U.S. Department of Labor

Office of Labor - Management 

Standards

November 2020
2

TABLE OF CONTENTS

TAB 1: AGENCY ORGANIZATIONAL OVERVIEW ........................................................ 1

TAB 2: STATE OF PLAY....................................................................................................... 5

TAB 3: CALENDAR .............................................................................................................. 7

TAB 4: BUDGET.................................................................................................................... 8

TAB 5: AGENCY PERFORMANCE................................................................................... 12
TAB 1: Agency Organizational Overview

1

TAB 1: AGENCY ORGANIZATIONAL OVERVIEW

Mission

The Office of Labor-Management Standards (OLMS) in the U.S. Department of Labor is the 

Federal agency responsible for administering and enforcing most provisions of the LaborManagement Reporting and Disclosure Act of 1959, as amended (LMRDA). For more detailed 

information please visit DOL.gov.

1

Authorizing Legislation

The Secretary of Labor enforces certain provisions of the LMRDA and has delegated that 

authority to OLMS. For more information, please visit DOL.gov.

2

Organizational Structure

Approximately 195 Federal and 12 contract employees staff OLMS. The structure includes five 

national office components in addition to the offices of the director and deputy director, and 16 

field offices including 4 regional offices and 12 subordinate district offices. National office 

components employ approximately 39 employees and 12 contractors; the field offices comprise 

approximately 144 employees, the majority of whom are investigators. 

 1 https://www.dol.gov/olms/about/mission_and_purpose.htm

2 https://www.dol.gov/olms/about/mission_and_purpose.htm
TAB 1: Agency Organizational Overview

2

Organizational Chart

OLMS Director

Vacant

(Non-Career SES)

Deputy Director

Andrew Auerbach

(Career SES)

Division of Enforcement

Tracy Shanker

(Career GS)

Division of Planning, 

Management and Technology

Teresa Thomas

(Career GS)

Office of Field Operations

Brian Pifer

(Career SES)

Office of Program Operations

Jena Raney 

(Career SES)

Special Assistant

Karen Torre

(Career GS)

Division of Interpretation and 

Standards

Andrew Davis

(Career GS)

Northeastern Region

Andriana Varrvakas

(Career SES)

Southern Region

Daniel Cherry

(Career SES)

Central Region

Daniel LaFond

(Career SES)

Western Region

Emily Prosise

(Career SES)

Division of Reports, 

Disclosures and Audits

James Haskins

(Career GS)
TAB 1: Agency Organizational Overview

3

Workforce At-A-Glance

Organizational Changes During the Past Four Years

In Fiscal Year (FY) 2020, OLMS dissolved the Division of Statutory Programs. The Division

administered DOL responsibilities under the Federal Transit Act by ensuring that fair and 

equitable arrangements protecting mass transit employees are in place before the release of 

federal transit grant funds. These arrangement protect against infringement to collective 

bargaining and other rights by the transit authorities receiving the grant funds. Due to 

Information Technology (IT) advances and streamlining of agency processes, the process for 

certifying the grants had been so simplified as to no longer require a standalone division. The 

responsibility for administering this program was transferred to the Division of Interpretations 

and Standards. 
TAB 1: Agency Organizational Overview

4

Key Leaders 

• Vacant, Director

• Andrew Auerbach, Deputy Director 

• Brian Pifer, Director of the Office of Field Operations 

• Jena Raney (Acting), Director of the Office of Program Operations

• Dan Cherry, Regional Director (Southern Region)

• Dan LaFond, Regional Director (Central Region)

• Andriana Vamvakas, Regional Director (Northeastern Region)

• Emily Prosise, Regional Director (Western Region)

• Andrew Davis, Chief, Division of Interpretations and Standards 

• Teresa Thomas, Chief, Division of Planning, Management and Technology 

• James Haskins, Chief, Division of Reports, Disclosure and Audits 

• Tracy Shanker, Chief, Division of Enforcement
TAB 2: State of Play

5

TAB 2: STATE OF PLAY

Key Meetings, Decisions and Announcements

Nothing scheduled

Policy and Regulatory Issues 

• The Office of Labor-Management Standards (OLMS) proposed a regulation on October 

9, 2020 that would revise the annual public disclosure report filed by labor unions, the 

Form LM-2. It would also introduce a new form, the Form LM-2 LF, which would be 

applicable to unions with $8,000,000 or more in annual receipts. The comment period 

closes December 14, 2020. 

• OLMS placed on the regulatory agenda a Notice of Proposed Rulemaking relating to the 

Form LM-30, Officer and Employee Report. Labor organization officers and employees 

complete Form LM-30, when they engage in certain transactions with employers and 

businesses. This is a conflict-of-interest report and OLMS will review the form and 

instructions to enhance transparency for union members and the public.

• Policy work over the past four years includes the establishment of the Form T-1 Trust 

Annual Report. Every covered labor organization, with total annual receipts of $250,000 

or more or which otherwise files the Form LM-2, must file a Form T-1 each year for each 

trust in which it is interested, if certain conditions exist.

Enforcement 

• OLMS conducts both civil and criminal investigations of alleged violations of the LaborManagement Reporting and Disclosure Act (LMRDA) and related laws. These 

investigations by OLMS District Offices involve issues such as embezzlements of union 

funds, union officer elections, the filing of required reports by unions and others with 

OLMS, and the imposition of trusteeships over subordinate unions by a parent body. 

These investigations may result in legal enforcement actions.

• In FY 2020, OLMS investigated 100 union elections after complaints of violations and 

supervised 17 rerun elections due to election violations, in our efforts to promote 

democracy in labor organizations. OLMS conducted 223 criminal investigations, and 

recorded 61 indictments and 69 convictions. OLMS conducted over 4,000 participant 

hours of compliance assistance instruction, helping labor organizations comply with the 

law. OLMS obtained restitution, or orders of restitution, of $3,886,997. OLMS also 

exceeded it goals by reducing the average number of days to resolve union officer 

election complaints to 64.9 days. OLMS finds evidence of criminal misconduct in 20% 

of its targeted audits.
TAB 2: State of Play

6

Key Agency Stakeholders

All labor organizations representing private sector or federal employees are Office of LaborManagement Standards (OLMS) stakeholders. Large national and international labor 

organizations are key stakeholders, in that 43 of them are members of OLMS’ voluntary 

compliance partnership (VCP) program. VCP is intended to help strengthen the compliance 

performance of approximately 16,000 intermediate and local labor union affiliates. OLMS VCP 

staff meets with international and national union staff to exchange information and strategize on 

how to best help affiliated local unions achieve compliance with the Labor-Management 

Reporting and Disclosure Act of 1959 (LMRDA). In addition, all large national and 

international labor organizations are subject to audit under OLMS’ International Compliance 

Audit Program (I-CAP). 

Transit authorities that make applications for grants for federal funds for capital or operating 

expenses, and the labor organizations representing affected employees, are stakeholders in 

OLMS’ 13(c) program. More information can be found at 

https://www.dol.gov/agencies/olms/foia/transit. 
TAB 3: Calendar

7

TAB 3: CALENDAR

Event Date

No calendar events currently scheduled
TAB 4: Budget

8

TAB 4: BUDGET

Budget Authority and FTE Summary

(Dollars in millions)

FY 2018

Enacted

FY 2019

Enacted

FY 2020

Enacted

FY 2021

Pres. Bud.

FY 2022

Request

Budget Authority $40.2 $41.2 $43.2 $50.4 $54.3

FTE 189 186 193 238 238

At-A-Glance

• OLMS is a single budget activity agency and is funded through an annual appropriation. 

Prior to FY 2009, OLMS was a part of the Employment Standards Administration (ESA). 

In 2009, ESA was eliminated and OLMS became an independent agency reporting 

directly to the Secretary of Labor. 

Budget and FTE Trends

• OLMS’ budget authority has ranged from a high of $45.3 million in FY 2009 to a low of 

$38.2 million in FY 2017. 

• OLMS’ funding was stable until it was reduced by $2.2 million for sequestration in FY 

2013. During sequestration, OLMS originally planned to absorb reductions by 

furloughing all employees for seven days. Due to unexpected attrition, however, OLMS 

was able to reduce the number of furlough days to 2.5. The agency absorbed the 

remainder of the reduction by eliminating performance bonuses, training, travel, and 

reducing its payment to the Working Capital Fund. 

• The agency’s budget authority was not increased from sequestration levels until FY 2016. 

However, the FY 2017 Enacted appropriation brought the agency back to sequestration 

levels. As a result, the Department’s Operating Plan provided OLMS with an additional 

$1.145 million to eliminate the need for furloughs and maintain program operations. 

• The FY 2018 Enacted appropriation provided OLMS with a $2 million increase above 

the FY 2017 level. However, OLMS still required a transfer of $1.2 million from the 

State Unemployment Insurance and Employment Service Operations (SUIESO) in FY 

2018 to cover Salary and Expenses (S&E) expenses and prevent furloughs. 

• The FY 2019 enacted budget provided resources to restore the OLMS core enforcement 

program and to bring the International Union Compliance Audit Program into full 

operation. However, OLMS required and received a transfer from ETA SUIESO for 

$1,235,000 to fully fund FTE in Salaries and Expenses which increased the total 

apportionment to $42.4 million.

• The FY 2020 enacted budget provided resources to restore core enforcement programs to 

better protect union financial integrity and democracy and to bring the International 

Union Compliance Audit Program into full operation. In Q3 OLMS required a transfer of 
TAB 4: Budget

9

$1.3 million from Community Service Employment for Older Americans CSEOA to 

cover S&E expenses and prevent furloughs. 

• The FY 2021 President’s Budget of $50.4 million and 238 FTE will allow OLMS to 

conduct more compliance audits of unions to uncover violations of the LMRDA and 

carryout more criminal investigations. This will expand the forum to provide compliance 

assistance regarding statutory reporting and recordkeeping requirements, and to deter and 

identify potential criminal violations.

• The FY 2022 request of $54.3 million and 238 FTE will greatly enhance its ability to 

pursue program improvements that deliver more effective and efficient protection of 

union financial assets through increased compliance audits and leveraging compliance 

assistance resources for e-filing, union election procedures, and bonding requirements.

Upcoming Issues

The electronic Labor Organization Reporting System (e.LORS) is the only business process 

technology supporting the various aspects of the OLMS mission (e.g., enforcement of the 

LMRDA, internal staff operations, data management, and public access to the information 

obtained). The system uses 20+ year old client-server technology that has no vendor support nor 

is it supportable by DOL’s cloud-based enterprise platform infrastructure. With modernization 

funding, OLMS will leverage the existing technology gains of the DOL enterprise platform, and 

also develop additional functionality that is not available from the platform but is required by the 

mission business processes using modern technology. Additionally, hiring support staff with 

knowledge of the Delphi technology has become increasingly difficult to fill vacant positions. 

The Office of the Chief Information Officer (OCIO) has identified e.LORS as one of highest 

priority systems for modernization due to the inherent risks associated with using outdated 

legacy technology. 
TAB 4: Budget

10

FY 2012 FY 2013 FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

PB

Request $41.4 $41.8 $46.9 $41.2 $47.0 $45.7 $46.6 $46.6 $49.1 $50.4

Enacted $41.3 $39.1 $39.1 $39.1 $40.6 $39.3 $41.4 $42.4 $44.5

$0

$10

$20

$30

$40

$50

$60

OLMS

Request vs. Enacted, FY 2012-FY 2021

(Dollars in millions)

FY

2012

FY

2013

FY

2014

FY

2015

FY

2016

FY

2017

FY

2018

FY

2019

FY

2020

Enacted $41.3 $39.1 $39.1 $39.1 $40.6 $39.3 $41.4 $42.4 $44.5

Inflation Adjusted $41.3 $41.9 $42.6 $42.6 $43.2 $44.1 $45.1 $46.0

$34

$36

$38

$40

$42

$44

$46

$48

OLMS

FY 2012 Inflation Adjusted BA vs. FY 2012-FY 

2020 Enacted BA

(Dollars in millions)
TAB 4: Budget

11

FY 2012 FY 2013 FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

Enacted $41.3 $39.1 $39.1 $39.1 $40.6 $39.3 $41.4 $42.4 $44.5

Obligations $41.2 $39.0 $39.0 $39.1 $40.5 $39.2 $41.3 $42.4 $44.4

$36

$37

$38

$39

$40

$41

$42

$43

$44

$45

OLMS

Budget Authority vs. Obligations, FY 2012-FY 

2020

(Dollars in millions)

FY

2012

FY

2013

FY

2014

FY

2015

FY

2016

FY

2017

FY

2018

FY

2019

FY

2020

FY

2021

PB

Authorized 230 228 218 215 209 196 189 186 193 238

Actuals 228 222 211 209 199 195 190 189 190

0

50

100

150

200

250

OLMS

Authorized FTE vs. Actuals, FY 2012-2021
TAB 5: Agency Performance

12

TAB 5: AGENCY PERFORMANCE

OLMS has implemented a number of changes in its internal processes to become more efficient. 

For instance, through changes such as increased communications between national and field 

offices, among staff and management, and its partnership with the Office of the Solicitor (SOL), 

OLMS has reduced the average number of days to resolve union officer election complaints from 

77 days in Fiscal Year (FY) 2006 to 65.6 days in FY 2019. OLMS has further reduced the 

average to 63.8 in FY 2020.

Because it is not feasible for OLMS to audit every union for malfeasance, OLMS developed a 

methodology to direct its auditing resources to unions where criminal activity is more likely to 

be found. Criminal cases arising from audits are known as “fallouts.” The “fallout” measure 

tracks the number of targeted audits that result in a criminal case. Improved targeting has 

allowed OLMS to mitigate somewhat the expected decline in criminal cases that could have 

resulted from the declining number of OLMS staff. While the decline in staff has resulted in a 

decrease in the number of both audits and criminal investigations, increased effectiveness, 

efficiency and targeting prevented the decline in cases processed from being significantly 

greater. Beginning in FY 2012, when OLMS formally began using a targeting model, the fallout 

rate increased from 13.81 percent to 19 percent in FY 2019. By the end of FY 2020, the fallout 

rate has increased to 20 percent.

77

86

92

70

81 79

71 71 72.4 70.2 67.4 64.7 68.8 65.6

63.8

0

10

20

30

40

50

60

70

80

90

100

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

AVERAGE DAYS

FISCAL YEAR

Average Number of Days to Resolve

Union Officer Election Complaints - FY 2006-2020
TAB 5: Agency Performance

13

Under the LMRDA, unions, employers, labor consultants and others must file a number of 

reports and documents. Some of these reports can be filed electronically through the OLMS 

electronic Labor Organization Reporting System (e.LORS). Some unions, employers, and other 

individuals continue to file paper versions of their documents, and OLMS must ensure these too 

are available for disclosure. OLMS ensures the public has access to these documents through the 

OLMS website. Increasing the percentage of forms filed electronically cuts costs by eliminating 

the need to scan manually submitted forms, aids in transparency by making electronically 

submitted forms available on the website almost instantaneously, and ensures that electronic 

submissions are submitted in accordance with a series of business rules to avoid inaccuracies. 

Through outreach and other efforts, OLMS has increased the percentage of reports filed 

electronically from 21.4 percent in FY 2011 to 85.3 percent in FY 2019 and 89.6 percent in FY 

2020. The regulatory requirement for LM-3 and LM-4 filers to file electronically, which began 

with the 2017 filing year, has helped to markedly increase the e-filing rate.

12.47%

14.76% 15.18%13.81%

20.97% 21.70% 21.46%

17.14% 18.75% 20.00% 19.00%20.00%

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

PERCENT

FISCAL YEAR

Fallout Rate (Percentage of Targeted Audits that Result in a Criminal 

Case) FY 2009-2020 

21.4%

37.8%

42.4% 45.0% 49.0% 50.1%

58.0%

76.5%

85.3% 89.6%

0%

20%

40%

60%

80%

100%

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

PERCENT

FISCAL YEAR

Percent of Disclosure Reports Filed Electronically 

FY 2011-2020