United States General Accounting Office

GAO Report to Congressional Requesters

July 1995 EMPLOYMENT

DISCRIMINATION

Most Private-Sector

Employers Use

Alternative Dispute

Resolution

GAO/HEHS-95-150

GAO United States

General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-257171 

July 5, 1995

The Honorable William L. Clay

Ranking Minority Member

Committee on Economic and

 Educational Opportunities

House of Representatives

The Honorable Major R. Owens

House of Representatives

In fiscal year 1994, the Equal Employment Opportunity Commission (EEOC)

received over 90,000 discrimination complaints from employees, almost

twice the number filed in 1981 and 10 times the number in 1966. The

number of employment law cases filed in the federal courts has increased

similarly.1

 In resolving these complaints, employers have become more

and more concerned about the costs—in time, money, and good employee

relationships. In response, some employers have adopted internal

alternative dispute resolution (ADR) approaches, including arbitration, that

is, submitting disputes to a neutral third person—an arbitrator—for

resolution. Some require their employees to agree to mandatory, binding

arbitration of discrimination complaints as a condition of their

employment, forcing employees to waive the right to sue.

To determine the extent to which employers in the private sector have

implemented ADR approaches, you asked us to determine (1) the extent to

which private-sector employers use ADR approaches, especially arbitration,

to resolve discrimination complaints of employees not covered by

collective bargaining agreements2

 and (2) the fairness of employers’

arbitration policies.

To determine the extent of the use of ADR approaches, we sent a

questionnaire to a stratified, random sample of 2,000 businesses that had

(1) filed equal employment opportunity (EEO) reports with the EEOC in 1992

and (2) reported having more than 100 employees. ADR approaches include

negotiation, fact finding, peer review, internal mediation, external

1

In addition to discrimination cases, employment law cases include suits filed by individuals under

such statutes as the Fair Labor Standards Act, the Family and Medical Leave Act, the Employee

Polygraph Protection Act, and the Employee Retirement Income Security Act.

2

When unionized employees collectively bargain with employers, arbitration procedures are strictly

controlled by the collective bargaining agreement. The employer and the union negotiate the

(1) disputes subject to arbitration and (2) rules to be followed during arbitration.

Page 1 GAO/HEHS-95-150 Employment Discrimination
B-257171 

mediation, and arbitration. The following are the definitions of these

approaches we used in the questionnaire:

• Negotiation is a discussion of a complaint by the employee and employer

and, if appropriate, their counsels, with the goal of setting the terms of a

resolution. Negotiation does not require involvement of a neutral party and

could include an open door policy, that is, a policy that guarantees an

employee the opportunity to discuss his or her complaint with a senior

manager without fear of reprisal.

• Fact finding involves a neutral person—someone either within the

company or external to the company—investigating a complaint and

developing findings that may form the basis for resolution. This would not

include formal investigations of charges by government agencies, such as

the EEOC.

• Peer review involves a panel of employees or employees and managers

working together to resolve employment complaints.

• Internal mediation is a process for resolving disputes in which a neutral

person—trained in mediation methods—from within the company helps

the disputing parties negotiate a mutually acceptable agreement. This

process does not lead to an imposed solution.

• External mediation is a process for resolving disputes in which a neutral

person—trained in mediation methods—from outside the company helps

the employer and employee negotiate a mutually acceptable agreement.

This process does not lead to an imposed solution.

• Arbitration involves a neutral person—an arbitrator from outside the

company—deciding how the complaint is to be resolved. The arbitrator’s

decision is usually binding on both the employee and the employer.

To obtain more detailed information on ADR approaches, we telephoned

those employers who had reported using arbitration and asked each of

them to send us a description of the arbitration policies used. As part of

our assessment of the policies, we compared the policies’ provisions with

the key quality standards3

 proposed by the Commission on the Future of

3

The Commission proposed six standards relating to (1) selection of the arbitrator, (2) procedures for

aggrieved employees to gather information, (3) payment of the arbitrator, (4) awards and remedies,

(5) final arbitrator ruling, and (6) judicial review. Although the Commission recognized a consensus

among employers and employees that a fair system must provide the right to independent

representation if the employee wants it, this was not included as one of the six standards. However,

we included this feature in our analysis of policies.

Page 2 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Worker-Management Relations4 as standards for a private arbitration

system that ensures employees a fair and full airing of their complaints.

Further details of our scope and methodology, including sampling errors,

are discussed in appendix I. Unless specifically noted, sampling errors do

not exceed plus or minus 5 percent. Our review was performed in

accordance with generally accepted government auditing standards

between April 1994 and April 1995. The questionnaire is reproduced in

appendix II, along with a summary of the responses.

Results in Brief We estimate, on the basis of our questionnaire results, that almost all

employers with 100 or more employees use one or more ADR approaches.

Arbitration is one of the least common approaches reported. Some

employers using arbitration make it mandatory for all workers.

Employer policies on arbitrating discrimination complaints vary

considerably in form and level of detail. However, some of these policies,

such as those for employees obtaining information and empowering the

arbitrator to use remedies equal to those under law, would not meet

standards of fairness proposed recently by the Commission on the Future

of Worker-Management Relations, which was established by the Secretary

of Labor and the Secretary of Commerce at the President’s request.

Background If workers believe that they have been discriminated against in an

employment matter, they may generally file a charge with EEOC, one of

several federal agencies responsible for enforcing equal employment

opportunity (EEO) laws and regulations.5

 Under title VII of the Civil Rights

Act of 1964, EEOC investigates—and may litigate, on its own behalf or on

behalf of the charging party—charges of employment discrimination

because of race, color, religion, sex, or national origin. EEOC has similar

responsibility under the Age Discrimination in Employment Act of 1967,

4

At the request of the President, the Commission was established in May 1993 and asked to investigate

and report back on three primary issues: what changes might be needed in labor-management

cooperation and employee participation to enhance workplace productivity; how the legal framework

and practices of collective bargaining should be altered to enhance cooperative behavior, improve

productivity, and reduce conflict and delay; and what can be done to enable employers and employees

to resolve workplace problems themselves, rather than turn to state and federal courts and

government regulatory bodies. In December 1994, the Commission completed its tasks and issued its

final report, summarizing its findings and recommendations.

5

In some instances, employees of federal contractors can file discrimination complaints with the Office

of Federal Contract Compliance Programs in the Department of Labor. Also, 46 states, 40 localities,

Puerto Rico, the District of Columbia, and the Virgin Islands have established fair employment practice

agencies to investigate employment discrimination. Individuals in these jurisdictions generally may

choose to file charges with either EEOC or the appropriate state or local agency.

Page 3 GAO/HEHS-95-150 Employment Discrimination
B-257171 

which prohibits employment discrimination against workers aged 40 and

older; under the Equal Pay Act of 1963, which prohibits payment of

different wages to men and women doing the same work; and under the

Americans With Disabilities Act, which prohibits employment

discrimination against workers with physical or mental disabilities.

In April 1995, EEOC announced changes in the way it processes

private-sector employment discrimination charges. As soon as guidance

and implementation instructions are issued, EEOC will begin categorizing

charges according to three priorities. The first category is for charges that

appear more likely than not to involve discrimination, and these charges

will be fully investigated. The second category includes charges that

appear to have some merit but will require additional evidence to

determine whether a violation occurred. The third category includes

charges that can be immediately dismissed without investigation. EEOC

also announced that it will initiate in October 1995 a voluntary ADR

program using mediation to handle some of its workplace discrimination

charges. Under this planned program, some employees filing charges and

their employers will work with a neutral mediator to settle discrimination

disputes, rather than go through EEOC’s traditional investigative

procedures. If the employer and employee fail to reach a resolution, the

charge will be returned to EEOC’s regular caseload.

If EEOC investigates the charge, it notifies the employer of the charge and

requests information from the employer and any witnesses with direct

knowledge of the incident that led to the discrimination charge. If the

evidence obtained by the EEOC investigator does not show reasonable

cause to believe discrimination occurred—for example, the employee was

terminated for poor performance and not due to discrimination—EEOC

dismisses the case after issuing a “no cause” finding and a right-to-sue

letter. When the evidence shows that reasonable cause exists to believe

discrimination occurred, EEOC tries conciliation. If conciliation attempts

fail, EEOC may go to court on behalf of the employee, although it rarely

chooses to do so. EEOC officials have said that the Commission lacks

sufficient legal staff to significantly increase the number of cases it can

litigate effectively. When EEOC decides not to go to court, it issues the

employee a right-to-sue letter, which allows the employee to sue.

While charges filed with EEOC may lead to legal relief for employees with

valid claims, each charge results in costs to the employer, even though

most are found to be in compliance with the law. Although the employee

does not pay for the EEOC investigation, he or she may incur psychological

Page 4 GAO/HEHS-95-150 Employment Discrimination
B-257171 

costs while pursuing the claim, the average time of which was 328 days in

fiscal year 1994. The federal government also incurs costs for each charge

investigated.

ADR approaches are being considered by employers because “almost any

system is quicker, cheaper, and less harrowing than going to court,”

according to an official of the Equal Employment Advisory Council, an

employers’ group. Their concerns have recently increased as a result of

(1) multimillion dollar jury awards to employees and (2) the provision in

the Civil Rights Act of 1991 that permits punitive damages in cases of

intentional discrimination under title VII of the Civil Rights Act of 1964 and

the Americans With Disabilities Act. In addition, a 1991 U.S. Supreme

Court decision upholding mandatory arbitration for statutory claims

concerning employment disputes in the securities industry6

 has led to

consideration of arbitration in particular. Finally, some employers feel that

ADR approaches can minimize the adversarial relationship between

employer and employee resulting from such complaints.

Commission Appointed to

Address

Worker-Management

Relations

The Commission was appointed at the request of the President by the

Secretary of Commerce and the Secretary of Labor to address three

questions:

• What (if any) new methods or institutions should be encouraged, or

required, to enhance workplace productivity through labor-management

cooperation and employee participation?

• What (if any) changes should be made in the present legal framework and

practices of collective bargaining to enhance cooperative behavior,

improve productivity, and reduce conflict and delay?

• What (if anything) should be done to increase the extent to which

workplace problems are directly resolved by the parties themselves, rather

than through recourse to state and federal courts and governmental

bodies?

In researching this third question, the Commission considered the range of

federal and state laws regulating the workplace, including those ensuring

minimum wages and maximum hours; a safe and healthy workplace;

secure and accessible pension and health benefits; adequate notice of

plant closings and mass layoffs; unpaid family and medical leave; and bans

6

See Employment Discrimination: How Registered Representatives Fare in Discrimination Disputes

(GAO/HEHS-94-17, Mar. 30, 1994).

Page 5 GAO/HEHS-95-150 Employment Discrimination
B-257171 

on wrongful dismissal, as well as those outlawing discrimination on the

basis of race, sex, religion, age, or disability.7

According to the Commission’s December 1994 report, both employers

and employees agree that, if private arbitration is to serve as a legitimate

form of private-sector enforcement of public employment law, arbitration

policies must provide

• a neutral arbitrator who knows the laws in question and understands the

concerns of the parties,

• a fair and simple method by which the employee can obtain the necessary

information to present his or her claim,

• a fair method of cost-sharing between the employer and employee to

ensure affordable access to the system for all employees,

• the right to independent representation if the employee wants it,

• a range of legal remedies equal to those available through litigation,

• a written opinion by the arbitrator explaining his or her rationale for the

decision, and

• sufficient judicial review to ensure that the result is consistent with

employment laws.

The Commission noted, however, that most experts who had testified

before it agreed that imposition of fairness standards must not turn

arbitration into a second court system.

Some Existing

Arbitration Policies

Would Not Meet

Commission’s

Recently Proposed

Standards

In our review of employers’ arbitration policies, we found that some do

not meet the fairness standards recently proposed by the Commission on

the Future of Worker-Management Relations.

Using the Commission’s six standards, we evaluated dispute resolution

policies provided by 26 employers that reported using arbitration to

resolve discrimination complaints by employees not covered under

collective bargaining agreements.8,9 Most of these policies, which are

discussed below, are recent: 15 had been implemented in the past 5 years.

7

Employer views on these topics are discussed in Workplace Regulation: Information on Selected

Employer and Union Experiences (GAO/HEHS-94-138, June 30, 1994).

8

From the employers that indicated in their questionnaire responses that they used arbitration, we

excluded employers we could not contact, employers who said they had no written policy, and

employers who did not use arbitration to resolve discrimination complaints by employees not covered

by collective bargaining agreements (see app. I).

9

We also evaluated whether the policies permitted employees independent representation if they

wanted it.

Page 6 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Almost All Employers

Reported Using ADR

Approaches, but Few

Use or Plan to Use

Arbitration

Almost 90 percent of employers that had more than 100 employees and

filed EEO reports with EEOC in 1992 use at least one ADR approach to resolve

discrimination complaints. The reported use of these approaches, which

ranges from about 80 percent for fact finding to about 9 percent for

external mediation, is shown in figure 1. Almost 40 percent of these

employers use a trained mediator from within the company to help resolve

disputes. Only about 10 percent of employers use arbitration. Arbitration

was mandatory for all covered employees for about one-fourth to one-half

of the employers using this approach.10

Figure 1: Percentage of Businesses

Using Selected ADR Approaches Percent

0

20.0

40.0

60.0

80.0

100.0

Negotiation

Fact Finding

Peer Review

Mediation (Internal)

Mediation (External)

Arbitration

Othera

ADR Approaches

74.2

80.6

19.9

38.2

8.6 9.9

19.5

aApproaches cited include internal investigation, open door policy, and using grievance

procedures.

In addition to those firms whose policies include arbitration, 8.4 percent of

employers with more than 100 employees that filed EEO reports with EEOC

10The percentage of employers using arbitration is 39.0 percent plus or minus 16.1 percent.

Page 7 GAO/HEHS-95-150 Employment Discrimination
B-257171 

in 1992 reported that they are considering implementing a policy requiring

arbitration of employee discrimination complaints.

Arbitration Is Frequently

the Final Step in a Policy

Including Other ADR

Approaches

A dispute resolution policy frequently has a series of steps, such as those

discussed below, that can be linked to different ADR approaches. Usually, a

policy that includes arbitration has it as the final step. (See fig. 2 for an

example of a dispute resolution system that includes arbitration.)

Page 8 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Figure 2: Steps in Example of

Company’s Employee Dispute

Resolution Policy

Step 1

Step 2

Step 3

Step 4

Step 5

Resolution

Employee

Supervisor

Employee

Supervisor

Human Resources

Representative

Employee

Senior Manager

Human Resources

Representative

Binding

Arbitration

Executive Adviser

Review Board

Employee

Executive Adviser

(optional)

Page 9 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Steps 1 and 2: Negotiation In step 1, an employee with a complaint is encouraged to discuss the

matter with his or her immediate supervisor. The employee and supervisor

should make sincere, good faith efforts to resolve the matter. If the

employee prefers not to present the matter directly to the immediate

supervisor or if they cannot resolve the matter, the employee then

discusses the matter with a representative of the establishment’s human

resources department and decides whether to proceed to the next step.

In step 2, the employee may request that a representative of the

establishment’s human resources department conduct an assessment of

the dispute and help the employee and supervisor reach a resolution.

Step 3: Fact Finding If resolution has not been reached, an employee may proceed to step 3 and

request an investigation by a representative of the establishment’s human

resources department. The results of the investigation are discussed with

the appropriate senior manager and the employee. The senior manager

decides how the complaint should be resolved. A decision letter is sent to

both the employee and supervisor at the end of this step.

Step 4: Review Board An employee who is dissatisfied with the senior manager’s decision may

request that the problem be reviewed by a review board, which is

composed of an executive, a manager, and a representative from the

corporate human resources office. The employee may request the help of

an executive adviser in preparing for this step. At the end of step 4, the

board will make a final company decision on the dispute’s merits,

including corrective action, if appropriate.

Step 5: Arbitration If an employee is dissatisfied with the board’s decision, he or she may

submit the complaint to binding arbitration, which is step 5 of this

company’s dispute resolution policy. An employee must give notice within

20 working days of the date the board reached its decision. The arbitration

is to be administered in accordance with the procedures of the American

Arbitration Association (AAA), a nonprofit organization that trains

arbitrators and maintains lists of arbitrators who can be used to resolve

different types of disputes, including labor-management and employment

disputes. The arbitration will be heard by an arbitrator who is licensed to

practice law in the state in which the arbitration takes place. Under this

company’s policy, the employer and the employee share equally the fees

and costs of the arbitrator, although the arbitrator may order the company

to pay the employee’s costs in excess of 2 weeks’ salary if the employee

demonstrates a continuing inability to pay his or her entire share.

Page 10 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Smaller Businesses Are as

Likely to Report Using

Arbitration as Larger Ones

Larger employers with larger human resource and legal staffs might be

assumed to be more likely to use arbitration. However, we found no

statistically significant difference in use of arbitration based on business

size. Figure 3 shows the percentage of businesses using arbitration by size.

Figure 3: Percentage of Businesses

Using Arbitration, by Size Percent

0

20.0

40.0

60.0

80.0

100.0

100 to

499

500 to

999

1,000 or

more

Number of Employees

10.2 7.5 9.5

Firms With Some Workers

Covered by Collective

Bargaining Agreements

Are More Likely to Report

Using Arbitration

Since arbitration has long been a feature of grievance procedures in the

collective bargaining arena, employers that have collective bargaining

agreements with some of their workers might be more likely to use

arbitration with those not covered by collective bargaining. Figure 4,

which shows that businesses with some union workers are nearly three

times as likely as those with no union workers to use arbitration, lends

credence to this notion.

Page 11 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Figure 4: Percentage of Businesses

Using Arbitration, by Existence of

Union

Percent

0

5.0

10.0

15.0

20.0

Some Union Workers

No Union Workers

18.4

6.7

Note: Confidence interval for businesses with some union workers is 18.4 percent plus or minus

8 percent.

Selection of Arbitrator

Usually Involves Both

Employer and Employee

In its final report, the Commission states that the arbitrator selection

process should allow both the employer and the affected employee(s) to

participate. The arbitrator should be selected from a roster of qualified

arbitrators who have training and experience in the area of law covering

the dispute being arbitrated and are certified by professional associations

specializing in such dispute resolution. The process should ensure that

rosters include significant numbers of women and minorities. Neither

party should be able to limit the roster unilaterally to avoid the possibility

that the arbitrator selected will be biased in favor of that party.

While we did not evaluate the qualifications or demographics of the panels

from which arbitrators would be chosen, we noted that in 22 of the 26

policies we examined, both the employee and employer are directly

involved in selecting the arbitrator. In 12 policies, this is done with the

help of AAA. Immediately after the complaint is filed, AAA simultaneously

Page 12 GAO/HEHS-95-150 Employment Discrimination
B-257171 

sends an identical list of people chosen from its panel of employment

arbitrators to both the employer and the employee. The employer and the

employee (1) strike any names they object to and (2) number the

remaining names in order of preference. In a single arbitrator case, the

employer and the employee may each strike up to three names. AAA

chooses an arbitrator from among those approved on both lists in

accordance with the designated order of preference. If no agreement is

reached on any of the names, AAA makes the appointment from other

members of the panel. In seven policies we reviewed, the employer and

employee alternate striking names from a list. One policy rather vaguely

calls for selection “based on the parties’ preferences.” In two policies, the

employer selects the names on the list, but the employee is involved in

selecting the arbitrator.

In one of the remaining four policies, the employer unilaterally selects the

arbitrator, while the other three do not discuss arbitrator selection.

Employee Access to

Information Is Rarely

Discussed

According to the Commission, employees should have the opportunity to

gather the relevant information they need to support their legal claims.

Employees pursuing a discrimination complaint, for example, should be

granted access to their personnel files. Broader access to personnel files

should also be available to employees bringing systemic discrimination

claims. During arbitration, an employee with a complaint should be

allowed at least one deposition,11 with a company official of the

employee’s choosing. The arbitrator should be empowered to expand

discovery (pretrial or prehearing procedure by which one party gains

information held by the other) to include any material he or she finds

valuable for resolving the dispute.

Only three policies we reviewed discuss access to information. One policy

states that discovery will be allowed and governed under the discovery

rules of the state code of civil procedure unless otherwise agreed to by the

parties; one policy provides for 2 days of depositions; and the remaining

policy limits the taking of depositions to one company representative, two

other persons, and one expert witness named by the company but also

allows requests for documents related to the complaint.

11A deposition is a statement of a witness under oath in which both parties can be present and

cross-examine the witness and which is transcribed by an official reporter.

Page 13 GAO/HEHS-95-150 Employment Discrimination
B-257171 

Both Employer and

Employee Usually Share

Payment of Arbitrator

To ensure impartiality of the arbitrator, the Commission proposes that

both the employee and the employer contribute to the arbitrator’s fee.

Ideally, the employee contribution should be capped in proportion to the

employee’s salary to avoid discouraging claims by low-wage workers.

Seven policies do not address cost sharing. In four policies, the employer

pays for all arbitration costs; costs are to be shared equally in nine

policies; and the employee share is either capped or limited to less than

half the costs in the remaining six policies. For example, one employer

pays all costs in excess of $50. Another firm pays 80 percent of the

arbitration costs, while the employee is responsible for 20 percent.

Right to Independent

Counsel Generally

Permitted

According to the Commission, both employers and employees agree that

fairness requires the right of independent representation if the employee

wants it. AAA rules state that “any party may be represented by counsel or

by any other representative.”

Twenty-one of the policies we reviewed permit the employee to be

represented by an attorney during arbitration. Four policies do not address

representation. Only one policy specifically states that representation by

an attorney will not be permitted.

Remedies Rarely

Addressed, but Not

Specifically Limited by

Policies

The Commission states that the introduction of a workplace arbitration

system should not curb substantive employee protections. This means that

private arbitration should offer employees the same array of remedies

available in court. Arbitrators should be allowed to award whatever

relief—including reinstatement, back pay, additional economic damages,

punitive awards, injunctive relief, and attorney’s fees—would be available

in court under the law in question.

Eighteen of the 26 policies do not address legal remedies—such as

monetary compensation—available to the arbitrator. Of the eight

remaining policies, seven state that the arbitrator can use any remedy

available under law, while one policy prohibits the arbitrator from

assessing damages beyond those required to compensate for actual losses.

Final Arbitrator Decision Is

Sometimes in Writing

The Commission states that the arbitrator should issue a written opinion

that states the findings of fact and reasons that led to his or her decision.

This opinion need not correspond in style or length to a court opinion.

Page 14 GAO/HEHS-95-150 Employment Discrimination
B-257171 

However, it should set out, in understandable terms, the basis for the

arbitrator’s ruling.

Ten policies do not address the form of the arbitrator’s decision. The

remaining 16 policies require the arbitrator to provide a written ruling, but

specific provisions of these policies vary considerably. For example, one

policy requires the decision to “contain findings of fact and conclusions of

law supporting the decision and the award,” while another states that the

written opinion should not include findings of fact and conclusions of law

unless requested by both the employer and the employee.

Judicial Review Is Not

Addressed in Policies

According to the Commission, judicial review of an arbitrator’s ruling must

ensure that the ruling reflects an appropriate understanding and

interpretation of the relevant legal doctrines.12 A reviewing court should

defer to an arbitrator’s findings of fact as long as it has substantial

evidentiary basis. However, the reviewing court’s authoritative

interpretation of the law should bind arbitrators much as it now binds

administrative agencies and lower courts. For example, if an arbitration

decision on a sexual harassment complaint disregards the standard set for

such claims by the Supreme Court, the reviewing court should have the

power to overturn the arbitration decision as inconsistent with current

law.

No policies require that the arbitration decision reflects an appropriate

understanding and interpretation of relevant legal doctrines and be

reviewable by a court on that basis. Sixteen policies call for the arbitration

results to be “final and binding.” However, none of these policies

specifically provide for judicial review. The remaining 10 policies do not

address reviewing the arbitrator’s opinion.

Conclusions Almost all employers that had more than 100 employees and filed EEO

reports with the EEOC in 1992 have established some sort of grievance

procedure using one or more ADR approaches. However, relatively few use

arbitration, and even fewer make it mandatory for employees.

Existing arbitration policies vary greatly. If expected to conform with all

the criteria for fairness recently proposed by the Commission on the

Future of Worker-Management Relations, most would not do so. This is

12Under present law, judicial review of arbitration decisions, unless explicitly stated otherwise in the

arbitration agreement, is generally very limited.

Page 15 GAO/HEHS-95-150 Employment Discrimination
B-257171 

especially true when considering the criteria for an employee’s

opportunity to obtain information for empowering the arbitrator to use

remedies equal to those available under law and for providing that the

arbitrator’s decision be subject to judicial review concerning the

arbitrator’s interpretation of relevant legal doctrines.

We are sending copies of this report to interested congressional

committees, the Chairman of the Equal Employment Opportunity

Commission, and other interested parties. Please call Cornelia Blanchette,

Associate Director, on (202) 512-7014, or me if you or your staff have any

questions. Other major contributors to this report are listed in appendix

III.

Linda G. Morra

Director, Education and Employment

 Issues

Page 16 GAO/HEHS-95-150 Employment Discrimination
Page 17 GAO/HEHS-95-150 Employment Discrimination
Contents

Letter 1

Appendix I 

Scope and

Methodology

20

Appendix II 

Summary of

Responses to GAO’s

Survey of

Employment Dispute

Resolution Policies

and Practices

23

Appendix III 

GAO Contacts and

Staff

Acknowledgments

31

Tables Table I.1: Universe of Potential Business Establishments, Sample

Size, and Respondents by Strata

21

Table I.2: Sampling Errors of Variables Used 21

Table I.3: Results of Telephone Survey of Businesses Reporting

Use of Arbitration

22

Figures Figure 1: Percentage of Businesses Using Selected ADR

Approaches

7

Figure 2: Steps in Example of Company’s Employee Dispute

Resolution Policy

9

Figure 3: Percentage of Businesses Using Arbitration, by Size 11

Figure 4: Percentage of Businesses Using Arbitration, by

Existence of Union

12

Page 18 GAO/HEHS-95-150 Employment Discrimination
Contents

Abbreviations

AAA American Arbitration Association

ADR alternative dispute resolution

EEO equal employment opportunity

EEOC Equal Employment Opportunity Commission

Page 19 GAO/HEHS-95-150 Employment Discrimination
Appendix I 

Scope and Methodology

We designed a questionnaire to obtain information on the use of

alternative dispute resolution (ADR) approaches by private-sector

businesses to resolve discrimination complaints brought by employees not

covered by collective bargaining agreements. We discussed development

of this questionnaire with the Equal Employment Advisory Committee, a

nonprofit association of employers; Chorda Conflict Management, Inc., an

Austin, Texas, consulting firm that helps employers design dispute

resolution systems; and the National Task Force on Civil Liberties in the

Workplace of the American Civil Liberties Union.

Before mailing our questionnaire, we pretested it with officials of five

employers. Results of the pretests indicated that questions, terms, and

definitions were generally familiar, clear, and free from confusion. During

the face-to-face pretest, officials completed the questionnaire as if they

had received it in the mail. Our staff recorded the time necessary to

complete the survey and any difficulties that respondents experienced.

Once the questionnaire was completed, we used a standardized series of

questions to gain feedback on difficulties and questions encountered with

each item.

We surveyed a nationally representative sample of businesses with more

than 100 employees in 1992, the most recent year for which data were

available. To determine our universe, we used the 1992 EEO-1 data file

maintained by the EEOC. This file consists of reports required to be filed by

all businesses with more than 100 employees during the reporting period,

as well as certain firms with fewer than 100 employees if they are

government contractors. We deleted consolidated reports13 and reports

from businesses that reported having less than 100 employees. This

yielded a universe of about 87,500 businesses.

We sent the survey to a sample of 2,000 businesses. The sample was

selected from three different strata by size: 100 to 499 employees, 500 to

999 employees, and 1,000 or more employees. We sent questionnaires to

random samples of businesses in each of the three strata. We obtained an

overall response rate of 75.0 percent. Response rates for individual strata

ranged from 63.6 percent to 80.0 percent. Table I.1 shows the universe of

potential establishments, the sample size, and the number of

establishments for which questionnaires were received by strata.

13Headquarters establishments are required to provide reports consolidating the statistics for all a

firm’s establishments.

Page 20 GAO/HEHS-95-150 Employment Discrimination
Appendix I 

Scope and Methodology

Table I.1: Universe of Potential

Business Establishments, Sample

Size, and Respondents by Strata

Size of business establishment Universe Sample Respondents

100 to 499 employees 75,178 500 318

500 to 999 employees 7,534 500 381

1,000 or more employees 4,785 1,000 800

Total 87,497 2,000 1,499

As agreed with the requesters’ offices, we pledged that businesses’

responses would be kept confidential. A sample questionnaire showing

aggregate responses and percentages appears in appendix II.

We calculated sampling errors for estimates from this survey at the

95-percent confidence level. This means the chances are about 19 out of 20

that the actual percentage being estimated falls within the range covered

by our estimate, plus or minus the sampling error. Sampling errors for

estimates discussed in this report are shown in table I.2.

Table I.2: Sampling Errors of Variables

Used

Variable Percent

Sampling error

(percentage points)

Employer uses at least one ADR approach 88.7 +-3

Employer uses negotiation 74.2 +-4

Employer uses fact finding 80.6 +-4

Employer uses peer review 19.9 +-4

Employer uses internal mediation 38.2 +-5

Employer uses external mediation 8.6 +-3

Employer uses arbitration 9.9 +-3

Employer uses other ADR approach 19.5 +-4

Arbitration mandatory for all it applies to 39.0 +-16

Employers with 100 to 499 employees using

arbitration 10.2 +-4

Employers with 500 to 999 employees using

arbitration 7.5 +-3

Employers with 1,000 or more employees using

arbitration 9.4 +-2

Employers with some union workers using

arbitration 18.4 +-8

Employers with no union workers using

arbitration 6.7 +-3

We weighted the data to account for different sampling rates and varying

response rates among the strata. Therefore, our data reflect national

Page 21 GAO/HEHS-95-150 Employment Discrimination
Appendix I 

Scope and Methodology

estimates for businesses with more than 100 employees and are based on

the assumption that the nonrespondents are similar to the respondents.

To obtain more detailed information on dispute resolution policies, we

then telephoned the 132 respondents that reported using arbitration to

resolve discrimination complaints brought by workers not covered by a

collective bargaining agreement. As shown in table I.3, we eventually

received and analyzed 26 policies.

Table I.3: Results of Telephone Survey

of Businesses Reporting Use of

Arbitration

Number of businesses

Result of telephone survey

Total

businesses

Could not reach business by telephone 31

No contact provided on questionnaire 8

Did not respond to our calls 23

Does not use arbitration for employment discrimination

complaints by nonunion workers 34

Does not use arbitration 8

Does not use arbitration for discrimination complaints 1

Arbitration used for union workers only 22

Arbitration by securities forums, not employers 3

No written policy for nonunion workers 19

Declined to send policy 22

Policy received 26

Total businesses telephoned 132

Page 22 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

Employment Dispute Resolution:

Policies and Practices

Introduction

The Congress has asked the U.S. General Accounting Office

(GAO) to conduct a study of employers’ personnel policies,

including arbitration, for resolving disputes that arise under

federal equal employment statutes for employees not covered

under collective bargaining agreements. These disputes arise

from allegations of discrimination because of race, sex,

religion, country of origin, age, or disability.

As part of our study, we are sending this questionnaire to a

random sample of business establishments to collect

information on the policies and practices they use to resolve

employment discrimination disputes. This questionnaire

should take about 15 minutes to complete. Most of the

questions can be answered quickly and easily by checking

boxes.

We will keep your responses to the questionnaire strictly

confidential. Only those responsible for the analysis of the

survey data will know how you have responded. When

GAO reports the results of this survey, no questionnaire

response will be attributed to any specific establishment.

Your responses will be combined with those of other

respondents and reported in the aggregate.

Instructions

For the purposes of this survey, we would like you to

respond for this business establishment alone, even if it is

part of a larger organization. If this establishment is a

corporate headquarters, please respond only for the corporate

headquarters level of the organization.

If you have any questions about this questionnaire, please

call Mr. Bob Sampson collect at (202) 512-7251.

Please return the completed questionnaire in the enclosed

self-addressed envelope within 10 days of receipt. In the

event that the envelope is misplaced, please send your

questionnaire to

Mr. Bob Sampson

U.S. General Accounting Office

NGB-Education and Employment

441 G Street, N.W.

Washington, DC 20548

Thank you for your help.

Background

1. Is this business establishment a corporate

headquarters? (Check one) (n=1487)

1. 35.9% Yes --> If yes, in responding to the

following questions, please

answer only for this

establishment, that is, the

corporate level of your

organization.

2. 64.1% No --> If no, please respond only

for this establishment even if

it is part of a larger

organization.

2. About how many employees (full-time and part-time)

does this business establishment currently employ?

(Enter number) (n=1365)

0-99 - 13.0%

________ Total employees 100-499 - 63.5%

500-999 - 10.5%

1000+ - 13.0%

3. Are the employees at this business establishment

covered or not covered by collective bargaining

agreements? (Check one) (n=1496)

1. 6.0% Yes, all employees are covered by

collective bargaining agreements

||

||

\/

If yes, stop here! Please return this

questionnaire in the enclosed envelope.

There is no need to answer the remaining

questions, but it is important that we

receive your responses to the first 3

questions. Your cooperation is

appreciated. Thank You.

2. 24.7% Yes, some employees are covered by a

collective bargaining agreement, but

some are not

3. 69.3% No, none of the employees at this

establishment are covered by a collective

bargaining agreement

l Data presented using percentages rounded to nearest

tenth; totals may not sum to 100 due to rounding.

Page 23 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

4. About what proportion of employees at this

establishment are NOT covered by a collective

bargaining agreement? (Enter percentage) (n=1179)

% of employees are NOT covered by a

|| collective bargaining agreement

||

\/

For the remainder of the questionnaire, please

consider your employee discrimination complaint

resolution policies and practices as they relate to

only those employees who are NOT covered by a

collective bargaining agreement.

0-24% - 14.3%

24-49% - 7.9%

50-74% - 5.6%

75-100% - 72.2%

Dispute Resolution Policies

Negotiation

5. Question in this section are about negotiation. By

"negotiation," we mean a discussion of a complaint

by the parties and, if appropriate, their counsel with

the goal of setting the terms of a resolution.

Negotiation does not require involvement of a neutral

party. Negotiation could include an "open door"

policy.

Does this establishment have a policy to use

negotiation as a method to resolve discrimination

complaints that arise under federal equal employment

status? (Check One) (n=1448)

1. 74.2% Yes -->If yes, go to question 7

2. 25.7% No

6. Is this establishment considering instituting a policy

to use negotiation to resolve discrimination

complaints? (Check one) (n=301)

1. 15.4% Yes -->If yes, go to question 11

2. 84.6% No-->If no, go to question 11

7. We would like to know what types of employees this

policy applies to. Does this policy apply to all those

not covered by a collective bargaining agreement or

only to those who are in certain positions or located

in certain divisions or departments? (Check one)

(n=1135)

1. 99.0% All

2. 1.0% Only those in certain positions or certain

divisions or departments

8. Does this policy apply to only those who were hired

on or after a certain date? (Check one)

(n=1134)

1. 0.1% Yes

2. 99.9% No-->If no, go to question 10

9. For those employees who were hired before that date,

does this policy begin to apply to them when their

status changes (for example, promotion, transfer,

position change)? (Check one) (n=5)

1. 65.6% Yes

2. 34.4% No

10. Is negotiation voluntary for everyone it applies to,

voluntary for some that it applies to, or mandatory for

everyone that it applies to? (Check one) (n=1121)

1. 90.5% Voluntary for all

2. 0.6% Voluntary for some

3. 8.9% Mandatory for all

2

Page 24 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

Fact Finding

11. For this section, our questions are about fact finding.

By "fact finding," we mean having a neutral party

(either someone within the company or external to the

company) investigate a complaint and develop

findings that may form the basis for resolution. This

would not include formal complaint investigations by

government agencies, such as the Equal Employment

Opportunity Commission (EEOC).

Does this establishment have a policy to use fact

finding as a method to resolve discrimination

complaints that arise under federal equal employment

statutes? (Check one) (n=1446)

1. 80.6% Yes -->If yes, go to question 13

2. 19.4% No

12. Is the establishment considering instituting a policy to

use fact finding to resolve discrimination

complaints? (Check one) (n=241)

1. 10.8% Yes -->If yes, go to question 17

2. 89.2% No-->If no, go to question 17

13. Does this policy apply to all those not covered by a

collective bargaining agreement or only to those in

certain positions or located in certain divisions or

departments? (Check one) (n=1199)

1. 99.2% All

2. 0.8% Only those in certain positions or certain

divisions or departments

14. Does this policy apply to only those who were hired

on or after a certain date? (Check one)

(n=1196)

1. 0.1% Yes

2. 99.9% No-->If no, go to question 16

15. For those employees who were hired before that date,

does this policy begin to apply to them when their

status changes (for example, promotion, transfer,

position change)? (Check one) (n=4)

1. 61.6% Yes

2. 38.4% No

16. Is fact finding voluntary for everyone it applies to,

voluntary for some that it applies to, or mandatory for

everyone that it applies to? (Check one) (n=1184)

1. 54.0% Voluntary for all

2. 1.1% Voluntary for some

3. 45.0% Mandatory for all

Peer Review

17. For this section, our questions are about peer review.

By "peer review," we mean a panel of employees or

employees and managers working together to resolve

employment complaints.

Does this establishment have a policy to use peer

review as a method to resolve discrimination

complaints? (Check one) (n=1447)

1. 19.9% Yes -->If yes, go to question 19

2. 80.1% No

18. Is this establishment considering instituting a policy

to use peer review to resolve discrimination

complaints? (Check one) (n=1136)

1. 11.1% Yes -->If yes, go to question 23

2. 88.9% No -->If no, go to question 23

3

Page 25 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

19. Does this policy apply to all those not covered by a

collective bargaining agreement or only to those in

certain positions or located in certain divisions or

departments? (Check one) (n=305)

1. 93.3% All

2. 6.7% Only those in certain positions or certain

divisions or departments

20. Does this policy apply to only those who were hired

on or after a certain date? (Check one) (n=305)

1. 0.3% Yes

2. 99.7% No-->If no, go to question 22

21. For those employees who were hired before that date,

does this policy begin to apply to them when their

status changes (for example, promotion, transfer,

position change)? (Check one) (n=4)

1. 100% Yes

2. 0% No

22. Is peer review voluntary for everyone it applies to,

voluntary for some that it applies to, or mandatory for

everyone that it applies to? (Check one) (n=300)

1. 69.2% Voluntary for all

2. 5.0% Voluntary for some

3. 25.7% Mandatory for all

Internal Mediation

23. Questions in this section are about internal mediation.

By "internal medication," we mean a process for

resolving disputes in which a neutral party--trained in

mediation techniques--from within the company helps

the disputing parties negotiate a mutually acceptable

agreement. This process does not involve an imposed

solution.

Does this establishment have a policy to use internal

mediation as a method to resolve these discrimination

complaints? (Check one) (n=1448)

1. 38.2% Yes -->If yes, go to question 25

2. 61.8% No

24. Is this establishment considering instituting a policy

to use internal mediation to resolve discrimination

complaints? (Check one) (n=908)

1. 10.6% Yes -->If yes, go to question 29

2. 89.4% No-->If no, go to question 29

25. Does this policy apply to all those not covered by a

collective bargaining agreement or only to those in

certain positions or located in certain division of

department? (Check one) (n=524)

1. 99.1% All

2. 0.9% Only those in certain positions or certain

divisions or departments

26. Does this policy apply to only those who were hired

on or after a certain date? (Check one) (n=522)

1. 0.2% Yes

2. 99.8% No-->If no, go to question 28

4

Page 26 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

27. For those employees who were hired before that date,

does this policy begin to apply to them when their

status changes (for example, promotion, transfer,

position change)? (Check one) (n=5)

1. 86.3% Yes

2. 13.7% No

28. Is internal mediation voluntary for everyone it applies

to, voluntary for some that applies to, or mandatory

for everyone that it applies to? (Check one)

(n=520)

1. 75.0% Voluntary for all

2. 1.9% Voluntary for some

3. 23.1% Mandatory for all

External Mediation

29. For this section, our questions are about external

mediation. By "external mediation," we mean a

process for resolving disputes in which a neutral

party--trained in medication techniques--external to

the company helps the disputing parties negotiate a

mutually acceptable agreement. This process does

not involve an imposed solution.

Does this establishment have a policy to use external

mediation as a method to resolve discrimination

complaints? (check one) (n=1448)

1. 8.6% Yes -->If yes, go to question 31

2. 91.4% No

30. Is this establishment considering instituting a policy

to use external mediation to resolve discrimination

complaints? (check one) (n=1336)

1. 8.9% Yes-->If yes, go to question 35

2. 91.1% No-->If no, go to question 35

31. Does this policy apply to all those not covered by a

collective bargaining agreement or only to those in

certain positions or located in certain divisions or

departments? (check one) (n=101)

1. 84.6% All

2. 15.4% Only those in certain positions or certain

divisions or departments

32. Does this policy apply to only those who were hired

on or after a certain date? (check one) (n=100)

1. 0.5% Yes

2. 99.5% No-->If no, go to question 34

33. For those employees who were hired before that date,

does this policy begin to apply to them when their

status changes (for example, promotion, transfer,

position change)? (check one) (n=4)

1. 31.7% Yes

2. 68.3% No

34. Is external mediation voluntary for everyone it applies

to, voluntary for some that it applies to, or mandatory

for everyone that is applies to?

(check one) (n=99)

1. 82.4% Voluntary for all

2. 4.6% Voluntary for some

3. 13.0% Mandatory for all

5

Page 27 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

Arbitration

35. Questions in this section are about arbitration. By

"arbitration," we mean having a neutral party (an

arbitrator external to the company) decide how the

complaint is to be resolved. The arbitrator’s decision

is usually binding on both parties.

Does this establishment have a policy to use

arbitration as a method to resolve discrimination

complaints? (check one) (n=1448)

1. 9.9% Yes -->If yes, go to question 37

2. 90.1% No

36. Is this establishment considering instituting a policy

to use arbitration to resolve discrimination

complaints? (check one) (n=1307)

1. 8.4% Yes -->If yes, go to question 41

2. 91.6% No-->If no, go to question 41

37. Does this policy apply to all those not covered by a

collective bargaining agreement or only to those in

certain positions or located in certain divisions or

departments? (check one) (n=130)

1. 55.7% All

2. 44.3% Only those in certain positions or certain

division or departments

38. Does this policy apply to only those who were hired

on or after a certain date? (check one) (n=127)

1. 11.8% Yes

2. 88.2% No-->If no, go to question 40

39. For those employees who were hired before that date,

does this policy begin to apply to them when their

status changes (for example, promotion, transfer,

position change)? (check one) (n=17)

1. 33.9% Yes

2. 66.1% No

40. Is this policy to use arbitration voluntary for everyone

it applies to, voluntary for some that it applies to, or

mandatory for everyone that it applies to? (check

one) (n=126)

1. 47.1% Voluntary for all

2. 13.9% Voluntary for some

3. 39.0% Mandatory for all

41. Does this business establishment use any other

dispute resolution methods to resolve discrimination

complaints? (check one) (n=1344)

1. 19.5% Yes --> Please describe

use agency grievance procedures; open door

policy; total quality management

2. 80.5% No

6

Page 28 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

Dispute Resolution Practices

42. During the past year, have any employee discrimination complaints in this establishment, not covered by collective

bargaining agreements, been resolved? (check one) (n=1387)

1. 44.1% Yes

2. 55.9% No-->If no, go to question 45

43. Of the discrimination complaints resolved in the pas year, about what proportion of these complaints were ultimately

resolved by each method listed below? (Enter percentage)

0% 1-24% 25-49% 50-74% 75%

(n=846) 1. Negotiation % 53.7% 10.3% 9.4% 14.8% 11.8%

(n=846) 2. Fact finding % 24.9% 6.3% 11.2% 16.4% 41.2%

(n=850) 3. Peer review % 91.1% 2.7% 3.4% 1.6% 1.2%

(n=847) 4. Internal Mediation % 70.6% 11.3% 4.2% 6.4% 7.5%

(n=851) 5. External Mediation % 93.8% 5.2% 0.1% 0.1% 0.8%

(n=851) 6. Arbitration % 96.6% 1.8% 0.8% 0.0% 0.8%

(n=847) 7. Other % 84.0% 2.8% 2.8% 1.0% 9.4%

TOTAL 100%

44. Listed below are various methods this establishment may have used during the resolution process for those employees who

are not covered by collective bargaining agreements. Once again, consider those disputes resolved in the part year. In

about what proportion of these cases were each of these methods used during the resolution process?

(Check one for each method)

Method

Cases in which the method was used

Not

Applicable

All or

almost all Most

About

half Some A few None

(n=673) 1. Negotiation 9.1% 31.2% 16.8% 12.8% 10.7% 6.8% 12.5%

(n=769) 2. Fact finding 2.4% 57.2% 19.1% 6.9% 6.3% 5.5% 2.7%

(n=521) 3. Peer review 33.6% 3.9% 4.0% 0..3% 5.6% 5.4% 47.2%

(n=577) 4. Internal Mediation 18.6% 18.1% 11.1% 7.1% 9.8% 8.2% 26.9%

(n=496) 5. External Mediation 31.2% 3.0% 1.4% 0.1% 2.0% 6.7% 55.6%

(n=492) 6. Arbitration 33.5% 1.8% 0.1% -- 1.5% 5.8% 57.3%

(n=381) 7. Other 29.0% 7.3% 2.6% 5.2% 2.5% 5.0% 48.4%

7

Page 29 GAO/HEHS-95-150 Employment Discrimination
Appendix II 

Summary of Responses to GAO’s Survey of

Employment Dispute Resolution Policies

and Practices

45. Thank you for participating in this study. If you have any additional comments about employment dispute resolution

methods or any questions asked in the questionnaire, please write them in the space provided below. (n=178)

Please provide the following information about the person we should call

if additional information or clarification is needed.

Name of person to call:

Official title:

Telephone number: ( )

HEHS/SL/7-94

(205272)

8

Page 30 GAO/HEHS-95-150 Employment Discrimination
Appendix III 

GAO Contacts and Staff Acknowledgments

GAO Contacts Bob Sampson, Lead Evaluator, (202) 512-7251

Larry Horinko, Assistant Director, (202) 512-7001

Acknowledgments In addition to those named above, the following individuals made

important contributions to this report: Susan Poling provided legal advice

and analyzed the policies we received; Catherine Baltzell reviewed the

technical sections of the report and wrote the technical appendix; Susan

Lawes designed and pretested the survey questionnaire; Joel Grossman

designed the telephone survey of employers who reported using

arbitration; Patricia Bundy managed the questionnaire responses and the

telephone survey; Joan Vogel analyzed the questionnaire responses; and

Linda Stokes assisted with the telephone survey.

(205272) Page 31 GAO/HEHS-95-150 Employment Discrimination
Ordering Information

The first copy of each GAO report and testimony is free.

Additional copies are $2 each. Orders should be sent to the

following address, accompanied by a check or money order

made out to the Superintendent of Documents, when

necessary. Orders for 100 or more copies to be mailed to a

single address are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office

P.O. Box 6015

Gaithersburg, MD 20884-6015

or visit:

Room 1100

700 4th St. NW (corner of 4th and G Sts. NW)

U.S. General Accounting Office

Washington, DC

Orders may also be placed by calling (202) 512-6000 

or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and

testimony. To receive facsimile copies of the daily list or any

list from the past 30 days, please call (301) 258-4097 using a

touchtone phone. A recorded menu will provide information on

how to obtain these lists.

PRINTED ON RECYCLED PAPER
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Mail

Postage & Fees Paid

GAO

Permit No. G100
GAO/HEHS-95-150 Employment Discrimination