a

GAO

United States General Accounting Office

Report to Congressional Requesters

July 2003 EQUAL 

EMPLOYMENT 

OPPORTUNITY 

SSA Region X’s 

Changes to Its EEO 

Process Illustrate 

Need for Agencywide 

Procedures

GAO-03-604
In a geographic area where minorities represent a small portion of the 

civilian workforce (about 13.5 percent), Region X generally had a higher 

percentage of each minority group, except for American Indian and Alaska 

Natives. Moreover, the percentage of minority employees in Region X had 

increased from about 19 percent in fiscal year 1997 to about 27 percent in 

fiscal year 2001. Women represented a much higher proportion of SSA’s 

workforce than of the civilian workforce. Differences among racial/ethnic 

and gender groups for most of the personnel actions reviewed were not 

statistically significant. 

For fiscal years 1997 and 1998, current and former Region X EEO counselors 

described a process that mirrored the informal stage of the required federal 

sector complaint process. In fiscal year 1999, Region X changed its EEO 

process, so that EEO counselors were no longer allowed to talk with 

managers but were required to submit their questions in writing. In addition, 

managers were encouraged to routinely have an attorney from the Office of 

the General Counsel (OGC) review their written responses before these 

responses were provided to the EEO counselors. After the changes were in 

place for about a year, SSA headquarters officials held discussions with 

Region X officials to explain that having written inquiries and OGC involved 

in the informal EEO process was not consistent with the intent of resolving 

issues informally. Beginning early in fiscal year 2001, neither written EEO 

counselor queries to managers nor OGC involvement was required in the 

informal process. Region X’s former use of written queries and OGC 

involvement were counter to the spirit of EEO regulations and their related 

guidance, which emphasize the informal nature of precomplaint counseling. 

In doing its work at Region X, GAO found that SSA had issued EEO 

handbooks for managers and employees, but the handbooks do not contain 

agency-specific procedures on how EEO counselors are to process 

complaints of discrimination. Agency-specific procedures are required by 

EEO regulations. Absent such procedures, components of an agency can 

use different procedures, as illustrated by Region X, resulting in employees 

across the country being treated differently. 

To gain an understanding of how familiar the Region’s employees are with 

the EEO process and their willingness to participate in it, GAO surveyed all 

of the Region’s employees. Most Region X employees reported having 

received or seen within the last 2 years written materials about EEO 

regulations and how to contact regional EEO counselors. Also, almost half 

the employees reported a willingness to participate in counseling or to file a 

formal EEO complaint if they believed they had been discriminated against. 

However, a sizeable portion of employees—about 40 percent—reported 

being unwilling or uncertain about becoming involved with the processes 

established for handling EEO complaints. 

Employees at the Social Security 

Administration’s (SSA) Region X—

which covers Alaska, Idaho, 

Oregon, and Washington—

expressed concern about the 

Region’s equal employment 

opportunity (EEO) process for 

employment discrimination 

complaints. GAO was asked to 

(1) provide information for fiscal 

years 1997 through 2001 on the 

composition of the Region X 

workforce and for personnel 

actions such as promotions, 

awards, and adverse actions by 

EEO group; (2) describe the EEO 

complaint process in Region X and 

any changes to it; (3) assess 

whether the Region’s process is 

consistent with federal regulations 

and related guidance; and (4) 

assess the familiarity with the EEO 

process of the Region’s employees 

and their attitude toward it. 

GAO recommends that SSA adopt 

agency-specific procedures for 

counselors to use in processing 

discrimination complaints, so 

employees have the same process 

everywhere. GAO also 

recommends that Region X take 

actions to enhance its EEO 

environment to increase trust and, 

where necessary, address 

differences in personnel actions 

across racial, ethnic, and gender 

groups. 

SSA agreed with GAO’s findings 

and cited actions it was taking on 

two of GAO’s three 

recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-03-604.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Victor S. 

Rezendes on (202) 512-6806 or at 

rezendesv@gao.gov. 

Highlights of GAO-03-604, a report to 

congressional requesters 

July 2003

EQUAL EMPLOYMENT OPPORTUNITY 

SSA Region X’s Changes to Its EEO 

Process Illustrate Need for Agencywide 

Procedures 
Page i GAO-03-604 EEO at SSA Region X

Contents

Letter 1

Letter 1

Results in Brief 3

Background 6

Composition of the Region X Workforce 8

Region X Made Temporary Changes to the Informal Stage of the EEO 

Process 17

GAO Survey of 

Region X Employees about EEO 20

Region X’s Temporary Changes Were Counter to the Spirit of EEOC’s 

Regulations and SSA’s Guidance 22

Conclusions 25

Recommendations 26

Agency Comments 27

Appendixes

Appendix I: Objectives, Scope, and Methodology 29

Objective 1 29

Objective 2 31

Objective 3 31

Objective 4 32

Appendix II: EEO Laws and Regulations Applicable to Federal Employees

34

Laws Prohibiting Discrimination 34

EEOC Regulations Governing the Processing of Employment 

Discrimination Complaints 34

Appendix III: Region X Workforce by Grade Level 39

Region X Employees in Grades GS-13 through GS-15 39

Region X Employees in Grades GS-9 through GS-12 40

Region X Employees in Grades GS-5 through GS-8 41

Region X Employees in Grades GS-1 through GS-4 43

Appendix IV: Temporary Promotions, Training, and Awards 46

Experience: Temporary Promotions 46

Training 48

Awards 49

Appendix V: Region X Adverse Actions, Appeals of Adverse Actions, EEO 

Complaints, and Grievances 53
Contents

Page ii GAO-03-604 EEO at SSA Region X

Adverse Actions 53

Adverse Actions Appealed to MSPB 54

Region X EEO Precomplaint Counseling and Formal EEO 

Complaints Filed 56

Grievances 63

Settlements 64

Appendix VI: Selected Results of GAO’s Survey of Region X Employees on 

Equal Employment Opportunity 66

Operations of Region X’s CREO 66

Experiences with Situations Involving EEO in Region X 68

Narrative Comments 69

Appendix VII: GAO Survey of Region X Employees about EEO 70

Appendix VIII: Comments from the Social Secuity Administration 78

Appendix IX: GAO Contact and Staff Acknowledgments 84

GAO Contact 84

Acknowledgments 84

Tables Table 1: Composition of Region X Workforce in Fiscal Years 1997 

and 2001 by EEO Group Compared With CLF and CWF 10

Table 2: Comparison of the Percentage of Competitive Promotions 

to the Average Percentage Representation of Each EEO 

Group in the Workforce for Fiscal Years 1997 Through 2001 

in Region X 14

Table 3: Comparison of the Percentage of Separations to the 

Average Percentage Representation of Each EEO Group in 

the Workforce for Fiscal Years 1997 Through 2001 in 

Region X 16

Table 4: Final Disposition of Questionnaire 32

Table 5: Percentage Distribution across Grade Levels by Race/

Ethnicity and Gender for Fiscal Year 1997 45

Table 6: Percentage Distribution across Grade Levels by Race/

Ethnicity and Gender for Fiscal Year 2001 45

Table 7: Comparison of the Percentage of JEPs to the Average 

Percentage Representation in the Workforce for Fiscal 

Years 1997 Through 2001 in Region X by EEO Group 47

Table 8: Comparison of the Percentage of Temporary Promotions 

to the Average Percentage Representation in the Region X 

Workforce for Fiscal Years 1997 through 2001 by EEO 

Group 48
Contents

Page iii GAO-03-604 EEO at SSA Region X

Table 9: Comparison of the Percentage of GETA Training to the 

Average Percentage Representation by EEO Group in the 

Region X Workforce for Fiscal Years 1998 through 2001 49

Table 10: Comparison of the Percentage of Monetary Awards to the 

Average Percentage Representation by EEO Group in the 

Region X Workforce for Fiscal Years 1997 through 2001 50

Table 11: Comparison of the Percentage of Quality Step Increases to 

the Average Percentage Representation by EEO Group in 

the Region X Workforce for Fiscal Years 1997 

through 2001 51

Table 12: Comparison of the Percentage of Honor Awards to the 

Average Percentage Representation by EEO Group in the 

Region X Workforce for Fiscal Years 1997 through 2001 52

Table 13: Types of Adverse Actions in Region X for Fiscal Years 1997 

through 2001 by EEO Group 54

Table 14: Adverse Actions in Region X for Fiscal Years 1997 through 

2001 That Were Appealed to MSPB and Their Disposition 

by EEO Group 55

Table 15: Requests for Counseling in Region X and Their Disposition 

in Fiscal Years 2000 and 2001 56

Table 16: Bases Cited in EEO Counseling for Region X in Fiscal Years 

2000 and 2001 57

Table 17: Issues Cited by Individuals Requesting Counseling in 

Region X in Fiscal Years 2000 and 2001 58

Table 18: Formal EEO Complaints Filed by Region X Employees for 

Fiscal Years 1997 through 2001 and Their Disposition 59

Table 19: Bases for EEO Complaints Filed in Region X in Fiscal Years 

1997 through 2001 60

Table 20: Issues Cited in Complaints Filed for Fiscal Years 1997 

through 2001 61

Table 21: Reasonable Accommodations Requested by Region X 

Employees for Fiscal Years 1997 through 2001 by EEO 

Group 63

Table 22: Section 9 Grievances Filed in Region X by EEO Group for 

Fiscal Years 1997 through 2001 64

Table 23: Number of Settlement Agreements and Amounts Awarded 

on Settlements for MSPB Appeals, EEO Complaints, and a 

Mixed Case Filed in Region X in Fiscal Years 1997 through 

2001 65

Table 24: Minority Status and Sex of Respondents Who Were 

Unwilling or Uncertain to Participate in Counseling 

Because They Feared Retaliation 67
Contents

Page iv GAO-03-604 EEO at SSA Region X

Table 25: Minority Status and Sex of Respondents Who Were 

Unwilling or Uncertain to File a Formal Complaint 

Because They Feared Retaliation 67

Table 26: Percentage of Respondents Indicating Whether Decisions 

Were Based on Merit and Free of Bias and Favoritism 68

Table 27: Percentage of Respondents Indicating Decisions Were 

Sometimes or Never Based on Merit and Free of Bias and 

Favoritism 69

Figures Figure 1: Region X Workforce in Fiscal Years 1997 and 2001 by EEO 

Group 9

Figure 2: Hiring in Region X for Fiscal Years 1997 and 2001 by EEO 

Group 13

Figure 3: The EEO Complaint Process with Related Time 

Frames 37

Figure 4: Region X Employees in Grades GS-13 through GS-15 in 

Fiscal Years 1997 and 2001 by EEO Group 40

Figure 5: Region X Employees in Grades GS-9 Through GS-12 in 

Fiscal Years 1997 and 2001 by EEO Group 41

Figure 6: Region X Employees in Grades GS-5 through GS-8 in 

Fiscal Years 1997 and 2001 by EEO Group 43

Figure 7: Region X Employees in Grades GS-1 through GS-4 in 

Fiscal Years 1997 and 2001 by EEO Group 44
Contents

Page v GAO-03-604 EEO at SSA Region X

Abbreviations

ADR alternative dispute resolution

AFGE American Federation of Government Employees

AIAN American Indian/Alaska Native

AJ administrative judge

CLF Civilian Labor Force

CPS Current Population Survey

CREO Civil Rights and Equal Opportunity

CWF civilian workforce

EEO equal employment opportunity

EEOC Equal Employment Opportunity Commission

GETA Government Employees Training Act

GS general schedule

JEP Job Enhancement Program

MD-110 Management Directive-110

MSPB Merit Systems Protection Board

NAACP National Association for the Advancement of Colored People

OCREO Office of Civil Rights and Equal Opportunity

OGC Office of the General Counsel

SES Senior Executive Service

SSA Social Security Administration

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

United States. It may be reproduced and distributed in its entirety without further 

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reproduce this material separately.
Page vi GAO-03-604 EEO at SSA Region X
Page 1 GAO-03-604 EEO at SSA Region X

United States General Accounting Office

Washington, D.C. 20548

A

July 16, 2003 Letr

The Honorable Jim McDermott

The Honorable Jennifer Dunn

The Honorable Adam Smith

House of Representatives Letr

An October 2000 report by the Seattle branch of the National Association 

for the Advancement of Colored People (NAACP)1

 alleged that the Social 

Security Administration’s (SSA) Region X—which covers Alaska, Idaho, 

Oregon, and Washington and has about 1,800 employees—may have 

violated federal regulations governing equal employment opportunity 

(EEO) and the processing of employment discrimination complaints. The 

report alleges, among other things, that the Office of the General Counsel 

(OGC) in Region X interfered with EEO precomplaint counseling, the 

informal stage of the EEO complaint process.2

 In addition, the report 

alleges that in the informal stage, EEO counselors were required by Region 

X management to submit written inquires to responsible management 

officials rather than conversing with them to get information. SSA did not 

agree with the report’s allegations but agreed to two of its 

recommendations: to provide on-site precomplaint counseling at one of 

the Region’s largest facilities and to provide ongoing training to 

management on provisions concerning employees’ rights in SSA’s labormanagement agreement. As a result of the NAACP report, you asked us to 

look at the Region’s EEO program.

Federal employees are protected by various federal laws that prohibit 

employment discrimination because of race, color, religion, sex, national 

origin, age, or disability (see app. II). In addition, federal employees are 

protected from retaliation for filing a complaint, participating in an 

investigation of a complaint, or opposing any practice made unlawful under 

these antidiscrimination laws. The Equal Employment Opportunity 

Commission (EEOC) has issued regulations that govern how the 

discrimination claims of federal employees are to be processed 

administratively.3

 Federal agencies covered by these regulations are 

1

Seattle Branch of the National Association for the Advancement of Colored People, Racism 

and Disparate Treatment Issues: Region 10, Social Security Administration (Seattle: 

2000).

2

Although the Region handles the informal stage of the EEO complaint process, SSA 

requires formal complaints be filed with SSA headquarters in Baltimore.

Letter
Page 2 GAO-03-604 EEO at SSA Region X

responsible for developing and implementing their own EEO programs and 

complaint processing procedures consistent with EEOC’s regulations. 

As agreed with your offices, our objectives were to (1) provide information 

on the composition of Region X’s workforce by EEO group (race/ethnicity 

and gender) for fiscal years 1997 through 2001 overall and for personnel 

actions such as promotions, awards, and adverse actions; (2) describe the 

Region’s EEO complaint process and any changes to it during the 5-year 

period; (3) assess whether the Region’s EEO complaint process was 

consistent with federal regulations and related guidance; and (4) assess the 

familiarity of the Region’s employees with the EEO process and their 

attitude toward it.

For our discussion of the composition of Region X’s workforce as well as 

the breakdown of personnel actions by EEO group, we used SSA data 

provided by the Region’s human resources management information 

system for fiscal years 1997 through 2001 for African Americans, American 

Indian/Alaska Natives (AIAN), Asian/Pacific Islanders (Asian), Hispanics, 

and Whites.4

 Each racial/ethnic group was broken down by gender. As part 

of our analysis of the composition of SSA staff for selected personnel 

actions, we tested to see if statistically significant differences by EEO 

group occurred.5

 Our analyses of personnel actions are designed to 

provide information at a common and aggregate level about EEO group 

differences in personnel actions at Region X and not to determine whether 

or not discrimination existed. The presence of a statistically significant 

difference does not prove discrimination, nor does the absence of a 

statistically significant difference prove that staff have not been 

discriminated against.

To describe the EEO process in the Region and any changes made to it for 

the 5-year period, we reviewed documents provided by SSA headquarters 

and Region X officials and interviewed those officials. To determine 

whether the Region’s EEO complaint process is consistent with federal 

3

29 C.F.R. Part 1614. 

4

These data include temporary employees but do not include SSA components in Region X 

that are not under the line authority of the then Regional Commissioner (i.e., the Office of 

Hearings and Appeals, OGC, the Office of Inspector General, and the Regional Office of 

Quality Assurance). 

5

The presence of statistically significant differences means that we are 95-percent confident 

that differences could happen by chance less than 5 percent of the time.
Page 3 GAO-03-604 EEO at SSA Region X

regulations, we reviewed EEOC’s regulations governing how the 

discrimination claims of federal employees are to be processed and 

compared their requirements with the processes employed by the Region. 

Also, to assess the familiarity of the Region’s employees with the EEO 

process and their attitude toward it, we surveyed all of the Region’s 

employees. 

We did our work in Washington, D.C., Baltimore, and Seattle from January 

2002 through May 2003 in accordance with generally accepted government 

auditing standards. Details of our scope and methodology are in 

appendix I.

Results in Brief Women made up over 70 percent of SSA’s national workforce in fiscal year 

2002, and Region X’s workforce has mirrored this throughout all ethnic 

groups for fiscal years 1997 through 2001, with about two-thirds of its 

employees being women in each of those years. Also in each year, White 

employees comprised the majority of the Region X workforce, but their 

representation declined from about 81 percent of the workforce in fiscal 

year 1997 to about 73 percent in fiscal year 2001. Conversely, minority 

employees in Region X increased a corresponding 8 percentage points, 

from about 19 percent in fiscal year 1997 to about 27 percent in fiscal year 

2001. Increases occurred in all minority EEO groups, except for AIAN 

women; the largest percentage increase occurred among Hispanic women. 

A comparison of the Region X workforce for fiscal years 1997 and 2001 

with the regional Civilian Labor Force shows that Region X generally had a 

higher representation of minority employees in its workforce for all EEO 

groups except AIANs.

Concerning selected personnel actions, Hispanic women had the largest 

increase in the percentage of hires they represent, and African American 

women had the largest decrease. For each EEO group, we looked at the 

percentage of promotions and found that most EEO groups were promoted 

at a rate that was about the same as or slightly higher than each group’s 

average percentage of representation in the workforce. African American 

men and White women had the highest positive percentage difference (1.1 

percentage points) between their percentage of competitive promotions 

and representation in the workforce. Only White men and African 

American women were promoted at rates lower than their average 

percentage representation in the workforce, with a 2.2 and 1.0 percentagepoint difference, respectively. Also, for each EEO group, we compared the 

percentage of separations with the average percentage of the workforce, 
Page 4 GAO-03-604 EEO at SSA Region X

and this comparison showed that all minority EEO groups separated at a 

rate that was slightly higher than the average percentage of each group 

represented in the workforce for the period. African American women had 

the largest percentage difference between their percentage of separations 

and representation in the workforce (1.3 percentage points), followed by 

AIAN women (1.1 percentage points). Only White men and women 

separated at rates lower than their average percentage of representation in 

the workforce. 

Our analysis showed no statistically significant differences among EEO 

groups for most of the personnel actions we reviewed. However, it did 

show statistically significant differences for some types of awards and 

adverse actions. The analysis for the 5-year period showed statistically 

significant differences among races concerning quality step increases and 

nonmonetary, or honor, awards. In addition, the analysis showed 

statistically significant differences among races for short-term suspensions 

and between the sexes concerning removals. This analysis was not 

designed to determine whether or not discrimination existed but can 

indicate areas warranting further study by management. Region X has not 

reviewed these differences to uncover their causes or to determine their 

appropriateness.

Region X made changes to its EEO process in fiscal years 1999 and 2001. 

For fiscal years 1997 and 1998, current and former Region X EEO 

counselors described a process that mirrored the informal stage of the 

complaint process outlined in EEOC’s guidance to federal agencies. In 

fiscal year 1999, Region X changed its EEO complaint process, so that EEO 

counselors were no longer allowed to talk with managers about what had 

transpired between employees alleging possible discrimination and 

managers but were required to submit their questions in writing. The then 

Regional Commissioner said the changes were instituted because regional 

managers said that EEO counselors were not accurately reporting their 

views. In addition, managers were encouraged to routinely have an 

attorney from OGC review their written responses before these responses 

were provided to the EEO counselors. After the changes were in place for 

about a year, SSA headquarters’ officials held discussions with Region X 

officials to explain that having written inquiries and OGC involved in the 

informal EEO process was not consistent with the intent of having the 

process arrive at an informal resolution of issues. Beginning early in fiscal 

year 2001, EEO counselors were not required to put queries to managers in 

writing, and OGC involvement was not required in the informal process. 

The changes Region X made to its complaint process in fiscal year 1999 are 
Page 5 GAO-03-604 EEO at SSA Region X

not specifically addressed in federal sector EEOC regulations. Neither 

EEOC’s regulations nor its related guidance addresses the appropriateness 

of written counselors’ queries, written managers’ responses, or OGC 

involvement in the informal process. However, these changes seem to have 

been counter to the spirit of the regulations and their related guidance, 

which emphasize the informal nature of precomplaint counseling. 

Also, in doing our work at Region X, we found that SSA had issued EEO 

handbooks for managers and employees that discussed EEO in general and 

the basic EEO process. However, the handbooks do not contain agencyspecific procedures on how EEO counselors are to process complaints of 

discrimination. Agency-specific procedures are required by EEO 

regulations. Absent such procedures, components of an agency can use 

different procedures, as illustrated by Region X, resulting in employees 

across the country being treated differently. 

To gain an understanding of how familiar the Region’s employees were with 

the EEO process and their willingness to participate in it, we surveyed all 

of the Region’s employees on the EEO process and EEO in the Region. 

Most Region X employees reported having received or having seen within 

the last 2 years written materials about EEO regulations and how to 

contact regional EEO counselors. When asked about their willingness, if 

they believed that they had been discriminated against, to either participate 

in EEO counseling or to file a formal EEO complaint, almost half of 

respondents indicated that they would be generally or very willing to 

participate in counseling or to file a formal EEO complaint. However, a 

sizeable portion of respondents to our survey—about 40 percent—

indicated they were unwilling or uncertain about becoming involved with 

the processes established for handling EEO complaints. Our survey results 

indicate that if Region X does not work to improve the perceptions of 

employees, it may not achieve a trusting workplace. 

We recommend that the Commissioner of SSA adopt agency-specific 

procedures for counselors to use in processing complaints of 

discrimination to ensure that employees face the same process 

everywhere. We also recommend that Region X take actions to enhance its 

EEO environment to increase trust and, where necessary, address 

differences in personnel actions across racial, ethnic, and gender groups. 

In commenting on a draft of this report, SSA said it was updating materials 

dealing with the EEO process and would include procedural guidelines as 

called for in EEOC’s regulations governing federal agencies’ EEO 

procedures. SSA also said that as part of its normal review process, it will 
Page 6 GAO-03-604 EEO at SSA Region X

review the statistically significant differences we found in Region X 

personnel actions. However, SSA did not agree with our recommendation 

that Region X take actions to enhance its EEO environment to increase 

trust. SSA’s written comments are discussed near the end of this letter and 

reproduced in appendix VIII.

Background SSA administers three major federal programs that provide benefits to 

more than 50 million people. The Old Age and Survivors Insurance 

program provides benefits to retired workers and their dependents and 

survivors. The Disability Insurance program provides benefits to disabled 

workers. Supplemental Security Income provides income for aged, blind, 

and disabled individuals with limited incomes and resources. Heading SSA 

is a Commissioner who leads a central office in Baltimore and 10 regional 

offices. The field organization, which is decentralized to provide service at 

the local level, includes approximately 1,300 field offices.

Federal law prohibits discrimination against employees and applicants for 

employment on the bases of race, color, religion, sex, national origin, age, 

or disability (see app. II for more details about antidiscrimination laws). 

Under EEOC regulations, employees or applicants for employment who 

believe that they have been discriminated against by a federal agency may 

file a complaint with that agency. Before filing a complaint, the employee 

must consult an EEO counselor at the agency in order to try to informally 

resolve the matter. The employee must contact an EEO counselor within 

45 days of the matter alleged to be discriminatory or, in the case of a 

personnel action, within 45 days of the effective date of the action. EEO 

counselors should determine if the employee believes that his or her 

problem is the result of one or more of the allowable bases—race, color, 

sex (including equal pay), religion, national origin, age (40 and over), or 

disability—or in retaliation for having participated in an activity, such as 

filing a complaint, that is protected by the various antidiscrimination 

statutes. Counselors are to advise individuals that, where the agency
Page 7 GAO-03-604 EEO at SSA Region X

agrees to offer alternative dispute resolution (ADR) in the particular case,6

they may choose to participate in either counseling or in ADR. 

After the counselor determines the basis or bases and claims, he or she is 

to conduct a limited inquiry of the matter, which generally involves 

speaking or meeting with the two parties. When the counselor has a good 

grasp of the issues involved, he or she is ready to attempt resolution. 

Resolution means that the employee and the agency come to terms with the 

matter and agree on a solution. In seeking resolution, the counselor is to 

listen to and understand the viewpoint of both parties and act as a neutral 

and not as an advocate for either the employee or the agency. Counseling 

is to be completed within 30 days from the date the employee contacted the 

EEO office for counseling.7

 If the matter is not resolved by the 30th day of 

counseling or if ADR is unsuccessful,8 the counselor is required to inform 

the employee in writing of his or her right to file a formal discrimination 

complaint with the agency. The written notice must inform the employee 

of the (1) right to file a discrimination complaint within 15 days of receipt 

of the notice, (2) appropriate agency official with whom to file a complaint, 

and (3) duty to ensure that the agency is informed immediately if the 

complainant retains counsel or a representative. 

After a complainant files a formal discrimination complaint, the agency 

must decide whether to accept or dismiss the complaint. If the agency 

dismisses the complaint, the complainant can appeal the dismissal to 

EEOC. If the agency accepts the complaint, it must investigate the 

complaint and present the complainant with a report of the investigation 

results. The complainant may then choose between requesting a hearing 

before an EEOC administrative judge or a final decision from the agency. 

Because SSA requires all employees to file formal complaints with its 

headquarters in Baltimore, the formal process was outside of the scope of 

6

ADR generally refers to any procedure agreed to by the parties in a dispute that is used to 

resolve issues in controversy including, but not limited to, mediation or arbitration. As of 

January 1, 2000, all federal agencies covered by 29 C.F.R. Part 1614 were required to 

establish or make available an ADR program during the informal (precomplaint counseling) 

and formal complaint stages of the EEO process. According to a Region X official, as of 

March 7, 2003, participation in the ADR process is currently limited to mediation and 

available to Region X employees within the Seattle commuting area.

7

Before the end of the 30-day period, the employee may agree in writing with the agency to 

postpone the final interview and extend the counseling period for up to an additional 60 

days.

8

ADR is to be completed within 90 days.
Page 8 GAO-03-604 EEO at SSA Region X

our review. Appendix II provides additional information on the processing 

of employment discrimination complaints.

Composition of the 

Region X Workforce 

SSA’s national workforce is predominantly women—about 71 percent in 

fiscal year 2002—and Region X’s workforce mirrors this in all ethnic 

groups. For each of fiscal years 1997 through 2001, about two-thirds of all 

Region X employees were women. The majority of Region X employees 

were age 40 and over, constituting about three-quarters of the workforce in 

each year. The number of employees with disabilities increased slightly 

from about 10 percent in fiscal year 1997 to 11 percent in fiscal year 2001. 

Over the 5-year period, most of the Region X workforce was in the general 

schedule (GS) grade levels 5 through 12. The distribution across grade 

levels by EEO group varied somewhat but was generally close to the 

representation of the various EEO groups in the Region’s workforce. The 

main differences were higher proportions of men in the GS-13 through 15 

grade levels and higher representation of African Americans and Hispanics 

in the GS-5 through 8 grades. As discussed in the section on hiring, 

substantial numbers of African Americans and Hispanics have been hired 

over the last few years, which may explain their higher representation in 

grades GS-5 through 8. See appendix III for a discussion of grade levels by 

EEO group. Figure 1 shows the Region X workforce by EEO group for 

fiscal years 1997 and 2001. 
Page 9 GAO-03-604 EEO at SSA Region X

Figure 1: Region X Workforce in Fiscal Years 1997 and 2001 by EEO Group

From fiscal year 1997 to fiscal year 2001, the EEO group that experienced 

the largest increase in its percentage of the workforce was Hispanic 

women, who almost doubled from 57, or 3.3 percent of the workforce, to 

120, or 6.5 percent. This increase was followed by that of Asian women, 

who increased by almost two-thirds from 55, or 3.2 percent of the 

workforce, in fiscal year 1997 to 93, or 5.0 percent of the workforce, in 

fiscal year 2001. The percentage of the workforce represented by White 

men and women and by AIAN women declined over the 5-year period. 

To judge its diversity, SSA compares its workforce with the Civilian Labor 

Force (CLF). Because the CLF data SSA uses are based on 1990 census 

Source: Region X data.

1997 (N=1,726)

2001 (N= 1,847)

Percentage of employees

Men

Women

Men

Women

Men

Women

Men

Women

Men

Women

African

American

AIAN

Asian

Hispanic

White

55.3

0.4

0.5

1.2

1.0

1.6 

2.2

3.2

 5.0

2.1

3.5

3.3

6.5

2.3 

2.6

5.0 

5.5

25.7

24.2

48.9

0 10 20 30 40 50 60
Page 10 GAO-03-604 EEO at SSA Region X

data, we also calculated regional civilian workforce (CWF) data of those 

age 18 and older in the four states covered by Region X for fiscal year 2001, 

based on 2001 Current Population Survey data.9

 Table 1 shows data on the 

composition of the Region X workforce in fiscal years 1997 and 2001 and 

compares those workforces to data on the CLF and CWF. Region X 

generally had a higher or equal representation of minority employees in its 

workforce for all EEO groups compared with both the CLF and the CWF, 

except AIAN men in fiscal years 1997 and 2001 and AIAN women in fiscal 

year 2001. In addition, the representation of White men in the Region was 

below the CLF and the CWF for both fiscal years 1997 and 2001. 

Table 1: Composition of Region X Workforce in Fiscal Years 1997 and 2001 by EEO Group Compared With CLF and CWF

Source: Region X data and GAO analysis of Current Population Survey.

Note: Totals do not sum to 100 percent due to rounding.

9

The Current Population Survey is a monthly survey of about 50,000 households conducted 

by the Bureau of the Census and is the primary source of current information on the labor 

force characteristics of the U.S. population. 

EEO group

Region X workforce Regional

 As of September 30, 1997 As of September 30, 2001

CLF

(FY 1990)

CWF

(FY 2001)

Number Percent Number Percent Percent Percent

African American men 39 2.3 48 2.6 1.1 1.1

African American women 87 5.0 101 5.5 0.9 1.1

AIAN men 7 0.4 9 0.5 0.9 1.0

AIAN women 21 1.2 19 1.0 0.8 1.5

Asian men 27 1.6 41 2.2 1.6 1.8

Asian women 55 3.2 93 5.0 1.6 2.2

Hispanic men 36 2.1 65 3.5 2.3 2.2

Hispanic women 57 3.3 120 6.5 1.5 2.6

White men 443 25.7 447 24.2 49.1 43.2

White women 954 55.3 904 48.9 40.0 43.3

Total 1,726 100.1 1,847 99.9 99.8 100.0
Page 11 GAO-03-604 EEO at SSA Region X

Composition of Selected 

Personnel Actions by EEO 

Group

We reviewed the EEO groups of those individuals who in fiscal years 1997 

through 2001 were hired, promoted, separated, or received awards or 

against whom Region X took adverse actions. For most of the personnel 

actions we reviewed, our analysis showed no statistically significant 

differences among EEO groups, but it did show statistically significant 

differences for some types of awards and adverse actions.10 The analysis 

showed statistically significant differences among races and between the 

sexes concerning quality step increases for fiscal year 2001. We also found 

statistically significant differences by race/ethnicity for nonmonetary, or 

honor, awards. Our statistical analysis showed no significant differences 

among EEO groups for written reprimands; however, it showed statistically 

significant differences among races for suspensions and statistically 

significant differences between the sexes concerning involuntary 

separations. Human capital management principles include certain 

internal safeguards to help achieve consistency, equity, nondiscrimination, 

and nonpoliticization in the performance management process. One of 

these safeguards can be reviewing the results of personnel actions for 

statistically significant differences across groups. According to a Region X 

official, the Region has not reviewed such differences to uncover their 

causes or to determine their appropriateness. 

Hiring From fiscal 1997 through fiscal year 2001, hiring among all minority groups 

except AIAN men and women increased as a percentage of those hired. 

The largest increase occurred among Hispanics. Hiring of Hispanic women 

increased from 9, or 5.1 percent of all hiring, in fiscal year 1997 to 21, or 9.8 

percent in fiscal year 2001. Hiring of Hispanic men increased from 4, or 2.3 

percent of all hiring, in fiscal year 1997 to 14, or 6.5 percent in fiscal year 

2001. According to SSA officials, one of the reasons for the increase in 

Hispanic hires was that in fiscal year 1998 the Region hired 57 Spanish 

language bilingual telephone service representatives11 when Spanish 

language calls began being routed to the Auburn Teleservice Center as part 

of the national phase-in of the “direct-in” option of service for the Spanishspeaking

10We were unable to determine whether minorities and women were significantly less likely 

to be hired or promoted because we had no data on applicants by race/ethnicity and gender.

11Telephone service representatives provide information to inquirers about eligibility and 

benefits paid under SSA programs. 
Page 12 GAO-03-604 EEO at SSA Region X

public.12 African American women had the largest decrease in the 

percentage of hires they represent, and the percentage of AIAN men and 

women declined slightly. Figure 2 shows hiring in Region X by EEO group 

for fiscal years 1997 and 2001. All EEO groups were hired at rates that 

were above their representation in the workforce, except White men and 

women.

12“Direct-in” refers to when a caller is first connected to the 1-800-number, hears an option 

that allows the bypass of English prompts, and allows the caller to go directly to Spanish 

prompts. According to a Region X official, in fiscal year 2002, the number of Spanish calls 

handled by Spanish bilingual employees in the teleservice center in Auburn, Wash., reached 

a high of 362,200.
Page 13 GAO-03-604 EEO at SSA Region X

Figure 2: Hiring in Region X for Fiscal Years 1997 and 2001 by EEO Group

Promotions Promotions involve either the selection of a current or former federal 

employee for a higher grade position, using procedures that compare the 

candidates on merit (i.e., competitive promotions), or promotion of an 

employee without competition when the employee had earlier been 

competitively selected and had demonstrated readiness for the next grade 

(i.e., career ladder promotions). Because career ladder promotions do not 

involve current competition, we focused on competitive promotions. We 

calculated the percentage of promotions received by members of each EEO 

group over the 5-year period and compared it with the group’s average 

percentage of the workforce overall. This comparison showed that most 

EEO groups were promoted at a rate that was generally about the same as 

or somewhat higher than each group’s average percentage of 

Source: Region X data.

1997 (N=175)

2001 (N=215)

Percentage of hires

Men

Women

Men

Women

Men

Women

Men

Women

Men

Women

African

American

AIAN

Asian

Hispanic

White

0 10 20 30 40 50

43.4 

1.7 

0.9

2.9 

1.9

2.3 

3.3

5.1 

5.6

2.3 

6.5

5.1 

4.0 

9.8

5.1

9.1 

7.4

24.0 

22.8

36.7
Page 14 GAO-03-604 EEO at SSA Region X

representation in the workforce for the period. African American men and 

White women had the largest positive percentage difference (1.1 percent) 

between their percentage of competitive promotions and representation in 

the workforce. Only White men and African American women were 

promoted at rates lower than their average percentage of representation in 

the workforce, with a 2.2 and 1.0 percentage difference, respectively. 13 

Table 2 compares the percentage of competitive promotions to the average 

percentage representation of each EEO group in the workforce for fiscal 

years 1997 through 2001 in Region X.

Table 2: Comparison of the Percentage of Competitive Promotions to the Average 

Percentage Representation of Each EEO Group in the Workforce for Fiscal Years 

1997 Through 2001 in Region X 

Source: GAO analysis of Region X data.

Experience, training, and awards are among the elements considered in the 

merit promotion process. Appendix IV describes by EEO group, those 

employees in Region X who participated in selected training opportunities 

and received temporary promotions and awards during fiscal years 1997 

13Hispanics were promoted at slightly lower rates than their representation in the 

workforce. Hispanic men represented 2.9 percent of competitive promotions and 3.0 

percent in the Region’s workforce for the 5-year period. Hispanic women represented 5.1 

percent of competitive promotions and 5.4 percent of the Region’s workforce.

EEO group

Total 

competitive 

promotions for 

5 years

Percentage of 

competitive 

promotions

Average percentage 

representation in the 

workforce (5 years)

African American men 25 3.6 2.5

African American women 30 4.3 5.3

AIAN men 4 0.6 0.4

AIAN women 12 1.7 1.0

Asian men 13 1.9 1.9

Asian women 31 4.5 4.0

Hispanic men 20 2.9 3.0

Hispanic women 35 5.1 5.4

White men 156 22.6 24.8

White women 364 52.8 51.7

Total 690 100.0 100.0
Page 15 GAO-03-604 EEO at SSA Region X

through 2001. Concerning awards, our statistical analysis showed that for 

the 5-year period, Whites were significantly more likely to receive quality 

step increases than African Americans, Hispanics, and AIANs; Asians were 

significantly more likely to receive quality step increases than Hispanics 

and AIANs; and African Americans were significantly more likely to receive 

quality step increases than Hispanics. There were no statistically 

significant differences between men and women. Because the Region 

acknowledged a disparity among racial/ethnic groups concerning quality 

step increases and began trying to address this disparity in fiscal year 1997, 

we also did a statistical analysis of quality step increases for fiscal year 

2001 alone. By fiscal year 2001, only two statistically significant differences 

remained—women were significantly more likely to receive quality step 

increases than men and Hispanics were significantly less likely to receive 

quality step increases than African Americans or Whites—which shows 

substantial progress. Our analysis also showed that for the 5-year period, 

Asians were significantly more likely to receive nonmonetary, or honor, 

awards than Whites, African Americans, and Hispanics. Also, AIANs were 

significantly more likely to receive honor awards than Hispanics. 

Our statistical significance analysis was not designed to determine whether 

or not discrimination occurred. However, the analysis could indicate areas 

warranting further study.

Separations Separations include voluntary transfer to another SSA regional office, 

resignation, retirement, and involuntary removal or termination. 

Involuntary separations are discussed under adverse actions. Although 

there were definite increases in the percentage of separations among 

specific EEO groups for fiscal years 1997 through 2001, all EEO groups 

experienced fluctuations in separations over the 5 years we reviewed. In 

addition, the percentage of separations accounted for by retirements 

increased from about a third in fiscal year 1997, to about 40 percent in 

fiscal year 1998, peaked at about 55 percent in fiscal year 1999, declined to 

almost 40 percent in fiscal year 2000, and returned to about a third in fiscal 

year 2001. 

We calculated the percentage of separations each EEO group represented 

over the 5-year period and compared it with the average percentage of the 

workforce by EEO. This comparison shows that all minority EEO groups 

separated at a rate that was slightly higher than the average percentage 

each group represented in the workforce for the period. African American 

women had the largest percentage difference between their percentage of 

separations and representation in the workforce (1.3 percentage points), 
Page 16 GAO-03-604 EEO at SSA Region X

followed by AIAN women (1.1 percentage points). Only Whites separated 

at rates lower than their average percentage representation in the 

workforce. Table 3 compares the percentage of separations to the average 

percentage of each EEO group in the workforce for fiscal years 1997 

through 2001 in Region X. 

Table 3: Comparison of the Percentage of Separations to the Average Percentage 

Representation of Each EEO Group in the Workforce for Fiscal Years 1997 Through 

2001 in Region X 

Source: GAO analysis of Region X data.

Adverse Actions Region X took 142 adverse actions over the 5-year period.14 These actions 

included written reprimands, short-term suspensions (i.e., 14 days or less), 

long-term suspensions (i.e., 15 days or more), demotions, and terminations 

or removals. Of the 142 actions, 65, or about 46 percent, were for 

individuals who entered computer databases without authorization. Our 

statistical analysis showed no significant differences among EEO groups 

for written reprimands. However, for short-term suspensions, AIANs and 

African Americans were significantly more likely to receive suspensions of 

14 days or less than Whites. Also, men were significantly more likely to 

EEO group

Total 

separations for 

5 years

Percentage of 

separations

Average percentage 

representation in the 

workforce (5 years)

African American 

men

20 2.6 2.5

African American 

women

50 6.6 5.3

AIAN men 4 0.5 0.4

AIAN women 16 2.1 1.0

Asian men 19 2.5 1.9

Asian women 37 4.9 4.0

Hispanic men 27 3.6 3.0

Hispanic women 48 6.3 5.4

White men 174 22.9 24.8

White women 365 48.0 51.7

Total 760 100.0 100.0

14Of the 142 actions, 8 were for performance, not conduct.
Page 17 GAO-03-604 EEO at SSA Region X

experience a removal or termination than women. As mentioned earlier, 

our statistical analysis was not designed to determine whether or not 

discrimination existed but can identify areas worthy of further study by 

management. Appendix V contains detailed information on adverse 

actions, appeals of such actions, formal EEO complaints filed, and 

grievances filed under the union grievance procedure for fiscal years 1997 

through 2001 in Region X. 

Region X Made 

Temporary Changes to 

the Informal Stage of 

the EEO Process 

Region X made changes to its informal EEO process in fiscal years 1999 

and 2001. For fiscal years 1997 and 1998, current and former Region X EEO 

counselors described an informal process that mirrored the federal sector 

complaint process outlined in EEOC’s guidance. In fiscal year 1999, Region 

X made changes to this process, under which EEO counselors were no 

longer allowed to talk with managers but were required to submit questions 

in writing to managers about what had transpired between employees and 

managers. In addition, managers were encouraged to routinely have an 

attorney from OGC review their written responses before these responses 

were provided to the EEO counselors. In fiscal year 2001, after discussions 

with SSA headquarters officials had occurred, additional training was 

provided (for EEO counselors, OGC, and executive staff), and the then 

Regional Commissioner made conference calls to every manager about this 

issue, EEO counselors were again allowed to talk with managers. 

Counselors said revoking the changes brought the process back to what it 

was previously.

Because the Region could not provide us with documentation on how it 

carried out its EEO complaint process or how it changed, we contacted 

former and current EEO counselors and discussed this area with regional 

officials. For fiscal years 1997 and 1998, Region X EEO counselors 

described an informal process similar to the informal stage of the federal 

sector complaint process outlined in EEOC guidance Management 

Directive 110 (MD-110).15 First an employee would approach an EEO 

counselor, who would take notes about the person’s complaint, including 

the claim being made and the basis or bases for the complaint. The EEO 

counselor would then advise the employee of his or her rights. The 

counselor would call the manager identified by the employee, identify for 

the manager the issues and bases of the complaint, and get the manager’s 

15EEOC uses MD-110 to supplement its EEO regulations (29 C.F.R. Part 1614) with 

additional guidance relating to the processing of complaints.
Page 18 GAO-03-604 EEO at SSA Region X

input on what had transpired. Several counselors said that after meeting or 

talking with the employees and managers, they would typically read back 

managers’ statements to them to make sure that they had captured what 

the managers said. One counselor mentioned letting managers read the 

statement. 

According to SSA headquarters and Region X officials, in fiscal year 1999, 

Region X made changes to the procedures in the informal stage of its EEO 

complaint process. These changes (1) required Region X EEO counselors 

to put in writing questions to managers and (2) commonly involved the 

Region’s OGC in the informal stage of the process. The then Regional 

Commissioner referred to these changes collectively as the “written 

approach.” After these changes took place, EEO counselors were no longer 

allowed to talk with managers. In addition, according to the then Regional 

Commissioner, as part of the written approach, managers were encouraged 

to routinely have an attorney from OGC review their written responses 

before these responses were provided to the EEO counselors. 

SSA’s then Associate Commissioner of the Office of Civil Rights and Equal 

Opportunity (OCREO) said that he thought the written queries came out of 

Region X managers’ distrust of what the EEO counselors attributed to 

managers in their reports. The then Regional Commissioner said that 

regional managers had reported that EEO counselors were not accurately 

reflecting managers’ views in the counselors’ reports, including a manager 

who in January 1998 said at a hearing on a formal EEO complaint that he 

had not said things attributed to him. In addition, according to the then 

Regional Commissioner, EEO counselor training was inadequate before 

1999, and the change to written queries was put in place about the same 

time that the Region put in place a formal training process for EEO 

counselors.16 The then Regional Commissioner said that she wanted to use 

the written approach to give managers the opportunity to give their views 

until training was completed. 

16A Region X official said that in 1999 Region X management instituted an intensive training 

plan to address subject matter needs of EEO specialists and established the practice of 

reinforcing each EEO counselor’s role as a neutral third party. This new training in the 

Region was put into place about the same time that EEOC began requiring specific training 

for EEO counselors. According to EEOC’s Director of Federal Sector Programs, EEOC 

guidance did not have a specific training requirement for EEO counselors until November 9, 

1999, when the regulations and guidance were revised. Under the revised guidance, EEOC 

requires new EEO counselors to receive a minimum of 32 hours of EEO counselor training 

before assuming counseling duties.
Page 19 GAO-03-604 EEO at SSA Region X

Also, in 1999, the Region began relying more on OGC in matters concerning 

employee relations. In a memo dated February 4, 1999, the Region 

announced that a new partnership had been put in place and that OGC 

would be providing advice and counsel on all employee relations issues and 

cases. According to the memo, these issues and cases were to include 

misconduct, performance and attendance problems, reasonable 

accommodation for employees with disabilities, and standards of conduct. 

The memo does not refer to OGC involvement in EEO complaints and 

cases. However, according to the then Regional Commissioner and others, 

in fiscal year 1999, OGC began reviewing managers’ written responses to 

counselors’ inquiries during the informal stage of the EEO process. The 

then Associate Commissioner of OCREO said that after the February 1999 

memo, he believes that it became normal in Region X for managers to 

consult with OGC. He said that he thought that the OGC involvement was 

gradual in the beginning. The Regional Chief Counsel said that not every 

manager availed himself or herself of OGC’s services. 

The then Associate Commissioner of OCREO said that he started in his 

position in March 2000 and that he thought he first became aware that 

Region X was involving OGC in a routine way in the EEO process in 

summer 2000. The then Associate Commissioner said that he and the then 

SSA Deputy Commissioner for Human Resources agreed that there was a 

perception that Region X’s reliance on OGC went beyond the informal 

process. The then Associate Commissioner said that during the informal 

process, there should be a limited inquiry and that it should not prevent 

EEO counselors from talking with managers or involve OGC. The then 

Associate Commissioner said that SSA headquarters officials held 

discussions with Region X officials to explain that having OGC involved in 

the informal EEO process gave the appearance that the “deck is stacked 

against employees.” In discussions between SSA headquarters and Region 

X officials, the then Associate Commissioner said that both headquarters 

and regional officials agreed that it would be good to have training to get 

the process back to what was outlined in EEOC’s guidance. As a result, the 

then Associate Commissioner said that SSA headquarters sent OCREO staff 

to the Region to provide training in October 2000 on basic counseling, 

limited inquiries, and report writing. According to the then Associate 

Commissioner, the training was provided to the Civil Rights and Equal 

Opportunity (CREO) staff, including EEO counselors and the CREO 

manager, OGC, and executive staff. 

In addition, the then Regional Commissioner said that she spoke with the 

Area Director for Alaska and Washington, the Area Director for Idaho and 
Page 20 GAO-03-604 EEO at SSA Region X

Oregon, and the Director of the Auburn Teleservice Center17 and told them 

that OGC was not to be used during the informal stage of inquiry. After the 

training took place, the then Regional Commissioner said that she also had 

conference calls with every manager about this issue. According to a 

Region X official, these conference calls took place on October 8, 2000. 

Notes from a Region X official concerning these conference calls indicate 

the following topics on the informal stage of the EEO process were 

discussed:

• The role of the counselor is to conduct a neutral and limited inquiry, not 

an investigation.

• Counselors will no longer submit questions in writing; they will engage 

in a verbal dialogue with managers and supervisors, with emphasis on 

informality.

• It is important to remember that a counselor is not trying to prove right 

or wrong. He or she is working toward a solution.

• Resolution during informal counseling varies with the nature of 

complaint.

Because the Region did not provide documentation that the written 

approach was no longer a part of its informal EEO process, we contacted 

Region X officials and former and current EEO counselors to confirm that 

such a change took place. According to two Region X EEO counselors who 

were in those positions at the time, beginning in early fiscal year 2001, they 

no longer had to put their queries in writing and were again allowed to talk 

with managers. 

GAO Survey of 

Region X Employees 

about EEO

To gain an understanding of how familiar the Region’s employees are with 

the EEO process, their willingness to participate in it, and their views on 

the work environment, we surveyed all of the Region’s employees on the 

EEO process and EEO environment in the Region and achieved a 

75 percent response rate. According to the results of our survey, most 

Region X employees are familiar with the EEO process, with almost twothirds of Region X employees reporting having received or having seen 

17The Auburn Teleservice Center is one of SSA’s four largest such centers with telephone 

service representatives.
Page 21 GAO-03-604 EEO at SSA Region X

within the last 2 years written materials about the federal government’s 

EEO regulations and written materials describing how to contact regional 

EEO counselors. Most respondents indicated that they believed decisions 

concerning job or project assignments, training, formal ratings, and 

monetary awards were always or mostly based on merit and free of bias 

and favoritism. However, 23 percent of respondents reported that they felt 

they had been discriminated against. For example, when asked if they felt 

they were denied a job, promotion, or other job benefit because of unlawful 

discrimination, 10 percent of respondents cited race, 8 percent cited age, 

and 8 percent cited sex. In addition, when asked if they chose not to apply 

for a promotion or developmental opportunity because they felt they had 

little or no chance of being selected, 11 percent of respondents indicated 

that age was the reason for not applying, 10 percent indicated race was the 

reason, and 6 percent indicated sex was the reason. 

When asked about their willingness, if they believed that they had been 

discriminated against, to either contact Region X’s CREO to participate in 

counseling or to contact OCREO in Baltimore to file a formal EEO 

complaint, almost half of respondents indicated that they would be 

generally or very willing to participate in counseling or to file a formal EEO 

complaint. About 40 percent of respondents indicated that they were 

unwilling or uncertain to participate in counseling or to file a formal EEO 

complaint if they believed that they had been discriminated against. When 

asked to describe their reason for this unwillingness or uncertainty, about 

55 percent indicated that they were unwilling or uncertain to participate in 

counseling, and 51 percent, to file a formal EEO complaint because they 

feared retaliation. Also, 45 percent of respondents indicated that they were 

unwilling or uncertain to participate in counseling because of a concern 

that their contact with the EEO counselor would not be kept confidential. 

Our prior work has shown that leading organizations work to ensure that 

they create a workplace that is free of discrimination and in which 

employees do not fear or experience retaliation for engaging in activities 

protected by antidiscrimination laws.18 Our survey results indicate that if 

Region X does not work to improve the perceptions of employees, it may 

not achieve a trusting workplace. Appendix VI discusses more of the 

results of our survey, and appendix VII contains a copy of our questionnaire 

and the responses to the questions.

18U.S. General Accounting Office, Human Capital: The Role of Ombudsmen in Dispute 

Resolution GAO/GGD-01-466 (Washington, D.C.: Apr. 13, 2001) and A Model of Strategic 

Human Capital Management GAO-02-373SP (Washington, D.C.: Mar. 15, 2002).
Page 22 GAO-03-604 EEO at SSA Region X

Region X’s Temporary 

Changes Were Counter 

to the Spirit of EEOC’s 

Regulations and SSA’s 

Guidance 

The changes Region X made to the informal stage of its EEO process are 

not specifically addressed in federal sector EEO regulations. Neither 

EEOC’s regulations nor the related guidance—MD-110—directly addresses 

the appropriateness of written counselors’ queries, written managers’ 

responses, or OGC involvement in the informal process. However, these 

changes were counter to the spirit of the regulations and the related 

guidance, which emphasize the informal nature of precomplaint 

counseling. In addition, these changes were counter to SSA’s EEO 

handbook for managers and supervisors, which discusses meetings and 

conversations between counselors and managers but not written 

inquiries.19

One of the stated purposes of precomplaint counseling is for employees 

who believe they have been discriminated against to attempt to informally 

resolve the matter.20 MD-110 states that in almost all instances, informal 

resolution, freely arrived at by all parties involved in the dispute, is the best 

outcome of a counseling action. Appendix A to MD-110, which contains 

methods for seeking resolution, suggests that during precomplaint 

counseling, the counselor talk or meet with agency officials to explain the 

employee’s allegations, afford the agency an opportunity to present its 

position concerning the allegations, and suggest how the problem might be 

resolved. 

SSA’s then Associate Commissioner of OCREO said that the changes made 

by Region X in the informal EEO process, although not illegal, were 

counter to the spirit of the regulations and the related guidance, MD-110.21 

The then Associate Commissioner said that by having written EEO 

counselor queries and managers’ responses and involving OGC, the 

informal stage of the EEO process in Region X was more like an 

investigation in the formal stage of the EEO process. In addition, in a June 

2001 letter to a Region X employee, SSA’s then Deputy Commissioner for 

Human Resources wrote that, “Except in rare instances, OGC should not be 

involved in the precomplaint process.” When asked whether OGC was 

19Social Security Administration, Equal Employment Opportunity Handbook for Managers 

and Supervisors of the Social Security Administration (Baltimore: Nov. 1995).

2029 C.F.R. sec. 1614.105(a).

21SSA’s then Associate Commissioner of OCREO said that he prefaced all of his remarks 

about the EEO process in Region X with the fact that his office did not find or see anything 

illegal or that any person had been discriminated against.
Page 23 GAO-03-604 EEO at SSA Region X

involved in the informal stage of the EEO complaint process in other SSA 

regions, the then Associate Commissioner for OCREO said that he has 

never had any complaints or allegations that OGC was involved in the 

informal part of the process in other regions.

In addition, the EEOC regulations require that all agencies ensure that all 

agency employees provide full cooperation to EEO personnel in the 

processing and resolution of precomplaint matters.22 According to a recent 

EEOC report,23 the involvement of OGC during the informal stage of the 

EEO process may thwart attempts during counseling to resolve matters 

before the filing of a formal complaint. An EEOC official responsible for 

overseeing agencies’ EEO programs said that involving OGC in the informal 

stage of the process causes EEOC concern because complaints should be 

resolved informally and OGC involvement can hinder the counselor’s 

ability to facilitate resolution. This official added that having managers put 

responses to counselors’ queries in writing and involving OGC at the 

informal stage of the process could drag out the process and that the longer 

the process takes, the less likely it is to result in an informal settlement. In 

addition, the EEOC official said that EEOC encourages alternative dispute 

resolution (ADR), and requiring managers to put responses in writing is 

counter to ADR. Finally, the EEOC official said that written EEO counselor 

queries and managers’ responses and the involvement of OGC in the 

informal process were counter to the spirit of the regulations. 

Written counselors’ queries and written managers’ responses were counter 

to SSA’s EEO handbook for managers, which discusses meetings and 

conversations between counselors and managers. The handbook also 

discusses EEO counselors contacting responsible management officials to 

discuss the issues causing concern,24 the basis or bases for the complaint, 

and the remedy sought by the employee. The handbook for managers also 

states that the manager’s cooperation with the counselor is required by 

regulation and that the manager may have a representative present when 

meeting with an EEO counselor. Thus, the language in the handbook for 

managers is similar to appendix A of MD-110, which suggests that the 

2229 C.F.R. sec. 1614.102(b)(6).

23U.S. Equal Employment Opportunity Commission, Onsite Report: U.S. Department of 

Agriculture (Washington, D.C.: Feb. 26, 2003).

24According to SSA officials, SSA is currently revising its EEO handbook for managers and 

supervisors as well as its employees’ edition. 
Page 24 GAO-03-604 EEO at SSA Region X

counselor talk or meet with agency officials and points out the requirement 

of EEOC’s regulations that all agencies ensure that all agency employees 

provide full cooperation to EEO personnel in the processing and resolution 

of precomplaint matters. 

SSA Has Not Adopted 

Procedures for Counselors 

Processing EEO Complaints 

as Required by EEOC 

Regulations

In doing our work on Region X, we asked SSA headquarters and Region X 

for documents pertaining to the processing of EEO complaints. Among 

other things, SSA provided its EEO handbook for managers and 

supervisors as well as its employees’ edition, which inform managers and 

employees what they can expect when faced with the EEO process. 

However, the handbooks, which were issued in November 1995, do not 

contain agency-specific procedures on how EEO counselors are to process 

such complaints. Under EEOC’s regulations, agencies have certain 

responsibilities for maintaining a continuing affirmative program to 

promote equal opportunity and to identify and eliminate discriminatory 

practices and policies.25 In order to implement their programs, the 

regulations require agencies to (1) make written materials available to all 

employees and applicants informing them of the variety of EEO programs 

and administrative and judicial remedial procedures available to them and 

(2) prominently post such materials in all personnel and EEO offices and 

throughout the workplace.26 In addition, the regulations require agencies 

to adopt procedures for processing—both at the informal and formal 

stage—individual and class complaints of discrimination that are 

consistent with all other applicable provisions of the regulations and the 

instructions for complaint processing contained in MD-110.27

SSA has addressed two of these regulatory requirements. It has 

communicated in memorandums to all employees its policy prohibiting 

discrimination against employees and applicants for employment, most 

recently in a February 10, 2003, memorandum. SSA headquarters and 

Region X officials provided us with copies of the written materials 

containing information on the administrative and judicial remedial 

procedures available. On a visit to Region X, we saw such written materials 

posted on a wall in the Auburn Teleservice Center. We also used SSA’s 

2529 C.F.R. sec. 1614.102 (a).

2629 C.F.R. sec. 1614.102 (b) (5).

2729 C.F.R. sec. 1614.104 (a).
Page 25 GAO-03-604 EEO at SSA Region X

Intranet to reach the Seattle Civil Rights and Equal Opportunity Web site 

and confirm that the information is available electronically to Region X 

employees as is current information about whom to contact. SSA’s EEO 

handbooks for managers and employees discussed earlier also provide 

much information to their target groups. However, SSA has not fully 

implemented the third regulatory requirement to adopt agency-specific 

procedures for processing EEO complaints. When asked if SSA had 

adopted procedures for processing EEO complaints, the then Associate 

Commissioner for OCREO and Region X’s manager for CREO said that SSA 

follows the processes and procedures outlined in the guidance on the 

EEOC regulations—MD-110. 

An EEOC official responsible for overseeing agencies’ EEO programs said 

that EEOC anticipated that an agency would have step-by-step, 

agency-specific procedures on how the agency would implement the 

broader requirements covered by EEOC’s regulations and related guidance. 

The EEOC official said that EEOC anticipated that when agencies adopted 

such procedures, they would be in writing, so others could review them, if 

necessary. According to the EEOC official, having agency-specific 

guidance is important so that people processing complaints know exactly 

how to implement the regulations. The official said he thinks it is 

appropriate for agencies to have standard operating procedures, especially 

when they have more than one installation or operations spread across 

installations or regions, to help ensure consistent compliance with the 

regulations. The EEOC official said that it was an issue of fairness to both 

the employees in the EEO offices because they need to know what to do 

and what is expected of them and to those who may file a complaint 

because they are entitled to similar treatment across geographic areas for 

fairness. 

Conclusions Our analysis showed no statistically significant differences for most of the 

personnel actions we reviewed. However, we found statistically significant 

differences among groups for certain awards and adverse actions in Region 

X. This analysis was not designed to determine whether or not 

discrimination existed. However, the analysis can identify areas worthy of 

further study by management. Human capital management principles 

include reviewing personnel actions to identify and address statistically 

significant differences across groups in order to help ensure EEO in the 

workplace. Region X has not reviewed such differences to uncover their 

causes or to determine their appropriateness.
Page 26 GAO-03-604 EEO at SSA Region X

Concerning whether the Region’s EEO complaint process is consistent with 

federal regulations, Region X’s changes to written queries and OGC 

involvement in its informal EEO complaint process are not specifically 

addressed in federal sector EEO regulations. However, these changes were 

counter to the spirit of the regulations and the related guidance, which 

emphasize the informal nature of precomplaint counseling and informal 

resolution. In addition, these changes were counter to SSA’s EEO 

handbook for managers and supervisors, which discusses meetings and 

conversations between counselors and managers.

In doing our work at Region X, we found that although SSA had issued EEO 

handbooks in November 1995 for managers and supervisors as well as 

employees, the handbooks do not contain agency-specific procedures on 

how EEO counselors are to process complaints of discrimination. Agencyspecific procedures on how to process EEO complaints—both at the 

informal and formal stage—are required by EEOC’s regulations and are 

especially important if employees are geographically dispersed, as in SSA, 

to ensure that all employees have the same process available to them. 

Without agency-specific procedures for EEO counselors to process 

complaints of discrimination, counselors in different components could 

use different procedures, with the result that employees are not treated 

consistently. Also, agency-specific procedures could alert managers to 

possible problem areas when they consider changing processes and could 

help prevent changes like the temporary ones in Region X that ran counter 

to the spirit of EEOC’s regulations.

In addition, a sizeable portion of respondents to our survey—about 40 

percent—indicated they were unwilling to become or uncertain about 

becoming involved with the processes established for handling EEO 

complaints. Frequently cited reasons for concern about becoming involved 

with the EEO process were a fear of retaliation and that contact with the 

EEO counselor would not be kept confidential. These concerns could 

deter individuals in Region X from exercising their rights concerning EEO. 

Recommendations We recommend that the Commissioner of SSA: 

• Direct the Regional Commissioner of Region X to review the statistically 

significant differences we found in adverse actions and awards to 

determine why they occurred and what, if any, corrective action is 

needed.
Page 27 GAO-03-604 EEO at SSA Region X

• Adopt standard operating procedures for EEO counselors that include 

step-by-step procedures for processing complaints of discrimination so 

that counselors and others involved in the process across the country 

know what to do and employees face the same process everywhere. 

• Direct the Regional Commissioner of Region X to establish a plan to (1) 

enhance the Region’s EEO environment to increase trust and (2) 

measure the plan’s effectiveness, such as with a periodic survey of 

employees. 

Agency Comments In a letter dated June 26, 2003 (see app. VIII), SSA’s Commissioner said that 

the agency acknowledged the report’s general findings and said that SSA is 

committed to ensuring equal treatment for all employees and that its 

policies and practices are in compliance with EEOC’s procedures for 

processing complaints of discrimination. Regarding our first 

recommendation, SSA said that it would continue to monitor statistically 

significant differences. However, SSA did not address the extent to which 

it would take action, if needed. We continue to believe that this is an 

important component of following up and alleviating concerns. Regarding 

our second recommendation that it adopt standard operating procedures 

for EEO counselors, SSA stated that it has standard operating procedures 

in the form of EEO handbooks and an EEO training manual that SSA uses 

to instruct EEO counselors on how to process EEO complaints. As 

discussed in the draft report, the handbooks did not provide detailed 

procedures on how EEO counselors are to process EEO complaints. 

However, the comments state that SSA is going to update the handbooks 

and training manual to provide the procedural guidelines called for in 

EEOC’s regulations governing the EEO process for federal agencies. 

SSA said that it agrees all regions should foster an environment where 

employees feel they can raise concerns and take part in a process designed 

to resolve complaints and acknowledged that the change to the EEO 

process in Region X may have caused some distrust. However, SSA 

disagreed with our third recommendation that the Regional Commissioner 

of Region X establish a plan to enhance the Region’s EEO environment to 

increase trust and measure the plan’s effectiveness. The comments said 

that our survey found that 51 percent of the Region’s employees were very 

or generally willing to participate in EEO counseling, 13 percent were as 

willing as unwilling, and 10 percent were uncertain. SSA also said that 

because Region X is no longer following the change to the EEO process 

that may have caused some distrust, implementing a plan to improve trust 
Page 28 GAO-03-604 EEO at SSA Region X

will not be necessary. Our survey was conducted in early 2003, or about 2 

years after the “written approach” to the informal stage of EEO complaint 

processing was discontinued. Our survey found that 40 percent of 

employees were unwilling or uncertain about using the current EEO 

process, indicating to us a need to focus on enhancing the environment to 

increase trust. While SSA said it would share best practices from other 

human resource management audits with Region X, a periodic focus on 

Region X would, in our view, provide knowledge of issues specific to 

Region X.

We will send copies of this report to the Commissioner of SSA, the Director 

of the Office of Management and Budget, and interested congressional 

committees. We also will make copies available to others upon request. In 

addition, the report is available on GAO’s home page at http://www.gao.gov. 

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

(202) 512-6806 or Kiki Theodoropoulos, Senior Analyst, on (202) 512-4579. 

Key contributors to this report are listed in appendix IX.

Victor S. Rezendes

Managing Director, Strategic Issues
Page 29 GAO-03-604 EEO at SSA Region X

Appendix I

Objectives, Scope, and Methodology AAppenednxidexiIs

As agreed, our objectives were to (1) provide information on the 

composition of Region X’s workforce by EEO group (race/ethnicity and 

gender) for fiscal years 1997 through 2001 overall and for personnel actions 

such as promotions, awards, and adverse actions; (2) describe the EEO 

complaint process and any changes to it in the Region for the 5-year period; 

(3) assess whether the Region’s EEO complaint process is consistent with 

federal regulations and related guidance; and (4) assess the familiarity 

with the EEO process of the Region’s employees and their attitude toward 

it.

Objective 1 To identify the composition of Region X’s workforce by EEO group 

(race/ethnicity and gender) for fiscal years 1997 through 2001 in general 

and for selected personnel actions (i.e., hires, promotions, separations, 

awards, training, and adverse actions), we used SSA data provided by the 

Region’s human resources management information system for the 5-year 

period.1

 These data were limited to those employees of Region X who were 

under the line authority of the then Regional Commissioner and, therefore, 

do not include employees of the Office of Inspector General, Office of 

Hearings and Appeals, the Office of the General Counsel, and the Regional 

Office of Quality Assurance. 

We assessed the reliability of data provided by Region X on the workforce, 

hires, promotions, separations, and awards for fiscal years 1997 and 2001 

by comparing them against the number of employees for Region X in the 

Office of Personnel Management’s Central Personnel Data File and doing 

electronic data testing for obvious errors in completeness, accuracy, and 

reasonableness. We found data on the workforce, permanent promotions, 

separations, and quality step increases to be sufficiently reliable for fiscal 

years 1997 and 2001 for the purposes of this report. We did not check the 

reliability of data on temporary promotions because they included details 

to lateral positions, which are not counted as temporary promotions in the 

Central Personnel Data File. Data on race/ethnicity for hires reported to 

us by Region X were significantly different from such data for SSA Region 

X hires in the Central Personnel Data File. 

1

Region X provided data on the following EEO groups: African American men and women, 

American Indian/Alaska Native (AIAN) men and women, Asian/Pacific Islander (Asian) 

men and women, Hispanic men and women, and White men and women. 
Appendix I

Objectives, Scope, and Methodology 

Page 30 GAO-03-604 EEO at SSA Region X

We discussed the differences with SSA headquarters and Region X officials 

to determine the reason for them. The lead human resources official in 

Region X said that when a new hire is processed via an accession action, 

the employee cannot be paid until the personnel action is released and 

updated through the Federal Personnel and Payroll System, the automated 

personnel action processing system SSA uses. During fiscal years 1997 

through 2001, the official said that often, because of time constraints, the 

system—which required a code for race/ethnicity—was coded with 

unverified data (i.e., White) so the action could go through and the 

employee be paid.2

 The official said that in August 2002 SSA began 

requiring the human resources staff processing the new hire personnel 

actions to have the completed form with race/ethnicity submitted 

electronically or by fax on the day the employee reports for duty, so the 

data can be coded properly into the initial accession action. An OPM 

official analyzed Region X data on hires and confirmed that submissions of 

subsequent personnel actions updated race/ethnicity for some Region X 

employees. As a result, we decided the data on hires were sufficiently 

reliable for our purposes.

We assessed the reliability of data on selections to the Job Enhancement 

Program, adverse actions and their appeals, EEO counseling requests, EEO 

complaints, reasonable accommodations, grievances, and settlements, by 

doing in-depth comparisons of narratives concerning the data with the 

data provided by Region X. In cases where we found differences, we 

discussed inconsistencies with regional officials and took steps to correct 

them. We determined that the data on Job Enhancement Program 

selections, adverse actions and their appeals, EEO counseling requests, 

EEO complaints, reasonable accommodations, grievances, and settlements 

were sufficiently reliable for the purposes of this report.

To judge its diversity, SSA compares its workforce with the Civilian Labor 

Force (CLF). Because data on the U.S. CLF that SSA uses are based on 

1990 census data, we decided to use data from the 2001 Current Population 

Survey, which is a monthly survey of about 50,000 households conducted 

by the Bureau of the Census and is the primary source of current 

information on the labor force characteristics of the U.S. population. To 

2

According to the Region X official, such coding was done with the knowledge and 

confidence that the code would be corrected when the new employee paperwork was 

received, usually within the following week, providing accurate race/ethnicity data based 

on the new employee’s self-identification for the system. 
Appendix I

Objectives, Scope, and Methodology 

Page 31 GAO-03-604 EEO at SSA Region X

identify the fiscal year 2001 regional civilian workforce, we used the March 

2001 Current Population Survey to identify the number of individuals 18 or 

older working in the private sector and for federal, state, and local 

governments in the states of Alaska, Idaho, Oregon, and Washington. 

As part of our analysis, for our discussion of the composition of SSA staff 

for selected personnel actions, we determined whether statistically 

significant differences by race/ethnicity or gender occurred. Our analyses 

of personnel actions are not designed to show that discrimination does or 

does not exist; instead they are designed to provide information at a 

common and aggregate level about race/ethnicity and gender differences 

in personnel actions at Region X. Therefore, our results should not be 

interpreted to indicate whether discrimination has or has not occurred. 

The presence of statistically significant difference does not prove 

discrimination, nor does the absence of statistically significant difference 

prove that staff have not been discriminated against. The presence of 

statistically significant differences means that we are 95 percent confident 

that differences could happen by chance in less than 5 percent of the cases.

Objective 2 To describe the EEO process in Region X and any changes made to it for 

the 5-year period, we reviewed documents provided by SSA headquarters 

and Region X officials and interviewed those officials. Because the Region 

was not able to provide us with written documentation on how it carried 

out the informal stage of the EEO complaint process and when changes to 

the process occurred, we contacted former and current Region X EEO 

counselors and headquarters officials and relied on their views concerning 

when these changes took place.

Objective 3 To determine whether the Region’s EEO complaint process was consistent 

with federal regulations, we reviewed EEOC’s regulations3

 and the related 

guidance—EEOC’s Management Directive 110 (MD-110)—governing how the 

discrimination claims of federal employees are to be processed 

administratively and compared their requirements with the processes 

described by SSA headquarters and Region X officials. We also reviewed a 

recent EEOC on-site report on the U.S. Department of Agriculture, part of 

which concerned the involvement of OGC in the informal part of the EEO 

3

29 C.F.R. Part 1614.
Appendix I

Objectives, Scope, and Methodology 

Page 32 GAO-03-604 EEO at SSA Region X

process. In addition, we contacted an EEOC official responsible for 

overseeing agencies’ EEO programs to identify EEOC’s views concerning 

whether the types of changes Region X made to its EEO process were 

consistent with federal regulations and the related guidance.

Objective 4 To assess the familiarity with the EEO process of the Region’s employees 

and their attitude toward it, we designed and sent questionnaires to all 

SSA Region X employees to get their views on EEO. We pretested the 

questionnaire instrument to minimize measurement error and assure 

ourselves that respondents could interpret the questions correctly and 

could provide the information requested. We modified question wording 

and questionnaire format on the basis of what we learned from these 

pretests.

SSA provided us with the home addresses for all individuals employed by 

Region X as of August 27, 2002. On September 18, 2002, we mailed 1,801 

questionnaires to these home addresses. One individual returned the 

questionnaire, indicating that he or she was no longer an employee of 

Region X. Because this individual did not answer any questions in the 

survey, we dropped this individual from the universe of employees, 

resulting in a revised universe of 1,800 Region X employees. After the 

initial and a follow-up mailing, we received 1,364 questionnaires. However, 

we received 9 questionnaires in which the tracking number for 

nonresponse follow-up had been removed (see table 4). Therefore, our 

analysis is based on 1,355 questionnaires, for a response rate of 75.3 

percent. Table 4 summarizes the disposition of the questionnaire returns 

for the revised universe of 1,800.

Table 4: Final Disposition of Questionnaire

Source: GAO analysis.

a

We received nine questionnaires in which the tracking number for nonresponse follow-up had been 

removed. Because anyone who did not respond to the initial mailing was sent two questionnaires, 

these nine questionnaires were not included in our analysis because they may have been duplicates. 

Disposition Number Percent

Useable returns 1,355 75.3

Delivered but not returned 436 24.2

Returned but not useablea 9 0.5

Total 1,800 100.0
Appendix I

Objectives, Scope, and Methodology 

Page 33 GAO-03-604 EEO at SSA Region X

The questionnaire offered respondents the option of providing additional 

comments relating to any of the items discussed therein. Of the 1,355 

useable returns, 307 respondents, or 22.7 percent, provided narrative 

comments. The questionnaire results express the viewpoints and attitudes 

of SSA Region X employees. All responses were anonymous; if 

respondents included references to names, these references were marked 

out before questionnaires were submitted to data entry. 

All data were double-keyed and verified as part of the data entry process. 

Computer analyses were performed to identify inconsistencies (e.g., 

inappropriate skip patterns) or other indications of errors. All computer 

analyses were verified by a second independent analyst. Although it was 

not possible to test the validity of the respondents’ answers or the 

comments they made, we took several steps to check the quality of our 

questionnaire data. We reviewed and edited completed questionnaires, 

made internal consistency checks on several items, and rechecked the 

accuracy of data entry on a random sample of questionnaires. The 

practical difficulties of administering any questionnaire may introduce 

errors, commonly referred to as nonsampling errors. For example, 

differences in how a particular question is interpreted by respondents 

could introduce unwanted variability in the questionnaire’s results. We 

took steps in the development of the questionnaire, the data collection, 

and the data analysis to minimize nonsampling errors. These steps, which 

we discussed earlier, included pretesting and revising the questionnaires 

accordingly. 

The percentage of respondents by race/ethnicity closely mirrored the 

percentage of each race/ethnicity in the population of Region X employees. 

The percentage of men and women responding to the survey also matched 

their respective percentages in the Region X workforce.

The 95-percent confidence intervals for the percentage of respondents who 

were unwilling or uncertain to participate in counseling or to file a formal 

discrimination complaint were +1.4 percentage points. The 95-percent 

confidence intervals for the reasons why respondents were unwilling or 

uncertain to participate in counseling or to file a formal discrimination 

complaint were + 2.3 percentage points.

We did our work in Washington, D.C., Baltimore, and Seattle from January 

2002 through May 2003 in accordance with generally accepted government 

auditing standards. 
Page 34 GAO-03-604 EEO at SSA Region X

Appendix II

EEO Laws and Regulations Applicable to 

Federal Employees ApendxiI

Laws Prohibiting 

Discrimination

Title VII of the Civil Rights Act of 1964, as amended, makes it illegal for 

employers, including federal agencies, to discriminate against their 

employees or job applicants on the basis of race, color, religion, sex, or 

national origin.1

 The Equal Pay Act of 1963 protects men and women who 

perform substantially equal work in the same establishment from sexbased wage discrimination.2

 The Age Discrimination in Employment Act of 

1967, as amended, prohibits employment discrimination against individuals 

who are 40 years of age or older.3

 Sections 501 and 505 of the 

Rehabilitation Act of 1973, as amended, prohibit discrimination against 

qualified individuals with disabilities who work or apply to work in the 

federal government.4

 Federal agencies are required to provide reasonable 

accommodation to qualified employees or applicants for employment with 

disabilities, except when such accommodation would cause an undue 

hardship. In addition, a person who files a complaint or participates in an 

investigation of an EEO complaint or who opposes an employment practice 

made illegal under any of the antidiscrimination statutes is protected from 

retaliation. The Equal Employment Opportunity Commission (EEOC) is 

responsible for enforcing all of these laws.

EEOC Regulations 

Governing the 

Processing of 

Employment 

Discrimination 

Complaints

Federal employees or applicants for employment who believe that they 

have been discriminated against by a federal agency may file a complaint 

with that agency.5

 EEOC has established regulations providing for the

1

42 U.S.C. secs. 2000e et seq. 

2

29 U.S.C. sec. 206(b).

3

29 U.S.C. secs. 621 et seq. 

4

29 U.S.C. secs. 791 and 794a.

5

For allegations of discrimination under Title VII and the Rehabilitation Act, filing an 

administrative complaint is a prerequisite to filing a civil action in court. See 42 U.S.C. sec. 

2000e-16(c) and 29 U.S.C. sec. 794a(a)(1).
Appendix II

EEO Laws and Regulations Applicable to 

Federal Employees

Page 35 GAO-03-604 EEO at SSA Region X

processing of federal sector employment discrimination complaints.6 This 

complaint process consists of two stages, informal, or precomplaint 

counseling, and formal. Before filing a complaint, the employee must 

consult an EEO counselor at the agency in order to try to informally 

resolve the matter. The employee must contact an EEO counselor within 

45 days of the matter alleged to be discriminatory or, in the case of a 

personnel action, within 45 days of the effective date of the action. EEO 

counselors should determine if the employee believes that his or her 

problem is the result of discrimination on one or more of the bases—race, 

color, sex (including equal pay), religion, national origin, age (40 and over), 

disability—or in retaliation for having participated in activity protected by 

the various antidiscrimination statutes. Counselors are to advise 

individuals that, when the agency agrees to offer alternative dispute 

resolution (ADR) in the particular case,7

 they may choose to participate in 

either counseling or in ADR. 

After the counselor determines the basis or bases and claims, he or she is 

to conduct a limited inquiry of the matter, which generally involves 

speaking or meeting with the two parties. When the counselor has a good 

grasp of the issues involved, he or she is ready to attempt resolution. 

Resolution means that the employee and the agency come to terms with 

the matter and agree on a solution. In seeking resolution, the counselor is 

to listen to and understand the viewpoint of both parties and act as a 

neutral and not as an advocate for either the employee or the agency. 

Counseling is to be completed within 30 days from the date the employee 

contacted the EEO office for counseling.8

 If the matter is not resolved by 

the 30th day of counseling or if ADR is unsuccessful,9 the counselor is 

6

29 C.F.R. Part 1614. EEOC has supplemented these regulations with additional guidance 

relating to the processing of complaints with Management Directive-110 (MD-110), issued 

November 9, 1999.

7

ADR generally refers to any procedure agreed to by the parties in a dispute that is used to 

resolve issues in controversy including, but not limited to, conciliation, facilitation, or 

mediation. As of January 1, 2000, all federal agencies covered by 29 C.F.R. Part 1614 were 

required to establish or make available an ADR program during the informal (precomplaint 

counseling) and formal complaint stages of the EEO processes. According to an SSA Region 

X official, as of March 7, 2003, participation in the ADR process is currently limited to 

mediation and is available to Region X employees within the Seattle commuting area.

8

Before the end of the 30-day period, the employee may agree in writing with the agency to 

extend the counseling period for up to an additional 60 days.

9

ADR is to be completed within 90 days.
Appendix II

EEO Laws and Regulations Applicable to 

Federal Employees

Page 36 GAO-03-604 EEO at SSA Region X

required to inform the employee in writing of his or her right to file a 

formal discrimination complaint with the agency. The written notice must 

inform the employee of the (1) right to file a discrimination complaint 

within 15 days of receipt of the notice, (2) appropriate agency official with 

whom to file a complaint, and (3) duty to ensure that the agency is 

informed immediately if the complainant retains counsel or a 

representative.

After a complainant files a formal discrimination complaint, the agency 

must decide whether to accept or dismiss the complaint. If the agency 

dismisses the complaint, the complainant has 30 days to appeal the 

dismissal to EEOC.10 If the agency accepts the complaint, it has 180 days to 

investigate the accepted complaint and present the complainant with a 

record of investigation.11 Once the agency finishes its investigation and the 

complainant receives the investigation results, the complainant has 30 

days to choose between requesting (1) a hearing before an EEOC 

administrative judge (AJ)12 or (2) a final decision from the agency. When a 

hearing is not requested, the agency must issue a final decision within 60 

days. In cases where a hearing is requested, the AJ has 180 days to issue a 

decision and send the decision to the complainant and the agency. If the AJ 

issues a finding of discrimination, he or she is to order appropriate relief. 

After the AJ decision is issued, the agency has 40 days to issue a final order 

notifying the complainant whether or not the agency will fully implement 

the decision of the AJ, and the employee has 30 days to file an appeal with 

EEOC.13 If the agency issues an order notifying the complainant that the 

agency will not fully implement the decision of the AJ, the agency also 

must file an appeal with EEOC at the same time. Figure 3 illustrates the 

EEO complaint process.

10An agency may dismiss an individual’s complaint for a number of reasons, including failure 

to contact an EEO counselor in a timely manner, failure to file a complaint in a timely 

manner, or failure to state a claim based on covered discrimination. 

11This period can be extended an additional 90 days when both parties agree. 

12A complainant may request a hearing at any time after 180 days have elapsed from the 

filing of the complaint, regardless of whether the agency has completed its investigation. 

13If the agency does not issue a final order within 40 days, the decision of the AJ becomes 

the final action of the agency.
Appendix II

EEO Laws and Regulations Applicable to 

Federal Employees

Page 37 GAO-03-604 EEO at SSA Region X

Figure 3: The EEO Complaint Process with Related Time Frames

a Where the agency agrees to offer ADR in the particular case, employees may choose between 

participation in ADR and counseling activities. ADR generally refers to any procedure agreed to by the 

parties in a dispute that is used to resolve issues in controversy including, but not limited to, mediation.

Alleged discriminatory

action occurs

EEO counselinga

Notice of right 

to file a formal

complaint

Formal complaint

filed with agency

Hearing not

requested

Dismissed

complaint

Final agency

decision

Administrative

judge’s decision

Hearing requested

by complainant

before EEOC

administrative

judge

Appeal to

EEOC

Accepted complaint

investigated and

report of investigation 

issued to complainant

Complainant and 

agency agreement 

to extend counseling

Informal

stage

Formal

stage

Additional

60 days

45 days

30 days

30 days

90 days

15 days

180 days

30 days

Additional

90 days

30 days

Complainant

30 days

Agency

40 days

60 days

180 days

Source: GAO, based on EEOC regulations.

Complainant and 

agency agreement 

to extend investigation
Appendix II

EEO Laws and Regulations Applicable to 

Federal Employees

Page 38 GAO-03-604 EEO at SSA Region X

If a complaint is one that can be appealed to the Merit Systems Protection 

Board (MSPB) such as a removal, reduction in grade or pay, or suspension 

for more than 14 days,14 the complaint is a “mixed case.” With a mixed-case 

complaint, the complainant has no right to a hearing before an EEOC AJ. 

However, a complainant may appeal a final agency decision to the MSPB 

within 30 days of receiving the agency’s decision. EEOC regulations 

provide that an individual may raise claims of discrimination in a mixed 

case, either as a mixed-case EEO complaint with the agency or a direct 

appeal to MSPB, but not both. Under EEOC regulations, whatever action 

the individual files first is considered an election to proceed in that forum. 

Filing a formal EEO complaint constitutes an election to proceed in the 

EEO forum; contacting an EEO counselor or receiving EEO counseling 

does not constitute such an election.15

14MSPB is an independent quasi-judicial agency in the executive branch that serves as the 

guardian of federal merit systems. 

15For employees of agencies subject to 5 U.S.C. sec. 7121(d) and covered by a collective 

bargaining agreement that permits claims of discrimination to be raised in a negotiated 

grievance procedure, the employees similarly must elect to file an EEO complaint or a 

grievance.
Page 39 GAO-03-604 EEO at SSA Region X

Appendix III

Region X Workforce by Grade Level ApendxiI

Over the 5-year period from fiscal years 1997 through 2001, with the 

exception of managers in the Senior Executive Service (SES) and eight 

wage grade employees, the Region X workforce was in the general 

schedule (GS) pay plan.1

 The GS pay plan consists of 15 grades. The 

following sections contain a discussion of Region X employees by EEO 

group in grade levels GS-13 through 15, GS-9 through 12, GS-5 through 8, 

and GS-1 through 4.

Region X Employees in 

Grades GS-13 through 

GS-15

A total of 75 employees were in grades GS-13 through GS-15 in fiscal year 

1997, and 134 in fiscal year 2001. The largest proportional gain in these 

grades was among White women, who increased from 19, or about 25 

percent of these grades, in fiscal year 1997 to 44, or about 33 percent, in 

fiscal year 2001. This was followed by a proportional increase in these 

grades among Asian women, who increased in number from 2, or almost 3 

percent of the grades, in fiscal year 1997 to 10, or 7.5 percent, in fiscal year 

2001. Proportional increases also occurred among African American 

women, AIAN men, and Hispanic men. Hispanic women increased from 0 

in fiscal year 1997 to 4, or 3 percent of these grades in fiscal year 2001. 

Figure 4 shows the change in Region X employees in grades GS-13 through 

GS-15 by EEO group between fiscal years 1997 and 2001.

1

The then Regional Commissioner, a White man, was the only SES manager in Region X in 

fiscal year 1997 and most of fiscal year 1998. In fiscal years 1999 through 2001, there were 

two SES managers in the Region, the then Regional Commissioner, an Hispanic woman, and 

the then Deputy Commissioner, an African American man. 
Appendix III

Region X Workforce by Grade Level

Page 40 GAO-03-604 EEO at SSA Region X

Figure 4: Region X Employees in Grades GS-13 through GS-15 in Fiscal Years 1997 

and 2001 by EEO Group

Region X Employees in 

Grades GS-9 through 

GS-12

A total of 791 employees were in grades GS-9 through GS-12 in fiscal year 

1997, and 837 in fiscal year 2001. The largest proportional gain in these 

grades from fiscal year 1997 to 2001 was among Hispanic women, who 

increased from 26, or 3.3 percent of the grades, in fiscal year 1997 to 46, or 

5.5 percent, in fiscal year 2001. This was followed by a proportional 

increase among Asian women, whose presence in the grades went from 28, 

or 3.5 percent in fiscal year 1997, to 41, or 4.9 percent, in fiscal year 2001. 

3

3

1

1

4

2

3

0

39

19

2

7

3

0

3

10

4

4

57

44

1997 (N=75)

2001 (N=134)

Source: Region X data.

Number of employees

0 10 20 30 40 50 60

Men

Women

Men

Women

Men

Women

Men

Women

Men

Women

African

American

AIAN

Asian

Hispanic

White
Appendix III

Region X Workforce by Grade Level

Page 41 GAO-03-604 EEO at SSA Region X

Proportional increases also occurred among African American men and 

women, Asian men, and Hispanic men. Figure 5 shows the distribution of 

Region X employees in grades GS-9 through GS-12 by EEO group from 

fiscal year 1997 to fiscal year 2001.

Figure 5: Region X Employees in Grades GS-9 Through GS-12 in Fiscal Years 1997 and 2001 by EEO Group

Region X Employees in 

Grades GS-5 through 

GS-8

A total of 818 employees were in grades GS-5 through GS-8 in fiscal year 

1997, and 844 in fiscal year 2001. The largest proportional gain in these 

grades was among Hispanic women, who increased from 28, or 3.4 percent 

of these grades, in fiscal year 1997 to 66, or 7.8 percent, in fiscal year 2001. 

13

26

187

475

21

46

183

463

Source: Region X data.

1997 (N=791)

2001 (N=837)

Number of employees

Men

Women

Men

Women

Men

Women

Men

Women

Men

Women

African

American

AIAN

Asian

Hispanic

White

0 100 200 300 400 500

8 

17

31 

35

4 

3

10 

8

9

20

28 

41
Appendix III

Region X Workforce by Grade Level

Page 42 GAO-03-604 EEO at SSA Region X

This increase was followed by a proportional increase among Hispanic 

men, whose presence in these grades doubled from 20, or 2.4 percent in 

fiscal year 1997, to 40, or 4.7 percent in fiscal year 2001 and Asian women, 

who increased from 22, or 2.7 percent, to 36, or 4.3 percent. The largest 

proportional loss occurred among White women, who decreased from 439, 

or 53.7 percent of the grades in fiscal year 1997, to 387, or 45.9 in fiscal 

year 2001; this was followed by a loss among White men, who decreased 

from 213, or 26 percent of the grades in fiscal year 1997, to 205, or 24.3 

percent in fiscal year 2001. No change occurred in the number of African 

American or AIAN men in these grades in fiscal years 1997 and 2001. 

Figure 6 shows Region X employees in grades GS-5 through GS-8 in fiscal 

years 1997 and 2001 by EEO group.
Appendix III

Region X Workforce by Grade Level

Page 43 GAO-03-604 EEO at SSA Region X

Figure 6: Region X Employees in Grades GS-5 through GS-8 in Fiscal Years 1997 and 2001 by EEO Group

Region X Employees in 

Grades GS-1 through 

GS-4

A total of 35 employees were in grades GS-1 through GS-4 in fiscal year 

1997, and 30 in fiscal year 2001. Numbers for both years included students. 

There were no African American, Asian, or Hispanic men in these grades in 

fiscal years 1997 and 2001. The largest proportional increase occurred 

among AIAN women, who increased from 1, or 2.9 percent of these grades 

in fiscal year 1997, to 5, or 16.7 percent in fiscal year 2001. This increase 

was followed by a proportional increase in Asian women, who doubled 

from 3, or 8.6 percent of these grades in fiscal year 1997 to 6, or 20.0 

percent in fiscal year 2001. The largest proportional loss was experienced 

among White women, who decreased from 21, or 60 percent of these 

3

1997 (N=818)

2001 (N=844)

Source: Region X data.

Number of employees

Men

Women

Men

Women

Men

Women

Men

Women

Men

Women

African

American

AIAN

Asian

Hispanic

White

2 

2

6

0 100 200 300 400 500

439 

14

 18

22 

36

28 

28

20 

40

28 

66

49

56

213

 205

387
Appendix III

Region X Workforce by Grade Level

Page 44 GAO-03-604 EEO at SSA Region X

grades in fiscal year 1997 to 10, or 33.3 percent in fiscal year 2001. Figure 7 

shows Region X employees in grades GS-1 through GS-4 from fiscal year 

1997 through fiscal year 2001 by EEO group.

Figure 7: Region X Employees in Grades GS-1 through GS-4 in Fiscal Years 1997 

and 2001 by EEO Group

Tables 5 and 6 show the distribution across grade levels by race/ethnicity 

and gender compared with their representation in the Region’s workforce 

for fiscal years 1997 and 2001, respectively. As shown in the tables, the 

distribution across grade levels by race/ethnicity or gender varied 

somewhat but was generally close to the representation of the various 

racial/ethnic groups or gender makeup of the Region’s workforce. The 

0

0

0

0

0

0

3

3

3

21

2

10

1997 (N=35)

2001 (N=30)

Source: Region X data.

Number of employees

0 5 10 15 20 25

Men

Women

Men

Women

Men

Women

Men

Women

Men

Women

African

American

AIAN

Asian

Hispanic

White

0

1

1

 5

 6

 3

 4

 3
Appendix III

Region X Workforce by Grade Level

Page 45 GAO-03-604 EEO at SSA Region X

main differences were higher proportions of men in the GS-13 through

GS-15 grade levels and higher representation of African Americans and 

Hispanics in the GS-5 through GS-8 grades. 

Table 5: Percentage Distribution across Grade Levels by Race/Ethnicity and Gender 

for Fiscal Year 1997

Source: GAO analysis of Region X data.

Note: Because the numbers were so small, we did not include data for grades GS-1 through 4.

Table 6: Percentage Distribution across Grade Levels by Race/Ethnicity and Gender 

for Fiscal Year 2001

Source: GAO analysis of Region X data.

Note: Because the numbers were so small, we did not include data for grades GS-1 through 4.

Group

GS-5 through 

GS-8

GS-9 through 

GS-12

GS-13 through 

GS-15

Workforce as of

September 30, 1997

African 

Americans 

9.4 4.9 8.0 7.3

AIANs 0.6 1.8 2.7 1.6

Asians 4.4 4.7 8.0 4.8

Hispanics 5.9 4.9 4.0 5.4

Whites 79.7 83.7 77.3 81.0

Men 33.9 27.9 66.7 32.0

Women 66.1 72.1 33.3 68.0

Group

GS-5 through 

GS-8

GS-9 through 

GS-12

GS-13 through 

GS-15

Workforce as of 

September 30, 2001

African 

Americans 

10.0 6.2 6.7 8.1

AIANs 0.9 1.3 2.2 1.5

Asians 6.4 7.3 9.7 7.3

Hispanics 12.6 8.0 6.0 10.0

Whites 70.1 77.2 75.4 73.1

Men 34.7 29.2 51.5 33.0

Women 65.3 70.8 48.5 67.0
Page 46 GAO-03-604 EEO at SSA Region X

Appendix IV

Temporary Promotions, Training, and Awards ApendxiIV

Experience, training, and awards are among the elements considered 

under SSA’s merit promotion process. Experience includes such 

developmental assignments as temporary promotions and outside 

activities. Training includes both external coursework (e.g., college 

courses) and internal courses (provided by the agency). Awards include 

monetary and nonmonetary, or honor, awards. The analysis for the 5-year 

period showed statistically significant differences among races concerning 

quality step increases and honor awards. These analyses were not 

designed to determine whether or not discrimination occurred but could 

indicate areas warranting further study by management.

The following sections describe by EEO group those who participated in 

temporary promotion and selected training opportunities or received 

awards for fiscal years 1997 through 2001. 

Experience: 

Temporary Promotions

For an employee to receive a temporary promotion to an existing position 

for which he or she is qualified, the employee must meet (1) established 

position qualification standards for the position and (2) time-in-grade 

requirements for promotion. Region X employees can gain experience 

through two kinds of temporary promotions or lateral assignments. The 

Job Enhancement Program (JEP) is a regional noncompetitive program 

that allows employees to voluntarily apply for temporary assignments 

(both promotions and details to existing positions) as a method of 

enhancing career development. According to a 2002 SSA report on Region 

X,1

 JEPs enable regional employees from grades GS-3 up to GS-14 to take a 

detail for up to 120 days in different positions. Table 7 shows the 

distribution of those employees selected for JEPs by EEO group over the 5 

years.

1

Social Security Administration, Human Resources Management Assessment Report for 

Review Conducted April 29-May 3, 2002 in Region X, Office of Human Resources 

(Baltimore: 2002).
Appendix IV

Temporary Promotions, Training, and Awards

Page 47 GAO-03-604 EEO at SSA Region X

Table 7: Comparison of the Percentage of JEPs to the Average Percentage 

Representation in the Workforce for Fiscal Years 1997 Through 2001 in Region X by 

EEO Group

Source: GAO analysis of Region X data.

Note: JEPs include both temporary promotions and details to lateral positions.

a

Total does not sum to 100 percent due to rounding.

According to a Region X official, temporary promotions other than those 

under a JEP can be made noncompetitively for up to 120 days.2

 For 

promotions greater than 120 days, a vacancy announcement is required for 

all positions. Some vacancies are announced as not-to-exceed promotions 

for periods ranging from 1 to 2 years, with a 5-year maximum allowable. 

Such announcements may state, “this position may be extended or become 

permanent without further competition.” Table 8 compares the 

percentage of temporary promotions to the average percentage 

representation of each EEO Group in the workforce for fiscal years 1997 

through 2001 in Region X. 

EEO group

Total JEPs 

across 5 years

Percentage of 

JEPs

Average percentage 

representation in the 

workforce

African American men 21 4.0 2.5

African American 

women

34 6.5 5.3

AIAN men 0 0 0.4

AIAN women 4 0.8 1.0

Asian men 4 0.8 1.9

Asian women 14 2.7 4.0

Hispanic men 9 1.7 3.0

Hispanic women 14 2.7 5.4

White men 125 24.0 24.8

White women 295 56.7 51.7

Total 520 99.9a 100.0

2

If a temporary promotion that was not expected to exceed 120 days was originally made on 

a noncompetitive basis, any extension beyond 120 days must be made under a competitive 

procedure. Temporary promotions can be made for either bargaining or nonbargaining unit 

positions.
Appendix IV

Temporary Promotions, Training, and Awards

Page 48 GAO-03-604 EEO at SSA Region X

Table 8: Comparison of the Percentage of Temporary Promotions to the Average 

Percentage Representation in the Region X Workforce for Fiscal Years 1997 through 

2001 by EEO Group

Source: GAO analysis of Region X data.

Training When asked for data on training opportunities in Region X for fiscal years 

1997 through 2001, the Region provided data on employees who 

participated in the Government Employees Training Act (GETA) program 

(for fiscal years 1998 through 2001). Under the GETA program, SSA pays 

for tuition and book expenses for an employee who enrolls in an approved 

course taken at a university, college, or other recognized educational 

institution. Courses covered included American Sign Language; various 

languages (e.g., Spanish, French, and Russian); writing; and Windowsbased computing (e.g., Excel, PowerPoint). Table 9 compares the 

percentage of individuals receiving GETA training to the average 

percentage representation by EEO group in the Region X workforce for 

fiscal years 1998 through 2001.

EEO group

Total temporary 

promotions 

across 5 years

Percentage of 

temporary 

promotions

Average percentage 

representation in the 

workforce

African American men 4 4.3 2.5

African American 

women

9 9.7 5.3

AIAN men 0 0.0 0.4

AIAN women 0 0.0 1.0

Asian men 2 2.2 1.9

Asian women 3 3.2 4.0

Hispanic men 4 4.3 3.0

Hispanic women 1 1.1 5.4

White men 19 20.4 24.8

White women 51 54.8 51.7

Total 93 100.0 100.0
Appendix IV

Temporary Promotions, Training, and Awards

Page 49 GAO-03-604 EEO at SSA Region X

Table 9: Comparison of the Percentage of GETA Training to the Average Percentage 

Representation by EEO Group in the Region X Workforce for Fiscal Years 1998 

through 2001 

Source: GAO analysis of Region X data.

a

Total does not sum to 100 percent due to rounding.

Awards SSA’s awards are divided into monetary and honor awards. According to 

Region X, monetary awards consist of Recognition of Contribution awards, 

which recognize employees who have maintained high-quality 

performance and may be either a one-time performance award paid as a 

lump sum or a quality step increase, which permanently increases pay; 

Commendable Act or Service awards, which are granted to an employee—

as an individual or as a member of a group—to recognize major 

accomplishments or contributions that have promoted the mission of the 

organization; and On-the-Spot awards, which are special act or service 

awards that recognize employees for noteworthy accomplishments or 

contributions on individual tasks or assignments.3

 We found for the 5-year 

period statistically significant differences among races concerning quality 

step increases and honor awards. Table 10 compares the percentage of 

EEO group

Total GETA training 

across 4 years

Percentage of 

GETA training

Average percentage 

representation in the 

workforce

African American men 8 1.8 2.5

African American 

women

35 7.9 5.3

AIAN men 0 0.0 0.4

AIAN women 4 1.0 1.0

Asian men 8 1.8 1.9

Asian women 11 2.5 4.0

Hispanic men 12 2.7 3.0

Hispanic women 30 6.8 5.4

White men 69 15.6 24.8

White women 265 60.0 51.7

Total 442 100.1a 100.0

3

For the 5-year period on which we focused, Region X gave group special act awards only in 

fiscal year 2001. 
Appendix IV

Temporary Promotions, Training, and Awards

Page 50 GAO-03-604 EEO at SSA Region X

monetary awards to the average percentage representation by EEO group 

in the workforce for the 5-year period.4

Table 10: Comparison of the Percentage of Monetary Awards to the Average 

Percentage Representation by EEO Group in the Region X Workforce for Fiscal 

Years 1997 through 2001

Source: GAO analysis of Region X data.

a

Total does not sum to 100 percent due to rounding.

According to the Region X Affirmative Employment Plan for fiscal year 

1997, the region conducted an analysis of award types and recipient EEO 

profiles in fiscal years 1996 and 1997. According to this report, in fiscal 

year 1996, only Whites received quality step increases; the Region began 

addressing this disparity in fiscal year 1997. Our statistical analysis for the 

5-year period showed that Whites were significantly more likely to receive 

quality step increases than African Americans, Hispanics, and AIANs; 

Asians were significantly more likely to receive quality step increases than 

Hispanics and AIANs; and African Americans were significantly more 

likely to receive quality step increases than Hispanics. There were no 

statistically significant differences between men and women. Because the 

4

Because more monetary awards are given than there are people in an EEO group in the 

Region (i.e., some individuals get more than one monetary award), we could not test for 

statistical significance of monetary awards.

EEO group

Total monetary 

awards for 5 years

Percentage of 

monetary 

awards

Average percentage 

representation in the 

workforce

African American men 173 2.0 2.5

African American 

women

443 5.0 5.3

AIAN men 27 0.3 0.4

AIAN women 96 1.1 1.0

Asian men 174 2.0 1.9

Asian women 296 3.3 4.0

Hispanic men 229 2.6 3.0

Hispanic women 436 4.9 5.4

White men 2,159 24.4 24.8

White women 4,823 54.5 51.7

Total 8,856 100.1a 100.0
Appendix IV

Temporary Promotions, Training, and Awards

Page 51 GAO-03-604 EEO at SSA Region X

Region acknowledged a disparity among racial/ethnic groups concerning 

quality step increases and began trying to address this disparity in fiscal 

year 1997, we also did a statistical analysis of quality step increases for 

fiscal year 2001 alone. By fiscal year 2001, only two statistically significant 

differences remained—women were significantly more likely to receive 

quality step increases than men and Hispanics were significantly less likely 

to receive quality step increases than African Americans or Whites—which 

shows substantial progress. Table 11 compares the percentage of quality 

step increases to the average percentage representation by EEO group in 

the workforce for the 5-year period.

Table 11: Comparison of the Percentage of Quality Step Increases to the Average 

Percentage Representation by EEO Group in the Region X Workforce for Fiscal 

Years 1997 through 2001 

Source: GAO analysis of Region X data.

a

Total does not sum to 100 percent due to rounding.

According to Region X, honor awards consist of the Commissioner’s 

Citation, which is SSA’s highest honorary award that is granted to 

individuals who have made a superior contribution to SSA; the 

Commissioner’s Team Award, which recognizes groups of employees for 

their team approach in carrying out or supporting SSA’s mission of 

providing quality service in administering national Social Security 

programs; and the Deputy Commissioner’s Citation and the Regional 

EEO group

Total quality step 

increases for 5 

years

Percentage of 

quality step 

increases

Average percentage 

representation in the 

workforce

African American men 8 1.6 2.5

African American 

women

22 4.4 5.3

AIAN men 0 0.0 0.4

AIAN women 2 0.4 1.0

Asian men 11 2.2 1.9

Asian women 22 4.4 4.0

Hispanic men 3 0.6 3.0

Hispanic women 12 2.4 5.4

White men 130 25.7 24.8

White women 295 58.4 51.7

Total 505 100.1a 100.0
Appendix IV

Temporary Promotions, Training, and Awards

Page 52 GAO-03-604 EEO at SSA Region X

Commissioner’s Citation, both of which recognize SSA employees for 

outstanding achievements to SSA. Our analysis showed that for the 5-year 

period, Asians were significantly more likely to receive honor awards than 

Whites, African Americans, and Hispanics. Also, Native Americans were 

significantly more likely to receive honor awards than Hispanics. Table 12 

compares the percentage of honor awards to the average percentage 

representation by EEO group in the workforce for the 5-year period.

Table 12: Comparison of the Percentage of Honor Awards to the Average 

Percentage Representation by EEO Group in the Region X Workforce for Fiscal 

Years 1997 through 2001 

Source: GAO analysis of Region X data.

a

Total does not sum to 100 percent due to rounding.

EEO group

Total honor 

awards for 5 years

Percentage of 

honor awards

Average percentage 

representation in the 

workforce

African American men 2 1.3 2.5

African American 

women

5 3.4 5.3

AIAN men 2 1.3 0.4

AIAN women 2 1.3 1.0

Asian men 4 2.7 1.9

Asian women 11 7.4 4.0

Hispanic men 4 2.7 3.0

Hispanic women 2 1.3 5.4

White men 31 20.8 24.8

White women 86 57.7 51.7

Total 149 99.9a 100.0
Page 53 GAO-03-604 EEO at SSA Region X

Appendix V

Region X Adverse Actions, Appeals of Adverse 

Actions, EEO Complaints, and Grievances ApendxiV

The following sections discuss the adverse actions taken by Region X,1

appeals of such actions filed with the Merit Systems Protection Board 

(MSPB), precomplaint EEO counseling sought, formal EEO complaints 

filed, and grievances filed by Region X employees in fiscal years 1997 

through 2001.

Adverse Actions Region X took 142 adverse actions over the 5-year period.2

 For 

nonprobationary employees, the common pattern of progressive discipline 

is reprimand, short-term suspension (a suspension of 14 days or less), longterm suspension (a suspension of 15 days or more), and removal. 

Probationary employees face terminations.3

 Of the 142 actions, 65, or 

about 46 percent, were for individuals who entered computer databases 

without authorization.4

 

Our statistical analysis showed no significant differences among EEO 

groups for written reprimands. However, we found statistically significant 

differences among races for short-term suspensions and between the sexes 

concerning removals. For short-term suspensions, AIANs and African 

Americans were significantly more likely to receive suspensions of 14 days 

or less than Whites. Men were significantly more likely to experience a 

removal or termination than women. About 14 percent of those who had 

adverse actions taken against them had disabilities compared with the 

representation in the Region’s workforce of about 11 percent. Table 13 

shows the types of adverse actions by EEO group.

1

Eight actions were for performance, not conduct.

2

Because numbers of adverse actions were small in each of the 5 years, we combined all 

actions for the 5-year period.

3

The Region stated that any of these steps may be bypassed if management determines by 

the severe nature of the behavior that a lesser form of discipline would not be appropriate. 

4

Other offenses each accounted for less than 10 percent of all actions and included failure to 

adhere to leave rules or being away without leave and failure to follow standards of 

conduct.
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 54 GAO-03-604 EEO at SSA Region X

Table 13: Types of Adverse Actions in Region X for Fiscal Years 1997 through 2001 by EEO Group

Source: GAO analysis of Region X data.

a

When a probationary employee is discharged or a temporary employee is separated because of 

conduct or performance, the action is characterized as a termination. When a nonprobationary 

employee is discharged, the action is characterized as a removal. Eight other individuals resigned 

when faced with termination or removal—one African American woman, one Hispanic man, three 

White men, and three White women.

Adverse Actions 

Appealed to MSPB

Employees can appeal adverse actions to MSPB.5 Appealable actions 

include removal, reduction in grade or pay, or suspension of 15 days or 

more. Under the negotiated national agreement between SSA and the 

American Federation of Government Employees (AFGE), employees may 

elect to appeal such actions to MSPB or through the negotiated grievance 

procedure but not both. 

Of the 142 adverse actions Region X took from fiscal year 1997 through 

fiscal year 2001, 15 employee appeals were filed with MSPB. Of these 15 

appeals, SSA settled 9; MSPB found that SSA’s action was appropriate in 3 

cases; MSPB dismissed 2 appeals; and 1 is still pending. Table 14 shows the 

EEO group

Written 

reprimand

Suspension Involuntary separationa

Demotion

Total 

Short-term Long-term Termination Removal actions Percent

African American 

men

0 5 1 1 3 0 10 7.0%

African American 

women

4 7 1 1 1 0 14 9.9%

AIAN men 0 0 2 1 0 0 3 2.1%

AIAN women 0 4 0 0 0 0 4 2.8%

Asian men 1 2 0 0 1 0 4 2.8%

Asian women 0 3 1 0 1 0 5 3.5%

Hispanic men 1 4 0 1 1 1 8 5.6%

Hispanic women 3 4 0 3 2 0 12 8.5%

White men 9 12 2 9 5 0 37 26.1%

White women 10 21 5 5 4 0 45 31.7%

Total 28 62 12 21 18 1 142 100.0

5

MSPB’s mission is to ensure that federal employees are protected against abuses by 

executive branch agency management, that agencies make employment decisions according 

to merit systems principles, and that federal merit systems are kept free from prohibited 

personnel practices. 
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 55 GAO-03-604 EEO at SSA Region X

number of Region X employee appeals to MSPB by EEO group and their 

disposition for the 5-year period.

Table 14: Adverse Actions in Region X for Fiscal Years 1997 through 2001 That Were Appealed to MSPB and Their Disposition 

by EEO Group

Source: GAO analysis of Region X data.

Note 1: Settlements include reduced, rescinded, and mitigated agency actions.

Note 2: One employee may have filed more than one appeal. 

a

Affirmed means that an agency’s action was found to be appropriate.

When a federal employee alleges that a removal, reduction in grade or pay, 

or suspension of 15 or more days is discriminatory, the employee may file a 

formal EEO complaint, and because the complaint can be appealed either 

to MSPB or EEOC, the complaint is a “mixed case.” Under EEOC 

regulations, whatever action an employee files first is considered an 

election to proceed in that forum. For example, filing a formal EEO 

complaint constitutes an election to proceed in the EEO forum, although 

contacting an EEO counselor or receiving EEO counseling does not 

constitute such an election. For Region X employees, who are covered by a 

collective bargaining agreement that permits claims of discrimination to be 

raised in a negotiated grievance procedure, they similarly may elect to file 

an EEO complaint or a grievance. Before filing a grievance that alleges 

discrimination, the employee may first discuss the allegation with an EEO 

counselor.

EEO group Appeals filed

Disposition

Settled Affirmeda Dismissed Pending

African American men 2 2

African American women 0

AIAN men 1 1

AIAN women 0

Asian men 0

Asian women 2 2

Hispanic men 0

Hispanic women 2 2

White men 3 2 1

White women 5 3 1 1

Total 15 9 3 2 1
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 56 GAO-03-604 EEO at SSA Region X

Region X EEO 

Precomplaint 

Counseling and Formal 

EEO Complaints Filed

SSA is required to prepare and submit an annual report to EEOC that 

includes the number of individuals counseled, monetary and nonmonetary 

settlements made during the precomplaint counseling phase, the number 

of complaints filed during a reporting period, the bases and issues alleged 

in all complaints filed during a reporting period, and the number and 

amounts of monetary and nonmonetary settlements of closed complaints. 

Precomplaint Counseling We requested data for fiscal years 1997 through 2001 on the number of 

individuals who approached the Region’s Civil Rights and Equal 

Opportunity office to ask for counseling because they felt that they had 

experienced discrimination. The Region provided data for only the last 2 

years because, according to a Region X official, verifiable data were only 

available for fiscal years 2000 and 2001.6

 Table 15 shows the incidents of 

counseling requests for fiscal years 2000 and 2001.

Table 15: Requests for Counseling in Region X and Their Disposition in Fiscal Years 

2000 and 2001

Source: GAO analysis of Region X data.

a

Does not necessarily equate to the number of individuals seeking counseling, because one individual 

may account for more than one request for counseling in each year.

b

Closed includes matters that were resolved with an informal settlement agreement, resolved without 

an informal settlement agreement, and unresolved.

Under EEOC regulations, before filing an EEO complaint, in order to try to 

informally resolve the matter, individuals who believe they have been 

discriminated against on the basis of race, color, religion, sex (including 

equal pay), national origin, age (i.e., 40 or over), or handicapping condition 

6

SSA changed its national reporting mechanism from manual to electronic reporting, and 

beginning in fiscal year 2000, SSA initiated a national database for tracking EEO counseling 

activity. 

Disposition

Fiscal year

Requests for 

counselinga Withdrawn Settled Not pursued Closedb

2000 38 6 2 2 28

2001 35 0 1 11 23

Total 73 6 3 13 51
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 57 GAO-03-604 EEO at SSA Region X

or who have suffered retaliation or reprisal must consult an EEO 

counselor. Table 16 provides the bases cited in fiscal years 2000 and 2001—

the 2 years for which Region X provided data on incidents of EEO 

counseling. 

Table 16: Bases Cited in EEO Counseling for Region X in Fiscal Years 2000 and 2001

Source: GAO analysis of Region X data.

Note: One request for counseling may contain one or more bases.

a

This basis is not covered by the EEOC regulations but is prohibited by Executive Order 13152 (May 2, 

2000).

Table 17 shows the issues cited by individuals who requested EEO 

counseling in fiscal years 2000 and 2001.

Bases

Fiscal years

2000 2001 Total

Race 14 7 21

Color 0 0 0

Religion 0 0 0

Sex 7 12 19

National origin 1 0 1

Age 13 7 20

Disability 17 16 33

Retaliation/reprisal 12 5 17

Parental statusa 0 1 1

Unstated 1 0 1

Total 65 48 113
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 58 GAO-03-604 EEO at SSA Region X

Table 17: Issues Cited by Individuals Requesting Counseling in Region X in Fiscal 

Years 2000 and 2001

Source: GAO analysis of Region X data.

Note: One request for counseling may contain one or more issues.

Employees requesting counseling and Region X entered into three informal 

settlement agreements during counseling requested in fiscal years 2000 

and 2001. The informal settlements agreed to included a lump sum 

payment of $5,000, a letter of recommendation, and a temporary 

promotion under a JEP.

Formal EEO Complaints 

Filed

If employees cannot resolve to their satisfaction the matters for which they 

sought counseling, they file formal complaints with the Office of Civil 

Rights and Equal Opportunity in SSA headquarters in Baltimore. Table 18 

shows the number of formal complaints filed by Region X employees for 

fiscal years 1997 through 2001 and the disposition of those complaints.

Issues

Number of requests for 

counseling citing issue

Assignment of duties 3

Suspension 3

Termination 4

Disparate treatment 3

Duty hours 3

Evaluation/appraisal 2

Harassment (nonsexual) 18

Harassment (sexual) 2

Hostile work environment 2

Promotion/nonselection 21

Retirement (involuntary) 2

Time and attendance/leave 5

Training 3

Reasonable accommodation 7

Working conditions 7

Other 10

Total 95
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 59 GAO-03-604 EEO at SSA Region X

Table 18: Formal EEO Complaints Filed by Region X Employees for Fiscal Years 1997 through 2001 and Their Disposition

Source: GAO analysis of Region X data.

Note: For settlements, a global settlement can address more than one filed EEO discrimination 

complaint, MSPB appeal, or union grievance and may account for more than one individual settlement.

a

Because one individual may have filed more than one EEO complaint, the number filed is not 

necessarily equal to the number of complainants.

b

The EEOC administrative judge hearing the case had a finding of discrimination and offered partial 

relief, which SSA and the complainant are appealing.

Table 19 shows by fiscal year the bases for the 89 EEO complaints filed by 

Region X employees in fiscal years 1997 through 2001.

Fiscal year Fileda

Disposition

Withdrawn Settled Dismissed

Finding of discrimination

No Yes Total closed Pending

1997 10 1 6 1 1 1b 10 0

1998 26 4 9 7 3 0 23 3

1999 23 3 10 4 4 0 21 2

2000 16 4 5 4 1 0 14 2

2001 14 0 2 3 0 0 5 9

Total 89 12 32 19 9 1 73 16
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 60 GAO-03-604 EEO at SSA Region X

Table 19: Bases for EEO Complaints Filed in Region X in Fiscal Years 1997 through 2001

Source: GAO analysis of Region X data.

Note: Because one individual may have filed more than one EEO complaint, the number filed is not 

necessarily equal to the number of complainants, and one EEO complaint may contain one or more 

bases.

Table 20 shows the number of issues cited in the 89 EEO complaints filed 

by Region X employees during fiscal years 1997 through 2001.

Bases

Fiscal years

1997 1998 1999 2000 2001 Total

Race 7 12 10 8 5 42

African American 5 4 8 4 2 23

Asian 1 0 0 1 0 2

Hispanic 1 1 0 0 2 4

Other 0 1 0 0 0 1

White 0 6 2 3 1 12

Color 0 0 0 0 1 1

Religion 0 3 0 0 1 4

Sex 4 25 14 7 3 53

Women 3 14 5 1 2 25

Men 1 11 9 6 1 28

National origin 2 3 7 1 1 14

Age 0 5 7 7 0 19

Handicapping

condition

2 7 11 9 8 37

Mental 1 0 4 3 3 11

Physical 1 7 7 6 5 26

Retaliation/reprisal 4 11 14 8 2 39

Total 19 66 63 40 21 209
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 61 GAO-03-604 EEO at SSA Region X

Table 20: Issues Cited in Complaints Filed for Fiscal Years 1997 through 2001

Source: GAO analysis of Region X data.

Note: One filed complaint may contain one or more issues.

As shown in table 19, the top four bases for which Region X employees 

filed EEO complaints were sex, race, retaliation (i.e., for filing a complaint 

or participating in an investigation of a complaint), and handicapping 

condition. Of those bases that involved handicapping condition, six also 

claimed that they were denied reasonable accommodation. Reasonable 

accommodation includes any modification or adjustment to a job 

application process, the work environment, or the way a job is customarily 

performed that enables a qualified applicant with a disability to compete 

equally or a qualified person with a disability to perform the essential

Issues Number of issues cited in complaints filed

Assignment of duties 5

Awards 8

Reprimand 7

Suspension 8

Termination 4

Duty hours 2

Evaluation/appraisal 2

Harassment (nonsexual) 30

Harassment (sexual) 2

Hostile work environment 4

Pay including overtime 3

Promotion/nonselection 29

Reasonable accommodation 16

Retirement (involuntary) 1

Time & attendance 11

Training 3

Working conditions 19

Other 4

Total 158
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 62 GAO-03-604 EEO at SSA Region X

functions of the position or enjoy equal benefits and privileges of 

employment.7

 

As shown in table 20, the top four issues cited in the filed complaints were 

harassment (nonsexual), nonselection for promotion, working conditions, 

and reasonable accommodation.

The reasonable accommodation process begins when an individual makes 

a request for the accommodation, followed by a request in writing 

(completion of a form) or in electronic format. Among the items that can 

be approved of as an accommodation at the regional level are requests of 

office equipment costing less than $100, a change in schedule, and requests 

for reassignment. For office equipment or assistive technologies (e.g., 

computer hardware or software that enable people with disabilities to 

perform the essential functions of their job) costing $100 or more, assistive 

technologies training, and sign language interpreter services, a request 

must be forwarded to the Disability Services Team in the Office of Civil 

Rights and Equal Opportunity in SSA headquarters in Baltimore. Table 21 

shows the number of accommodations requested by Region X employees 

for fiscal year 1997 through 2001 and their disposition.

7

The accommodation must be job related and not items already required for personal use 

(e.g., hearing aids, prosthetic devices, wheelchairs, and transportation to work). 

Reasonable accommodation is determined on a case-by-case basis, taking into consideration 

the individual’s specific disability and existing limitations to the performance of a job 

function, the essential duties of the job, the work environment, and the feasibility of the 

proposed accommodation. 
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 63 GAO-03-604 EEO at SSA Region X

Table 21: Reasonable Accommodations Requested by Region X Employees for Fiscal Years 1997 through 2001 by EEO Group

Source: GAO analysis of Region X data.

Note: Multiple categories may be recorded for a single request for accommodation. For example, in 

one case, an accommodation may be denied. In another case, a request may be forwarded to the 

Disability Services Team, which may deny the requested accommodation and approve an alternative 

accommodation. We counted each category of accommodation; therefore, one person may have 

multiple results to his or her request.

a

For three requested accommodations that were forwarded to the Disability Services Team, there is no 

record of the Disability Services Team’s decision.

Grievances Under the negotiated national agreement between SSA and the AFGE, 

individual employees or their union representatives may file Section 9 

grievances on such matters as adverse actions or EEO issues.8

 At any time 

after the Section 9 grievance is filed, up to the time the grievance decision 

is issued, the grievance may be withdrawn. If a management official finds 

that the grievance has merit, or can agree with the 

employee/representative on some or all of the points at issue, he or she 

may grant full or partial relief, giving the employee all or a portion of what 

was requested.9

 If the management official does not find a violation of the 

negotiated agreement or workplace policy or practice, or cannot agree to 

EEO group Requested

Accommodation Disability Services Team

Withdrawn Approved Denied Alternate Forwarded Approved Denied Alternate

African 

American men

6 0 0 2 1 3 3 0 0

African 

American 

women

7 0 4 3 0 1 1 0 0

Hispanic 

women

4 1 1 0 0 3 2 1 0

White men 23 0 9 6 4 4 2 0 1

White women 45 5 18 4 4 19 7 10 0

Total 85 6 32 15 9 30a 15 11 1

8

Such grievances are filed in accordance with Article 24, Section 9 of the SSA/AFGE 

National Agreement. In addition, the union as an institution may file grievances against a 

particular level of management in accordance with Article 24, Section 10 of the SSA/AFGE 

National Agreement; such grievances are not discussed in this report.

9

Occasionally, management may offer something other than what was requested, which 

satisfies the employee/representative, and the grievance is resolved.
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 64 GAO-03-604 EEO at SSA Region X

the requested relief, the grievance is denied. Unresolved Section 9 

grievances may be advanced to arbitration by the union. Multiple 

categories may be recorded for a single grievance. For example, in one 

case, a grievance may be denied, and the grievant takes no additional 

action. In another case, a grievance may be denied, and the 

grievant/representative invokes arbitration, and then does or does not 

pursue the case. We counted each category of relief or arbitration for each 

grievance. Table 22 shows the Section 9 grievances filed in Region X for 

fiscal years 1997 through 2001.

Table 22: Section 9 Grievances Filed in Region X by EEO Group for Fiscal Years 1997 through 2001

Source: GAO analysis of Region X data.

Note 1: One individual may have filed more than one grievance.

Note 2: Multiple categories may be recorded for a single grievance. For example, in one case, a 

grievance may be denied, and the grievant takes no additional action. In another case, a grievance 

may be denied, and the grievant/representative invokes arbitration, and then does or does not pursue 

the case. We counted each category of relief or arbitration, when appropriate, for each grievance; 

therefore, one person may have multiple categories to his or her grievance.

a

Two grievances were found not grievable, so they were only counted as filed.

b

Withdrawn includes five grievances that were withdrawn after arbitration was invoked.

Settlements Twenty-one settlement agreements were signed by SSA and the individuals 

who appealed an adverse action, filed an EEO complaint, or filed a 

EEO group

Grievances 

fileda Withdrawnb

Relief Arbitration

Granted Partial Denied Invoked

Not 

pursued Awarded

Settlement

reached

African American 

men

16 2 2 0 13 8 1 3 3

African American 

women

24 8 7 4 6 2 1 0 0

AIAN men 2 1 0 0 1 1 1 0 0

AIAN women 3 0 0 1 2 0 0 0 0

Asian men 1 0 0 0 1 0 0 0 0

Asian women 5 0 1 0 4 0 0 0 0

Hispanic men 6 2 2 0 3 3 1 0 1

Hispanic women 12 3 1 1 7 3 2 0 1

White men 57 17 7 6 28 5 2 1 1

White women 134 20 36 11 66 10 8 0 0

Total 260 53 56 23 131 32 16 4 6
Appendix V

Region X Adverse Actions, Appeals of 

Adverse Actions, EEO Complaints, and 

Grievances 

Page 65 GAO-03-604 EEO at SSA Region X

grievance. These agreements could consist of monetary or nonmonetary 

terms or both, and five consisted entirely of nonmonetary terms.10 A global 

settlement addressed more than one filed EEO discrimination complaint, 

MSPB appeal, or union grievance; therefore, the number of complaints 

settled is higher than the number of settlement agreements.11 Table 23 

contains information on settlement agreements for appealed adverse 

actions, filed EEO complaints, and a mixed case that includes a union 

grievance for fiscal years 1997 through 2001. 

Table 23: Number of Settlement Agreements and Amounts Awarded on Settlements 

for MSPB Appeals, EEO Complaints, and a Mixed Case Filed in Region X in Fiscal 

Years 1997 through 2001

Source: GAO analysis of Region X data.

Note: A global settlement can address more than one filed EEO discrimination complaint, MSPB 

appeal, or union grievance; therefore, the number of complaints settled may be higher than the 

number of settlement agreements.

a

The number of settlement agreements includes five that had only nonmonetary terms. Settlement 

agreements do not constitute an admission of any wrongdoing, harassment, discrimination, and/or 

violation of law, statute, or regulation. 

10The terms of the five nonmonetary settlements agreed to for complaints filed in fiscal 

years 1997 through 2001 included rescinded terminations, removals, or suspensions; 

restoration or credit for sick and annual leave; lateral reassignment or promotion; and a 

handwritten apology. 

11For EEO complaints alone, 32 complaints filed in fiscal years 1997 through 2001 were 

settled (as shown in table 18).

Fiscal year settled

Number of settlement 

agreementsa Amount

1999 2 $17,820.00

2000 4 11,163.91

2001 2 8,337.86

2002 11 143,831.66

2003 2 20,000

Total 21 $201,153.43
Page 66 GAO-03-604 EEO at SSA Region X

Appendix VI

Selected Results of GAO’s Survey of Region X 

Employees on Equal Employment 

Opportunity ApendxiVI

In our survey of Region X employees about EEO, we asked all Region X 

employees for their views (1) on the operations of Region X’s Civil Rights 

and Equal Opportunity (CREO) office and (2) about their experiences with 

situations involving EEO in Region X within the past 2 years. Because we 

received more than a 70 percent response rate (75 percent), our results are 

representative of the views and attitudes of Region X employees.1

Operations of Region 

X’s CREO

Almost 60 percent of respondents were either generally or very familiar 

with the responsibilities of the CREO office before reading our description 

of those responsibilities. In addition, most Region X employees are 

familiar with the EEO process. About two-thirds of respondents reported 

having received or having seen within the last 2 years written materials 

about the federal government’s EEO regulations and written materials 

describing how to contact regional EEO counselors. 

When asked about their willingness, if they believed that they had been 

discriminated against, to either contact Region X’s CREO to participate in 

counseling or to contact the Office of Civil Rights and Equal Opportunity 

(OCREO) in Baltimore to file a formal EEO complaint, almost half of 

respondents indicated that they would be generally or very willing to 

participate in counseling or to file a formal EEO complaint. Also, 3 percent 

of respondents indicated that they had contacted CREO to participate in 

counseling in the last 2 years, and 2 percent of respondents indicated that 

they had contacted OCREO in Baltimore to file a formal complaint during 

that time. 

About 40 percent of respondents indicated that they were unwilling or 

uncertain to participate in counseling or to file a formal EEO complaint if 

they believed that they had been discriminated against; we did an analysis 

of their responses to identify the reason for this unwillingness or 

uncertainty. About 55 percent of the respondents indicated that they were 

unwilling or uncertain to participate in counseling and 51 percent to file a 

formal EEO complaint if they believed that they had been discriminated 

against because they feared retaliation. 

1

The percentage of respondents by race/ethnicity closely mirrored the percentage of each 

race/ethnicity in the population of Region X employees. The percentage of men and women 

responding to the survey also matched their respective percentages in the Region X 

workforce.
Appendix VI

Selected Results of GAO’s Survey of Region X 

Employees on Equal Employment 

Opportunity

Page 67 GAO-03-604 EEO at SSA Region X

We did a further analysis of those respondents who indicated that they 

were unwilling or uncertain to participate in counseling if they believed 

that they had been discriminated against because they feared retaliation. 

Table 24 shows the breakdown of respondents by race/ethnicity and sex of 

those who indicated an unwillingness or uncertainty to participate in 

counseling. Table 25 shows the breakdown of respondents by 

race/ethnicity and sex of those who indicated an unwillingness or 

uncertainty to file a formal complaint.

Table 24: Minority Status and Sex of Respondents Who Were Unwilling or Uncertain 

to Participate in Counseling Because They Feared Retaliation

Source: GAO’s survey of Region X employees about EEO.

Table 25: Minority Status and Sex of Respondents Who Were Unwilling or Uncertain 

to File a Formal Complaint Because They Feared Retaliation

Source: GAO’s survey of Region X employees about EEO.

Other reasons respondents indicated for being unwilling or uncertain to 

participate in counseling if they believed that they had been discriminated 

against included the concern that their contact with the EEO counselor 

would not be kept confidential (about 45 percent) and the concern that the 

matter, if resolved informally, would not result in a mutually satisfactory 

solution for all parties concerned (about 34 percent). Other reasons 

respondents indicated for being unwilling or uncertain to file a formal 

Race/ethnicity Percentage of respondents who feared retaliation

Nonminority 73

Minority 27

Sex

Men 29

Women 71

Race/ethnicity Percentage of respondents who feared retaliation

Nonminority 77

Minority 23

Sex

Men 28

Women 72
Appendix VI

Selected Results of GAO’s Survey of Region X 

Employees on Equal Employment 

Opportunity

Page 68 GAO-03-604 EEO at SSA Region X

complaint if they believed that they had been discriminated against 

included the concern that their complaint would not be handled in a fair 

manner (about 33 percent).

Experiences with 

Situations Involving 

EEO in Region X

As shown in table 26, most Region X employees responding to our survey 

indicated that they believed decisions concerning job or project 

assignments, training, formal ratings, and monetary awards were always 

or mostly based on merit and free of bias and favoritism. About half of the 

respondents indicated that they believed that decisions concerning 

nonmonetary awards and recognition were always or mostly based on 

merit and free of bias and favoritism. Less than half of the respondents 

indicated that they believed decisions concerning promotion and career 

advancement were always or mostly based on merit and free of bias and 

favoritism.

Table 26: Percentage of Respondents Indicating Whether Decisions Were Based on 

Merit and Free of Bias and Favoritism

Source: GAO’s survey of Region X employees about EEO.

Table 27 shows, by sex and minority status, those respondents who 

indicated that they believed such personnel or pay decisions were 

sometimes or never or almost never based on merit and free of bias and 

favoritism. 

Type of personnel or pay 

decision

Percentage of respondents indicating decisions 

were 

Always or mostly based on 

merit and free of bias and 

favoritism

Sometimes or never or 

almost never based on 

merit and free of bias 

and favoritism

Job or project assignments 61 18

Training 68 12

Formal performance 

appraisals/ratings

74 11

Monetary awards and bonuses 61 21

Promotion and career 

advancement

44 21

Nonmonetary awards and 

recognition

50 22
Appendix VI

Selected Results of GAO’s Survey of Region X 

Employees on Equal Employment 

Opportunity

Page 69 GAO-03-604 EEO at SSA Region X

Table 27: Percentage of Respondents Indicating Decisions Were Sometimes or 

Never Based on Merit and Free of Bias and Favoritism 

Source: GAO’s survey of Region X employees about EEO.

Narrative Comments The questionnaire offered respondents the option of providing additional 

comments relating to any of the items discussed therein. Of the 1,355 

useable returned questionnaires (see app. I), 307 respondents, or 22.7 

percent, provided narrative comments. In descending order, these 

comments most frequently concerned

• perceived inequities in merit hiring, promotions, and awards (30.3 

percent);

• complaints of perceived discrimination or other negative personal 

experiences (21.5 percent); or

• disgruntlement over affirmative action and workforce diversity (9.4 

percent).

Type of personnel or pay decision Men Women Nonminority Minority

Job or project assignments 7 11 13 6

Training 5 8 8 4

Formal performance 

appraisals/ratings

4 6 7 3

Monetary awards and bonuses 8 14 15 6

Promotion and career advancement 9 13 16 6

Nonmonetary awards and recognition 8 15 17 6
Page 70 GAO-03-604 EEO at SSA Region X

Appendix VII

GAO Survey of Region X Employees about 

EEO ApendxiVI

United States General Accounting Office 

Survey of SSA Region X Employees About 

Equal Employment Opportunity 

Introduction 

The U.S. General Accounting Office (GAO), an independent agency of Congress, is reviewing 

equal employment opportunity (EEO) issues and the EEO complaint process at SSA Region X at 

the request of Representatives Jim McDermott, Jennifer Dunn, and Adam Smith. As part of this 

review, we are surveying all SSA Region X employees to get their views on the operations of 

SSA Region X’s Civil Rights and Equal Opportunity (CREO) Office and their experiences 

concerning EEO. 

Your responses will help GAO understand how SSA Region X employees view the Region’s 

EEO operations and their work environment. Responses will be discussed in summary form in a 

report to congressional requesters and will not include any information that could be used to 

identify individual respondents. The survey is numbered only to allow us to send follow-up 

surveys to people who do not respond the first time and will not be used to identify you with your 

response. The link between you and your response will be destroyed before the report is issued, 

and your individual responses will not be shared with SSA. 

The survey should take about 20 to 30 minutes to complete. Space has been provided at the end 

of the survey for any comments you may want to make. Additional pages may be added if 

necessary. 

Please complete and return the survey in the pre-addressed envelope within 5 working days to 

avoid costly follow-up efforts. Because of delays in mail delivery in the Washington, D.C. area, 

please send the survey to our Norfolk Office in the event the envelope is misplaced. 

 U.S. General Accounting Office 

 Norfolk Office 

5029 Corporate Woods Drive 

Suite 300 

Virginia Beach, VA 23462 

Attention: Ms. Kiki Theodoropoulos 

 SSA Region X Survey 

If you have any questions, please contact Kiki Theodoropoulos on (202) 512-4579 or at 

theodoropoulosv@gao.gov.

Thank you for your time and cooperation. 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 71 GAO-03-604 EEO at SSA Region X

SECTION I—Civil Rights and Equal Opportunity (CREO) Office 

The CREO office manages the Region’s equal employment opportunity (EEO), affirmative action, and complaint 

programs. Among other things, it is responsible for disseminating information on the agency’s EEO program and 

complaint process, developing EEO and affirmative action plans, and processing and resolving discrimination 

complaints. 

The following questions ask for your views on the operations of SSA Region X’s CREO. Please mark your answers 

with an “X” --- _

1. Before reading the description of the responsibilities of SSA Region X’s CREO at the beginning of this section, 

how familiar or unfamiliar were you with these responsibilities? (Mark only one response)

1.  Very familiar 15% (196) 

2.  Generally familiar 44% (751) 

3.  As familiar as unfamiliar 15% (944) 

4.  Generally unfamiliar 15% (1130) 

5.  Very unfamiliar 11% (1,269) 

2. At any time within the past 2 years, do you recall receiving the following materials or seeing them posted at 

SSA Region X? (Mark all that apply)

I received 

this

information 

I saw this 

information 

posted

I neither 

received

nor saw this 

information 

posted

I don’t remember 

whether I received 

or saw this 

information posted 

Total

Respondents

a. Written materials about the federal 

government’s EEO regulations. 

← 65% (852) Æ 8% (105) 27% (354) 1,311 

b. Written materials that describe SSA 

Region X’s EEO program. 

Å 59% (768) Æ 10% (134) 31% (405) 1,307 

c. Written materials describing how to 

contact SSA Region X’s EEO 

counselors, such as their names, 

locations, and telephone numbers. 

Å 63% (823) Æ 12% (157) 25% (330) 1,310 

d. Notices, memoranda, or newsletters 

that communicate SSA Region X’s 

EEO complaint policy.

Å 51% (668) Æ 15% (194) 34% (440) 1,302 

e. Notices, memoranda, or newsletters 

that communicate SSA Region X’s 

sexual harassment policy.

Å 79% (1040) Æ 6% (77) 15% (199) 1,316 

f. Notices, memoranda, or newsletters 

that communicate SSA Region X’s 

reasonable accommodation policy.

Å 48% (627) Æ 17% (223) 35% (456) 1,306 

g. Other materials (Please specify): Å 27% (46) Æ 12% (21) 61% (104) 171 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 72 GAO-03-604 EEO at SSA Region X

3. If you believed that you had been discriminated 

against, how willing or unwilling would you be to 

contact SSA Region X’s CREO to participate in 

counseling? (Mark only one)

1.  Very willing→Skip to question 5 24% (317) 

2.  Generally willing→ Skip to ques 5 27% (352)

3.  As willing as unwilling 13% (178) 

4.  Generally unwilling 18% (234) 

5.  Very unwilling 9% (115) 

--------------------------------------- 

6.  Uncertain 10% (127) 

4. If you were uncertain or unwilling to participate in 

counseling, which of the following describes your 

reason(s)? (Mark all that apply)

1.  I would be concerned that my 274 

 contact with the EEO counselor 

 during the counseling session 

 would not be kept confidential. 

2.  I would be concerned that I would 152 

be assigned to an EEO counselor 

 who was not competent or 

 well trained. 

3.  I would be concerned that the 167 

matter would not be resolved in a 

 timely manner. 

4.  I would be concerned that too 210 

much of my time would be 

 consumer in the complaint process. 

5.  I would be concerned that the 227 

matter, if resolved informally, 

 would not result in a mutually 

 satisfactory solution for all parties 

 involved 

6.  I would be concerned that I would 194 

be alienated from my coworkers. 

7.  I would fear retaliation. 345 

8.  I would not be willing to 96 

participate for personal reasons. 

9.  Other – Please specify: 97 

 _____________________________________ 

 _____________________________________ 

5. Within the past 2 years, have you contacted SSA 

Region X’s CREO to participate in counseling?

1.  Yes 3% (41) 

2.  No 97% (1,283) 

6. If you believed that you had been discriminated 

against and the matter had not been resolved in 

counseling, how willing or unwilling would you be 

to contact SSA OCREO in Baltimore to file a 

formal discrimination complaint? (Mark only one)

1.  Very willing→ Skip to question 8 20% (263) 

2.  Generally willing→ Skip to ques 8 26% (345) 

3.  As willing as unwilling 12% (163) 

4.  Generally unwilling 19% (249) 

5.  Very unwilling 12% (154) 

--------------------------------------- 

6.  Uncertain 11% (145) 

7. If you were uncertain or unwilling to file a formal 

discrimination complaint, which of the following 

describes your reason(s)? (Mark all that apply)

1.  I would be concerned that my 149 

complaint would not be investigated 

 in a competent manner. 

2.  I would be concerned that my 198 

complaint would not be thoroughly 

 investigated. 

3.  I would be concerned that my 233 

complaint would not be handled in 

 a fair manner. 

4.  I would be concerned that my 159 

complaint would not be handled 

 in a timely manner. 

5.  I would be concerned that too 218 

much of my time would be 

 consumed in the complaint process. 

6.  I would be concerned that I would 184 

be alienated from my coworkers. 

7.  I would fear retaliation. 346 

8.  I would not be willing to file a 122 

formal complaint for personal reasons. 

9.  Other – Please specify: 90 

 _____________________________________ 

 _____________________________________ 

8. Within the past 2 years, have you contacted SSA 

OCREO in Baltimore to file a formal 

discrimination complaint?

1.  Yes 2% (21) 

2.  No 98% (1,304) 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 73 GAO-03-604 EEO at SSA Region X

SECTION II—Your EEO Experiences 

The following questions ask for your views about your experiences about situations involving EEO in SSA Region 

X within the past 2 years.

9. Within the past 2 years, how much of the time, if any, have decisions about you in each of the following areas 

been based on merit and free of bias and favoritism. (Mark only one box in each row)

Almost 

always 

(1) 

Most of the 

time 

(2)

As often as 

not

(3)

Some of the 

time 

(4)

Never or 

almost never 

(5)

Does not 

apply

(6)

a. Job or project 

assignments 

44% (581) 17% (224) 6% (83) 9% (114) 10% (131) 14% (191) 

b. Training 51% (665) 17% (222) 6% (85) 6% (80) 6% (83) 14% (180) 

c. Formal performance 

appraisals/ratings 

56% (732) 18% (243) 6% (76) 5% (62) 6% (77) 10% (127) 

d. Monetary awards and 

bonuses

45% (588) 16% (218) 7% (90) 11% (151) 10% (128) 11% (145) 

e. Promotion and career 

advancement 

34% (443) 10% (129) 7% (93) 8% (107) 13% (177) 28% (365) 

f. Non-monetary awards 

and recognition 

37% (487) 13% (172) 8% (101) 9% (123) 13% (172) 20% (257) 

g. Other (Please specify)

__________________ 

__________________ 

15% (14) 6% (6) 3% (3) 3% (3) 23% (22) 50% (48) 

10. Within the past 2 years, do you feel you have been denied a job, promotion, or other job benefit because of 

unlawful discrimination based on any of the following characteristics? (Mark only one box in each row)

Yes

(1)

No

(2)

Don’t know/ 

Can’t judge 

(3)

a. Age 8% (111) 76% (1,009) 16% (209) 

b. Sex 8% (100) 77% (1,018) 15% (197) 

c. Handicapping condition 4% (48) 80% (1,050) 16% (209) 

d. Marital status 2% (21) 86% (1,125) 13% (166) 

e. National origin 5% (66) 82% (1,075) 13% (172) 

f. Political affiliation 1% (19) 85% (1,108) 15% (182) 

g. Race 10% (137) 75% (988) 15% (200) 

h. Religion 2% (21) 84% (1,099) 14% (183) 

i. Other (Please specify)

_____________________ 

_____________________ 

50% (84) 33% (55) 17% (29) 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 74 GAO-03-604 EEO at SSA Region X

11. Within the past 2 years, do you feel you have experienced any of the following? (Mark only one box in each row)

Yes

(1)

No

(2)

Don’t know/ 

Can’t judge 

(3)

a. Deliberately misled by an agency official about your right to 

compete for a job or promotion 

 9% (115) 80% (1077) 11% (149) 

b. Influenced by an agency official to withdraw from competition 

for a federal job or promotion to help another person’s chances 

for getting that job or promotion 

 2% (29) 89% (1186) 9% (123) 

c. Denied a job or promotion because one of the selecting or 

recommending officials gave an unlawful advantage to another 

applicant 

10% (139) 73% (976) 17% (228) 

d. Denied a job or promotion that went instead to a relative of one 

of the selecting officials 

 2% (27) 83% (1,099) 15% (205) 

12. Within the past 2 years, did you choose not to apply for any promotion or developmental opportunity because 

you felt you had little or no chance of being selected? (Mark only one box in each row)

Yes

(1) 

No

(2)

Don’t know/ 

Can’t judge 

(3)

a. Because of your age 11% (145) 81% (1,078) 8% (106) 

b. Because of your sex 6% (85) 86% (1,128) 8% (104) 

c. Because of your handicapping condition 4% (51) 86% (1,128) 10% (136) 

d. Because of your marital status 2% (24) 91% (1,193) 8% (99) 

e. Because of your national origin 4% (59) 88% (1,155) 8% (99) 

f. Because of your political affiliation 1% (16) 91% (1,191) 8% (107) 

g. Because of your race 10% (134) 82% (1,084) 8% (106) 

h. Because of your religion 1% (11) 91% (1,183) 9% (111) 

i. Other (Please specify)

 ________________________________________________ 

58% (108) 31% (58) 10% (19) 

13. Within the past 2 years, do you feel that you have been retaliated against or threatened with retaliation by 

management for doing any of the following? (Mark only one box in each row) If no to all, go to question 18.

Yes

(1) 

No

(2) 

Don’t know/ 

Can’t judge 

(3) 

a. Making disclosures concerning health and safety dangers; 

unlawful behavior; and/or fraud, waste, and abuse 

5% (67) 88% (1,149) 7% (96) 

b. Exercising any appeal, complaint, or grievance right 8% (110) 84% (1,100) 8% (105) 

c. Testifying for or otherwise assisting any individual in the 

exercise of whistleblowing, equal employment opportunity, or 

appeal rights 

4% (51) 87% (1,146) 9% (115) 

d. Refusing to obey an unlawful order 2% (29) 90% (1,168) 8% (107) 

e. Reporting unwanted sexual attention or sexual harassment 1% (13) 91% (1,191) 8% (101) 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 75 GAO-03-604 EEO at SSA Region X

I was threatened 

with 

(1) 

This was done 

to me 

(2) 

Does not apply 

(3) 

a. Poor performance appraisal 21 20 196 

b. Denial of promotion 18 41 182 

c. Denial of opportunity for training 6 41 189 

d. Denial of award 9 69 162 

e. Assignment to less desirable or less important 

duties

9 37 193 

f. Transfer or assignment to a job with less 

desirable duties or working conditions 

10 18 206 

g. Assignment to a different geographical location 2 10 222 

h. Suspension from my job 11 8 217 

i. Fired from my job 12 4 222 

j. Grade level demotion 3 7 221 

k. Shunned by coworkers or managers 14 80 153 

l. Verbal harassment or intimidation 22 83 138 

m. Required to take a fitness-for-duty exam 1 7 223 

n. Other (Please specify)

_________________________________ 

_________________________________ 

6 20 18 

15. In response to retaliation or threat of retaliation, did you take any of the following actions? (Mark all that apply)

 1.  I took no action (Go to question 17) 104 

 2.  Complained to a higher level of agency management 46 

 3.  Complained to the Office of Inspector General within my agency 2 

 4.  Complained to some other office within my agency (e.g., the personnel office or CREO office) 14 

 5.  Filed a complaint through my union representative 49 

 6.  Filed a formal grievance within my agency 18 

 7.  Filed an EEO (discrimination) complaint 18 

 8.  Filed a complaint with the Office of Special Counsel 3 

 9.  Filed an action with the Merit Systems Protection Board 3 

10.  I took an action that has not been specified (Please specify) 37

 __________________________________________________________________________________________ 

 __________________________________________________________________________________________ 

16. What happened to you as a result of your reporting retaliation or threat of retaliation? (Mark all that apply)

1.  It got me into more trouble 27 

2.  It made no difference 39 

3.  The action of retaliation was withdrawn 5 

4.  The threat of retaliation was withdrawn 9 

5.  Actions were taken to compensate me for the action of retaliation 5 

6.  Decision concerning the action of retaliation is still pending 22 

7.  Other (Please specify): 33 

 __________________________________________________________________________________________ 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 76 GAO-03-604 EEO at SSA Region X

17. If you took no action in response to retaliation or threat of retaliation, why did you choose not to take any 

formal action? (Mark all that apply)

 1.  Not applicable, I took action 18 

 2.  Still might take some action 6 

 3.  Not serious enough 14 

 4.  Didn’t know I could 7 

 5.  Process wouldn’t solve the problem 50 

 6.  Fear of management retaliation 71 

 7.  Problem was solved informally 2 

 8.  Waited too long/missed deadline 4 

 9.  Too complicated 8 

10.  Too expensive 3 

11.  Process isn’t fair 23 

12.  I left the work unit 8 

13.  Don’t know/can’t judge 15 

14.  Other (Please specify) 31

 __________________________________________________________________________________________ 

 __________________________________________________________________________________________ 

III. Demographic Questions 

Please answer the following questions to help us analyze the results of the survey. 

18. How many years have you been in your current 

position at SSA Region X?

1.  Less than 1 year 11% (153) 

2.  1 to less than 3 years 29% (390) 

3.  3 to less than 10 years 30% (406) 

4.  10 or more years 29% (396) 

19. Are you currently a supervisor or non-supervisor?

1.  Supervisor 9% (123) 

2.  Non-supervisor 91% (1,212) 

20. Please indicate your current grade. 

 1.  GS-4 1% (7) 

 2.  GS-5 4% (55) 

 3.  GS-6 4% (55) 

 4.  GS-7 5% (72) 

 5.  GS-8 29% (391) 

 6.  GS-9 6% (76) 

 7.  GS-10 <1% (2) 

 8.  GS-11 29% (392) 

 9.  GS-12 12% (164) 

10.  GS-13 6% (86) 

11.  GS-14 2% (28) 

12.  GS-15 1% (9) 

13.  SES or Executive <1% (2) 

14.  Other <1% (6) 

21. How many years have you been employed with 

SSA Region X?

1.  Less than 1 year 6% (80) 

2.  1 to less than 5 years 26% (352) 

3.  5 to less than 10 years 18% (240) 

4.  10 or more years 50% (671) 

22. Please identify your office:

Name: _______________________________ 

 City: _______________________________ 

 State: _______________________________ 

23. Please indicate your sex.

1.  Male 33% (444) 

2.  Female 67% (889) 

24. Are you of Hispanic origin?

1.  Yes 11% (140) 

2.  No 89% (1,188) 

25. Please indicate your race. (Mark only one)

1.  American Indian/Alaska Native 1% (14) 

2.  African American/Black 8% (103) 

3.  Asian/Pacific Islander 8% (105) 

4.  White 74% (950) 

5.  Other (Please specify) 8% (104) 
Appendix VII

GAO Survey of Region X Employees about 

EEO

Page 77 GAO-03-604 EEO at SSA Region X

If you have any comments relating to any of the items discussed in this questionnaire, please write them here.

23% (307)
Page 78 GAO-03-604 EEO at SSA Region X

Appendix VIII

Comments from the Social Secuity 

Administration ApendxiVI
Appendix VIII

Comments from the Social Secuity 

Administration

Page 79 GAO-03-604 EEO at SSA Region X
Appendix VIII

Comments from the Social Secuity 

Administration

Page 80 GAO-03-604 EEO at SSA Region X
Appendix VIII

Comments from the Social Secuity 

Administration

Page 81 GAO-03-604 EEO at SSA Region X
Appendix VIII

Comments from the Social Secuity 

Administration

Page 82 GAO-03-604 EEO at SSA Region X
Appendix VIII

Comments from the Social Secuity 

Administration

Page 83 GAO-03-604 EEO at SSA Region X
Page 84 GAO-03-604 EEO at SSA Region X

Appendix IX

GAO Contact and Staff Acknowledgments ApendxiIX

GAO Contact Victor S. Rezendes, (202) 512-6806

Acknowledgments In addition to the individual named above, Thomas G. Dowdal, Karin K. 

Fangman, Nathan Morris, Terry Richardson, Kiki Theodoropoulos, Michael 

R. Volpe, and Gregory H. Wilmoth made key contributions to this report.

(450090)
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