Diversity Management: Expert-Identified Leading Practices and Agency Examples
Published: 2005-01-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: A high-performance organization relies on a dynamic workforce with the requisite talents, multidisciplinary knowledge, and up-to-date skills to ensure that it is equipped to accomplish its mission and achieve its goals. Such organizations typically (1) foster a work environment in which people are enabled and motivated to contribute to mission accomplishment and (2) provide both accountability and fairness for all employees. To accomplish these objectives, high-performance organizations are inclusive, drawing on the strengths of employees at all levels and of all backgrounds--an approach consistent with diversity management. For purposes of our review, diversity management is defined as a process intended to create and maintain a positive work environment where the similarities and differences of individuals are valued, so that all can reach their potential and maximize their contributions to an organization's strategic goals and objectives. As part of a request that GAO report on the federal government's performance in managing its diverse workforce, GAO was asked to identify (1) leading diversity management practices and (2) examples of the identified practices in the federal government. This report contains no recommendations.
section_title: What GAO Found
paragraphs: Of the experts in the field of diversity management we spoke with or whose publications we reviewed to identify leading diversity management practices, a majority cited the following nine practices as leading. Top leadership commitment--a vision of diversity demonstrated and communicated throughout an organization by top-level management. Diversity as part of an organization's strategic plan--a diversity strategy and plan that are developed and aligned with the organization's strategic plan. Diversity linked to performance--the understanding that a more diverse and inclusive work environment can yield greater productivity and help improve individual and organizational performance. Measurement--a set of quantitative and qualitative measures of the impact of various aspects of an overall diversity program. Accountability--the means to ensure that leaders are responsible for diversity by linking their performance assessment and compensation to the progress of diversity initiatives. Succession planning--an ongoing, strategic process for identifying and developing a diverse pool of talent for an organization's potential future leaders. Recruitment--the process of attracting a supply of qualified, diverse applicants for employment. Employee involvement--the contribution of employees in driving diversity throughout an organization. Diversity training--organizational efforts to inform and educate management and staff about diversity. Experts and the literature generally agree that a combination of the identified practices should be considered when an organization is developing and implementing diversity management. We selected 10 agencies with the highest summary rankings from a 1999 governmentwide survey of federal agencies' diversity management programs to review for examples of the implementation of the identified practices. The implementation of the leading practices by these agencies may provide insights to other agencies as they undertake or attempt to strengthen or improve their own diversity management initiatives. We provided a draft of this report to the Equal Employment Opportunity Commission and the U.S. Office of Personnel Management for review and comment. In their comments, agency officials generally agreed with the findings of the draft report.

section_title: Letter
paragraphs: A high-performance organization relies on a dynamic workforce with the  requisite talents, multidisciplinary knowledge, and up-to-date skills to  ensure that it is equipped to accomplish its mission and achieve its goals.   Such organizations typically foster a work environment in which people are  enabled and motivated to contribute to continuous learning and  improvement as well as mission accomplishment.  Such organizations also  provide both accountability and fairness for all employees.  In addition, the  approach that a high-performance organization takes toward its workforce  is inclusive and draws on the strengths of employees at all levels and of all  backgrounds.  This approach is consistent with that of diversity  management.  For purposes of our review, diversity management is a  process intended to create and maintain a positive work environment  where the similarities and differences of individuals are valued, so that all  can reach their potential and maximize their contributions to an  organization’s strategic goals and objectives.
This report responds, in part, to your request that we report on the federal  government’s performance in managing its diverse workforce.  Our  objectives were to identify (1) leading diversity management practices and  (2) examples of how federal agencies implement the identified practices in  the federal government.  To identify leading diversity management  practices, we first reviewed literature on diversity management.  We then  met with various federal officials and experts in the field of diversity  management.  We identified as leading those diversity management  practices that a majority of experts cited in interviews or publications as  leading practices, best practices, or components of a successful diversity  initiative.  We recognize that other experts may have identified other  practices and are not suggesting that this list is exhaustive.  We did not evaluate the effectiveness of the cited practices, although many of these  practices are consistent with practices identified in prior GAO reports on  human capital management.
To identify agency examples of leading practices in the federal government,  we reviewed diversity management literature and met with officials from  the National Academy of Public Administration and others who directed us  to agencies that may have implemented some of the expert-identified  practices.  Through our literature search, we located a 2001 paper that  ranked federal agencies’ diversity management programs based on results  from a 1999 governmentwide survey, which was administered to 160  agencies and subagencies that represented more than 80 percent of the  federal civilian workforce. We used this paper for selecting federal  agencies because (1) it employed a systematic methodological approach  for gauging agencies’ diversity management programs and (2) we found no  other research subsequent to the paper that assessed agencies’ diversity  management programs using a systematic methodological approach that  covered a large number of agencies and subagencies.  Using the rankings in  that paper, we selected the 10 agencies with the highest summary rankings to examine in more detail. These agencies—in the ranked order cited in  the paper, starting with the highest—were the U.S. Coast Guard, National  Institute of Standards and Technology (NIST), the Department of Veterans  Affairs (VA), Federal Bureau of Prisons (BOP), U.S. Postal Service,  National Oceanic and Atmospheric Administration (NOAA), Veterans  Health Administration (VHA), Food and Drug Administration (FDA),  Federal Aviation Administration (FAA), and National Institutes of Health  (NIH).  Officials from these 10 agencies also provided documents that  illustrated their agencies’ diversity management efforts, including the  expert-identified practices.  The agency examples of diversity management  practices in this report do not represent all the potential ways that an  agency could implement diversity management initiatives or address the  specific diversity management practice being discussed.  We did not  evaluate the effectiveness of each agency’s implementation of the  practices, and the fact that an agency is profiled to illustrate the  implementation of a particular diversity management practice is not meant  to imply agency success or lack of success in the implementation of other  diversity management practices or diversity management overall.
We did our work in Washington, D.C., between July 2003 and October 2004,  in accordance with generally accepted government auditing standards.   Details of our scope and methodology are in appendix I.
subsections: section_title: Background
paragraphs: During the 1980s and 1990s, the composition of the U.S. workforce, as  documented in demographic statistics, became increasingly diverse.  In  1987, a landmark report entitled Workforce 2000, written by researchers  with the Hudson Institute for the Department of Labor, described the  increasing diversity of the American workforce by the year 2000.  Among  the demographic changes the report projected was a rise in the average age  of the workforce and an increase in the number of women and minorities  entering the workforce.  Against this backdrop of expectations for an  increasingly diverse workforce, by the 1990s, an industry of consultants  had developed, offering books, videos, and training to sensitize workplaces  “to the different perspectives and needs of a more diverse workforce.”  Dr.  R. Roosevelt Thomas, Jr. is generally credited with originating the term  “managing diversity” in 1990.
The concept of managing diversity includes everyone and therefore serves  as a complement to equal employment opportunity (EEO).  EEO focuses  on those groups protected by law from employment discrimination.  By  law, employment actions are to be free from prohibited discrimination on  such bases as race, color, religion, gender, national origin, age, or disability.  For purposes of this review, workforce diversity refers to ways  in which people in a workforce are similar and different from one another.   In addition to the characteristics protected by law, other similarities and  differences commonly cited by the literature include but are not limited to  background, education, language skills, personality, sexual orientation, and  work role.  OPM includes workforce diversity as a critical success factor  for one of the six elements of human capital leadership—results-oriented  performance culture—in its Human Capital Assessment and  Accountability Framework.   OPM uses the critical success factors in this  framework when scoring a federal agency’s implementation of Strategic  Human Capital under the President’s Management Agenda.  Among other  things, OPM examines whether an agency maintains an environment  characterized by inclusiveness of individual differences and is responsive  to the diverse needs of employees as a critical success factor.
section_title: Experts Identified Nine Diversity Management Practices as Leading
paragraphs: Of the experts in the field of diversity management we spoke with or whose  publications we reviewed, the majority cited nine practices as leading.   These practices are (1) commitment to diversity as demonstrated and  communicated by an organization’s top leadership; (2) the inclusion of  diversity management in an organization’s strategic plan; (3) diversity  linked to performance, making the case that a more diverse and inclusive  work environment could help improve productivity and individual and  organizational performance; (4) measurement of the impact of various  aspects of a diversity program; (5) management accountability for the  progress of diversity initiatives; (6) succession planning; (7) recruitment;  (8) employee involvement in an organization’s diversity management; and  (9) training for management and staff about diversity management.   Experts and the literature generally agree that some combination of these  identified practices should be considered when an organization is  developing and implementing diversity management.
section_title: Agencies Provided Examples of Their Implementation of the Cited Practices
paragraphs: We met with officials from the 10 agencies selected for our review, and  these officials provided examples of diversity management practices that  their respective agencies had implemented and considered to be leading  practices.  We judgmentally chose from the examples agencies provided to  illustrate the implementation of the nine practices that a majority of  experts cited as leading.  The following sections of this report further  describe the nine practices as well as provide examples of how the selected  agencies have implemented them.
subsections: section_title: Top Leadership Commitment
paragraphs: As we testified in 1999, perhaps the single most important element of  successful management improvement initiatives is the demonstrated  commitment of top leaders to change.  Similarly, top management  commitment is a fundamental element in the implementation of diversity  management initiatives.  According to the literature, leaders and managers  within organizations are primarily responsible for the success of diversity  management because they must provide the visibility and commit the time  and necessary resources.  A leader committed to diversity management  communicates the organization’s support for diversity in newsletters,  policy statements, speeches, meetings, and Web sites.  Communication of  this commitment from senior management throughout the organization  sends a clear message to others in the organization about the seriousness  and business relevance of diversity management.
section_title: Diversity as Part of the Strategic Plan
paragraphs: Because successful change management initiatives in large public and  private sector organizations suggest that it can often take 5 to 7 years to  substantially complete such initiatives, it is important to institutionalize  them by integrating the initiatives into agencies’ strategic planning efforts.
As we have said, sustaining top leadership commitment to improvement is  particularly challenging in the federal government because of the turnover  of senior agency political officials.  In 2003, we reported that  governmentwide, the average tenure of political appointees for 1990  through 2001 was just under 3 years.  Integrating diversity management  into an organization’s strategic plan fosters a culture change that supports  and values differences.  One recognized expert we talked with also pointed  out that an organization must link diversity to its overall strategic plan to  ensure that diversity initiatives are not viewed as an “extra,” which could  make them vulnerable to cuts, for example, when funds are tight.
section_title: Diversity Linked to Performance
paragraphs: By focusing on diversity management and looking for more ways to be truly  inclusive, leading organizations have recognized that diversity can  contribute to the achievement of improved individual and organizational  performance.  According to the literature reviewed, diversity management  makes good business sense that enhances productivity and innovation.  For  example, promoting diversity might help an organization expand services  to meet the needs of a more diverse customer base.   The literature also  stated that fostering a diverse and inclusive workplace could help  organizations reduce costs by reducing turnover, increasing employee  retention across demographic groups, and improving morale.
section_title: Measurement
paragraphs: Quantitative and qualitative performance measures “help organizations  translate their diversity aspirations into tangible practice.”  For example,  an organization can track data on its workforce to evaluate the  effectiveness of the organization’s diversity management efforts and the  progress it is making in those efforts.  Organizations also can track the  return they receive on investments in such areas as diversity training and recruitment to evaluate the progress they are making in those efforts.  In  addition to analyzing quantitative workforce data, organizations can use  qualitative data derived from interviews, focus groups, and surveys for  identifying employee perceptions—including available opportunities and  work environment/culture—among various segments of their workforces.   For example, organizations can ask employees a series of general  organizational questions in such areas as climate, organizational  commitment, promotions, job satisfaction, supervision, and performance  evaluations.  Over time, trends in responses are the types of qualitative  information that can help organizations assess how their diversity  initiatives are progressing in achieving organizational goals and objectives.   Finally, in a 2001 report on human capital and workforce diversity, the  National Academy of Public Administration stated that good performance  measurements shared some common traits regardless of the environment  in which they were used, including being based on reliable and accurate  data that are consistent and compatible with existing business systems and  processes.  VA, for example, provides data on its workforce, including data  on those in the leadership pipeline (i.e., employees in grades 13, 14, and 15),  to all managers through their personal computers.
section_title: Accountability
paragraphs: We have previously pointed to the importance of holding managers  accountable for contributing to the achievement of an organization’s  strategic goals through performance management and rewards systems.   According to diversity management literature, accountability is also a key  element for organizations to ensure the success of a diversity management  effort by providing a means for ensuring that managers at all levels are  made responsible for diversity in their organizations and evaluated on their  progress toward achieving their diversity goals and their ability to manage  a diverse group of employees.  An organization may make managers’  performance ratings and compensation dependent, in part, on their success  in achieving diversity-related goals.  For federal senior executives, such  accountability is consistent with section 4313 of title 5, which provides  performance appraisal criteria for those in the Senior Executive Service  (SES), including the achievement of EEO requirements.  This  accountability also is consistent with EEOC’s recent instructions to federal  agencies for implementing EEO Management Directive 715.  The  instructions describe the requirement that agencies inform managers and  supervisors that success and a positive evaluation will include an  assessment of how that manager contributes to the agency’s EEO program  by emphasizing to managers and supervisors that equality of opportunity is  essential to attracting, developing, and retaining the most qualified  workforce, with such a workforce being essential to ensuring the agency’s  achievement of its strategic mission.
Recognizing that an agency’s people are vital assets and people achieve  organizational goals and results, OPM’s regulations on SES performance  management call for appraisal of executives using measures that balance  organizational results with employee perspectives.  In 2002, we reported  that senior executives can foster fairness and diversity by protecting the  rights of all employees, providing a fair dispute resolution system, and  working to prevent discrimination through equality of employment and  opportunity.  We found examples of senior executive performance  expectations included (1) taking steps to implement EEO requirements;   (2) requiring all subordinate managers and supervisors to receive diversity  awareness and EEO training; and (3) establishing a zero tolerance standard  for discrimination, harassment, and hostile work environments.
section_title: Succession Planning
paragraphs: Succession planning is a comprehensive, ongoing strategic process that  provides for forecasting an organization’s senior leadership needs;  identifying and developing candidates who have the potential to be future  leaders; and selecting individuals from among a diverse pool of qualified  candidates to meet executive resource needs.  Succession planning and  management can help an organization become what it needs to be, rather  than simply recreate the existing organization.  Leading organizations go  beyond a “replacement” approach that focuses on identifying particular  individuals as possible successors for specific top-ranking positions and  engage in broad, integrated succession planning and management efforts  that focus on strengthening both current and future capacity.  They  anticipate the need for leaders and other key employees with the necessary  competencies to successfully meet the complex challenges of the 21st  century.
Succession planning also is tied to the federal government’s opportunity to  change the diversity of the executive corps through new appointments.  As we testified in October 2003, the federal government faces large losses in  its SES, primarily through retirement but also because of other normal  attrition.  The SES generally represents the most experienced and senior  segment of the federal workforce.  The expected loss of more than half of  current career SES members through fiscal year 2007, as well as significant  attrition in the GS-15 and GS-14 workforce—the key source for SES  appointments—has important implications for federal agencies and  underscores the need for effective succession planning.  This presents the  government with substantial challenges for ensuring an able management  cadre and also presents opportunities to affect the composition of the SES.   In September 2003, we reported that agencies in other countries use  succession planning and management to achieve a more diverse  workforce, maintain their leadership capacity, and increase the retention of  high-potential staff.  Our work has shown that federal agencies will need to  enhance their efforts to improve workforce diversity as the SES turns over.
section_title: Recruitment
paragraphs: Recruitment, a key process by which federal agencies attract a supply of  qualified, diverse applicants for employment, is the first step toward  establishing a diverse workforce.  To ensure that organizations are reaching  out to diverse pools of talent, they can widen the selection of schools from  which they recruit to include, for example, historically Black colleges and  universities, Hispanic-serving institutions, women’s colleges, and schools  with international programs.  In addition, the literature discusses the  importance of organizations building formal relationships with such  schools to ensure the cultivation of talent for future talent pools.  The  literature states that organizations also may want to consider partnering  with multicultural professional organizations and speaking at their  conferences to communicate their commitment to diversity to external  audiences and strengthen and maintain relationships.  Although the focus  of recruitment efforts in the diversity management literature is with  colleges and universities, given the number of federal employees, including  those in the SES, who are eligible for retirement in the next few years, there  will be a need for the federal government to also recruit midcareer  employees, which we are defining as employees who are generally 40 and  over and have 10 or more years of work experience.
section_title: Employee Involvement
paragraphs: According to the literature, involving employees in diversity management  helps them contribute to driving diversity throughout an organization.   Employees may become involved in their organizations’ diversity  management efforts by forming employee diversity task forces, councils,  boards, and networks (also called advisory, advocacy, support, affinity, or  resource groups) to identify issues, recommend actions, and help develop  initiatives.  Organizations also can establish advisory groups that include  representatives from many specific groups.  In addition, mentoring  programs are a popular method for organizations to develop and retain  newer employees and require the involvement of more senior or  experienced employees.   The diversity management literature also  describes employees reaching out in their communities.
subsections: section_title: Forming Advisory Groups to Facilitate Change
paragraphs: Most of the 10 agencies had some type of diversity advisory board.
According to one expert, mentoring programs became popular in the mid- 1980s as part of organizations’ efforts to improve the promotion and  retention of women and minorities.  However, as mentoring success stories  continued, organizations increasingly realized that mentoring relationships  could benefit all employees, not just those from the protected groups.   Mentoring can help new employees adjust to an organization’s culture.  It  also can help identify and develop high-potential employees, improve  employee productivity and performance, and promote retention and  diversity.
Several sources described organizations’ encouraging employees to  volunteer in their communities to help make the communities aware of  what the organization does. In addition, in its recent instructions to  federal agencies for implementing EEO Management Directive 715, EEOC  suggests that agencies allocate mission personnel to participate in, among  other things, community outreach programs with private employers, public  schools, and universities.
section_title: Diversity Training
paragraphs: According to the literature, diversity training can help an organization’s  management and staff increase their awareness and understanding of  diversity as well as help them develop concrete skills to assist them in  communicating and increasing productivity.  Such training can provide  employees with an awareness of their differences—including cultural,  work style, and personal presentation—and an understanding of how  diverse perspectives can improve organizational performance.  It also  should teach employees about the importance of the organization’s  diversity goals and the skills required to work effectively in a diverse  workforce.  In addition, to increase employee effectiveness in a diverse  environment, one source stated that training should include teambuilding,  communication styles, decision making, and conflict resolution.  This is  consistent with EEOC’s recent instructions to federal agencies for  implementing EEO Management Directive 715, which requires that  agencies develop supervisors and managers who have effective managerial,  communication, and interpersonal skills to supervise most effectively in a  workplace with diverse employees.  Finally, as we recently reported on  training in the federal government, agencies should attempt to assess the  effectiveness of their training efforts.  Such an assessment can help  decision makers in managing scarce resources and help agencies improve  results.
section_title: Agency Comments
paragraphs: On November 10, 2004, we provided a draft of this report to EEOC and  OPM for review and comment.  In written comments, the Director of  EEOC’s Office of Federal Operations generally agreed with the findings of  the draft report and stated that expanding agency knowledge of the  available tools to achieve diversity is critical to the government’s success in  maintaining a workplace that is inclusive and responsive to the needs of an  increasingly diverse workforce (see app. IV).  The Director stated that  federal agencies can learn from the experiences and successes of others  and that this report would assist in that effort.  He added that future studies  of diversity management practices are warranted and could explore the  effectiveness of these practices, particularly measurement.   We agree.  We  have an engagement under way that reviews measurement practices for  EEO and diversity management in selected federal agencies.  We also have  begun work that is to provide examples from the private sector of the  leading diversity management practices identified in this report.  In written  comments, the Director of OPM generally agreed with the findings of the  draft report, noting that the agencies identified merit recognition for their  efforts in diversity management (see app. V).  The Director of OPM also  noted that the area of diversity is an important element in the President’s  Management Agenda.  In addition, the Director of OPM provided technical  comments, which we incorporated.
We also provided drafts of the relevant sections of this report to cognizant  officials from the 10 agencies we reviewed.  We made technical  clarifications based on these comments where appropriate.
As arranged with your office, unless you publicly announce its contents  earlier we plan no further distribution of this report until 7 days from the  date of this letter.  At that time, we will send copies of this report to other  interested congressional parties, the Director of OPM, and the Chair of  EEOC.   We also will make copies available to others upon request.  In  addition, the report is available on GAO’s home page at http://www.gao.gov.
If you or your staff have questions about this report, please contact me on  (202) 512-9490 or Belva Martin, Assistant Director, on (202) 512-4285.  Key  contributors to this report are listed in appendix VI.
section_title: Objectives, Scope, and Methodology
paragraphs: Our objectives were to identify (1) leading diversity management practices  and (2) examples of those practices in federal agencies.
subsections: section_title: Objective 1: Identifying Leading Practices
paragraphs: To identify leading diversity management practices, we first reviewed  literature on diversity management.  This review included academic  literature on diversity management, books and articles written by  consultants and practitioners, and reports produced by government  agencies and research organizations.
We then met with various federal officials and experts in diversity  management.  This included officials from the central leadership  agencies—the Equal Employment Opportunity Commission (EEOC), Merit  Systems Protection Board, U.S. Office of Personnel Management (OPM),  and the U.S. Office of Special Counsel.  At the National Academy of Public  Administration (NAPA), we met with one former official—a former  Director of the Center for Human Resource Management—and two current  officials—the Director and Deputy Director of the Center for Human  Resources Management.  These officials were helpful in suggesting experts  to contact in the field of diversity management.
On the basis of our literature review and our discussions with federal and  NAPA officials, we established criteria for and identified a list of  recognized experts.  These criteria included  the expert’s recognition in the professional or academic community,  depth of experience in diversity management, and  relevance of his or her published work or research to diversity  management.
We defined recognition as an acknowledgment of expertise from officials  of such organizations as NAPA, the Society for Human Resource  Management, and the Private Sector Council.  We defined experience as  having practical or academic experience in diversity management for at  least 7 years.  After the experts were selected, we gathered their views on  leading practices using questions from a data collection instrument.  We  reviewed their responses and counted the number of times an expert or a  publication by an expert cited a diversity management practice.  We  identified as leading those practices that a majority of experts cited in  interviews or publications as leading practices, best practices, or  components of a successful diversity initiative.
Our characterization of diversity management practices is  methodologically dependent on the experts contacted and sources  reviewed.  We recognize that had we interviewed other experts or reviewed  other sources that other practices may have been identified as leading.  We  also recognize that diversity management practices are dynamic in nature  and other practices that were not cited by a majority of our sources may,  over time, achieve greater acknowledgment.  In addition, we did not  evaluate the effectiveness of the cited practices, although many of these  practices are consistent with practices identified in prior GAO reports on  human capital management.
section_title: Objective 2: Identifying Examples of Leading Diversity Management Practices in the Federal Government
paragraphs: To identify agency examples of leading practices in the federal government,  we reviewed diversity management literature and met with officials from  NAPA and others who directed us to agencies that may have implemented  some of the expert-identified practices.   Through our literature search, we  located a 2001 paper by Dr. J. Edward Kellough of the University of Georgia  and Dr. Katherine Naff of San Francisco State University.  This paper  ranked federal agencies’ diversity management programs based on results  from a 1999 governmentwide survey, which was administered to 160  agencies and subagencies. We used this paper for selecting federal  agencies because it employed a systematic methodological approach for  gauging agencies’ diversity management programs.  Through our literature  search, we found no other research subsequent to the paper that assessed  agencies’ diversity management programs using a systematic  methodological approach that covered a large number of agencies and  subagencies.  Of the organizations responding to the governmentwide  survey, 138, or 86 percent, returned usable questionnaires.  These  organizations represented more than 80 percent of the federal civilian  workforce, including components from the 23 largest departments and  agencies as well as the U.S. Postal Service and most of the smaller  agencies.
In their paper, Drs. Kellough and Naff identified five separate aspects of  agencies’ diversity management programs that address  characteristics of diversity training efforts,   internal communications regarding programs,   activities reflective of broader resource commitments to the programs,   the scope of programs in terms of the dimensions of diversity addressed.
Drs. Kellough and Naff assigned scores by summing agency responses to  each of the relevant survey items.  From the Kellough-Naff list, we chose  the 10 agencies with the highest summary ranking to examine in more detail.  These agencies were the U.S. Coast Guard, National Institute of  Standards and Technology, the Department of Veterans Affairs  (headquarters), Federal Bureau of Prisons, U.S. Postal Service, National  Oceanic and Atmospheric Administration, Veterans Health Administration,  Food and Drug Administration, Federal Aviation Administration, and  National Institutes of Health.
We developed a list of topics related to diversity management practices to  facilitate our discussion with agency officials.  The list included  identification of leading diversity management practices, definition of  diversity, measures of success, barriers to implementation, and examples  of leading practices that have been implemented.  We provided the list to  each agency.  For some agencies, when we were able to obtain information  on their diversity management practices before meeting with them, we  developed more extensive questions.  We then conducted interviews with  officials from these agencies who were responsible for diversity  management and equal employment opportunity (EEO).  During these  interviews, we covered the material on the list, and agency officials  described what they considered to be the agencies’ leading diversity  management practices.  Agency officials also provided documents that  illustrated their agencies’ diversity management efforts, including the  expert-identified practices.
The agency examples of diversity management practices in this report do  not represent all the potential ways that an agency can implement diversity  management initiatives or address the specific diversity management  practice being discussed.  Because our review objectives did not include  evaluating the effectiveness of agencies’ implementation of diversity  management practices, we did not evaluate the effectiveness of the agency  examples. Further, the fact that an agency is profiled to illustrate the  implementation of a particular diversity management practice is not meant  to imply agency success or lack of success in the implementation of other  diversity management practices or diversity management overall.
We did our work in Washington, D.C., between July 2003 and October 2004,  in accordance with generally accepted government auditing standards.
section_title: Summary of Selected Antidiscrimination Laws
paragraphs: Over the past 40 years, Congress has enacted a number of laws prohibiting  employment discrimination with the intent of ensuring equal opportunity in  employment, both in the public and private sectors.  Among these  enactments is Title VII of the Civil Rights Act of 1964, amended in 1972 to  include the federal sector, which makes it illegal for employers to  discriminate against their employees or job applicants on the basis of race,  color, religion, sex, or national origin.   The 1972 amendment also requires  federal agencies to maintain an affirmative program of equal employment  opportunity.
Section 501 of the Rehabilitation Act of 1973, as amended, prohibits  discrimination against qualified individuals with disabilities who work or  apply to work in the federal government and requires federal agencies to  prepare affirmative action plans.   Title I of the Americans with Disabilities  Act (ADA) of 1990 prohibits employment discrimination against qualified  individuals with disabilities in the private sector and in state and local  governments.   In 1992, the Rehabilitation Act was amended to adopt the  ADA standards in determining whether a federal employer engaged in  prohibited discrimination.
The Age Discrimination in Employment Act of 1967, amended in 1974 to  include the federal sector, prohibits employment discrimination against  individuals who are 40 years of age or older.
The Equal Pay Act of 1963 protects men and women who perform  substantially equal work in the same establishment from sex-based wage  discrimination.
section_title: Recognized Experts
paragraphs: Susan Black   Vice President, Catalyst, Canada Todd Campbell  Diversity Initiative Manager,   Society for Human Resource Management Taylor H. Cox, Jr.*  CEO, Taylor Cox Associates John P. Fernandez*  President,   Advanced Research Management Consultants Edie Fraser  President, Diversity Best Practices Lee Gardenswartz & Anita Rowe*  Partners, Gardenswartz & Rowe Carol A. Hayashida  Former Deputy Director,   Center for Human Resources Management   National Academy of Public Administration Robert C. Holland*  Director, Diversity Analysis Research Team,   SEI Center for Advanced Studies in Management,   Wharton School, University of Pennsylvania Karen A. Jehn*  Faculty Coordinator of the George Harvey Program  for Redefining Diversity, Wharton School,  University of Pennsylvania J. Edward Kellough  Director, Department of Public Administration and Policy,  University of Georgia Ann M. Morrison*  Honorary Senior Fellow, Center for Creative Leadership Katherine C. Naff  Associate Professor, Department of Public Administration,  San Francisco State University Nancy Nelkin  Director Audit Services,   Equal Employment Advisory Council Jeffrey A. Norris  President, Equal Employment Advisory Council Al Ressler  Former Director, Center for Human Resources Management,   National Academy of Public Administration Myra Howze Shiplett  President, Randolph Morgan Consulting, LLC Pete Smith  Former President, Private Sector CouncilR. Roosevelt Thomas, Jr.  President, The American Institute for Managing Diversity Mauricio Velasquez*  President, The Diversity Training Group Jo Weiss  Former Vice President of   Advisory Service and Member Relations,   Catalyst Trevor Wilson  President, TWI, Inc.
We also spoke with officials from and reviewed publications of the U.S.  Equal Employment Opportunity Commission, the U.S. Office of Personnel  Management, and the Corporate Leadership Council.  For experts with an  asterisk by their names (*), we reviewed their publications but did not  interview them.
section_title: Comments from the Equal Employment Opportunity Commission
paragraphs: The Honorable David M. Walker  Comptroller General of the United States  U. S. Government Accountability Office  Thank you for the opportunity to review and comment on the draft report, Diversity  Management:  Expert-Identified Leading Practices and Agency Examples (GAO-05-90).
I commend you for identifying leading diversity management practices and their use in  the federal government.  Expanding agency knowledge of the available tools to achieve diversity  is critical to the government’s success in maintaining a workplace that is inclusive and  responsive to the needs of an increasingly diverse workforce.
The agency examples included in the report should demonstrate the principles of  workforce diversity.  Federal agencies can learn from the experiences and successes of others.
While this report will assist in that effort, additional studies are clearly needed to explore this  area in more depth.
EEOC believes that Management Directive-715 will be an invaluable tool to help  agencies to improve their workforce diversity and could assist in this effort.  As you know,  EEOC expects to begin receiving federal agency MD-715 reports beginning in January, 2005   and EEOC can begin providing data that would facilitate GAO’s knowledge base in such an  evaluation.  In short, future studies of this area are warranted to evaluate whether the identified  diversity management practices have actually achieved or improved workforce diversity in  general or in the federal agencies covered.
One of the nine important factors to diversity management GAO cites is “measurement.”
A future study could also examine  initiatives to measure diversity and  how particular measures  relate  to the cited practices.  Because GAO reports are widely read throughout the federal  government and viewed as being highly authoritative, and because there are so few reports on  diversity in the federal sector, future studies could explore in more depth the effectiveness of  leading diversity practices.
The Honorable David M. Walker  This report defines diversity as the ways in which people in a workforce are similar and different  from each other, including race, ethnicity, gender, age, background, education,   work role and personality. A future report might provide a discussion of the means through   which agencies can determine how the multitude of similarities and differences that individuals  bring to the workplace are important to creating a “high performance organization” with “a  positive work environment where . . . all can reach their potential and maximize their  contributions to an organization's strategic goals and objectives.”
Such a study would be a valuable supplement to this report. Several organizations in this  area could be consulted in studying the relationships among these variables such as Diversity  Inc. and the National Multicultural Institute. Diversity Inc, for example, periodically publishes  various lists showing the top companies for diversity and which also purport to show a  relationship between diversity and profitability.
Again, thank you for the opportunity to submit the EEOC’s views on your draft report.
section_title: Comments from the Office of Personnel Management
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the individual named above, Karin K. Fangman, Eric Gorman,  Emily Hampton-Manley, Sharon Hogan, Belva Martin, Kiki  Theodoropoulos, Michael R. Volpe, and Gregory H. Wilmoth made key  contributions to this report.