United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on the Constitution, Committee on the

Judiciary, House of Representatives

July 1997 U.S. COMMISSION ON

CIVIL RIGHTS

Agency Lacks Basic

Management Controls

GAO/HEHS-97-125

GAO United States

General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-274033 

July 8, 1997

The Honorable Charles T. Canady

Chairman, Subcommittee on the Constitution

Committee on the Judiciary

House of Representatives

Dear Mr. Chairman:

Racially motivated church burnings across the country; racial and civil

unrest in major metropolitan cities such as St. Petersburg, Florida; and the

national debate over the continuing need for federal affirmative action

programs and policies are only some of the issues the U.S. Commission on

Civil Rights is working on today. Established by the Civil Rights Act of

1957, the Commission had a budget of $8.75 million, 8 part-time

commissioners, and a staff of 91 in fiscal year 1996. Its commissioners

have two principal responsibilities—investigating claims of voting rights

violations, and studying and disseminating information, often collected

during specific projects, on the impact of federal civil rights laws and

policies.

Last year, in preparation for the Commission’s reauthorization and in

response to complaints of mismanagement, your Subcommittee began to

look into how the Commission carries out its responsibilities and manages

its resources. To assist you in this effort, you asked us to provide

information on the Commission’s management of projects during fiscal

years 1993 through 1996 and its process for disseminating project reports

to the public.

To respond to your request, we interviewed all of the current

commissioners; the Staff Director; and the Commission officials

responsible for budgeting, personnel, projects, and dissemination to the

public of the Commission’s project results. We reviewed Commission

records, applicable legislation and regulations, and internal administrative

guidance the Commission developed to carry out its operations. We also

attended several Commission meetings to gain an understanding of the

role of the commissioners. In addition, we reviewed the process for

managing all projects the Commission identified as initiated, ongoing, or

completed during fiscal years 1993 through 1996. We did not, however,

receive all the information on project time frames, costs, and other

Commission activities that we requested. (See app. I for details on our

Page 1 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

scope and methodology, including a discussion of the limitations in the

data we received.)

Results in Brief Although our review focused on the management of individual projects,

we found broader management problems at the Commission on Civil

Rights. The Commission appears to be an agency in disarray, with limited

awareness of how its resources are used. For example, the Commission

could not provide key cost information for individual aspects of its

operations, such as its regional offices; its complaints referral process; the

clearinghouse; public service announcements; and, in one case, a project.

Furthermore, significant agency records documenting Commission

decision-making were reported lost, misplaced, or nonexistent. The

Commission has not established accountability for resources and does not

maintain appropriate documentation of agency operations. Lack of these

basic, well-established management controls makes the Commission

vulnerable to resource losses due to waste or abuse.

Commission records indicate that projects accounted for only about

10 percent of the agency’s appropriations during fiscal years 1993 through

1996 despite the number of civil rights issues addressed. Furthermore, our

work shows that management of the 12 Commission projects completed or

ongoing during this 4-year period appears weak or nonexistent. The

Commission’s guidance for carrying out projects is outdated, and the

process described as how projects are actually conducted—including

specifying anticipated costs, completion dates, and staffing—is largely

ignored. For example, 7 of the 12 projects had no specific proposals

showing their estimated time frames, costs, staffing, or completion dates.

Specific time frames were not set for most projects and when they were,

project completion dates exceeded the estimates by at least 2 years.

Overall, projects took a long time to complete, generally 4 years or more.

Some projects took so long that Commission staff proposed holding

additional hearings to obtain more current information. Poor project

implementation is likely to have contributed to the lengthy time frames.

Furthermore, we found no systematic monitoring of project costs or time

frames by Commission management to ensure project quality and

timeliness.

Finally, we found that the Commission disseminates project reports to the

public through three different Commission offices, none of which appears

to coordinate with the others to prevent duplication.

Page 2 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

Background The Commission on Civil Rights was created to protect the civil rights of

people within the United States. The Commission is an independent,

bipartisan, fact-finding agency directed by eight part-time commissioners.

Four commissioners are appointed by the president, two by the president

pro tempore of the Senate, and two by the speaker of the House of

Representatives. No more than four commissioners can be of the same

political party, and they serve 6-year terms. The Commission accomplishes

its mission by (1) investigating charges of citizens being deprived of voting

rights because of color, race, religion, sex, age, disability, or national

origin; (2) collecting and studying information concerning legal

developments on voting rights; (3) monitoring the enforcement of federal

laws and policies from a civil rights perspective; (4) serving as a national

clearinghouse for information; and (5) preparing public service

announcements and advertising campaigns on civil rights issues. The

Commission may hold hearings and, within specific guidelines, issue

subpoenas to obtain certain records and have witnesses appear at

hearings. It also maintains state advisory committees and consults with

representatives of federal, state, and local governments and private

organizations to advance its fact-finding work.

The Commission is required to issue reports on the findings of its

investigations to the Congress and the president and to recommend

legislative remedies. The Commission also must submit at least one report

annually to the president and the Congress that monitors federal civil

rights enforcement in the United States. In addition, because it lacks

enforcement powers that would enable it to apply remedies in individual

cases, the Commission refers specific complaints it receives to the

appropriate federal, state, or local government agency for action.1

A staff director, who is presidentially appointed with the concurrence of a

majority of the commissioners, oversees the day-to-day operations of the

Commission and manages the staff in its six regional offices and

Washington, D.C. headquarters. Figure 1 shows the Commission’s current

organizational structure, and table 1 describes the functions and staffing of

the major components. (For additional background on the Commission,

see app. II)

1

Several agencies have enforcement authority for civil rights issues. For example, the Equal

Employment Opportunity Commission is charged with enforcing specific federal employment

antidiscrimination statutes, such as title VII of the Civil Rights Act of 1964, the Americans With

Disabilities Act of 1990, and the Age Discrimination in Employment Act of 1967. Also, the Assistant

Attorney General for Civil Rights in the Department of Justice is the enforcement authority for civil

rights issues for the nation.

Page 3 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

Figure 1: Commission on Civil Rights Organization Chart as of November 1996

Source: Commission on Civil Rights.

Page 4 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

As of September 30, 1996, the Commission had 8 part-time commissioners

and a total of 91 staff members. Projects conducted by the Commission to

study various civil rights issues are largely the responsibility of its Office

of the General Counsel (OGC) with a staff of 15, and the Office of Civil

Rights Evaluation (OCRE) with a staff of 12, as of fiscal year 1996. The

largest component of the Commission is the Regional Programs

Coordination Unit with 2 staff members in the Washington, D.C., office

and 25 staff members in six regional offices. The regional offices direct the

Commission’s work, which is carried out through 51 advisory

committees—one in each state and the District of Columbia—composed

of citizens familiar with local and state civil rights issues (see table 1).

Table 1: Commission on Civil Rights Components, Functions, and Staff as of September 30, 1996

Component Function

Number of

staff

Commissioners Set policy and direction for the Commission; hold monthly meetings except

during August; and convene several other times a year to conduct hearings,

briefings, conferences, and consultations. 8

Commissioners’ assistants Assist the commissioners in carrying out their responsibilities. 7a

Office of the Staff Director Responsible for the day-to-day management of the Commission; enforces the

policy decisions of the commissioners; plans, manages, directs, and

coordinates functional operations and administrative activities of all the

Commission’s offices in headquarters and the field; and liaisons with the

Congress, the White House, and heads of federal agencies. 5

Office of the General Counsel Responsible for advising commissioners and Commission staff on legal issues;

ensuring that Commission operations are within the scope of the Commission’s

statutory authority; conducting public fact-finding hearings; and drafting reports

on civil rights issues from information obtained through hearings, investigations,

and Commission studies, reports, or other work. 15

Office of Civil Rights Evaluation Responsible for monitoring and evaluating civil rights enforcement efforts of the

executive departments and agencies of the federal government; preparing

appropriate documents, such as staff papers, correspondence, and reports

presenting the Commission’s views and concerns regarding federal civil rights

enforcement; receiving complaints alleging denial of civil rights; and referring

complaints received to the appropriate federal agencies for investigation and

resolution. 12

Regional Programs Coordination Unit Responsible for planning, directing, and monitoring the programs and policies

of 51 State Advisory Committees (SAC) and coordinating SAC programs with

the policies and programs of the Commission. Six regional offices, each

headed by a director, located in Washington, D.C.; Atlanta; Chicago; Kansas

City, Kans.; Denver; and Los Angeles coordinate SAC studies conducted on a

variety of civil rights issues, report to the Commission on the results of SAC

studies, and assist with follow-up on recommendations included in Commission

and SAC reports. Members of SACs are volunteers appointed by the

Commission. 2

(continued)

Page 5 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

Component Function

Number of

staff

Regional offices Responsible for submitting action memorandums, staff reports, project

concepts, and proposals to the Office of Regional Programs for approval.

Regional offices are directly responsible for reports submitted by state advisory

committees, but the SACs are responsible for program planning, receiving

information from scheduled speakers, and reviewing and approving their

reports. Regional office directors are responsible for final approval of SAC

reports. The Commission votes to accept or publish SAC reports, but it is the

Commission’s practice not to allow commissioners to change the reports. 25

Public Affairs Unit Responsible for providing the public with a national clearinghouse repository for

civil rights information; keeping the public informed about civil rights

developments through the distribution of Commission reports and publications;

and managing the Commission’s public service announcements, media

releases, and the Commission’s Internet communications. 6

Congressional Affairs Unit Serves as liaison between the Commission and members of Congress and their

staffs, participates in the review of civil rights legislation, and keeps the

Commission informed of legislative developments. 2

Office of Management Consists of the Personnel, Budget and Finance, and Administrative Services

and Clearinghouse Divisions, which are responsible for operations.

Personnel Responsible for all facets of human resource development including staffing,

classification, benefits, training, and compensation. 5

Budget and Finance Responsible for budget preparation, formulation, justification, and execution;

financial management; and accounting, including travel for commissioners and

staff. 3

Administrative Services 

and Clearinghouse

Responsible for space management, procurement, transportation, security,

telecommunications, supply, and duplication services. 9

Total 99

aOne commissioner’s assistant position was vacant at the time of our review.

The Commission’s authorization expired on September 30, 1996. Although

the Congress did not reauthorize the Commission, it appropriated funds

that allowed the Commission to continue its operations through

September 30, 1997.2

 The Commission’s funding, adjusted for inflation, has

declined by about 58 percent since fiscal year 1980. As shown in figure 2,

the largest cuts in funding occurred between fiscal years 1986 and 1988,

when funding was reduced by 56 percent. Since fiscal year 1991, funding

has been largely unchanged.

2

The Congress appropriated $8.74 million for Commission operations for fiscal year 1997 despite a lack

of authorizing legislation. The Commission’s continued operation is based on a 1992 GAO decision that

stands for the proposition that appropriation legislation is sufficient authority to permit an agency to

continue operating pending reauthorization action. Commission Authority to Operate, 71 Comp. Gen.

378 (Apr. 29, 1992).

Page 6 GAO/HEHS-97-125 Management of Commission on Civil Rights
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Figure 2: Commission Appropriations, FY 1980-97

Dollars in Millions

0

5

10

15

20

1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997

Fiscal Year

Actual Appropriation

Inflation-Adjusted Appropriation

Commission’s

Management Reflects

an Agency in Disarray

The management of the Commission’s operations at the time of our review

showed a lack of control and coordination. The Commission had not

updated its depiction of its organizational structure as required under the

Freedom of Information Act (FOIA) nor its administrative guidance to

reflect a major reorganization that occurred in 1986. Obsolete

documentation of the agency’s operating structure and its administrative

guidance leaves the public and Commission employees unsure of the

agency’s procedures and processes for carrying out its mission. Moreover,

Commission officials reported key records as lost, misplaced, or

nonexistent, which leaves insufficient data to accurately portray

Commission operations. Agency spending data are centralized, and

Commission officials could not provide costs for individual offices or

functions. We also found that the Commission has never requested any

audits of its operations, and information regarding Commission audits in

its fiscal year 1996 report on internal controls is misleading.

Page 7 GAO/HEHS-97-125 Management of Commission on Civil Rights
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Agency Policies and

Procedures Unclear

The Commission has no documented organizational structure available to

the public that reflects current procedures and program processes. FOIA

requires that federal agencies publish and keep up to date their

organizational structure and make available for public inspection and

copying the agencies’ orders, policies, and administrative staff manuals

and instructions. The Code of Federal Regulations, the principal document

for publishing the general and permanent rules of federal agencies, shows

the Commission’s organizational structure as of May 1985;3

 but the

Commission’s current organizational structure is substantially different

because of the major reorganization in 1986.

Confusion also exists regarding which Commission unit has the

responsibility for certain organizational functions. For example, it is not

clear who at the Commission has responsibility for agency publications,

the clearinghouse, and the library. Some Commission officials believed

that these duties are housed within the Office of Management in the

Administrative Services and Clearinghouse Division. However, the

description of Commission component functions provided us put

responsibility for publications and clearinghouse duties under the Public

Affairs Unit. Another Commission official told us that publications and

clearinghouse responsibilities fall under the Regional Programs

Coordination Unit. In addition, the commissioners presented conflicting

views about the responsibilities of the staff director. Half the

commissioners interpreted the staff director’s role as carrying out the

directives of the commissioners, while the other half viewed the staff

director as having wider latitude to manage Commission operations.

In addition, the Commission’s Administrative Manual was issued in

May 1975 as “the official medium for administrative management of the

United States Commission on Civil Rights,” but the Commission has paid

little attention to maintaining and updating its guidance to accurately

reflect agency operations over the last 10 years. The purpose of the

manual is to translate administrative policy derived from the various

legislative and regulatory policies affecting the day-to-day operations into

procedures that the Commission staff can rely on for guidance in carrying

out the agency’s mission. The major reorganization that occurred at the

Commission in the mid-1980s, coupled with high turnover of staff in key

positions of the agency, makes up-to-date operating guidance especially

important for maintaining continuity and performing work efficiently and

effectively. The two office directors responsible for conducting projects,

however—who had been employed at the Commission for 5 and 2-1/2

3

U.S. Commission on Civil Rights mission and functions: 45 C.F.R., part VII.

Page 8 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

years, respectively—had only the 1982 version of the Administrative

Manual to rely on for official procedures for conducting projects.

Commission officials told us that, although it was outdated, the guidance

in the Administrative Manual still reflects the basic Commission policy for

conducting projects. However, we found that projects did not follow all

steps outlined in this guidance, and could not for some steps because the

offices no longer existed (see table 2).

Table 2: Project Development and

Oversight Guidance From the

Administrative Manual Compared With

Actual Practice

Administrative Manual

guidance Characterization of actual practice

Project teams prepare and

submit for approval project

concepts, proposals, and

designs.

Largely ignored. Only 4 of 22 projects in our review had

concepts and proposals; only 3 had design papers.

Project officials obtain

account codes at the

appropriate point in the

planning process.

Partially followed. Projects have account codes; however,

Commission officials could not provide completed forms

for requesting, assigning, and closing out account codes

for the 22 projects reviewed.

Project officials submit

monthly progress reports in

writing to the staff director

through the Office of Program

Planning and Evaluation.

Does not occur. The Office of Program Planning and

Evaluation, which was responsible for preparing monthly

reports to the staff director on the status of all

Commission activities, no longer exists. Commission

officials did not provide any monthly progress reports to

the staff director for any of the projects. However, our

review of completed project files for OCRE showed

memorandums to the staff director about the status of

projects, although not monthly. Completed project files for

OGC were not available for our review.

Budget and Fiscal Division

maintains current records of

all expenditures of money

and staff time and provides

quarterly reports by account

codes to staff director.

Data incomplete. Commission officials told us that they do

not maintain any information on staff time by project. They

did provide fiscal year reports of expenditures for

projects, and all but one included total expenditures.

Officials said that quarterly reports are made to the staff

director. We requested copies of the reports but never

received them.

Publications Management

Division edits national

publications and designs,

produces, and distributes all

publications.

Process unclear. This division no longer exists, and it is

not clear where this function is currently located. We

found three offices that were identified as performing

distribution duties, none of which coordinated distribution

lists. The list identified as the main mailing list did not

appear to have been updated in at least 5 years.

Commission officials told us that they were in the process of updating the

Commission’s Administrative Manual and had updated 8 of 73

administrative instructions; however, the instruction for implementing

Page 9 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

projects is not one of the 8. The Staff Director4 told us that she had

recently convened a task force, made up of the two office directors

responsible for conducting projects and the Special Assistant to the Staff

Director, to revamp the administrative instruction for projects. As of

June 16, 1997, Commission officials said that the task force has met at

least three times over the past several months and the Commission

expects to have a proposed final version of the administrative instruction

for projects for the new staff director’s consideration.

Key Commission Records

Missing

The Commission reported that key records—which either provided the

basis for or documented decisions about Commission operations and

project management—were lost, misplaced, or nonexistent. Minutes of

certain Commission meetings were reported to be lost. According to

officials, minutes of the Commission’s meetings discussing the initiation of

7 of the Commission’s 22 projects were lost or misplaced. Additionally, the

files for these seven projects were either misplaced, misfiled, or not

available for review.5

 Other key records outlining critical information

about projects did not exist, such as project proposals, or were not

available, such as the actual start dates for projects. Officials could not

locate the Commission’s log for issuing its administrative guidance and

could not provide issuance dates for some of its guidance, specifically,

that outlining the criteria for conducting projects. Finally, the Commission

did not have records showing the total cost of its project on funding

federal civil rights enforcement.

Spending Data Not

Maintained by Office or

Function

Commission officials told us that they maintain a central budget but could

not provide the amount or percentage of the budget used by various

Commission offices or functions. Officials did not provide the costs of

complaint referrals, clearinghouse activities, regional operations, report

publication and dissemination, or public service announcements. The only

function Commission officials provided separate financial information on

was the projects’ costs. But even for project costs, records were poorly

maintained, and it is unclear whether they reflect the true costs for the

projects. For example, the Commission approved one project’s report for

publishing on September 9, 1994, and the report shows an issuance date of

September 1994, yet financial information provided to us showed costs

4

The staff director at the time of our review resigned effective Dec. 31, 1996. As of May 1997, the

Commission did not have a staff director.

5

These projects included six on racial and ethnic tensions in American communities that were

completed or ongoing and one completed project on funding federal civil rights enforcement.

Page 10 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

incurred through fiscal year 1996 for this project. A November 1, 1995,

letter from the Commission to the House Constitution Subcommittee

showed actual costs for the project of $261,529, but data Commission

officials provided us showed total project costs of $531,798. At the time of

our audit work, the Commission was not able to reconcile the difference.6

Commission’s Management

Controls Are Weak

The Commission’s management controls over its operations are weak and

do not ensure that the Commission is able to meet its statutory

responsibilities7

 or its program objectives. Federal agencies are required

under the Federal Manager’s Financial Integrity Act to report on internal

controls annually to the president and the Congress; however, the

Commission did not report on the agency’s internal controls for fiscal year

1995. In addition, the Commission’s report on internal controls for fiscal

year 1996 appears to misrepresent information concerning audits of the

Commission. The report claims that several administrative activities are

randomly audited by the Department of Agriculture’s Inspector General,

when in fact no such audits were done. The only direct connection

between the Commission and the Department of Agriculture is that the

Commission’s financial transactions are handled through Agriculture’s

National Finance Center. Vendors submit invoices directly to the National

Finance center for payment, and the Commission does not verify the

accuracy of the invoices submitted. The Agriculture Inspector General is

responsible for auditing the automated systems of Agriculture’s National

Finance Center. But the Inspector General’s office told us that the

Commission has never requested any audits of its transactions.

Furthermore, we did not find that any other audits of Commission

expenditures had been performed.8

Recent reviews of the Commission’s operations by the Office of Personnel

Management (OPM) and a civil rights advocacy group have been critical of

Commission management. OPM reviewed the Commission’s personnel

practices and concluded in a 1996 report that the Commission is “an

6

The project evaluated the enforcement of the Fair Housing Amendments Act of 1988. In responding to

a draft of this report, the Office of the Staff Director said that the project produced two reports and

data provided to Congress reflected fiscal year 1994 cost while the GAO request represented all costs

on the project and adding the costs associated with the two reports reconciles the difference. Records

provided us during the audit do not support these comments.

7

The Subcommittee on the Constitution, House Committee on the Judiciary, reported that for fiscal

year 1995 the Commission did not meet its statutory requirement to submit to the Congress at least

one report each fiscal year that monitors federal civil rights enforcement. (104th Congress, House

Report 104-846, Sept. 1996).

8

The Commission is not required by statute to have an Inspector General, and its operations have not

been audited by an outside accounting firm.

Page 11 GAO/HEHS-97-125 Management of Commission on Civil Rights
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agency badly in need of managerial attention.”9 According to the report,

the Commission had numerous instances of poor documentation of

staffing actions, which made it impossible for OPM to definitively determine

the Commission’s compliance with OPM regulations. However, in one

instance, OPM did find violations of laws and regulations in the

Commission’s appointment of a staff member, resulting in that staff

member’s appointment being terminated.10 In addition, a 1995 report11 by

the Citizens’ Commission on Civil Rights12 reported that the Commission’s

performance has been “disappointing.” The report noted that projects take

so long to complete that they may be out of date because conditions have

changed by the time the project is completed, reducing the effectiveness of

the Commission’s work.

Commission Projects

Poorly Managed and

Take Years to

Complete

Although Commission projects address a number of civil rights issues, its

project spending accounts for a small percentage of the Commission’s

budget. Furthermore, the Commission’s efforts to manage these projects

fall short in areas such as following project management guidance,

meeting projected time frames for completing projects, and systematic

monitoring of projects. Commission projects entail collecting and

analyzing information on civil rights issues to appraise federal laws and

regulations. During fiscal years 1993 through 1996, the Commission

completed 5 projects, deferred 10 others, and worked on another 7 that

were still ongoing at the end of fiscal year l996 (see tables 3 and 4). These

22 projects cover a variety of issues, including racial and ethnic tensions in

American communities; the enforcement of fair housing, fair employment,

and equal education opportunity laws; economic opportunities for

minority youths; and naturalization and citizenship issues.

9

OPM, Office of Merit Systems Oversight and Effectiveness, Report of an Oversight Review: U.S.

Commission on Civil Rights-Washington, D.C. (Washington, D.C.: OPM, Nov. 1996).

10In response to OPM’s recommendations, the Commission wrote to OPM of its planned corrective

actions. In a February 21, 1997, letter, OPM wrote that the Commission’s response reflects that efforts

are in place to promote an effective human resources management program and the changes the

Commission described should ensure the Commission’s adherence to merit system principles and Civil

Service rules and regulations.

11Citizens’ Commission on Civil Rights, New Challenges: The Civil Rights Record of the Clinton

Administration Mid-Term: Interim Report on Performance of U.S. Commission on Civil Rights During

the Clinton Administration (Washington, D.C.: Citizens’ Commission on Civil Rights, 1995).

12The Citizens’ Commission on Civil Rights is a private, bipartisan group of former officials who have

served in federal government positions with responsibility for equal opportunity. The Citizens’

Commission was established in 1982 to monitor the civil rights policies and practices of the federal

government and to seek ways to accelerate progress in the area of civil rights.

Page 12 GAO/HEHS-97-125 Management of Commission on Civil Rights
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Table 3: Completed and Ongoing Commission Projects, FY 1993-96

Project title

Assigned

office

Project

approval date Concept paper Proposal Hearing date

Report

approval date

Completed

Racial and Ethnic Tensions in

American Communities: Poverty,

Inequality, and Discrimination—A

National Perspective

OGC 2/91 Yes No 5/92 3/3/95

Racial and Ethnic Tensions in

American Communities: Poverty,

Inequality, and

Discrimination—Chicago

OGC 2/91 Yes No 6/92 4/21/95

The Fair Housing Amendments

Act of 1988: The Enforcement

Report

OCRE 5/90 No Yes N/A 9/9/94

Federal Title VI Enforcement to

Ensure Nondiscrimination in

Federally Assisted Programs

OCRE 9/93 Yes Yes N/A 1/11/96

Funding Federal Civil Rights

Enforcement

Staff director No date No No N/A 6/20/95

Ongoing

Racial and Ethnic Tensions in

American Communities: Poverty,

Inequality, and

Discrimination—Mississippi Delta

OGC 2/91 Yes No Hearing

rescheduled

Federal Affirmative Action

Programs and Policies Hearing

OGC 4/95 Yes Yes Hearing

canceled

Racial and Ethnic Tensions in

American Communities: Poverty,

Inequality, and

Discrimination—Los Angeles

OGC 2/91 Yes No 6/93

Racial and Ethnic Tensions in

American Communities: Poverty,

Inequality, and

Discrimination—New York

OGC 2/91 Yes No 9/94 and 7/95

Racial and Ethnic Tensions in

American Communities: Poverty,

Inequality, and

Discrimination—Miami

OGC 2/91 Yes No 9/95

Evaluation of Equal Education

Opportunity Law Enforcementa

OCRE 2/91 Yes Yes N/A

Evaluation of Fair Employment

Law Enforcement

OCRE 2/91 Yes Yes N/A

Note: N/A means not applicable.

aVolume I was completed in December 1996 and volumes II through VI are projected to be

completed in FY 1997.

Page 13 GAO/HEHS-97-125 Management of Commission on Civil Rights
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Table 4: Deferred Commission

Projects, FY 1993-96

Deferred projects Assigned office

Project

approval

date Concept paper

Expanding the Economic

Opportunities of African American,

Asian, and Latino Youth

OCRE/OGC

7/94

Yes

Schools and Religion OGC 7/94 No

Financial Aid for Higher Education OGC 10/94 No

Voting Rights OGC 10/94 No

Environmental Justice OGC 10/94 No

Enforcement of Americans With

Disabilities Act

OCRE/OGC

4/94

Yes

Naturalization and Citizenship Issues OCRE 4/94 No

Technological Change and Job

Opportunities of Women, Minorities,

and Older Persons

OGC

4/94

No

The Crisis of Young African American

Males in Inner Cities

OGC

3/95

Yes

Summary Report on Racial and

Ethnic Tensions Project

OGC

5/93

No

Project Spending Accounts

for Small Percentage of

Commission Budget

Although the Commission appears to spend about 10 percent of its

resources annually on projects, we were unable to verify project spending

because of the Commission’s poor record-keeping. According to

Commission records, costs incurred for individual ongoing and completed

projects during fiscal years 1993 through 1996 ranged from about $33,00013

for a completed project on funding for federal civil rights enforcement to

about $764,000 for a project on racial and ethnic tensions in Los Angeles

that had been ongoing throughout the 4-year period (see table 5).

13The total cost of this project is not known because Commission officials did not, as they had for

other projects, account for staff salaries spent to conduct the project.

Page 14 GAO/HEHS-97-125 Management of Commission on Civil Rights
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Table 5: Commission Spending on Completed and Ongoing Projects, FY 1993-96

Spending by fiscal year

Project title 1993 1994 1995 1996

Total

spendinga

Racial and Ethnic Tensions in American 

Communities: Poverty, Inequality, and Discrimination

National Perspectiveb $ 25,550 $ 5,991 $ 20,170 0 $ 51,711

Chicagob 66,489 20,995 16,373 0 103,857

Los Angeles 465,152 56,105 92,977 $149,498 763,732

New York 3,038 336,947 119,529 74,400 533,914

Miami 0 4,789 62,050 14,087 80,926

Mississippi Delta 0 0 52,385 162,753 215,138

Federal Affirmative Action Programs and Policies Hearing 0 0 68,402 53,165 121,567

The Fair Housing Amendments Act of 1988: The Enforcement

Reportb 157,511 122,413 3,624 5,430 288,978

Federal Title VI Enforcement to Ensure Nondiscrimination in

Federally Assisted Programsb 7,500 238,126 131,229 38,080 414,935

Funding Federal Civil Rights Enforcementb 0 24,057 9,052 18 33,127c

Evaluation of Equal Education Opportunity Law Enforcement 0 0 193,704 307,969 501,673

Evaluation of Fair Employment Law Enforcement 0 0 0 0 0

Total project spending $725,240 $809,423 $769,495 $807,865d $3,112,023d

Total Commission appropriation for year

$7.8 million $7.8 million $9.0 million $8.7 million

$33.3

million

Percentage of appropriation spent on projects 9.3 10.4 8.5 9.3 9.3

aTotal spending on particular projects may be more if funds spent prior to fiscal year 1993 are

included.

bProject completed.

cDoes not include salaries for this project.

dIncludes $2,465 spent in fiscal year 1996 on a deferred project, Enforcement of Americans With

Disabilities Act.

Project Management

Guidance Often Ignored

The Commission’s Administrative Manual, administrative instruction 5-1,

governs the process for conducting projects; however, the guidance has

not been updated since 1982 and does not accurately reflect the current

practices as they were described to us. Furthermore, our review of the

projects showed that the process described was often not followed.

According to Commission officials, the process that should be used to

develop an idea into a project and ultimately a report includes five stages:

(1) initiating an idea as a concept, (2) selecting concepts to develop into

Page 15 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

proposals for projects, (3) conducting project research, (4) approving final

publication of a report, and (5) publishing and disseminating the report

(see table 6).

Table 6: Stages of Project Development at the Commission on Civil Rights

Project stage Staff role Staff director role Commissioners’ role

Initiation Staff, including regional staff,

submit ideas or concepts for

possible projects to the staff

director.

Decides which ideas or

concepts to forward to the

commissioners.

The Commission holds annual

planning meetings in January

or February. At that time, they

vote on which concepts to

return to the staff to develop

into proposals for further

consideration.

Selection Develop approved concepts

into proposals that identify time

frames, budget, staffing levels,

scope and methodology, and

type of anticipated report.

Submits proposals to the

commissioners.

Commissioners approve the

proposals as projects.

Research Conduct research. Assigns the project, usually to

either OCRE or OGC.

Hold hearings as necessary.

Approval OGC reviews for legal issues. Submits draft for legal and

editorial reviews and transmits

to commissioners for review

and approval.

Commissioners and their

assistants review the draft

product and make changes.

Commissioners vote to

approve the product.

Publication and dissemination Assist the staff director in

making all final report

decisions for publication,

including the number to be

printed in addition to the

minimum 5,000 copies of each

report.

Makes and approves all final

decisions for publication and

dissemination.

None.

Project documentation showed that this process was frequently ignored,

with less than half of the projects during the period we studied following

these procedures. Of the 12 completed and ongoing projects, only 4 had

both concept papers and detailed proposals specifying the focus of the

project, time frame, budget, and staff levels. None of the racial and ethnic

tensions projects included proposals indicating the time frame for

completion, proposed budget, or anticipated staff level. These six projects

have absorbed years of staff time and accounted for more than 50 percent

of the Commission’s total spending on projects, yet only two of these

projects have been completed. Although concept papers are required for

deferred projects, only 3 of the 10 deferred projects had concept papers.

The funding federal civil rights enforcement project deviated from the

Page 16 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

process in the initiation stage, and the records were not available for

assessing the project relative to other stages of the process.

Projects Take Years to

Complete

The Commission has no overall standard for how long a project should

take nor expectations for the length of time specific projects should take.

While an estimate of the time to conduct projects is required in proposals,

very few projects had estimated time frames for completing projects. For

the projects that did specify time frames, the actual time a project took to

complete was 2 to 3 years beyond their planned duration. Only two of the

five completed projects had anticipated start and finish dates, but both

overran their time frames. Both projects had anticipated time frames of 1

year, but one project took 3 years to complete (Federal Title VI

Enforcement to Ensure Nondiscrimination in Federally Assisted Programs,

issued June 1996), and one took 4 years (The Fair Housing Amendments

Act of 1988: The Enforcement Report, issued Sept. 1994). The Commission

attributed delays in meeting anticipated time frames to staff turnover,

limited staff resources, and the need to update factual information.

Although the length of the projects cannot generally be compared with the

expected or approved length, we found that their actual time frames

spanned several years. During the period of our review, projects took an

average of 4 years to complete from the time they were approved by the

commissioners.14 Four of the five completed projects had data available on

time frames—three of the projects took 4 or more years to complete, and

one was completed in about 2-1/2 years. For one project, the Commission

held a hearing in May 1992 and in the ensuing 3 years incurred additional

project costs of about $50,000. In 1995, it issued the hearing transcript,

accompanied by a summary of its contents without any further analysis, as

a final product.15 The Commission’s Staff Director reported in a

November 1995 letter to the House Judiciary Committee, Subcommittee on

the Constitution that the Commission originally scheduled publication of

the hearing transcript for fiscal year 1993 but “subsequently, the decision

was made to publish an executive summary in addition to the transcript,

which delayed publication of the document.”

14Because the Commission did not have information on actual start dates, we determined our cycle

time calculations using the project approval date as the start date and the report issuance date as the

end date.

15Commission on Civil Rights, Racial and Ethnic Tensions in American Communities: Poverty,

Inequality, and Discrimination-A National Perspective, executive summary and transcript of hearing

held in Washington, D.C. (Washington, D.C.: U.S. Commission on Civil Rights, May 21-22, 1992).

Commission data provided us showed that the Commission approved the transcript and executive

summary for publication as of March 1995, but the actual document is dated May 1992.

Page 17 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

Ongoing projects appeared likely to overrun their estimated time frames as

well. For six of the seven ongoing projects, nearly 6 years have elapsed

since their approval. Anticipated time frames were available for three of

the seven ongoing projects. The “Evaluation of Fair Employment Law

Enforcement” project was anticipated as a 2-year project approved in

February 1991. The Commission expected to begin the project in May 1995

and complete it in September 1997, but it appears that no work was done

on this project in fiscal years 1995 and 1996. Therefore, we believe it is

unlikely that this project will be completed on time. The “Evaluation of

Equal Education Opportunity Law Enforcement” project was also

approved by the commissioners in February 1991. The Commission

anticipated starting work on this project in February 1995 and planned to

complete the project and issue four reports by September 1996. In July

1996 the responsible project official proposed that the Commission

publish six separate reports and informed the staff director that the

project milestones had to be extended. The Commission issued the first

volume of the anticipated six in December 1996 and now expects to issue

the last of the remaining reports by December 1997, more than 1 year later

than initially anticipated and more than 6 years from the date the project

was approved. The remaining project that had a time frame, “Federal

Affirmative Action Programs and Policies,” approved in April 1995, was

expected to take 2 to 3 years, and is ongoing.

Problems with the quality of the work in planning and implementing

certain projects have apparently contributed to lengthy project time

frames. For example, the Commission’s General Counsel requested

additional hearings on three projects because of poor planning for the

initial hearings and the resulting inadequate data gathering. For the racial

and ethnic tensions projects for New York, Chicago, and Los Angeles, the

General Counsel determined that the information gathered at previous

hearings was insufficient, outdated, or too weak to support a quality

report. The New York project had insufficient testimony and

documentation in eight different areas. The Chicago project was criticized

by city officials as presenting an unbalanced picture, including

unsubstantiated testimony, mischaracterized information, inadequate or

nonexistent analyses, and missing certain recent city initiatives. The Los

Angeles report contained information that the Commission’s General

Counsel viewed as outdated and therefore required further investigation

for the Commission’s report to be current.

Projects Not

Systematically Monitored

The Commission does not systematically monitor projects to ensure

quality and timeliness of project results and to help set priorities. The only

Page 18 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

formal mechanism in place to inform the commissioners about the status

of projects is through the discretion of the staff director, orally or in the

monthly report the staff director provides to the commissioners.16 We

found that the commissioners only received limited updates on some

projects in the staff director’s monthly report. The staff director did

receive periodic updates about the progress of projects being conducted

by OCRE. However, because of frequent staff turnover and misfiled or lost

records, we could not determine whether the staff in the General

Counsel’s office similarly informed the staff director about project

progress.

Commissioners did not receive routine information on the costs of

projects or the personnel working on the projects. After a vote to approve

a project, commissioners are not aware of (1) those projects the staff

director decides to start, (2) when projects are actually started, (3) cost

adjustments for projects, (4) time frame changes, and (5) personnel

changes, all of which can affect the timeliness and quality of projects. All

of the commissioners told us that they are not involved in assigning

projects or specific tasks to the staff and that this is strictly a

responsibility of the staff director. However, most commissioners

expressed a desire to have routine reporting on the status of individual

projects, specifically, costs and time frames for completion, so they would

know when to expect draft reports. In fact, most of the commissioners

told us that they frequently have no knowledge of the status of a particular

project from the time they approve it until a draft report is given to them

for review. Some commissioners said that communication is a big problem

at the Commission and that improvement in communications up and down

staff levels could help resolve the problem.

Dissemination of

Project Reports

The Commission uses three different offices to disseminate project

reports, but a lack of coordination among these offices raises the potential

for duplicative work. Commission officials told us that these three

offices—the office responsible for conducting the project (OGC or OCRE),

the Congressional Affairs Unit, and the Office of Management

(Administrative Services and Clearinghouse Division)—maintain mailing

lists that are used to disseminate Commission project reports, hearing

transcripts, and other documents to the public. The responsible project

office maintains targeted lists and may develop other mailing lists of

routine document recipients. The Congressional Affairs Unit is responsible

16While the Commission holds planning meetings to discuss future projects, these meetings are held

annually and therefore do not serve to routinely inform the commissioners about the status of

projects.

Page 19 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

for disseminating Commission publications to the Congress. The

Administrative Services and Clearinghouse Division maintains the

agency’s general mailing list, coded by subject matter, and is responsible

for sending reports to the public and other federal agencies.

With no coordination among the offices, duplicate mailings are likely. We

noted, for example, that the Administrative Services unit’s general mailing

list included members of Congress, which should be the responsibility of

the Congressional Affairs unit. Efforts to update the lists could eliminate

duplication among the offices, but the Commission had not made such

efforts. Our review of the agency’s general mailing list indicated that the

list had not been updated in at least 5 years. Commission officials told us

that they update the general mailing list annually, but did not provide

documentation verifying the updates. In fact, the general list showed

various individuals in specific federal positions who, at the time of our

review, no longer served in those positions. According to a Commission

official, a staff member had offered to purge the various lists to eliminate

duplication and update the agency’s general mailing list, but the offer was

refused.

Commission officials told us that they did not know the costs for

publishing and disseminating project reports. The officials said that they

authorize the printing of at least 5,000 copies of each report.17 One official

said that she did not know what the mailing costs are, but the agency has

never “had a problem” sending out reports.

Conclusions Our overall assessment of the Commission suggests that its operations

lack order, control, and coordination. Management is unaware of how

federal funds appropriated to carry out its mission are being used, lacks

control over key functions, and has not requested independent audits of

Commission operations. These weaknesses make the Commission

vulnerable to misuse of its resources. The lack of attention to basic

requirements applying to all federal agencies, such as up-to-date

descriptions of operations and internal guidance for employees, reflects

poorly on the overall management of the Commission.

Projects embody a key component of the Commission’s operations, yet the

management of projects is haphazard or nonexistent. No overall standard

exists for assessing the timeliness of projects or the expectations of how

17In comments provided on this report, Commission officials provided costs of $29,900 for 8,000 copies

of the Federal Title VI Enforcement to Ensure Nondiscrimination in Federally Assisted Programs and a

cost of $18,693 for 5,100 copies of volume I of the Equal Educational Opportunity project series.

Page 20 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

long projects should take. And the lack of project documentation,

systematic monitoring to detect delays and review priorities, and

coordination among offices that disseminate reports seriously hampers the

Commission’s ability to produce, issue, and disseminate timely reports.

Results from independent reviews of the Commission’s operations, such as

the Citizens’ Commission on Civil Rights and OPM, substantiate our

assessment of the Commission’s weak management and the need for

improvements.

Recommendations to

the Commission

We recommend that the Commission develop and document policies and

procedures that (1) assign responsibility for management functions to the

staff director and other Commission officials and (2) provide mechanisms

for holding them accountable for properly managing the Commission’s

day-to-day operations. This effort should include

• updating the C.F.R. to provide for public access to the current

organizational structure, procedures, and program processes of the

Commission;

• updating internal management guidance so that staff are assured that their

efforts comply with the administrative policies of the Commission,

applicable legislation, and federal rules and regulations; and

• establishing a management information system for commissioners and

staff to use to plan projects and track progress using the best information

available about projects’ expected and actual costs, time frames, staffing

levels, and completion dates.

Agency Comments The U.S. Commission on Civil Rights provided us with two sets of

comments on a draft of this report. We received one set of comments from

four commissioners and another set from the Chairperson, Vice

Chairperson, and the two remaining commissioners. The latter set

included comments from the Commission’s Office of the Staff Director.

The comments are printed in their entirety in appendixes IV and V.

In one set of comments, Commissioners Anderson, George, Horner, and

Redenbaugh concurred with our assessment and the recommendations on

management improvements needed at the Commission. These four

commissioners said that they will closely monitor the performance of the

new staff director to ensure that the report’s recommendations are

implemented, Commission operations are accounted for, and agency

Page 21 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

procedures and processes for carrying out its mission are updated. (See

app. IV.)

In the other set of comments, Chairperson Berry, Vice Chairperson

Reynoso, and Commissioners Higginbotham and Lee challenged our

report, calling it “short” on historical content, relevant context, and

substantiated facts. These four commissioners believed that our

recommendations only narrowly addressed aspects of the Commission’s

management but pledged to implement the recommendations.

Furthermore, these commissioners said that operational deficiencies cited

in the report do not affect the Commission’s performance of its basic

mission and that many of the findings cited may well be based on

miscommunication during the audit. In this regard, they said that the

Commission’s Office of the Staff Director would point out the concerns in

detail in attached comments. The commissioners addressed four areas of

concern that they believed caused our report to provide a distorted view

of Commission operations. These areas are the following:

• Update of the Commission’s Administrative Manual—The four

commissioners said that the report does not tell the full story because it

omits the impact of budget cuts, downsizing, and reductions-in-force that

occurred in the 1980s.

• Method used by the Commission to maintain its budget—The

commissioners said that the report criticizes the Commission for not being

able to provide the amount or percentage of the budget used by the

Commission’s various offices or functions, which they maintained is an

inaccurate criticism. They said that the Commission does know this

information but we did not ask for it.

• Characterization of the OPM report on Commission personnel

practices—According to the four commissioners, upon receipt of the

Commission’s response to the OPM report, OPM concluded that efforts are in

place to promote an effective human resources management program.

• Commissioner supervision of projects—The four commissioners said that

commissioners do in fact monitor all projects and, upon request, are

afforded updated information on the progress of projects.

The four commissioners concluded that they perceived the draft report to

be a great injustice to the Commission.

We believe that our report contains adequate historical information and, in

fact, includes information regarding changes in funding from 1980 to 1997.

We also discuss in appendix I the limitations we faced in reporting on

Page 22 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

Commission operations that were caused by a lack of documentation and

the Commission’s poor record-keeping. We did not receive information we

asked for that would have provided more context for Commission

operations. We asked Commission officials repeatedly for records, files,

and other documentation about major aspects of the Commission’s

operations, including costs incurred for the Commission’s various offices,

functions, and projects, but were told that several key documents were

misplaced, lost, or did not exist. For example, we asked Commission

officials for staffing information showing when downsizing,

reductions-in-force, and reorganizations occurred. We were told in a letter

from the Commission dated December 4, 1996, and in several meetings

with Commission officials, that much of the information we requested,

including the staffing and cost information, was not available. We did not

receive all minutes requested describing the commissioners’ initial

discussions of the six racial and ethnic tension projects and the project on

Funding Civil Rights Enforcement. The minutes were particularly

important to show how these projects were initiated and planned.

We believe the Commission’s efforts to implement the OPM

recommendations regarding human resources management represent a

step in the right direction and encourage future efforts to improve its

management. We have modified our report to reflect the OPM assessment

of corrective actions the Commission took in response to the OPM review.

We are also encouraged by the statements of both the commissioners and

the Office of the Staff Director that the Commission will have a revised

management information system in place by October 1, 1997, that will

accurately track the status of Commission projects and the human and

budgetary resources committed to those projects so that, on a monthly

basis, commissioners will be in a position to evaluate the progress of

projects and assess the effectiveness of management operations.

The comments submitted by the Office of the Staff Director, which are an

attachment to the commissioners’ comments, addressed 19 points in our

report relating to our analysis of the management issues at the

Commission and recommendations for improvement. Most of the

comments generally discussed the reasons that the situations we reported

exist and actions the Commission is taking or plans to take to address

management weaknesses. For example, with regard to our statement that

Commission projects took so long that Commission staff proposed holding

additional hearings, the Office of the Staff Director agreed that some

projects take too long and said that the Commission has attempted to

Page 23 GAO/HEHS-97-125 Management of Commission on Civil Rights
B-274033 

speed up the process. It noted, however, that these efforts have been

hindered by commissioner and staff turnover.

We have incorporated, as appropriate, technical changes based on the

comments of the four commissioners critical of our report and those of the

Office of the Staff Director. For example, we are now separately reporting

the number of commissioners and the number of Commission staff and

have added that the Commission holds annual project planning meetings.

We have also modified our report to reflect comments about task force

meetings to revamp the administrative instruction for projects and to show

the costs for publishing two reports. In addition, we have added the

explanation from the Office of the Staff Director of the $270,000 difference

between the cost figure the Commission provided to the House

Constitution Subcommittee and the cost it gave us for the Fair Housing

Amendment Act project.

We are sending copies of this report to the eight commissioners and the

Commission Staff Director; the Director, Office of Management and

Budget; and other interested parties.

Please contact me on (202) 512-7014 or Sigurd R. Nilsen, Assistant

Director, on (202) 512-7003 if you have any questions about this report.

GAO contacts and staff acknowledgments are listed in appendix VI.

Sincerely yours,

Cornelia M. Blanchette

Associate Director, Education

 and Employment Issues

Page 24 GAO/HEHS-97-125 Management of Commission on Civil Rights
Page 25 GAO/HEHS-97-125 Management of Commission on Civil Rights
Contents

Letter 1

Appendix I 

Scope and

Methodology

30

Data Collection Strategy 30

Background Data on the Commission 30

Project Management 30

Limitations 31

Appendix II 

Additional

Information on the

U.S. Commission on

Civil Rights

32

Commission Reauthorizations 33

Organizational Structure 34

Staffing 34

Commission Spending 35

Appendix III 

U.S. Commission on

Civil Rights

Commissioners for

the Period August

1996-May 1997

37

Appendix IV 

Comments From

Commission on Civil

Rights Commissioners

Anderson, George,

Horner, and

Redenbaugh

38

Page 26 GAO/HEHS-97-125 Management of Commission on Civil Rights
Contents

Appendix V 

Comments From the

Commission on Civil

Rights Chairperson,

Vice Chairperson,

Commissioners

Higginbotham and

Lee, and Staff

Director

39

Appendix VI 

GAO Contacts and

Staff

Acknowledgments

74

Related GAO Products 76

Tables Table 1: Commission on Civil Rights Components, Functions, and

Staff as of September 30, 1996

5

Table 2: Project Development and Oversight Guidance From the

Administrative Manual Compared With Actual Practice

9

Table 3: Completed and Ongoing Commission Projects, FY

1993-96

13

Table 4: Deferred Commission Projects, FY 1993-96 14

Table 5: Commission Spending on Completed and Ongoing

Projects, FY 1993-96

15

Table 6: Stages of Project Development at the Commission on

Civil Rights

16

Table II.1: Commission Authorizations, 1957-96 34

Table II.2: Commission Staffing Levels Over the 4-Year Period

Reviewed, Oct. 15, 1993-Sept. 30, 1996

35

Table II.3: Commission Spending Levels in Fiscal Year 1996 35

Table II.4: Commission Actual and Inflation-Adjusted

Appropriations

36

Page 27 GAO/HEHS-97-125 Management of Commission on Civil Rights
Contents

Figures Figure 1: Commission on Civil Rights Organization Chart as of

November 1996

4

Figure 2: Commission Appropriations, FY 1980-97 7

Abbreviations

EEO Equal Employment Opportunity

FOIA Freedom of Information Act

OCRE Office of Civil Rights Evaluation

OGC Office of the General Counsel

OPM Office of Personnel Management

SAC State Advisory Committee

Page 28 GAO/HEHS-97-125 Management of Commission on Civil Rights
Page 29 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix I 

Scope and Methodology

In designing our study, we obtained all legislation and regulations

governing the Commission. We also gathered data on all projects initiated,

ongoing, and completed during fiscal years 1993 through 1996, the period

of our review; and we obtained data on the Commission’s budget, staffing,

projects, and legislative history. We conducted our work between August

1996 and May 1997 in accordance with generally accepted government

auditing standards.

Data Collection

Strategy

We reviewed all applicable legislation, regulations, and historical

information, which included Commission appropriations for fiscal years

1980 through 1997 and Commission reauthorizations beginning with its

creation in 1957 through September 30, 1996. We interviewed each

commissioner on the role of the Commission, management of Commission

projects, and overall management of the agency. To determine how and to

what extent the Commission manages its projects, we obtained internal

administrative guidance, staff listings over the 4-year period reviewed, an

organization chart depicting the Commission’s current organizational

structure, definitions of all Commission functions, and other relevant

documents. We attended Commission meetings, interviewed the staff

director, and interviewed Commission officials responsible for budget,

staffing, projects, and dissemination of project results to the public. We

obtained all documents through the Office of the Staff Director.

Background Data on

the Commission

To review the role of the Commission, we obtained pertinent sections of

the U.S. Code, Public Laws, the Code of Federal Regulations, the

legislative history, and other relevant documents about the Commission.

We synthesized the relevant sections of the legislation and regulations to

form a complete view of the role of the Commission.

Project Management To review the management of projects, the Commission provided us with a

list of approved projects that were initiated, ongoing, or completed during

fiscal years 1993 through 1996. Because the Commission’s internal

guidance and administrative instructions for carrying out projects were

outdated, we reviewed agency project files to determine the process the

Commission followed for the projects. We also interviewed the staff

director and Commission officials responsible for staffing, budget,

projects, and dissemination of reports to the public. The Commission

provided a list of staff, broken out by office, but could not provide data on

actual staff time devoted to projects, nor could it provide budget

Page 30 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix I 

Scope and Methodology

information by Commission function. The Commission provided us with

cost data for all but one project, but we are not confident that the data are

accurate because of the Commission’s poor record-keeping.

Limitations Our ability to accurately portray the Commission’s management of its

projects was hampered due to inadequate Commission record-keeping, a

lack of data, and the inability of Commission officials to generate certain

data. In addition, we could not link budget information to specific

activities because the Commission has a central budget and does not

break down allocations to headquarters by unit and to regional offices.

Nor was budget data available for Commission operations, such as the

fiscal resources spent to carry out the Commission’s complaints referral

process, the clearinghouse, and public service announcements.

We were unable to examine records for three of the five projects

completed during our review period because the Commission told us that

documents were lost, misplaced, or nonexistent. Other data not available

included the total cost for one project, planned budget costs for seven

projects, concept papers for nine projects, and proposals for seven

projects. We were unable to validate the process the Commission followed

for projects by using the administrative guidance because the Commission

told us the guidance was out of date and was being updated.

Page 31 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix II 

Additional Information on the U.S.

Commission on Civil Rights

Established by the Civil Rights Act of 1957, the Commission on Civil Rights

is an independent bipartisan agency created to protect the civil rights of

people within the United States. The mission and authority of the

Commission is to (1) investigate charges that citizens are being deprived

of certain voting rights by reason of color, race, religion, sex,18 age,

disability,19 or national origin; (2) relative to deprivation of voting rights,

study and collect information concerning legal developments; and

(3) appraise federal laws and policies; (4) serve as a national

clearinghouse for information;20 and (5) prepare public service

announcements and advertising campaigns.21 To accomplish its mission,

the Commission may hold hearings and issue subpoenas within the state in

which the hearing is being held and within a 100-mile radius of the site for

the production of documents and the attendance of witnesses at such

hearings. It also maintains state advisory committees, and consults with

representatives of federal, state, and local governments, and private

organizations in furtherance of its fact-finding functions.

The Commission is required to issue reports and findings of its

investigations to the Congress and the president and recommend

legislative remedies. The Commission must submit at least one report

annually to the president and the Congress that monitors federal civil

rights enforcement in the United States. In addition, because it lacks

enforcement powers that would enable it to apply specific remedies in

individual cases, the Commission refers specific complaints it receives to

the appropriate federal, state, or local government agency for action.

In 1957, the Commission consisted of six commissioners appointed by the

president, with not more than three to be from the same political party.

There were no specified terms of office. The Commission operated for

more than 25 years before its structure changed from the original

formulation. In 1983, the Congress passed legislation22 creating a new Civil

Rights Commission to succeed the presidentially appointed Commission

established in 1957. Under the 1983 legislation, the number of

commissioners was expanded from six to eight, with not more than four to

18Sex was added as a protected group in 1978, P.L. 92-496, section 3.

19Age and Handicap were added as protected groups in 1983, P.L. 95-444, section 3. The term

“handicap” was changed to “disability” in 1994 by P.L. 103-419.

20This duty was authorized by title V of the Civil Rights Act of 1964, P.L. 88-352.

21The additional duties of public service announcements and advertising campaigns were added by the

1994 statute, P.L. 103-419.

22P.L. 98-183.

Page 32 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix II 

Additional Information on the U.S.

Commission on Civil Rights

be from the same political party. The way commissioners were appointed

changed also, allotting four to the president, two to the president pro

tempore of the Senate, and two to the speaker of the House of

Representatives. Additionally, the commissioners now served a 6-year

term, with certain provisions at enactment for staggering the terms. The

original legislation created the position of staff director, appointed by the

president with the advice and consent of the Senate; the 1983 legislation

replaced Senate confirmation with concurrence of a majority of the

commissioners.

Commission

Reauthorizations

The Commission on Civil Rights has been in existence for 40 years even

though a sunset clause in its authorizing legislation provided that the

Commission would submit a final report to the Congress and the president

no more than 2 years after enactment, and that 60 days later the

Commission would “cease to exist.” The Commission’s authorizing

legislation was extended numerous times between 1959 and 1982; the

longest extension was for 5 years. By 1982, the debate in the Congress was

not over whether to extend the life of the Commission but on how best to

do so while enabling it to function effectively in a bipartisan manner and

without altering its historical structure and integrity.23

Before its 1983 reauthorization, the President, in his budget message to the

Congress in 1982 proposed that the Commission be allowed to continue its

work until 2003, saying, “[s]ince its inception, the Commission has focused

its energies on research demonstrating the existence of civil rights

problems. This emphasis was appropriate in the early years of the

Commission’s existence. However, the questions of the 1980’s involve not

whether civil rights problems exist, but how to most effectively resolve

them.” The President also proposed that commissioners serve for specified

terms.24 Between 1989 and 1996, the Commission was reauthorized three

more times, until September 30, 1996 (see table II.1). The Congress did not

reauthorize the Commission in 1996 but appropriated funds that allowed it

to continue operations through September 30, 1997.25

23House Debate of H.R. 2230, Cong. Rec. H. 23134-23149.

24Special Analysis J, Civil Rights Activities of the Budget, 1982.

25Commission Authority to Operate, 71 Comp. Gen. 378 (Apr. 29, 1992).

Page 33 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix II 

Additional Information on the U.S.

Commission on Civil Rights

Table II.1: Commission Authorizations,

1957-96 Public Law Expiration Duration

85-315 Sept. 1959 2 years

86-383 Sept. 1961 2 years

87-264 Sept. 1963 2 years

88-152 Sept. 1964 1 year

88-352 Jan. 1968 3-1/2 years

90-198 Jan. 1973 5 years

92-496 Jan. 1978 5 years

95-444 Sept. 1983 5 years

98-183 Nov. 1989 6 years

101-180 Sept. 1991 2 years

102-167 Sept. 1994 3 years

103-419 Sept. 1996 2 years

Organizational

Structure

The Commission had a major reorganization in November 1986. This

reorganization and subsequent staff changes through November 1996

eliminated or combined 5 of the 13 major offices, leaving 8 major offices

and units in place; the 19 smaller offices, including 10 regional offices,

were reduced to 9 offices, which included 6 regional offices. The

Commission also eliminated the Office of Program and Policy, the Office

of Research, the Planning and Coordination Unit, the Solicitor’s Unit, and

the Equal Employment Opportunity Unit. It apparently merged the duties

of the eliminated units or offices into existing units.

Staffing As of fiscal year 1996, the staff director for the Commission managed 83

employees located in six regional offices and in Washington, D.C. This

staff assisted eight part-time commissioners and their assistants in

carrying out Commission work. The Office of General Counsel (OGC) and

the Office of Civil Rights Enforcement (OCRE) conduct the projects and

had a combined total of 27 staff members who also had other

responsibilities. The Regional Programs Unit is the single largest

component of the Commission with 27 staff members, which include 2 at

headquarters and 25 in the six regional offices (see table II.2 for the

Commission’s staffing levels over the 4 years included in our review).

Page 34 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix II 

Additional Information on the U.S.

Commission on Civil Rights

Table II.2: Commission Staffing Levels

Over the 4-Year Period Reviewed,

Oct. 15, 1993-Sept. 30, 1996 Office/unit

Staff as of

9/30/96

Staff as of

10/1/95

Staff as of

10/3/94

Staff as of

10/15/93

Commissioners 8 8 8 8

Commissioners’ Assistants 7 8 8 8

Staff Director 5 6 6 5a

OCRE 12 13 9 11

OGC 15 b 12c 15

Regional Programs 27 28 28 27

Office of Management 17 16 14 16

Public Affairs 6 7 4 4

Congressional Affairs 2 2 2 1

Total 99 89b 92 95

aTwo employees were assigned to other units but served in the roles of Acting Staff Director and

Acting Deputy Staff Director.

bNumber of employees not provided for the office.

cThe positions of General Counsel and Deputy General Counsel were vacant.

Commission Spending The Commission on Civil Rights does not maintain budget information by

component office, and Commission officials told us that they could not

separately estimate the percentage of the Commission’s budget spent on

each component office or on the cognizant responsibilities of the offices.

On the basis of information contained in the Commission’s fiscal year 1998

budget request, about 72 percent of the Commission’s spending for fiscal

year 1996 was for salaries and benefits, and another 13 percent was for

rent (see table II.3).

Table II.3: Commission Spending

Levels in Fiscal Year 1996

Category

Spending

(thousands)

Percentage of

total spending

Personnel compensation and benefits $6,316 72.4

Rent 1,114 12.7

Other (utilities, reproduction,a services,

supplies, and equipment) 989 11.3

Travel and transportation 293 3.3

Total $8,712 99.7

aThe Commission’s budget showed a line item of “printing and reproduction”; however,

Commission officials told us that they did not know the cost of publishing and disseminating

project reports; thus, it is not clear what amount and percentage of the funds spent in this

category generally would cover printing costs for project reports as opposed to typical agency

xeroxing or copying costs.

Page 35 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix II 

Additional Information on the U.S.

Commission on Civil Rights

The Commission’s appropriations ranged from a high of $12.7 million in

fiscal year 1985 to a low of $5.7 million in fiscal year 1988 and has since

leveled off to around $7.8 million from fiscal year 1993 to the present (see

table II.4).

Table II.4: Commission Actual and

Inflation-Adjusted Appropriations Dollars in thousands, 1996 = 100

Fiscal year Appropriation

Adjusted

appropriationa

1980 $11,230 $20,748

1981 11,719 19,749

1982 12,318 19,529

1983 11,626 17,747

1984 11,887 17,654

1985 12,747 18,294

1986 12,300 17,223

1987 7,500 10,277

1988 5,707 7,576

1989 5,707 7,323

1990 5,707 7,078

1991 7,075 8,318

1992 7,159 8,240

1993 7,776 8,606

1994 7,776 8,310

1995 9,000 9,224

1996 8,750 8,750

1997 8,740 8,763b

aAmount calculated using the federal, nondefense government consumption price index.

bEstimated on the basis of the amounts for the 3rd quarter of 1996.

Source: Economic Report of the President, table B-3 (Washington, D.C.: Feb. 1997).

Page 36 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix III 

U.S. Commission on Civil Rights

Commissioners for the Period August

1996-May 1997

Name Date appointed Appointed by Political affiliation

Mary F. Berry, Chairpersona 2/3/93b Speaker of the House Independent

Cruz Reynoso, Vice Chairpersonc 4/19/93 Senate President Pro Tempore Democrat

Carl A. Anderson 2/8/90 Speaker of the House Republican

Robert P. George 1/20/93 President Independent

A. Leon Higginbotham, Jr. 11/30/95 President Democrat

Constance Horner 1/20/93 President Republican

Yvonne Y. Lee 12/30/95 President Democrat

Russell G. Redenbaugh 12/12/95d Senate President Pro Tempore Independent

aThe President designated Commissioner Berry as Chairperson on Sept. 17, 1993, and a majority

of commissioners concurred on Nov. 19, 1993.

bThe date the current term of office (6 years) began. It will expire in 1999. Commissioner Berry

was first appointed to the Commission in 1980.

cPresident designated Commissioner Reynoso as Vice Chairperson on Sept. 27, 1993, and a

majority of commissioners concurred on Nov. 19, 1993.

dCommissioner Redenbaugh was first appointed to the Commission in 1990 and was reappointed

in 1995 for a second term.

Page 37 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix IV 

Comments From Commission on Civil

Rights Commissioners Anderson, George,

Horner, and Redenbaugh

Page 38 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 39 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 40 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 41 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 42 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 43 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 44 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 45 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 46 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 47 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 48 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 49 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 50 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 51 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 52 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 53 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 54 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 55 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 56 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 57 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 58 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 59 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 5.

Now on p. 2.

Page 60 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 2.

Now on p. 8.

Page 61 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 10.

Now on p. 8.

Now on p. 8.

Page 62 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 10.

Now on p. 10.

Page 63 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on pp. 10-11.

Now on p. 11.

Page 64 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on pp. 11-12.

Page 65 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 15.

Page 66 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 17.

Now on pp. 17-18.

Now on p. 18.

Page 67 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 19.

Now on p. 19.

Page 68 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Now on p. 20.

Now on p. 20.

Page 69 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 70 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 71 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 72 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V 

Comments From the Commission on Civil

Rights Chairperson, Vice Chairperson,

Commissioners Higginbotham and Lee, and

Staff Director

Page 73 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix VI 

GAO Contacts and Staff Acknowledgments

GAO Contacts Sigurd R. Nilsen, Assistant Director, (202) 512-7003

Jacqueline Harpp, Evaluator-in-Charge, (202) 512-8380

Staff

Acknowledgments

Patricia M. Bundy, Evaluator

Stefanie Weldon, Senior Attorney

Page 74 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix VI 

GAO Contacts and Staff Acknowledgments

Page 75 GAO/HEHS-97-125 Management of Commission on Civil Rights
Related GAO Products

Commission on Civil Rights: Commissioners’ Travel Activities

(GAO/GGD-94-130, Aug. 8, 1994).

Request for Reconsideration of Claim for Relocation Allowance

(B-246538.4, Mar. 18, 1994).

Civil Rights Commission Employee’s Claim for Relocation Expenses

(B-246538.2, Jan. 27, 1993).

U.S. Commission on Civil Rights: The Commission Has Complied With

FY90 Appropriation Act Provisions (GAO/GGD-92-83, May 12, 1992).

Civil Rights Commission Authority to Operate (B-246541, Apr. 29, 1992).

U.S. Commission on Civil Rights: The Commission Has Complied With

FY89 Appropriation Act Provisions (GAO/GGD-91-32, Feb. 8, 1991).

U.S. Commission on Civil Rights: Compliance With Appropriation

Provisions as of March 31, 1988 (GAO/GGD-88-91, June 2, 1988).

U.S. Commission on Civil Rights: Concerns About Commission Operations

(GAO/GGD-88-71, May 26, 1988).

U.S. Commission on Civil Rights: Commission Publications During Fiscal

Years 1978-1986 (GAO/GGD-87-117BR, Sept. 25, 1987).

Civil Rights Commission Employees’ Claim for Severance Pay (B-217050,

July 30, 1986).

The Operations of the United States Commission on Civil Rights

(Testimony, Mar. 25, 1986).

(205322) Page 76 GAO/HEHS-97-125 Management of Commission on Civil Rights
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