EQUAL

EMPLOYMENT

OPPORTUNITY

The Postal Service

Needs to Better

Ensure the Quality of

EEO Complaint Data

United States General Accounting Office

GAO Report to the Postmaster General of the

United States

September 1999

GAO/GGD-99-167

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

B-283618

September 28, 1999

William J. Henderson

Postmaster General

U.S. Postal Service

Dear Mr. Henderson:

During the course of our work examining trends in federal employees’

discrimination complaints, we analyzed equal employment opportunity

(EEO) complaint data that the Postal Service and other federal agencies

reported to the Equal Employment Opportunity Commission (EEOC).1

 The

purpose of this report is to bring to your attention certain discrepancies in

the complaint data that the Postal Service reported and the need for the

Service to take additional steps to ensure that such data are complete,

accurate, and reliable.

In our limited analyses of the data the Postal Service reported to EEOC,

we found errors in statistics on the underlying bases for EEO complaints

and on the length of time complaints had been in inventory. We also found

that required data on the issues raised in complaints were not completely

reported. These discrepancies were generally linked to statistical reports

generated by the Service’s automated complaint information system. After

we brought these discrepancies to the attention of Postal Service staff,

they promptly corrected them and appeared to correct the underlying

causes for the errors, with one exception. That situation need not be

resolved until EEOC revises its reporting form.

Because we examined only a limited portion of the reported data for

obvious discrepancies and because the errors we identified were related to

data generated by an automated complaint information system put in place

in 1995, we have concerns about the completeness, accuracy, and

reliability of the data that we did not examine. Therefore, we are

recommending that the Postal Service review its controls over the

recording and reporting of the data that it submits to EEOC.

 1

Equal Employment Opportunity: Rising Trends in EEO Complaint Caseloads in the Federal Sector

(GAO/GGD-98-157BR, July 24, 1998) and Equal Employment Opportunity: Data Shortcomings Hinder

Assessment of Conflicts in the Federal Workplace (GAO/GGD-99-75, May 4, 1999).

Results in Brief
B-283618

Page 2 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

Federal regulations and EEOC policy require federal agencies to report

certain EEO complaint-related data annually to EEOC. Agencies report

these data on EEOC form 462, Annual Federal Equal Employment

Opportunity Statistical Report of Discrimination Complaints. EEOC

compiles the data from the agencies for publication in the annual Federal

Sector Report on EEO Complaints Processing and Appeals. According to

EEOC Management Directive 110, agencies should make every effort to

ensure accurate recordkeeping and reporting of these data. In our recent

report, we said that reliable data are important to program managers,

decisionmakers, and EEOC in identifying the nature and extent of

workplace conflicts.2

We analyzed the data contained in EEOC’s annual federal sector reports to

prepare our reports dealing with employment discrimination complaint

trends. Because the Postal Service accounts for a large share of complaints

filed by federal employees with their agencies, we analyzed forms 462

submitted by the Service for fiscal year 1991 through fiscal year 1998, as

well as other complaint data provided at our request.3

 Because our studies

generally focused on trends in the number and age of unresolved

complaints in inventory, the number of complaints filed, the bases and

issues cited in complaints, and complaint processing times, we did not

examine the full scope of data reported on form 462. Although we did not

examine the Service’s controls for ensuring accurate recordkeeping and

reporting or validate the data the Service reported, we examined the data

for obvious inconsistencies or irregularities.

We requested comments on a draft of this report from the Postmaster

General. The Postal Service’s oral comments are discussed near the end of

this letter. We performed our work in July and August 1999 in accordance

with generally accepted government auditing standards.

The most significant error that we identified in Postal Service data

involved the number of race-based complaints filed by white postal

workers. EEOC requires agencies to report the bases (e.g., race, sex,

disability) for complaints that employees file. For fiscal year 1996, the

Postal Service had reported that 9,044 (about 68 percent) of the 13,252

complaints filed contained allegations by white postal workers of race

discrimination. For fiscal year 1997, the Service had reported that 10,040

(70 percent) of the 14,326 complaints filed contained such allegations.

 2

GAO/GGD-99-75, May 4, 1999.

3

In fiscal year 1998, postal workers accounted for about half of the discrimination complaints filed by

federal employees.

Background

Scope and

Methodology

Discrepancies in the

Postal Service’s EEO

Complaint Data
B-283618

Page 3 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

These figures represented significant increases over the figures reported

for previous fiscal years. For example, in fiscal year 1995, the Service

reported to EEOC that 1,534 of the complaints filed contained allegations

by white postal workers of race discrimination. In fiscal year 1994, the

figure reported was 2,688.

We questioned Postal Service officials about the sudden increase in the

number of complaints containing allegations by white postal workers of

race discrimination. The officials said that they also had been concerned

about these data, and had discussed the data with EEOC officials. After we

raised this issue, the officials intensified their efforts to identify the true

magnitude and source of the increase and subsequently found that a

computer programming error had resulted in a significant overcounting of

these complaints. They said that the corrected figures were 1,505 for fiscal

year 1996 (or 11.4 percent of the 13,252 complaints filed) and 1,654 for

fiscal year 1997 (or 11.5 percent of the 14,326 complaints filed). They also

provided these figures to EEOC.

In explaining how the error occurred, the officials said that each

automated case record in the complaint information system contains a

data field for race, which is to be filled in with a code for the applicable

racial category when an employee alleges racial discrimination. If an

employee alleges discrimination on a basis or bases other than race, this

data field is to remain blank. According to the officials, the faulty

computer program counted each blank racial data field as indicating an

allegation by a white employee of racial discrimination. These results were

then tallied with complaints in which the data field was properly coded as

an allegation by a white employee of racial discrimination. The officials

advised us that the programming error had been corrected. Although we

did not examine the computer program, our review of the data reported on

the Postal Service’s form 462 for fiscal year 1998 appeared to confirm that

the correction had been made.

Other errors that we found in data that the Service reported on form 462

related to the age of cases in the inventory of unresolved complaints.

EEOC requires agencies to report statistics on the length of time that cases

have been in the agencies’ inventories of unresolved complaints, from the

date of complaint filing. These data are broken out by each stage of the

complaint process—acceptance/dismissal, investigation, hearing, and final

decision. We questioned figures for fiscal year 1997 about the age of (1)

cases pending acceptance/dismissal, because the reported total number of

days such cases had been in inventory seemed unusually high, and (2)

cases pending a hearing before an EEOC administrative judge, because the
B-283618

Page 4 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

reported average age of such cases seemed unusually low. After we

brought the questionable figures to the attention of the Postal Service EEO

Compliance and Appeals Manager, he provided corrected figures and said

that the errors, like the problem with the reporting of complaint bases

described previously, were due to a computer programming error. He said

that the faulty computer program had been corrected. In addition, the

Service provided the corrected figures to EEOC.

We also found that the Postal Service has not been reporting all issues—

the specific conditions or events that are the subjects of complaints—as

EEOC requires. Because some complaints involve more than one basis or

more than one issue, EEOC’s instructions for completing part IV of form

462 require agencies to include all bases and issues raised in complaints.

While the Postal Service’s complaint information system allows more than

one complaint basis (like racial and sexual discrimination) to be recorded,

the system’s data field allows only one “primary” issue (like an adverse

personnel action) to be recorded for each complaint, regardless of the

number of issues that a complainant raises. Although this practice results

in underreporting complainants’ issues to EEOC, the EEO Compliance and

Appeals Manager said that the Postal Service adopted this approach to give

the data more focus by identifying the primary issues driving postal

workers’ complaints.

This matter has not been resolved. In order to report more than one issue

for each complaint, the Service would have to modify the automated

complaint information system to allow for the recording of more than one

issue for a complaint. However, we have reported that part IV of form 462

for reporting statistics on bases and issues is methodologically flawed and

results in an overcounting of bases and issues.4

 We have made a

recommendation to EEOC that it correct this problem, and the agency said

that it would address our concerns.5

 Therefore, we believe that it would be

prudent for the Postal Service to wait for EEOC to resolve this issue before

modifying its data recording and reporting practices.

In addition to the discrepancies already noted, we found that the Postal

Service’s statistical reports to EEOC for fiscal years 1996 and 1997 did not

include data for complaints involving certain categories of primary issues.

 

4

GAO/GGD-99-75, May 4, 1999.

5

EEOC, with the National Partnership for Reinventing Government, is cosponsoring the Interagency

Federal EEO Task Force. One task force team of representatives from federal agencies and

departments, in response to recommendations made in GAO/GGD-99-75, is to review and recommend

approaches to improve the type and quantity of data, the method of collection, the accuracy and

reliability of the data, and the timeliness and availability of the data.
B-283618

Page 5 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

The form 462, which EEOC requires agencies to complete, contains a list

of issues. For its own management needs, the Service supplemented

EEOC’s list with three additional categories of specific issues: (1) denial of

worker’s compensation, (2) leave, and (3) other pay. However, we found

that in completing part IV of EEOC form 462 for fiscal years 1996 and 1997,

the Service omitted the data about complaints in which these additional

issues were cited. After we brought our observations to the attention of

Service officials, they provided the omitted data to EEOC. The officials

explained that, for fiscal year 1998, in lieu of including data about

complaints involving the three additional issues on part IV of form 462,

they provided these data separately to EEOC. The EEO Compliance and

Appeals Manager explained that he did not want to “force fit” the data

about the three issues into one of the categories listed on the form 462,

such as “other,” because the issues thereby would lose their identity and

significance. He added that part IV of form 462 needs to be revised because

the categories of issues listed are too broad and do not recognize emerging

issues.

Further, we found certain underreportings of the bases and issues cited in

complaints for fiscal year 1995. After we brought the underreporting to the

attention of the Postal Service officials, they provided corrected data to

EEOC and us. Service officials attributed this underreporting to difficulties

associated with implementing a new complaint information system in

fiscal year 1995.

Both Postal Service management and EEOC need complete, accurate, and

reliable information to deal with EEO-related workplace conflicts.

Discrepancies that we found in our limited review of the Postal Service’s

EEO complaint data raised questions about the completeness, accuracy,

and reliability of the reported data, particularly data generated through the

automated complaint information system. All but one of the reporting

problems we found and their underlying causes appear to have been

corrected. However, because we examined only a limited portion of the

reported data for obvious discrepancies and because the errors we

identified were related to data generated by an automated complaint

information system put in place in 1995, we have concerns about the

completeness, accuracy, and reliability of the data that we did not

examine.

To help ensure that the EEO complaint data submitted to EEOC are

complete, accurate, and reliable, we recommend that you review the

Postal Service’s controls over the recording and reporting of these data,

including evaluating the computer programs that generate data to prepare

Conclusions

Recommendation to

the Postmaster

General
B-283618

Page 6 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

the EEOC form 462, Annual Federal Equal Employment Opportunity

Statistical Report of Discrimination Complaints. We recognize that

recording and reporting issues raised in complaints are matters that

cannot be completely addressed until EEOC resolves the methodological

flaws in part IV of form 462.

In oral comments on a draft of this report made on August 20, 1999, the

Postal Service Manager, EEO Compliance and Appeals, generally

concurred with our observations and offered comments of a clarifying

nature. In response to our recommendation that the Service’s controls over

the recording and reporting of EEO complaint data to EEOC be reviewed,

this official said that the Postal Service plans to adopt more

comprehensive management controls to ensure that the data submitted are

complete, accurate, and reliable. The official further said that these

controls would involve (1) an analysis of trend data to identify anomalies

and (2) an examination of data categories in which discrepancies have

previously been found. He also said that complaint information system

controls would be examined to determine whether they ensure that data

recorded and reported are complete, accurate, and reliable. He said,

however, that because the complaint information system has been

certified for year 2000 compatibility and because the Service has decided

not to modify any computer systems until March 2000, any modifications

to improve the complaint system will not be made until then. We believe

that the actions the Postal Service proposes, if carried out, will address the

substance of our recommendation.

We are sending copies of this report to Senators Daniel K. Akaka, Thad

Cochran, Joseph I. Lieberman, and Fred Thompson and Representatives

Robert E. Andrews, John A. Boehner, Dan Burton, William L. Clay, Elijah

E. Cummings, Chaka Fattah, William F. Goodling, Steny H. Hoyer, Jim

Kolbe, John M. McHugh, David Obey, Harold Rogers, Joe Scarborough,

Jose E. Serrano, Henry A. Waxman, and C. W. Bill Young in their capacities

as Chair or Ranking Minority Member of Senate and House Committees

and Subcommittees. In addition, we will send a copy to Representative

Albert R. Wynn. We will also send copies to the Honorable Ida L. Castro,

Chairwoman, EEOC; the Honorable Janice R. Lachance, Director, Office of

Personnel Management; the Honorable Jacob Lew, Director, Office of

Management and Budget; and other interested parties. We will make

copies of this report available to others on request.

Because this report contains a recommendation to you, you are required

by 31 U.S.C. 720 to submit a written statement on actions taken on this

recommendation to the Senate Committee on Governmental Affairs and

Agency Comments and

Our Evaluation
B-283618

Page 7 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data

the House Committee on Government Reform not later than 60 days after

the date of this report and to the House and Senate Committees on

Appropriations with the agency’s first request for appropriations made

more than 60 days after the date of this report.

If you or your staff have any questions concerning this report, please

contact me or Stephen Altman on (202) 512-8676. Other major contributors

to this report were Anthony P. Lofaro, Gary V. Lawson, and Sharon T.

Hogan.

Sincerely yours,

Michael Brostek

Associate Director, Federal Management

and Workforce Issues
Page 8 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
Ordering Information

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

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

following address, accompanied by a check or money order made

out to the Superintendent of Documents, when necessary. VISA

and MasterCard credit cards are accepted, also. Orders for 100 or

more copies to be mailed to a single address are discounted 25

percent.

Order by mail:

U.S. General Accounting Office

P.O. Box 37050

Washington, DC 20013

or visit:

Room 1100

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

U.S. General Accounting Office

Washington, DC

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

fax number (202) 512-6061, or TDD (202) 512-2537.

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

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

from the past 30 days, please call (202) 512-6000 using a touchtone phone. A recorded menu will provide information on how to

obtain these lists.

For information on how to access GAO reports on the INTERNET,

send e-mail message with “info” in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Rate

Postage & Fees Paid

GAO

Permit No. G100

(410445)