COAST GUARD

Continued 

Improvements Needed 

to Address Potential 

Barriers to Equal 

Employment 

Opportunity

Report to Congressional Requesters

December 2011

GAO-12-135

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-135, a report to 

congressional requesters

December 2011

COAST GUARD

Continued Improvements Needed to Address 

Potential Barriers to Equal Employment 

Opportunity

Why GAO Did This Study

In the past, allegations of management 

weakness and inadequate provision of 

civil rights services were made against 

the U.S. Coast Guard’s (USCG) Civil 

Rights Directorate (CRD). To address 

these allegations, in 2008, the Director 

of CRD commissioned an external 

review of CRD’s operations. As a result 

of recommendations made in that 

review, CRD has developed steps, 

such as reorganizing its operations, 

with the intent of program 

improvement. As requested, GAO 

examined (1) how the USCG’s equal 

employment opportunity (EEO) 

program compares to the Equal 

Employment Opportunity 

Commission’s (EEOC) Management 

Directive 715 (MD-715) reporting 

standards for a model program, and 

(2) the extent to which CRD has 

defined performance goals and 

measures that are useful in assessing 

program improvements. To conduct 

this work, GAO reviewed 

documentation from the USCG and 

EEOC, and literature on performance 

measurement. GAO also interviewed 

USCG, EEOC and other relevant 

agency officials.

What GAO Recommends

GAO recommends that the USCG 

(1) take a systematic approach in 

conducting barrier analyses and 

reporting its progress toward becoming 

a model EEO program and (2) refine 

its performance measurement plan to 

address gaps in key areas. DHS 

concurred with both GAO 

recommendations. 

What GAO Found

The USCG is making progress toward becoming a model equal employment

opportunity (EEO) program, as defined by EEOC. In fiscal year 2008, the USCG 

established a cross-functional task force, including many divisions of Coast 

Guard and co-led by the Civil Rights Director and the Assistant Commandant for 

Human Resources, to identify EEO problems, review data, as well as develop 

and implement plans to address barriers to EEO. EEOC officials commended 

the USCG’s cross-functional approach, noting that it could strengthen the 

USCG’s ability to bring together different divisions of the USCG toward a 

common goal of identifying and eliminating barriers to EEO. According to EEOC, 

progress has been most noticeable with the commitment of USCG’s leadership 

to equality for all employees and applicants and its focus on resolving complaints 

in a quick and cost effective manner. However, EEOC noted that USCG could 

improve the way it conducts analyses of its barriers to equal employment. To 

attract and retain top talent, EEOC’s MD-715 states that federal agencies are to 

identify barriers to EEO in the workplace, execute plans to eliminate barriers, and 

report annually to EEOC. USCG has several initiatives to improve how it 

identifies and addresses possible barriers. Still, based on its MD-715 reporting, 

there is no evidence that the USCG is taking a structured and consistent, or 

systematic approach to identifying and eliminating barriers in the workplace. For 

example, USCG has not documented any assumptions or reasoning to support 

the rationale for its improvement initiatives, and it is not apparent that the 

initiatives are part of a larger strategy. By clearly demonstrating its efforts to 

identify and eliminate barriers, the USCG could improve its program, and the 

ability of EEOC and others to assess USCG’s progress towards becoming a 

model EEO program.

In response to a prior GAO recommendation, CRD developed a performance 

measurement plan in July 2011 to help it assess the actions it has taken to 

improve its provision of EEO services, including counseling and training, to 

USCG personnel. The plan incorporated some common practices of performance 

plans, such as establishing annual goals, objectives, quantifiable measures, and 

targets that could help CRD maintain accountability for the changes it has made 

to improve services. However, there are weaknesses in key areas of CRD’s 

performance plan, such as measures that do not consistently provide a valid 

representation of the performance goals. Additionally, while nearly all CRD’s 

measures have targets, CRD has not included baselines against which to 

compare goals and future performance. Further, CRD’s plan does not include 

credible procedures to verify and validate performance information. Refining its 

performance measurement plan would help address these gaps and provide 

reasonable assurance that CRD is achieving its intended objectives for program 

improvements.

View GAO-12-135. For more information, 

contact Yvonne D. Jones at (202) 512-6806 or 

jonesy@gao.gov.
Page i GAO-12-135 Coast Guard

Letter 1 

Background 3

USCG Is Taking Steps toward Becoming a Model EEO Program; 

Opportunities Exist for Continued Progress 8

CRD Needs to Address Gaps in Its Performance Plan to Improve 

Effectiveness 16

Conclusions 21

Recommendations for Executive Action 22

Agency Comments and Our Evaluation 23

Appendix I Scope and Methodology 26

Appendix II Comments from Department of Homeland Security 28

Appendix III Contact and Staff Acknowledgments 30 

Tables

Table 1: EEOC’s Six Elements of a Model EEO Program 9

Table 2: CRD Performance Goals and Descriptive Statements, as of 

July 2011 17

Figure

Figure 1: EEOC’s Barrier Analysis Process 6

Contents
Page ii GAO-12-135 Coast Guard

Abbreviations

BAH Booz Allen Hamilton

CRCL Civil Rights and Civil Liberties

CRD Civil Rights Directorate

CRSP Civil Rights Service Provider

DHS Department of Homeland Security

EO Equal Opportunity

EEO Equal Employment Opportunity

EEOC Equal Employment Opportunity Commission

MD-715 Management Directive 715

USCG United States Coast Guard

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Page 1 GAO-12-135 Coast Guard

United States Government Accountability Office

Washington, DC 20548

December 6, 2011

Congressional Requesters

In response to concerns from its workforce about inadequate provision of 

civil rights services, the United States Coast Guard (USCG) has 

undertaken efforts during the past several years to improve these 

services. At USCG, civil rights services include equal employment 

opportunity (EEO) services that are provided to civilian employees, and 

equal opportunity (EO) services, which are provided to active duty 

military. Providing these services is the responsibility of USCG’s Civil 

Rights Directorate (CRD). As part of USCG’s efforts to improve civil rights 

services, it continues to take actions to be a model EEO program, as 

defined by the Equal Employment Opportunity Commission’s (EEOC) 

Management Directive 715 (MD-715). Federal agencies are required to

submit MD-715 reports annually to EEOC on such topics as 

‘demonstrated leadership commitment’ and ‘proactive prevention of 

discrimination’, among others. EEOC then uses the information to assess 

how an agency’s EEO program compares to its standards for a model 

EEO program.

Additionally, in April 2010, we reported that CRD had taken actions to 

improve its provision of civil rights services, such as revamping its 

organizational structure, and replacing part-time civil rights service 

providers or counseling staff with full-time staff, with the intent to improve 

its program.

1

As requested, to determine CRD’s status in continuing to improve the 

provision of civil rights services to USCG personnel, we examined: (1) 

how USCG’s EEO program compares to EEOC’s MD-715 standards for a 

In the same report, we made recommendations to help CRD 

improve its civil rights program; one of them being that the agency 

establish measurable performance goals and measures to determine the 

results of actions taken to improve its program. The Department of 

Homeland Security (DHS), of which USCG is a component agency, 

concurred with our recommendations and is taking steps to address 

them. 

 

1 GAO, Coast Guard: Civil Rights Directorate’s Action Plans to Improve Its Operations 

Could Be Strengthened by Implementing Several Aspects of Project Planning and 

Implementation Practices, GAO-10-571T (Washington, D.C.: Apr. 27, 2010). 

 
 

Page 2 GAO-12-135 Coast Guard

model program, and (2) the extent to which CRD has defined 

performance goals and measures that are useful in assessing program 

improvements. 

This report is part of your larger request. In July 2011, we reported on the 

reorganization of CRD’s workforce and how it contributed to the 

improvement of the provision of civil rights services. Specifically, we 

reviewed the reorganization of field operations, and the qualifications of 

staff that provide civil rights services to USCG personnel, and made 

recommendations for the purpose of further enhancing CRD’s workforce 

restructuring efforts.2

For this report, to assess USCG’s program relative to EEOC’s model 

program, we reviewed MD-715 and EEOC instructions and guidance for 

MD-715. We also reviewed USCG’s MD-715 reports for fiscal years 2008 

through 2010 and analyzed USCG’s identified barriers and plans to 

address those barriers. Because it was beyond the scope of this 

engagement, we did not evaluate the accuracy of the data contained in 

the workforce data tables, the extent to which CRD identified all potential 

barriers, or the extent to which plans to eliminate barriers or activities 

would address identified barriers. In addition, we reviewed USCG’s

policies, guidance, and plans related to identifying and addressing 

barriers. We also interviewed officials from EEOC, CRD, USCG’s MD-715 

task force, and DHS’ office of Civil Rights and Civil Liberties (CRCL).

 The agency concurred with our recommendations.

3

To assess CRD’s efforts to develop and implement performance goals 

and measures against common practices, we reviewed the 2009 Booz 

 

 

2 GAO, Coast Guard: Civil Rights Directorate Can Enhance Workforce Restructuring 

Efforts, GAO-11-718 (Washington, D.C.: July 18, 2011). The recommendations in this 

report were: (1) to promote transparency in decision making, develop a disciplined and 

documented strategic approach that includes criteria for making geographic staffing 

allocation decisions, which would include helping identify the highest priorities for placing 

additional staff among its regions and zones; and (2) implement a centralized system for 

CRSP training records that provides design specifications with associated implementation 

milestones and that aligns with internal control standards for data tracking, monitoring, 

and reporting.

3 DHS’ Office of Civil Rights and Civil Liberties (CRCL) provides oversight of EEO 

programs of all DHS component agencies, including USCG.
 

Page 3 GAO-12-135 Coast Guard

Allen Hamilton (BAH) study of the civil rights program.4

We conducted this performance audit from November 2010 through 

December 2011 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe the evidence provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 We also reviewed 

CRD’s action plans to address the recommendations in the BAH report 

for the improvement of USCG’s civil rights operations. In addition to 

previous GAO work on common practices on developing performance 

goals and measures, we obtained and analyzed documentation from 

CRD on the guidance it used to develop its performance plan. We also 

obtained performance information from EEOC and DHS’ CRCL on 

developing performance goals and measures. See appendix I for more 

information regarding our scope and methodology. 

The USCG CRD’s principal function is to facilitate USCG’s compliance 

with federal antidiscrimination laws, regulations, and policies consistent 

with MD-715 model program elements. In this role, CRD provides EO 

services to its approximately 50,000 active duty military and EEO services 

to its approximately 8,000 civilian personnel. Under the EEO program, 

CRD is responsible for ensuring USCG compliance with federal statutes 

prohibiting employment discrimination as well as EEOC’s regulations and 

directives, including its MD-715, which provides the framework for a 

model EEO program.5

 

4 In September 2008, CRD commissioned Booz Allen Hamilton to conduct a review that 

would help address historical issues of weaknesses in CRD’s organizational structure, 

complaint processes, and program effectiveness. See Booz Allen Hamilton, U.S. Coast 

Guard Office of Civil Rights Program Review (2009) 

Under the EO program, while military members are 

not covered by the antidiscrimination statutes and EEOC regulations and 

directives, USCG’s policy provides that military equal opportunity policies 

are generally based upon principles set forth in civilian EEO policy, 

5 MD-715 provides policy guidance and standards for establishing and maintaining 

effective affirmative programs of equal employment opportunity under section 717 of Title 

VII of the Civil Rights Act of 1964 as amended, and effective affirmative action programs 

under section 501 of the Rehabilitation Act of 1973, as amended. See, 42 U.S.C. § 2000e16 and 29 U.S.C. § 791. 

Background 
 

Page 4 GAO-12-135 Coast Guard

including affording military members with discrimination complaint 

procedures that mirror the EEO process. CRD’s military and civilian Civil 

Rights Service Providers (CRSPs) provide these services in the form of 

EO/EEO counseling, complaint investigation/processing, and EO/EEO 

training. CRD is headed by a Director who reports to the Commandant of 

USCG and is responsible for all EEO/EO activities within USCG. CRD 

oversees and manages all CRSPs through three Civil Rights Regional 

offices.

Under a prior Director, two separate external reviews of the civil rights 

operations recommended improvements in CRD’s organizational 

structure, complaint processes, and program effectiveness. In the past, 

allegations of management weaknesses, unsecured personal information, 

and employee dissatisfaction were made against CRD. The current CRD 

Director commissioned a third external review and evaluation in 

September 2008 to improve the operations of the civil rights program. In 

February 2009, Booz Allen Hamilton completed this commissioned review 

and made 53 recommendations, which were similar to those of the 

previous reports.6

In our April 2010 testimony, we noted that EEOC’s MD-715 provides 

guidance to federal agencies to identify the basic elements necessary to 

create and maintain a model EEO program.

 The Director of CRD subsequently developed action 

plans to address these recommendations.

7 Under MD-715, federal 

agencies are to establish and maintain a model EEO program to provide 

the infrastructure necessary to achieve a discrimination-free work 

environment characterized by free and open competition for employment 

opportunities. EEOC guidance states that an agency should review its 

EEO and personnel programs, policies, and performance against 

standards defined by EEOC.8

Further, according to EEOC, agencies have an ongoing obligation to 

ensure that all employment decisions are free from discrimination by 

eliminating barriers that impede free and open competition in the 

workplace and prevent individuals from any racial or national origin group 

 

 

6 Booz Allen Hamilton, U.S. Coast Guard Office of Civil Rights Program Review (2009).

7 GAO-10-571T.

8 Additional details of the standards as defined by EEOC are in the body of the text. 
 

Page 5 GAO-12-135 Coast Guard

or of either sex from realizing their full potential. As part of this ongoing 

obligation, agencies must conduct a self-assessment on at least an 

annual basis to monitor progress and identify areas where barriers may 

exist to exclude certain groups.9

EEOC defines a barrier as an anomaly that affects employment 

opportunities of certain EEO groups in an agency’s workforce. An 

analysis of such anomalies involves an investigation of workplace 

policies, procedures, practices, and conditions, with the goal of identifying 

the root cause of the anomaly, so that the barrier can be eliminated. 

Further, EEOC’s MD-715 guidance states that agencies and their 

subcomponents have an “ongoing obligation to prevent discrimination on 

the basis of race, color, national origin, religion, sex, age, reprisal and 

disability, and eliminate barriers that impede free and open competition in 

the workplace.”

 

10

One of the first steps in identifying barriers is finding a “trigger’, or “red 

flag” (e.g., a high number of women who leave an agency’s workforce) 

that something is amiss, and therefore should be investigated. (See fig. 1 

for more details.) 

 

 

9 According to EEOC, consistent with Section 717 of Title VII of the Civil Rights Act, EEOC 

requires operating components and field installations with 500 or more employees to 

develop separate plans in accordance with these instructions. MD-715 reports are due by 

January 31 following the end of the fiscal year that is being reported. The heads of all 

covered departments and agencies are responsible for preparing and submitting annual 

fiscal year status reports. 

10 MD-715.
 

Page 6 GAO-12-135 Coast Guard

Figure 1: EEOC’s Barrier Analysis Process

According to EEOC, agencies identify these triggers by comparing racial, 

national origin, and gender profiles of relevant occupational categories to 

an agency's workforce and workforce benchmarks.11

 

11 According to EEOC, agencies must conduct a workforce analysis comparing the 

internal representation of designated group members in an employer's workforce to the 

external labor pool of designated group members from which the employer can 

reasonably be expected to recruit. Agencies must also conduct analysis of hiring, 

promotion, and termination data, along with an analysis of whether designated group 

members are concentrated in the lower levels of occupational groups with 

underrepresentation. Typical benchmarks include the Civilian Labor Force (CLF), Total 

Workforce, Permanent Workforce, and Occupational CLF. 

This comparison 

can serve as a diagnostic tool to help agencies determine possible areas 

where differences and barriers may exist and that may require closer 
 

Page 7 GAO-12-135 Coast Guard

attention. Where an agency's self-assessment indicates that a racial, 

national origin, or gender group may have been denied equal access to 

employment opportunities, the agency must take steps to identify the 

potential barrier. The process further requires each agency to develop 

action plans to eliminate or modify, where appropriate, any policy, 

practice, or procedure that creates a barrier to equality of opportunity.12

EEOC guidance also indicates that agencies cannot meet the mandate of 

the EEO MD-715 by relying solely on workforce statistics to identify and 

eliminate barriers. Instead, EEOC guidance requires agencies to go 

beyond examining workforce statistics to taking a systematic approach, 

such as one where agencies methodically examine their employment 

policies and practices to identify and remove barriers to EEO in the 

workplace.

 

Agencies must also assess whether the action plans were successful in 

eliminating barriers. According to EEOC, some indicators of success are 

increases in workforce participation rates, decreases in separation rates 

and complaints, and favorable responses in surveys and exit interviews.

13

In our April 2010 testimony, we also noted that CRD had taken action to 

resolve certain management challenges such as dissatisfaction among 

USCG personnel and to improve its civil rights program.

Further, within a systematic approach agencies would 

consider additional information to identify areas where barriers may exist 

to exclude certain groups. Surveys, for example, may reveal information 

on experiences, perceptions, or difficulties with a practice or policy with

an agency. Following EEOC’s guidance, this kind of systematic approach 

would require agencies, for example, to develop hypotheses about factors 

that create barriers. EEOC guidance also indicates that a thorough and 

systematic analysis may identify certain barriers that are interrelated and 

could, therefore, be addressed in a comprehensive manner that can be 

noted in the agencies’ MD-715 report. 

14

 

12 Barrier analyses and action plans must be updated each year in Part I of EEOC’s MD715. 

 In that 

testimony, however, we concluded that selected action plans consistently 

lacked evidence of how CRD defined program outcomes, and, therefore, 

we recommended that CRD establish measurable performance goals for 

13 MD-715 instructions.

14 GAO-10-571T. 
 

Page 8 GAO-12-135 Coast Guard

each of the action plans, and create an evaluation strategy for each 

action plan.

EEOC’s MD-715 provides policy guidance and standards for establishing 

and maintaining a model EEO program.15 According to EEOC, a model 

EEO program should include effective management, accountability, and 

self-analysis that will ensure program success and compliance with MD715. Agency personnel programs and policies should be evaluated 

regularly to ascertain whether such programs have any barriers that tend 

to limit or restrict equitable opportunities in the workplace. MD-715 

guidance further refers to six elements that an agency’s EEO program 

should encompass to create and maintain a model EEO program. 

Agencies are to consider these elements when identifying areas where 

their EEO program can become more effective.16 Table 1 provides 

additional details about the six elements. 

 

15 Both section 717 of Title VII and 29 U.S.C. § 791 et seq. require the establishment of 

federal affirmative action plans. 

16 We did not evaluate the extent to which CRD’s action plans met the criteria for EEOC 

model elements. 

USCG Is Taking Steps 

toward Becoming a 

Model EEO Program; 

Opportunities Exist 

for Continued 

Progress 
 

Page 9 GAO-12-135 Coast Guard

Table 1: EEOC’s Six Elements of a Model EEO Program

Element Element description and requirement Recent USCG actions

1. Demonstrated Commitment 

from Agency Leadership

Agency leadership is to demonstrate strong 

commitment to equality for all employees and 

applicants.

Requirement - Agency leadership is to be 

instrumental in translating equal opportunity into 

everyday practice so that EEO principals can be a 

fundamental part of agency culture.

• Increased collaboration with EEOC for 

workshops facilitation and leadership 

conferences 

• Hired additional staff to support civil rights 

services for USCG personnel, and analyze 

MD-715 data and compile reports.

2. Efficiency Agencies are required to have an efficient and fair 

dispute resolution process and systems for 

evaluating the effectiveness of their EEO and 

Alternative Dispute Resolution programs.a

 Also, 

the agency is to demonstrate to complainants that 

it is committed to expeditious complaint 

resolution.

Requirement - The benefit of ADR is instrumental 

in the early resolution of EEO complaints. 

EEOC’s regulations provide that each agency 

assures that individual complaints are fairly and 

thoroughly investigated and that final action is 

taken in a timely manner.

• For fiscal year 2010, increased percentage 

of formal complaints settled through ADR 

by 23 percent over 2009.

• For fiscal year 2010, increased timeliness 

of investigations to 98 percent, an increase 

of 2 percent over 2009.

• For fiscal year 2010, reduced the number 

of days an investigation took to 184 days, 

from 249 days in 2009, a 27 percent 

improvement. 

3. Integration of EEO into the 

Agency’s Strategic Mission 

The role of an EEO office is to serve as a 

resource for managers by providing direction, 

guidance, and monitoring of key activities to 

achieve a diverse workplace free of barriers to 

equal opportunity.

Requirement - The EEO office is essential in 

attracting, developing, and retaining the most 

qualified workforce to support the agency’s 

achievement of its strategic mission. 

• Held Senior Executive Leadership Equal 

Opportunity seminars. 

• Hosted a Diversity Leadership Summit in 

2010. 

4. Management and Program 

Accountability

Managers, supervisors, EEO officials, and 

personnel officers are to be held accountable for 

the effective implementation and management of 

the agency’s EEO program. Agencies are also 

required to maintain defined and consistently 

applied personnel policies, selection and 

promotion procedures, and training systems, as 

well as implement reasonable accommodation 

procedures.

Requirement - Accountability ensures effective 

coordination between the agency’s EEO 

programs and related human resource programs.

• Convened a task force to identify and 

resolve potential barriers to equal 

employment opportunity, among other 

activities. 

• Developed plans to evaluate hiring 

decisions to identify potential barriers to a 

diverse workforce. 

• Developed plans to use a web-based 

application to validate and increase the 

timeliness of required training. 

5. Responsiveness and Legal

Compliance. 

Agency head or designee is to certify to the 

EEOC that the agency is in full compliance with 

EEO laws, regulations, policy guidance, and other 

written instructions. This annual certification is 

reported on EEOC form 715-01, Part F.

Requirement - EEOC uses this element to assess 

if agencies meet submission requirements. 

• For fiscal year 2010, USCG certified that 

the agency has conducted an annual selfassessment of Section 717 and Section 

501 programs against the essential 

elements as prescribed by EEO MD-715.
 

Page 10 GAO-12-135 Coast Guard

Element Element description and requirement Recent USCG actions

6. Proactive Prevention of 

Unlawful Discrimination 

The MD-715 requires agencies to conduct a selfassessment annually to monitor progress, identify 

areas where barriers may operate to exclude 

certain groups, and develop strategic plans to 

eliminate identified barriers. 

Requirement - Agencies must exhibit their 

ongoing obligation to prevent discrimination on 

the bases of race, color, national origin, religion, 

sex, age, reprisal, and disability, and eliminate 

barriers that impede free and open competition in 

the workplace.

• USCG included complaint, and other data 

in its 2010 MD-715 report that it uses to 

aid its efforts to identify and resolve 

barriers to equal employment opportunity.

• DHS’ Civil Rights and Civil Liberties 

(CRCL) unit provided the USCG MD-715 

task force team with barrier analysis 

training in March 2011.

Source: EEOC’s MD-715 guidance, USCG, and GAO analysis.

a

According to EEOC, Alternative Dispute Resolution (ADR) generally refers to a continuum of 

processes and approaches that are designed to resolve disputes in a manner which avoids the cost, 

delay, and unpredictability of more traditional adversarial and adjudicatory processes, such as, 

litigation, hearings, and appeals. Numerous types of ADR techniques exist, including mediation, 

facilitation, fact finding, early neutral evaluation, the use of an Ombudsman, settlement conferences, 

minitrials, and peer review.

Based on our review of USCG’s 2008–2010 MD-715 reports and 

discussions with USCG officials, we determined that USCG has taken 

actions for each element, which is also summarized in table 1. Further, in 

our recent discussions with EEOC officials, they credited USCG for taking 

steps toward building a solid foundation for a model EEO program. 

EEOC officials noted that USCG has progressed in its efforts, particularly 

in two of the six elements—Demonstrated Commitment from Agency 

Leadership, and Efficiency. Even with the progress in efficiency, EEOC 

officials identified further improvements that could be made in this area as 

well as the area of Proactive Prevention of Unlawful Discrimination 

element, which we discuss in more detail later in this report. 

The EEOC commended USCG for demonstrating leadership commitment 

through such actions as increased collaboration with EEOC for educating 

senior management on EEO issues, and for dedicating more resources 

towards addressing the EEO needs of USCG personnel. Further, 

according to USCG, an operations research specialist was hired to assist 

with the evaluation of workforce and other data to identify problems, such 

as potential barriers to EEO. Adding this analytical skill set helps address 

a concern expressed by BAH in its 2009 report that USCG did not have 

the requisite skills and knowledge to conduct barrier analysis. This action 

also further supports USCG’s demonstration of leadership commitment.

Demonstrated 

Commitment from Agency 

Leadership
 

Page 11 GAO-12-135 Coast Guard

EEOC noted that USCG made progress over the years in resolving 

complaints in a quick and cost effective manner. For fiscal year 2010, 

USCG reported conducting timely investigations for 98 percent of 

complaints, compared to 94 and 96 percent for fiscal years 2008 and 

2009, respectively.17 In our discussions with EEOC officials, they 

corroborated USCG’s success in this area, stating that counseling and 

timely resolution of complaints was near 100 percent. Further, according 

to EEOC, USCG has improved in the Efficiency element by increasing its 

use of the ADR program, which is critical for resolving complaints before 

the formal complaint process is initiated. As stated in the fiscal year 2010 

MD-715 report, USCG offered ADR to 100 percent of its workforce for 

pre-complaint resolution, whereas for fiscal 2006, USCG offered the 

program to only approximately 4 percent of its workforce, based on 

EEOC’s review. Moreover, according to USCG’s fiscal year 2010 MD-715 

filing, the number of formal cases settled by ADR increased by 16 (23 

percent) over fiscal year 2009. USCG attributed the improvement to such 

factors as better internal processes and increased management 

participation. According to EEOC, the increased use of ADR is important 

because ADR provides prompt resolution of complaints and saves USCG 

the time and expense involved with going through the formal complaint 

process. Although EEOC describes Efficiency as an area of progress for 

USCG, officials also noted that USCG complainants who accept the ADR 

participation offer and resolutions through ADR at USCG are below their 

respective governmentwide averages. EEOC said that USCG has not 

identified specific reasons as to why this is the case. 

For this element, USCG’s fiscal year 2010 MD-715 states that the agency 

conducted activities such as hosting a Diversity Leadership Summit in 

2010, in which over 200 USCG representatives participated in 

educational and multicultural awareness sessions, networked with 

national and international leaders in diversity management, and shared 

best practices and resources. Additionally, the fiscal year 2010 MD-715 

report describes three 2-day Senior Executive Leadership Equal 

Opportunity Seminars held in fiscal year 2010 focusing on civil rights, 

equal employment opportunity, and diversity in the workplace. The overall 

completion rate among senior leadership, according to USCG, was 72 

 

17 Timely resolution of investigation of complaints should be completed within 180 days for 

civilians, and military personnel. However, USCG-CRD must issue a final action for 

military personnel within 60 days after the 180 days allowed for investigation. 

Efficiency 

Integration of EEO into the 

Agency’s Strategic Mission
 

Page 12 GAO-12-135 Coast Guard

percent. Coast Guard plans to continue holding this course to ensure 100 

percent of senior leaders attend. 

Additionally, the 2010 ‘Annual Report on the Coast Guard Workforce’, 

presented to USCG’s Senior Executive Leadership Conference, 

described USCG’s workforce profile for targeted population groups and 

actions underway to address identified gaps. 

These actions are consistent with the requirements necessary for an 

agency to integrate its EEO office and programs into the agency’s 

mission and to regularly inform the agency head and other senior 

management officials of the status of EEO programs. 

USCG officials also told us about actions they had taken that were 

consistent with the Management and Program Accountability element. In 

particular, USCG established a MD-715 Task Force in 2008, co-led by the 

Civil Rights Director and the Assistant Commandant for Human 

Resources that includes representatives from 10 divisions across 

USCG.18

In addressing the element of Responsiveness and Legal Compliance, 

USCG states in its fiscal year 2009 and 2010 MD-715 reports that it is in 

full compliance with MD-715 model program standards. In a 2008 trend 

letter to USCG, EEOC gave credit for overall compliance with MD-715 

Officials said, and our document review indicated, that the task 

force meets quarterly to conduct activities such as reviewing workforce 

data, identifying recruitment strategies, developing plans to address 

barriers to equal opportunity employment, and developing 

recommendations for improving diversity recruitment and retention efforts. 

The MD-715 Task Force is also responsible for developing and compiling 

information for the agency’s annual MD-715 report. EEOC officials 

commended USCG’s approach of using this cross-functional team 

approach, which they believe, and we agree, helps improve USCG’s MD715 reporting and, perhaps more importantly, strengthens USCG’s ability 

to bring together different divisions of USCG to eliminate barriers to equal 

opportunity employment. 

 

18 These 10 divisions include representatives from CRD’s three geographical regions, 

diversity, human resources, civil engineering, reserve and leadership, and community 

services, representing a cross-functional team. 

Management and Program 

Accountability 

Responsiveness and Legal 

Compliance
 

Page 13 GAO-12-135 Coast Guard

reporting requirements.19 In general, these requirements are that USCG 

has submitted its MD-715 reports on a timely basis, reported on agency 

program efforts and accomplishments, and followed EEO instructions 

regarding EEOC orders, regulations, and directives. For example, EEOC 

credited USCG for posting Notification and Federal Employee 

Antidiscrimination and Retaliation Act (No FEAR) of 2002 data,pertaining 

to EEO complaints filed with the agency, on its external website, and 

providing No FEAR Act data to EEOC.20 

In reference to barrier analysis under the Proactive Prevention of 

Unlawful Discrimination element, our review of USCG’s MD-715 reports 

for fiscal years 2008-2010 showed that USCG’s fiscal year 2009 and 

fiscal year 2010 reports contained additional analysis of workforce data 

that was not provided in the fiscal year 2008 report. For instance, for 

fiscal years 2008-2010, USCG reported that a low workforce participation 

rate for persons with targeted disabilities was a recurring problem.21

 

19 EEOC reviews MD-715 reports when they are submitted annually. Every 3 years, 

EEOC issues trend letters to agencies that contain EEOC’s assessment of the respective 

agency’s EEO program in regards to MD-715 reporting. 

 

However, the 2010 report included more details about planned activities 

to monitor and track applicants with disabilities and target dates for 

activity completion than did the 2009 report, such as reviewing USCG and 

DHS employee survey data. Further, USCG augmented its analyses with 

additional workforce analysis of both hiring and separation rates for 

persons with targeted disabilities. USCG officials explained that the 

addition of these data elements could help them better understand if 

additional efforts should focus on, for example, recruitment and hiring, or 

development and retention.

20 According to EEOC, Section 301 of the Notification and Federal Employee 

Antidiscrimination and Retaliation Act of 2002 (the No Fear Act) requires each federal 

agency to post summary statistical data pertaining to complaints of employment 

discrimination filed against it by employees, former employees, and applicants for 

employment under 29 C.F.R. Part 1614. The specific data to be posted are described in 

section 301(b) of the act and 29 CFR 1614.704.

21According to MD-715 instructions, participation rates below a designated benchmark for 

a particular group are triggers or problems for additional analysis. EEOC defines a trigger 

as a “red flag”; i.e., conditions, disparities, or anomalies in the workplace warranting 

inquiry.

Proactive Prevention of 

Unlawful Discrimination
 

Page 14 GAO-12-135 Coast Guard

EEOC officials stated that additional opportunities exist for improvements 

under this element, particularly in barrier analysis and elimination. We 

agree with EEOC’s assessment based on our review of 2008-2010 MD715 reports and discussions with USCG’s MD-715 task force officials. At 

least since 2004, at one time or another, USCG has experienced low 

participation rates in its total workforce among: (1) women overall, 

Hispanics, and other racial and ethnic groups; (2) women overall, 

Hispanics, and other groups in the Senior Executive Service and within 

the feeder-pool positions for promotion to senior management; and (3) 

persons with targeted disabilities. In addition, there has been an 

unspecified impact of nonretirement separations on workforce diversity. 

EEOC officials identified some key areas in which USCG could address 

these low participation rates by improving its efforts to conduct barrier 

analyses, eliminate barriers, and demonstrate the results to EEOC:22

• After a September 2011 meeting with USCG’s MD-715 Task Force, 

EEOC officials stated in a written summary of the visit that USCG, like 

most agencies, has made efforts to conduct barrier analysis and 

identify triggers. They also stated in the summary that USCG provided 

them with a list of a number of planned activities and 

accomplishments that EEOC defined as proactive measures to 

enhance the diversity of its workforce, including outreach strategies 

aimed at particular groups, utilization of educational and internship 

programs, creation of agencywide mentoring opportunities, and 

development of relationships with organizations and institutions 

serving minority communities. However, EEOC officials stated that 

even with these initiatives planned or underway, the participation rate 

of these targeted groups has remained low, and that USCG had not 

actually identified barriers to equal employment opportunity for these 

groups. 

• During discussions, EEOC officials told us that overall, they did not 

see evidence of a structured and systematic approach—an overall 

strategy to barrier analysis, which would include identifying the root 

causes of triggers that USCG identified in its fiscal year 2010 MD-715 

 

22 Another area that EEOC stated that USCG could improve on was timeliness of final 

agency decisions (FADs) on case settlements. However, EEOC also commented that the 

responsibility for the issuance of FADs is directly under the purview of DHS. USCG 

officials told us that a change they would like to see take place is for DHS to allow USCG 

to be the final authority on FAD issuances for military staff. 
 

Page 15 GAO-12-135 Coast Guard

report; nor did they receive such information during their 2011 

discussion with USCG officials.23 EEOC officials said that during the 

technical visit with USCG, officials requested training from EEOC on 

properly conducting barrier analysis, which EEOC said it will provide 

during fiscal year 2012. As a way of providing support on a more 

immediate basis, EEOC officials said they walked USCG officials 

through a barrier analysis exercise, which involved a decision-tree 

methodology the National Oceanic Atmospheric Administration 

(NOAA) had developed through a contractor. NOAA refers to the 

methodology as a ‘Root Cause Analysis Tool’ that outlines steps to 

complete barrier analysis, including determining the root causes of 

why a particular group does not fully participate in an agency’s 

workforce.24

EEOC believes that the NOAA approach is systematic, based on 

information in the NOAA report in that once workforce data indicate a 

demographic anomaly, the Root Cause Analysis Tool takes into 

account the agency’s policies, practices, and conditions that affect all 

parts of the employment cycle, beginning at recruitment and hiring, 

and extending through employee separations. Then, through a series 

of questions about policies, procedures, and practices, the tool helps 

the agency identify barriers and if barriers are job-related, and then 

guides the agency in determining what the agency can do to resolve 

the problem. EEOC officials said in addition to USCG’s use of the 

Root Cause Analysis tool, they would support other agencies’ use of 

this model to accomplish barrier resolution in a timely manner.

 According to EEOC officials, it is important that USCG 

follows a systematic approach to barrier analyses and elimination. 

• Another concern that EEOC officials stated about USGC’s barrier 

analyses was that the agency had not submitted statistical data about 

its applicant pool in its previous MD-715 reports. These applicant flow 

data, as they are commonly referred to, are a valuable tool that can

be instrumental for an agency in examining the fairness and 

inclusiveness of its recruitment efforts, which would help strengthen a 

planned approach to barrier analyses. According to EEOC, without 

 

23 The triggers USCG identified in fiscal year 2010 were: (1) low participation rates of 

women overall, Hispanics, and other racial and ethnic groups in the total workforce; (2) 

low participation rates of women overall, Hispanics, and other groups in the Senior 

Executive Service and within the feeder-pool positions for promotion to senior 

management; (3) low participation rates of persons with targeted disabilities across the 

board; and (4) unspecified impact of nonretirement separations on workforce diversity.

24 The model was created for NOAA in May 2010, and includes some consideration of the

agency’s policies, procedures, and practices.
 

Page 16 GAO-12-135 Coast Guard

applicant flow data, there cannot be meaningful review of the 

effectiveness of an agency’s recruitment efforts. Although USCG has 

not included these data in its MD-715 reports in past years, USCG 

officials said they plan to include them in the 2011 MD-715 report.

As we reported in April 2010, CRD developed action plans in response to 

the 53 recommendations that BAH made as a result of the study that 

CRD commissioned.25

In July 2011, CRD provided us with its most recent performance 

measurement plan that included information about its performance goals 

and measures. CRD’s performance measurement plan also included 

actions taken relative to each goal to address the 53 BAH 

recommendations. In the performance plan, CRD also aligned each goal 

to the original BAH recommendations. 

 At that time, we recommended that CRD establish 

measurable performance goals to aid in tracking progress and 

determining when each action plan had been completed, and whether or 

not the intended goal has been achieved. CRD concurred with this 

recommendation. 

In reviewing CRD’s performance plan, our focus was on how useful its 

performance goals and measures would be in assessing CRD’s actions 

towards program improvements. Building upon our previous review of 

CRD, we selected four goals and their respective measures that are 

related to key issues in the BAH review as well as the actions taken by 

CRD to address the BAH recommendations. These four goals we 

selected for further review encompass 21 measures that are related to 

the BAH 53 recommendations. (See table 2.) 

 

25 GAO-10-571T. 

CRD Needs to 

Address Gaps in Its 

Performance Plan to 

Improve Effectiveness 
 

Page 17 GAO-12-135 Coast Guard

Table 2: CRD Performance Goals and Descriptive Statements, as of July 2011

Goal Goal statement Measure

Fiscal year 

2012 target

1. Enhanced CRD 

Management and 

Leadership 

Effectiveness

CRD leadership creates 

and fosters a collaborative, 

professional work 

environment for all 

Directorate staff

The percentage of new improvement in the satisfaction of 

the CRD workforce with the office climate as measured by 

the Defense Equal Opportunity Climate Survey (DEOCS)a

+5%

The percentage of regional, zone, and headquarters CRD 

management and leadership who received at least “meets” 

ratings on the leadership competencies on their annual 

evaluations

100%

The percentage of CRD managers and leaders attending at 

least one professional development training

100%

Average staff rating of “teamwork” series of seminars Good

2. Optimize 

Organizational 

Structure 

The CRD’s organizational 

structure promotes 

accountability, privacy, and 

integrity

The rate, measured as a percentage of CRDs compliance 

with reporting structure questions in the MD-715 

assessment

100%

The net change in percentage of positive responses by 

CRD staff on whether CRD’s structure supports 

accountability, privacy, and integrity, as measured through 

the DEOCS

+15%

The net change of formal and informal complaint 

processing times after fiscal year 2009 (when restructuring 

occurred)

-10%

The number of discrimination inquiries received from the 

workforce in the form of official correspondence

10

The rate, measured as a percentage of CRD’s compliance 

with all MD-715 factors

100%

3. Civil Rights Manual 

Accessible to 

Workforce

Provide an accessible, 

single resource for civil 

rights policy and doctrine to 

USCG’s workforce

The number of communication channels utilized to offer the 

workforce access to the Civil Rights (CR) Manual (e.g., 

CRD public internet website, CRD internal Coast Guard 

internet website) 

5 

The percentage of people completing Civil Rights 

Awareness Training evaluation forms who acknowledge 

they know how to access the CR Manual

50%

The average number of days between management 

direction to modify an existing policy and the submission of 

updates to the CR manual for internal USCG clearance

60 days or less

The percentage of staff members who have measurable 

performance goals for timely submission of policy updates

50%

The percentage of staff members who have measurable 

performance goals for ensuring the CR manual is revised 

and updated

25%

The average number of days required for CRD to develop 

a new policy and submit it for internal USCG clearance

120 days or 

less

The percentage of USCG Districts submitting the EO 

Compliance Checklist by October 31

100%
 

Page 18 GAO-12-135 Coast Guard

Goal Goal statement Measure

Fiscal year 

2012 target

4. Secure Privacy and 

Appropriately 

Manage Records

CRD personnel handle and 

manage personally 

identifiable information and 

records in accordance with 

federal statutes and 

regulations and DHS 

policies and procedures

The percentage of Districts that comply with the Personally 

Identifiable Information (PII)/Records management portion 

of the Command Checklist

100%

The percentage of field and headquarters CRD personnel 

who received at least a “satisfactory” rating on the 

PII/Records management portion of their annual 

evaluations

100%

The percentage of files held by the Solutions and 

Complaints Division and the Regions, that were not 

accessed by an unauthorized user, as measured by the file 

management security system, iComplaints

100%

The percentage of CRD Headquarters and Field personnel 

who complete the annual USCG Information System 

Security training test

100%

The number of policy violations officially detected and 

validated

0 

Source: GAO, based on information obtained from CRD.

a

DEOCS is a survey for military organizations developed by the Defense Equal Opportunity 

Management Institute. It is used to assess problems in the area of equal opportunity.

Consistent with our previous work on assessing performance plans, we 

examined whether or not CRD’s plan generally incorporates common 

practices in performance measurement planning.26

Developing the performance plan is an important step because it helps 

CRD assess progress in its EEO program improvements. However, we 

found that the four selected goals and measures in CRD’s performance 

plan were consistent with common practices to varying extents as 

described below. 

 In general, the more 

agencies incorporate these practices into their performance plans, the 

more useful the results can be to the agency officials for setting program 

performance goals and in assessing progress toward those goals. 

• Performance goals or their measures should be objective, 

measurable, and quantifiable: In response to our April 2010 

recommendation, CRD has made progress articulating performance 

goals and measures in its plan to help in determining if it is achieving 

 

26 GAO, The Results Act: An Evaluator’s Guide to Assessing Agency Performance Plans, 

GAO/GGD-10.1.20 (Washington, D.C.: April 1998). 
 

Page 19 GAO-12-135 Coast Guard

its intended objectives.27

• Measures should be valid representations of the performance goals: 

Some of the measures CRD identified are not valid representations of 

the goals. For example, to assess progress under the goal of 

enhancing CRD management and leadership effectiveness, CRD 

cited the results from an Organizational Climate Survey, which 

measures the percentage of improvement in the job satisfaction of 

CRD’s workforce.

While the four CRD performance goals we 

selected for review were not quantifiable, we found that the measures 

included within each goal were quantifiable. For example, CRD’s goal 

to enhance CRD management and leadership effectiveness included 

several measures that are quantifiable, including ‘the percentage of 

new improvement in the satisfaction of the CRD workforce with the 

office climate as measured by DEOCS’, and ‘the percentage of CRD 

managers and leaders attending at least one professional 

development training.’ 

28 We have previously reported that such survey 

data may reveal information on experience with, perceptions of, or 

difficulties with a practice or policy within the unit.29

CRD is also assessing its management and leadership effectiveness 

with a measure of the “average staff rating of the ‘teamwork’ series of 

seminars.” The fiscal year 2012 target for this measure is “good.” 

 However, as 

noted above, the relationship between leadership effectiveness and

job satisfaction is not clear. Consequently, in addition to the job 

satisfaction, CRD might include one or more other measures in the 

same survey, such as “perceived work group effectiveness,” 

“leadership cohesion,” “work group cohesion,” or “organizational 

commitment,” as indicators of improved management and leadership 

effectiveness, possibly even comparing results to other EO/EEO 

programs. 

 

27 GAO-10-571T. 

28 According to the Defense Equal Opportunity Management Institution, the Organizational 

Climate Survey measures climate factors associated with the military EO program, civilian 

EEO program, and organizational effectiveness (OE). The questionnaire contains 63 items 

for civilian personnel and 56 for military. It is designed to assess the “shared perceptions” 

of respondents about formal or informal policies, practices, and procedures likely to occur 

in the organization. The survey measures 14 climate factors: 8 EO/EEO and 6 OE factors, 

such as organizational commitment, work group cohesion, leadership cohesion, job 

satisfaction, and perceived work group effectiveness. 

29 GAO-09-639, p. 9.
 

Page 20 GAO-12-135 Coast Guard

While the seminars may enhance teamwork among CRD staff, it is 

unclear how ratings align with the effectiveness of CRD’s 

management and leadership. Including a more direct assessment of 

management’s effectiveness on specific aspects related to 

organizational performance, such as their effectiveness at preventing 

litigation as measured by the percentage of complaints resolved 

through the ADR process, might help CRD assess the results of 

improvements. Another measure for this goal is the percentage of 

CRD managers and leaders attending at least one professional 

development training per year. However, there is no indication that the 

training is directly related to effective management or leadership; 

consequently, the measure may be subject to interpretation and, 

therefore, lacks reliability. Rather than considering a generic 

professional development training, perhaps expanding the measure to 

reflect completion of a course or program of training that has been 

demonstrated to improve effectiveness with meaningful results could 

help CRD align its measures to the specific goal. CRD might also 

include a related measure that reflects the results of the content of the 

training, such as those noted above, to be more reflective of progress 

toward the specific goal. 

Similar gaps exist for several of the measures for the goal of 

organizing CRD’s structure to promote accountability, privacy, and 

integrity. For example, one measure, the net change of formal and 

informal complaint processing times, may be an appropriate measure 

to promote accountability. However, the quality of processing 

complaints may be equally, if not more important—yet there is no 

measure of quality for processing complaints for this goal.

• Performance goals and measures should state a particular target level 

of performance, or improvement: CRD provided fiscal year 2012 

targets for nearly all measures, which is consistent with one of the 

common practices. These targets help CRD establish intended 

performance that can be used to assess progress towards goals.

• Use baseline of benchmark data to assess progress towards goals: 

Within the four goals we reviewed, only 1 of the 21 performance 

measures had baseline data, “the number of policy violations officially 

detected and validated.”30

 

30 Baseline data and measures are described as basic information gathered before a 

program begins. It is used later to provide a comparison for assessing program impact. 

Additionally, none of the measures 
 

Page 21 GAO-12-135 Coast Guard

included data from the previous period. It is important to establish 

baseline performance levels, or at least data from a previous period, 

to set goals and measure performance. Further, without baselines or 

data from the previous period, CRD cannot be assured that it has set 

realistic targets. For example, CRD set a target to increase the 

satisfaction of CRD’s workforce with the office climate by 5 percent. 

But, it is unclear how CRD was able to set realistic targets absent 

performance data. CRD officials have stated they need to do 

additional work in this area, and noted they would use fiscal year 2011 

performance levels as baselines for assessing changes in future 

years. 

• Performance measurement data should be verified and validated:

CRD did not provide documentation that it had credible procedures in 

place to verify and validate performance data for the four selected 

goals. According to CRD officials, they constructed performance 

measures using data that were readily available, but did not attempt to 

validate the data. As we have previously reported, errors can occur at 

various points in the collection, maintenance, processing, and 

reporting of data that can lead to inaccurate estimates of program 

performance.31 Without procedures in place to verify and validate 

performance measurement data, CRD cannot ensure the accuracy 

and completeness of the data used to develop and assess its 

performance measures. 

The USCG has undertaken a number of actions under each of EEOC’s 

essential elements to be considered a model of EEO standards. 

However, while USCG is engaged in a number of initiatives to identify, 

address, and resolve barriers to an equal opportunity workplace, the 

same populations remain underrepresented in its workforce at one time or 

another in the past several years. Based on EEOC’s MD-715 standards, 

it is important that USCG follows a systematic approach to barrier 

analyses and elimination. Further, it is important that USCG describe this 

systematic approach in its annual MD-715 report, because demonstrating 

a systematic approach would help EEOC, relevant units of DHS, and 

Congress more accurately determine if USCG has a structured, 

consistent and robust approach to identify and eliminate potential barriers 

to EEO. According to EEOC officials, this would also assist them in 

 

31 GAO/GGD-10.1.20. 

Conclusions 
 

Page 22 GAO-12-135 Coast Guard

further assessing CRD’s prospects of achieving model EEO program 

status. This approach would also help USCG further develop plans to 

eliminate or modify, where appropriate, policies, practices, or procedures 

that create barriers to equality of opportunity. The benefits of 

demonstrating this approach could serve as a model to other EEO 

programs within DHS and to external ones as well.

CRD has made progress addressing our prior recommendation that it 

develop measurable performance goals, by articulating performance 

goals and measures to help CRD determine if it is achieving its intended 

objectives. However, because CRD has faced previous charges in the 

past of alleged mismanagement and employee dissatisfaction, it is 

particularly important for CRD to ensure that it is taking a proven and 

sound approach to establishing goals and measures, including 

addressing the gaps that exist in its performance measurement plan. 

Such an approach will help CRD determine if changes in the provision of 

equal employment services to USCG personnel are effective. CRD’s 

performance measurement plan is an important step in demonstrating 

that notable improvements in its program have been made in the past few 

years. However, refining its performance measurement plan is needed to 

address gaps in CRD’s plan and help to improve the plan’s effectiveness 

in providing reasonable assurance that CRD is achieving its intended 

objectives.

We recommend that the Secretary of Homeland Security direct the 

Commandant of the Coast Guard to take the following two actions:

• Develop and implement a systematic approach in conducting barrier 

analyses, including defining barriers, and demonstrate this approach 

in MD-715 reports so that EEOC, relevant units of DHS, and 

Congress can accurately assess USCG’s status in achieving model 

program status.

• Refine its performance measurement plan, with implementation time 

frames, in the key areas to include: 

• ensuring measures are valid representations of performance 

goals,

• including baseline measures, and

• verifying and validating data used for the measures.

Recommendations for 

Executive Action
 

Page 23 GAO-12-135 Coast Guard

We provided a draft of this report to the Secretary of Homeland Security 

for review and comment. In written comments, which are reprinted in 

appendix II, DHS concurred with our recommendations, and provided 

additional comments about USCG’s accomplishments and program 

activities. Regarding the first recommendation, DHS concurred that 

USCG should develop and implement a systematic approach in 

conducting barrier analysis, including defining barriers and demonstrate 

the approach in MD-715 reports. However, DHS also noted that USCG 

believes that it has a systematic approach to barrier analysis, which it has 

demonstrated to the extent possible in past MD-715 reports. DHS added 

that USCG will continue to refine and codify its approach to barrier 

analysis and will document improvements in its annual MD-715 

submissions. Still, based on EEOC’s assessment, and our work, USCG 

did not provide sufficient information about its approach to barrier analysis 

to determine if it was systematic. Therefore, to the extent that USCG’s 

improvements help it establish and demonstrate a systematic approach to

barrier analysis, we encourage its efforts to address our recommendation.

DHS also concurred with our second recommendation for USCG to refine 

its performance measurement plan, with implementation time frames, in 

key areas. The Director noted additional efforts to be taken by USCG to 

improve its plan. 

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

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Homeland Security and other interested parties. In addition, the report 

will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

Agency Comments 

and Our Evaluation
 

Page 24 GAO-12-135 Coast Guard

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

please contact Yvonne D. Jones at (202) 512-6806 or jonesy@gao.gov. 

Contact points for our Office of Congressional Relations and Public 

Affairs may be found on the last page of this report. GAO staff who made 

major contributions to this report are listed in appendix III. 

Yvonne D. Jones 

Director, Strategic Issues 
 

Page 25 GAO-12-135 Coast Guard

List of Requesters

The Honorable John L. Mica

Chairman

The Honorable Nick J. Rahall, II

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Bennie Thompson

Ranking Member 

Committee on Homeland Security

House of Representatives

The Honorable Frank A. LoBiondo 

Chairman

The Honorable Rick Larsen

Ranking Member

Subcommittee on Coast Guard and Maritime Transportation

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Elijah Cummings

House of Representatives
Appendix I: Scope and Methodology

Page 26 GAO-12-135 Coast Guard

To assess how the United States Coast Guard’s (USCG) program 

compares to the Equal Employment Opportunity Commission’s (EEOC) 

standards—as defined in EEOC’s Management Directive 715 (MD-715)—

for a model program, we reviewed EEOC’s MD-715 instructions, 

guidance, and related information available to agencies for completing its 

annual assessments and reports, including how to identify and potentially 

eliminate barriers. 

We reviewed and analyzed USCG’s MD-715 reports for fiscal years 2008 

through 2010 and, more specifically, compared and reviewed the triggers, 

potential barriers, as well as USCG’s plans and activities to eliminate 

barriers. Because it was beyond the scope of this engagement, we did 

not evaluate the accuracy of the data contained in the workforce data 

tables, the extent to which USCG identified all potential barriers, or the 

extent to which plans to eliminate barriers or activities would address 

identified barriers. However, we interviewed agency officials about data 

collection efforts and databases used for establishing and monitoring 

progress. We determined the data to be sufficiently reliable for purposes 

of providing context about the USGC Civil Rights Directorate’s (CRD)

efforts in developing their plan.

We obtained and reviewed information about USCG’s policies, guidance, 

and directives related to MD-715 reporting, including the identification and 

elimination of workforce barriers. We also interviewed USCG officials, 

including CRD officials and officials from the Office of Civilian Human 

Resources and other members of USCG’s MD-715 Task Force, regarding 

policies related to MD-715 reporting. Further, we interviewed EEOC 

officials from its Office of Federal Operations and the Department of 

Homeland Security’s (DHS) Office of Civil Rights and Civil Liberties 

(CRCL) officials regarding MD-715-related issues. 

To assess CRD’s efforts to develop and implement performance goals 

and measures against common practices, we examined the 2009 Booz 

Allen Hamilton (BAH) review of USCG’s CRD program and CRD’s action 

plans to address the 53 recommendations made by BAH for the 

improvement of Coast Guard’s civil rights operations.1

 

1 Booz Allen Hamilton, U.S. Coast Guard Office of Civil Rights Program Review (2009).

To provide 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 27 GAO-12-135 Coast Guard

additional context of CRD’s actions to address the BAH 

recommendations, we reviewed our prior work on CRD.2

We obtained CRD’s performance plan, including performance goal and 

measures to be used by CRD to assess program improvements, as well 

as supporting documentation. We interviewed CRD officials about CRD’s 

plan, to better understand the process CRD took in developing its 

performance plan. We also interviewed CRD officials on their 

development of CRD’s performance plan, including the steps taken and 

guidance used to develop CRD’s performance plan. 

 

To evaluate CRD’s performance plan, we reviewed GAO work on 

common practices of performance goals and measures.3

 

2 GAO, Coast Guard: Civil Rights Directorate Can Enhance Workforce Restructuring

Efforts, 

We determined 

that the performance data were sufficiently reliable for the purposes of 

this report. We also obtained performance information from EEOC and 

DHS’s CRCL about their role and responsibilities in the development of 

agencywide performance measures to use for the evaluation of EEO 

programs. 

GAO-11-718 (Washington, D.C.: July 2011) and GAO, Coast Guard: Civil Rights 

Directorate’s Action Plans to Improve Its Operations Could Be Strengthened by 

Implementing Several Aspects of Project Planning and Implementation Practices, 

GAO-10-571T (Washington, D.C.: Apr. 24, 2010).

3 GAO, The Results Act: An Evaluator’s Guide to Assessing Agency Annual Performance 

Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998) and GAO, Agency Performance 

Plans: Examples of Practices That Can Improve Usefulness to Decisionmakers, 

GAO/GGD/AIMD-99-69 (Washington, D.C.: February 1999).
Appendix II: Comments from Department of 

Homeland Security

Page 28 GAO-12-135 Coast Guard

Appendix II: Comments from Department of 

Homeland Security
Appendix II: Comments from Department of 

Homeland Security

Page 29 GAO-12-135 Coast Guard
Appendix III: Contact and Staff 

Acknowledgments

Page 30 GAO-12-135 Coast Guard

Yvonne D. Jones, (202) 512-6806 or JonesY@gao.gov

In addition to the contact named above, individuals making key 

contributions to this report included Neil A. Pinney, Assistant Director; 

Cheri Y. Truett, Analyst-In-Charge; Irina Carnevale; Robert Gebhart; Lois 

Hanshaw; Angela Leventis; and Terry Richardson.

Appendix III: Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(450868)
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