-08-725T. Washington, D.C.: April 23, 2008.

NASA: Progress Made on Strategic Human Capital Management, but 

Future Program Challenges Remain. GAO-07-1004. Washington, D.C.: 

August 8, 2007. 

Managing for Results: Enhancing Agency Use of Performance 

Information for Management Decision Making. GAO-05-927. Washington, 

D.C.: September 9, 2005. 

Human Capital: Key Principles for Effective Strategic Workforce 

Planning. GAO-04-39. Washington, D.C.: December 11, 2003. 

Human Capital Management: FAA’s Reform Effort Requires a More 

Strategic Approach. GAO-03-156. Washington, D.C.: February 3, 2003. 

Human Capital: Effective Use of Flexibilities Can Assist Agencies in 

Managing Their Workforces. GAO-03-2. Washington, D.C.: December 6, 

2002. 

A Model of Strategic Human Capital Management. GAO-02-373SP. 

Washington, D.C.: March 15, 2002. 

Management Reform: Elements of Successful Improvement Initiatives. 

T-GGD-00-26. Washington, D.C.: October 15, 1999. 

(998266) Page 30 GAO-08-1098 Diversity at GAO
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