The Federal Workforce: Additional Insights Could Enhance Agency Efforts Related to Hispanic Representation
Published: 2006-08-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Hispanic representation in the federal workforce has historically been lower than in the Civilian Labor Force (CLF). Understanding factors affecting representation is important to developing and maintaining a high-quality and inclusive workforce. In this report, GAO identifies and analyzes factors affecting Hispanic representation in the federal workforce, examines oversight roles of EEOC and OPM, and provides illustrations of selected federal agencies' efforts with respect to Hispanic representation. GAO constructed a multivariate logistic regression model, with advice from experts, to determine how factors affected the likelihood of Hispanics and non-Hispanics being in the federal versus nonfederal workforce. GAO's analyses are not intended to and do not show the existence or absence of discrimination in the federal workforce.
section_title: What GAO Found
paragraphs: U.S. citizenship and educational attainment had the greatest effect, of the measurable factors we identified, on Hispanic representation in the federal workforce. Our statistical model showed that when accounting for citizenship, required for most federal employment, Hispanics were nearly as likely as non-Hispanics to be employed in the federal workforce, relative to the nonfederal workforce (the portion of the CLF excluding federal employees). In addition, the federal workforce has a greater proportion of occupations that require higher levels of education than the CLF. When we compared citizens with similar levels of education, Hispanics were more likely than non-Hispanics to be employed in the federal workforce relative to the nonfederal workforce. Other factors in our model, including age, gender, race, veteran's status, English proficiency, and geography (state where employed), had a more limited or almost no effect on the likelihood of Hispanics being in the federal workforce. In addition to reporting and comparing representation levels overall and in subsets of the federal workforce to the CLF, EEOC and OPM require that agencies analyze their own workforces. However, the CLF benchmarks of representation that EEOC, OPM, and the agencies use do not differentiate between citizens and noncitizens, and therefore do not identify how citizenship affects the pool of persons qualified to work for the federal government. Where these analyses identify differences in representation, EEOC, for example, requires agencies to determine if there are barriers to participation and develop strategies to address them. OPM provides resources and guidance to assist agencies in implementing human capital strategies. Through these efforts, OPM has promoted the use of student employment programs as a source of qualified candidates. Analyzing agency use of these programs, including the extent to which agencies convert participants to permanent employment, could provide OPM with valuable information to assist agencies in maximizing the use of these programs in their strategic workforce planning. The agencies we reviewed use a variety of approaches to address Hispanic representation, including recruiting at colleges and universities with large Hispanic populations, publicizing employment opportunities in Hispanic media, reaching out to Hispanic communities and Hispanic-serving organizations, and using student employment, internship, career development, and training programs. For example, the U.S. Air Force partners with vocational-technical schools to develop aircraft maintenance technicians, and staff at selected National Aeronautics and Space Administration facilities mentor and tutor students to encourage careers in science, technology, engineering, and math.

section_title: Letter
paragraphs: Hispanics are the fastest-growing segment of the Civilian Labor Force  (CLF), with their representation having increased from 8.5 percent in 1990  to 12.6 percent in 2005. The Equal Employment Opportunity Commission  (EEOC) and the Office of Personnel Management (OPM) have reported  that Hispanic representation in the federal workforce has also increased,  but remains lower in the federal workforce than in the CLF. For 2005, OPM  reported that Hispanics were 7.4 percent of the federal workforce, up from  5.3 percent in 1990.
Previous studies have identified factors that can affect Hispanic  representation in the federal workforce but generally did not assess the  extent to which these factors influence representation. Understanding how  the factors affect Hispanic representation in the federal workforce is  important to guiding agency efforts, under the leadership of OPM and  EEOC, to develop approaches to recruit, develop, and retain a high-quality  workforce that uses the talents of individuals from all segments of society.  In this report, prepared in response to your request, we (1) identify and  analyze the factors that are affecting Hispanic representation in the federal  workforce, (2) examine the steps that EEOC and OPM, in their oversight  roles, are taking related to Hispanic representation, and (3) illustrate the  efforts within selected federal agencies related to Hispanic representation.  We will also be providing additional data on Hispanic representation in the  federal workforce under separate cover.
In accomplishing our objectives, we interviewed federal agency officials  and representatives from Hispanic-serving organizations and reviewed  previous studies to identify factors that can affect Hispanic representation.  To determine the effect of these factors on Hispanic representation in the  federal workforce, we constructed a multivariate logistic regression model  using 2000 Decennial Census data. Logistic regression analysis is a very  common and widely accepted approach to analyze outcomes that have two  possibilities (such as being in the federal vs. nonfederal workforce) when  the interest is in determining the net effects of multiple factors that may be  related to one another. We used the model to measure the extent to which  the identified factors that could be reliably measured affected the  likelihood of Hispanics and non-Hispanics being in the federal workforce,  as opposed to the nonfederal workforce. In developing the model, we  obtained the opinions of experts identified by the National Academy of  Sciences as well as officials from EEOC, OPM, the Department of Justice  (DOJ), and the Census Bureau. We also obtained the experts’ views on the  preliminary results of our analyses. Our analyses are not intended to and do  not show either the existence or absence of discrimination against  Hispanics or any other group in the federal workforce. Our analyses are at  an aggregate level encompassing all occupations governmentwide and do  not reflect factors that affect representation within individual agencies,  individual occupations, different geographic areas, or any other subsets of  the federal government.
To examine the steps that EEOC and OPM have taken in their oversight of  Hispanic representation, we reviewed the statutes, regulations, and  policies relating to Hispanic representation in the federal workforce;  interviewed EEOC and OPM officials; reviewed relevant documents; and  analyzed data on Hispanic representation governmentwide.
To illustrate the efforts related to Hispanic representation within federal  agencies, we selected five agencies—the U.S. Air Force (USAF), Food and  Nutrition Service (FNS) of the U.S. Department of Agriculture, National  Aeronautics and Space Administration (NASA), Small Business  Administration (SBA), and Social Security Administration (SSA)— representing different employee populations, geographic locations, and  concentrations of jobs by grade level and occupational categories. We  interviewed representatives from the selected agencies and reviewed  relevant documents. We also reviewed documents provided by and spoke  with officials from the White House Initiative on Educational Excellence  for Hispanic Americans. We conducted our work from October 2004 to  June 2006 in accordance with generally accepted government auditing  standards. The details of our objectives, scope, and methodology are in  appendix I.
subsections: section_title: Background
paragraphs: For more than 35 years, the federal government has implemented  authorities—applicable to various demographic groups and some specific  to Hispanics—calling for agencies to ensure equal opportunity in the  federal workplace. EEOC and OPM or its predecessor agency, the Civil  Service Commission (CSC), have leadership roles in furthering these  authorities. Signed in 1969, Executive Order No. 11478, Equal Employment  Opportunity in the Federal Government, stated that it is the policy of the  U.S. government to provide equal opportunity in federal employment.  Later, Congress passed the Equal Employment Opportunity Act of 1972,  which extended to federal workers the protections of title VII of the Civil  Rights Act of 1964 prohibiting employment discrimination on the basis of  race, color, religion, gender, or national origin. This law requires each  federal department and agency to prepare plans to maintain an affirmative  program of equal employment opportunity and establish training and  education programs. Pursuant to this and other authorities, EEOC  establishes equal employment program standards, monitors federal  agencies’ compliance with equal employment opportunity laws and  procedures, and reviews and assesses the effectiveness of agencies’ equal  employment programs. EEOC has carried out its responsibilities by issuing  regulations and management directives providing guidance and standards  to federal agencies for establishing and maintaining effective programs of  equal employment opportunity.
Recruitment should be from qualified individuals from appropriate sources in an endeavor  to achieve a work force from all segments of society, and selection and advancement should  be determined solely on the basis of relative ability, knowledge and skills, after fair and open  competition which assures that all receive equal opportunity.
The CSRA also created the Federal Equal Opportunity Recruitment  Program (FEORP) to carry out the government’s policy to ensure equal  employment opportunity. The act required OPM to evaluate and oversee  agency programs and issue implementing regulations for the program.  These regulations provide that recruitment processes prepare qualifiable  applicants (those who have the potential but do not presently meet valid  qualification requirements) for job openings through development  programs.
Programs specific to Hispanics include the 16-Point Program for Spanish- Speaking citizens, established in 1970, which outlined steps agencies  should take to ensure equal opportunity in federal employment for  Hispanics. In 1997, OPM implemented the 9-Point Plan calling for agencies  to recruit greater numbers of qualified Hispanic Americans for federal  service and improve their opportunities for management and senior  executive positions. More recently, Executive Order No. 13171, Hispanic  Employment in the Federal Government, signed in 2000, provides that  agencies, among other actions, (1) develop recruiting plans for Hispanics  and (2) assess and eliminate any systemic barriers to the effective  recruitment and consideration of Hispanics. The order requires OPM to  take the lead in promoting diversity to executive agencies and for the  director of OPM to establish and chair an Interagency Task Force on  Hispanic employment in the federal government to review best practices,  provide advice, assess overall executive branch progress, and recommend  further actions related to Hispanic representation.
As an indicator to Congress and the President of the government’s progress  toward ensuring equal employment opportunity, both EEOC and OPM, in  their oversight roles, analyze and report on governmentwide and agency  workforce data. The most recent data show that in September 2005,  Hispanics constituted 7.4 percent of the permanent federal workforce  while making up 12.6 percent of the CLF. While both EEOC and OPM report  these data annually, neither agency has assessed on a governmentwide  level the factors contributing to the differences in Hispanic representation  between the two workforces.
section_title: Citizenship and Education Had the Largest Effect on Hispanic Representation in the Federal Workforce
paragraphs: Citizenship and educational attainment had the most effect on the  likelihood of Hispanics’ representation in the federal workforce, relative to  the nonfederal workforce. Other measurable factors in our statistical  model—gender, veteran’s status, race, English proficiency, age, disability  status, school attendance (enrolled or not enrolled), employment status  (full or part-time), and geography (state where employed)—had a more  limited or almost no effect on the likelihood of Hispanics being in the  federal workforce. When we analyzed the effect of all the factors  simultaneously, we found that, among citizens, Hispanics were 24 percent  or 1.24 times more likely than non-Hispanics to be employed in the federal  workforce than in the nonfederal workforce. (See app. II for a detailed  discussion of the steps we took to conduct our analyses and our results.)
subsections: section_title: Effect of Citizenship
paragraphs: Our analysis showed that citizenship had the greatest effect of the factors  we analyzed on Hispanics’ representation in the federal workforce. We  analyzed the effect of citizenship before analyzing any other individual  factor because of long-standing policy and practice to restrict federal  government hiring to U.S. citizens and nationals—99.7 percent of federal  executive branch employees were U.S. citizens or nationals in 2005. (See  app. III for a discussion of the federal government’s policy and practice on  the employment of citizens.) Before accounting for the effect of citizenship,  Hispanics 18 and older were 30 percent less likely than non-Hispanics to be  employed (i.e., represented) in the federal workforce, relative to the  nonfederal workforce. However, when we analyzed the likelihood of only  citizens 18 and older being employed in the federal workforce, we found  that Hispanics were 5 percent less likely than non-Hispanics to be  employed in the federal workforce compared to their representation in the  nonfederal workforce.
Our analysis of 2000 Census data showed that Hispanics had lower  citizenship rates than other racial/ethnic groups, with the exception of  Asians who had similar rates. In 2000, of those 18 and older in the  combined federal and nonfederal CLF, 65 percent of the Hispanics were  U.S. citizens compared with 95 percent of blacks, 96 percent of whites,   65 percent of Asians, 87 percent of Hawaiians/Pacific Islanders, and  96 percent of American Indians/Native Alaskans. Additionally, Hispanic  immigrants have lower naturalization rates than other immigrant groups.  According to the Pew Hispanic Center, 27 percent of the adult foreign-born  Hispanic population in the United States were naturalized citizens in 2004  compared with 54 percent of the adult foreign-born non-Hispanic  population.
Hispanic-serving organizations have undertaken citizenship initiatives. For  example, the League of United Latin American Citizens (LULAC)  encourages legal residents of the United States to become citizens and  reports that it conducts a national drive to have those eligible for  citizenship apply for and attain citizenship.
section_title: Effect of Education
paragraphs: After citizenship, education had the largest effect on Hispanic  representation in the federal workforce. We compared Hispanic and non- Hispanic citizens with similar levels of education. We limited our  examination of the effect of education to citizens because citizenship is a  basic qualification for most federal employment. As discussed above,  among citizens, Hispanics were 5 percent less likely to be employed in the  federal government. After accounting for education, Hispanic citizens were  1.16 times or 16 percent more likely than similarly educated non-Hispanic  citizens to be in the federal workforce than the nonfederal workforce.
The federal workforce contains a greater percentage of occupations that  require higher levels of education than the CLF. EEOC divides occupations  in the federal workforce and the CLF into nine categories, including among  others professionals, operatives, and laborers. For example, in 2000, the  year in which EEOC data on the CLF are based, occupations in the  professional category—those occupations, such as lawyers, engineers,  accountants, and registered nurses, requiring either college graduation or  experience of such kind and amount as to provide a comparable  background—constituted 29 percent of the federal workforce versus 18  percent of the CLF. Conversely, occupations in the operatives (semiskilled  workers) and laborers (unskilled workers) categories, which generally do  not require high education levels, constituted 3 percent of the federal  workforce compared to 16 percent of the CLF. Figure 1 shows the  composition of the federal workforce and the CLF by EEOC’s occupational  categories.
Our analyses showed that the likelihood of being a federal worker  increased with higher levels of education. A person with some college was  1.7 times more likely to be a federal worker than a person with only a high  school diploma, a person with a bachelor’s degree was 2.2 times more  likely, and a person with more than a bachelor’s degree was 2.7 times more  likely. OPM reported that in 2004, 42 percent of federal workers had a  bachelor’s degree or higher. In addition, approximately 60 percent of new  permanent hires to the federal government in 2005 had at least some  college—20 percent with some college, 23 percent with a bachelor’s degree,  and 17 percent with more than a bachelor’s degree.
Our analysis of 2000 Census data showed that regardless of citizenship  status, Hispanics overall have lower educational attainment than other  groups, with non-U.S. citizens having the lowest levels of educational  attainment. Among citizens in the CLF 18 and older, as table 1 shows,  Hispanics had a higher percentage of those without a high school  diploma—26.4 percent—and lower percentage of those with a bachelor’s  degree or higher—15.4 percent—than most other racial/ethnic groups.
When noncitizens were included, as table 2 below shows, the proportion of  Hispanics with less than a high school diploma increased and the  proportion having bachelor’s degree or higher decreased.
Educational attainment for Hispanics 18 and older in the CLF who were not  citizens was lower compared with those who were U.S. citizens. Table 3  shows that, among Hispanics in the CLF who were not U.S. citizens, 62.8  percent had less than a high school diploma while 6.2 percent had a  bachelor’s degree or higher.
In addition to having lower educational attainment levels than other  racial/ethnic groups, there were differences in Hispanics’ educational  patterns. For example, Hispanics have enrolled in 2-year colleges at a  higher rate than other racial/ethnic groups. According to data reported in  the American Council on Education’s Minorities in Higher Education,  Twenty-First Annual Status Report, 2003–2004, 59 percent of Hispanics  enrolled in postsecondary institutions are enrolled in community colleges,  compared to 37 percent of whites, 43 percent of blacks, 41 percent of  Asians, and 50 percent of American Indians. In addition, Hispanics are less  likely than other groups to complete a bachelor’s degree. According to data  from the National Center for Education Statistics’ National Educational  Longitudinal Study beginning in 1988, by age 26, 47 percent of white  students who had enrolled in postsecondary education had completed a  bachelor’s degree compared to 23 percent of Hispanics—lower than other  racial/ethnic groups.
The federal government and Hispanic-serving organizations have  implemented initiatives to address gaps in Hispanics’ educational  achievement. In October 2001, Executive Order No. 13230 created the  President’s Advisory Commission on Educational Excellence for Hispanic  Americans, within the U.S. Department of Education, to examine issues  related to the achievement gap between Hispanic Americans and their  peers. The commission issued an interim report in September 2002, The  Road to a College Diploma: The Complex Reality of Raising Educational  Achievement for Hispanics in the United States, and a final report in  March 2003, From Risk to Opportunity: Fulfilling the Educational Needs  of Hispanic Americans in the 21st Century. The commission’s final  report, concluding its work, contained six recommendations, which  encompassed the entire education continuum, from early childhood  through postsecondary, as well as federal accountability and coordination  and research. According to the White House Initiative on Educational  Excellence for Hispanic Americans, which provided the staff support and  assistance to the commission and continues to work within the Department  of Education, it is taking steps to implement the commission’s six  recommendations and is working with the Department of Education, other  federal agencies, and public and private organizations.
In addition to federal government initiatives, Hispanic-serving  organizations also have ongoing efforts to improve the educational  attainment of Hispanics. According to LULAC, the organization has 16  counseling centers whose mission is to increase educational opportunities  and attainment for Hispanic Americans through the development and  implementation of programs in Hispanic communities throughout the  United States. LULAC also reports that it provides educational counseling,  scholarships, mentorships, leadership development, and literacy programs.  According to its Web site, the National Council of La Raza (NCLR) works to  build and strengthen community-based educational institutions, to improve  the quality of instruction for Hispanic students, and to more effectively  involve Hispanic families in the education of their children. NCLR reports  that its education program services and activities are targeted to over 300  affiliated organizations while its education policy work addresses national  issues in public education. NCLR also reports that it cochairs the Hispanic  Education Coalition, an ad hoc coalition of national organizations  dedicated to improving educational opportunities for Latinos living in the  United States and Puerto Rico. Other organizations such as the Hispanic  College Fund also work to provide college scholarships for Hispanic youth.
section_title: EEOC and OPM Have Taken Steps in Their Oversight Roles to Address Hispanic Representation
paragraphs: In their respective oversight roles, both EEOC and OPM report  representation levels of racial, ethnic, and gender groups overall and in  subsets of the federal workforce and require that agencies conduct  analyses of their own workforces. However, the benchmarks that EEOC,  OPM, and agencies use to compare federal workforce representation levels  to the CLF do not differentiate between citizens and noncitizens, and  therefore do not identify how citizenship affects the pool of persons  qualified to work for the federal government. Where differences in  representation occur, such as within occupations or by grade, agencies are  to determine if there are barriers to participation and, if so, develop  strategies to address any barriers. OPM provides human resource guidance  and resources to agencies to assist agencies in implementing these  strategies.
subsections: section_title: EEOC and OPM Reports on the Federal Workforce
paragraphs: In its Annual Report on the Federal Workforce, prepared pursuant to its  oversight responsibilities, EEOC provides data on the representation of  racial, ethnic, and gender groups, including Hispanics, compared to the  CLF overall, by senior pay and average grade level, and for selected  agencies with 500 or more employees. To make its comparisons, EEOC  uses the Census 2000 Special EEO File, which provides workforce data on  the CLF. The Census 2000 Special EEO File is a special tabulation  constructed by the U.S. Census Bureau according to the specifications of,  and under a reimbursable agreement with, a consortium of agencies— EEOC, OPM, DOJ, and the Department of Labor (DOL). The Special EEO  File, which has been prepared every 10 years since 1970 based on the  Decennial Census, serves as the primary external benchmark to compare  the racial, ethnic, and gender composition of each employer’s workforce to  its available labor market. The datasets on the Census 2000 Special EEO  Tabulation present data on race and ethnicity cross-tabulated by other  variables such as detailed occupations, occupational groups, gender,  worksite geography, residence geography, education, age, and industry.  Data are available at the national level and by state, metropolitan area,  county, and place.
However, the Census 2000 Special EEO File data does not include  citizenship data. According to a Census Bureau official, at DOJ’s request,  the Census 2000 Special EEO File specifications originally included  citizenship data for metropolitan statistical areas in four states for persons  in the CLF 20 to 34 years of age, with 4 or more years of high school, by  race and ethnicity. Because of narrow data specifications, concerns were  raised about the privacy of Census respondents and the request was  withdrawn. The consortium and Census are planning the 2010 Special EEO  File, which will be based on 5 years (2005–2009) of American Community  Survey (ACS) data—which is replacing the long form of the Decennial  Census. Subsequent to the completion of our audit work, EEOC sent a  letter requesting that the Census Bureau review the possibility of including  citizenship data in the 2010 Special EEO File. According to the Census  Bureau, citizenship data can be included but at an additional cost to  consortium members based on the extent of data requested (e.g.,  geographic or occupational specificity) and amount of staff and  programming resources to produce the requested data. In addition, the  Census Bureau said that the extent of geographic or occupational  specificity of citizenship data could be limited based on the risk of  disclosing the identity of a respondent. Census Bureau officials also noted  that because the 2010 Special EEO File will be based on a 5-year roll up of  annual ACS data, current plans are to produce an updated Special EEO File  every 5 years.
OPM also presents data on Hispanic representation in its reports to the  President under Executive Order No. 13171 and to Congress under the  FEORP. In its Annual Report to the President on Hispanic Employment in  the Federal Government, prepared pursuant to Executive Order No. 13171,  and in Statistical Information on Hispanic Employment in Federal  Agencies, OPM has included data on Hispanic representation overall, for  each agency, by pay plan/group, and among new hires. The FEORP report  compares overall representation levels in the federal workforce to the CLF  and provides representation levels by pay group, in occupational  categories, and within each agency. OPM also uses the Census 2000 Special  EEO File when comparing representation of women and minorities within  agencies to the relevant CLF (the labor force comprising only the particular  occupations for the particular agency) for its FEORP report. However, in  making comparisons of the demographic composition of the overall federal  workforce to the CLF for the FEORP and the statistical reports on Hispanic  employment, OPM has used the Current Population Survey (CPS). By using  the CPS, OPM reports more-current CLF data than EEOC’s and reflects the  changing composition of the CLF. At the time of our review, OPM was  benchmarking to the September 2005 CPS, which showed Hispanic  representation in the CLF to be 12.6 percent. In its Annual Report on the  Federal Workforce, EEOC uses the 2000 Special EEO File as its benchmark  showing Hispanic representation in the CLF to be 10.7 percent. Although  using the CPS enables OPM to report more-current data on Hispanic  representation in the CLF, OPM does not distinguish between citizens and  noncitizens in its analysis of the CPS data.
Figure 2 shows Hispanic representation in the permanent federal  workforce compared to the CLF with and without noncitizens from 1994 to  2005, based on data from the CPS and OPM. These data show how  citizenship affects the pool of Hispanics eligible for federal employment  and that, when only citizens are considered in the CLF, Hispanic  representation in both the federal workforce and CLF is more comparable.
section_title: EEOC and OPM Guidance on Workforce Analyses
paragraphs: EEOC’s Mangement Directive 715 (MD-715) provides guidance and  standards to federal agencies for establishing and maintaining effective  equal employment opportunity programs, including a framework for  agencies to determine whether barriers to equal employment opportunity  exist and to identify and develop strategies to mitigate the barriers to  participation. EEOC defines barriers as agency policies, principles, or  practices that limit or tend to limit employment opportunities for members  of a particular gender, race, or ethnic background, or based on an  individual’s disability status. EEOC requires agencies to report the results  of their analyses annually.
The initial step is for an agency to analyze its workforce data with  designated benchmarks. As part of this analysis, in addition to comparing  the overall workforce to the CLF, EEOC instructs agencies to compare  major (mission-related and heavily populated) occupations to the CLF in  the appropriate geographic area in order to get a more accurate picture of  where differences in representation may exist and to guide further analysis.  Agencies may use the Census 2000 Special EEO File and the Census 2000  EEO Data Tool, which allows agencies to tailor the Special EEO File data in  accordance with EEOC instructions. In their analyses, agencies may find  that Hispanic representation in some of their major occupations is higher  than in similar occupations in the CLF, but lower in others. Similarly, our  review of data on the 47 occupations with 10,000 or more federal  employees showed that Hispanic representation was higher in the 2005  federal workforce than the 2000 CLF in 22 of those occupations and lower  in 25. (See app. IV.) EEOC also instructs agencies to analyze workforce  data by grade level, applicants, new hires, separations, promotions, career  development programs, and awards to identify where there may be barriers  to participation. With respect to grade level, our review of data on Hispanic  representation in the federal workforce showed that Hispanics are more  highly represented in the lower grade levels than in higher grade levels (see  app. IV). Our review was based on descriptive data and did not take into  account citizenship, education, or other factors that can affect an  individual’s placement in the federal government.
When numerical measures indicate low representation rates, EEOC  instructs that agencies conduct further inquiry to identify and examine the  factors that contributed to the situation revealed by the data. Below is an  example from EEOC’s MD-715 instructions of such an analysis to  determine the existence of limits or barriers to participation.
An agency has uncovered a lack of Black women in its program analyst occupation at the  grade 13 level and above. However, below the grade 13 level the program analyst occupation  is quite diverse, including a significant number of Black females. Further examination of the  matter reveals that several years ago the agency instituted a requirement that program  analysts hold a Masters of Business Administration (MBA) degree in order to be promoted  to the grade 13 level or above. Few internal candidates, and none of the Black female  program analysts employed by the agency, hold an MBA. Therefore, the agency was  recruiting higher level program analysts from a local business school with a student  population comprised of primarily White males. Over time, program analysts at the grade 13  and above did not reflect the racial diversity of the program analysts at the lower grade  levels.
First, the agency should re-visit the issue of whether the skill set represented by an MBA is  available by some alternative means such as years of work experience in certain areas. This  experience might be substituted for holding an MBA in rendering an applicant qualified for  consideration for a higher-graded position. If it is determined that the agency’s requirement  for an MBA is in fact job-related and consistent with business necessity, the agency should  consider whether other alternatives exist which will have less impact on a particular group.  Most obviously, the agency could recruit MBAs from other schools with more diverse  student populations. In addition, the agency might consider steps it could take to facilitate  its own lower-graded employees obtaining MBAs.
Under OPM’s FEORP regulations and guidance under the Human Capital  Accountability and Assessment Framework (HCAAF), agencies are also to  analyze their workforces. Under FEORP, agencies are required to  determine where representation levels for covered groups are lower than  the CLF and take steps to address them. Agencies are also required to  submit annual FEORP reports to OPM in the form prescribed by OPM.  These have included (1) data on employee participation in agencywide and  governmentwide career development programs broken out by race,  national origin, gender, and grade level and (2) a narrative report  identifying areas where the agencies had been most successful in  recruiting, hiring, and formal training of minorities and women, and how  they were able to achieve those results. The HCAAF, according to OPM,  fuses human capital management with merit system principles and other  civil service laws, rules, and regulations and consists of five human capital  systems that together provide a consistent, comprehensive representation  of human capital management for the federal government. According to  recently proposed regulations, each system consists of standards against  which agencies can assess their management of human capital and related  metrics. The HCAAF practitioners guide outlines suggested performance  indicators reflecting effective practices in meeting these standards. One  suggested performance indicator, for example, is that agencies have  systems that track and analyze workforce diversity trends in mission- critical occupations in order to continually adjust the agency’s recruitment  and retention strategy to its current state of need.
OPM Assistance to Agencies OPM provides assistance to agencies in recruiting Hispanics as part of  broad-based recruitment efforts and developing employees onboard  through (1) governmentwide outreach and recruitment initiatives;  (2) providing information on student employment programs;   (3) disseminating information on leading practices; and (4) providing  guidance on training and development of employees.
subsections: section_title: Governmentwide Outreach and Recruitment Initiatives
paragraphs: In 2003 and 2004, OPM held recruitment fairs in cities across the country,  including those with high concentrations of Hispanics, such as Los Angeles,  San Antonio, Tucson, Miami, and New York. Additionally, in 2005, OPM  participated in 25 career fairs sponsored by others including LULAC, the  National Association of Hispanic Federal Executives, and the University of  New Mexico. Under its Veteran Invitational Program, launched in 2004,  OPM has conducted career fairs, visited military installations and veterans’  medical facilities, and provided information on employment opportunities  for veterans on its Web site. In 2004, OPM signed a Memorandum of  Understanding with the American GI-Forum—an organization that works  on behalf of Hispanic veterans—in support of Executive Order No. 13171.
OPM has also taken steps to improve the USAJOBS Web site, the federal  government’s official source for jobs and employment information. As part  of its Recruitment–One Stop Initiative, launched in 2003, OPM reports that  the Web site contains improved search capability options, a more user- friendly resume builder, and a streamlined job application process.  USAJOBS also links to OPM’s Student Jobs Web site, which contains  listings of federal student employment positions, and e-scholar, a listing of  federal educational scholarships, fellowships, grants, internships,  apprenticeships, and cooperative programs offered by federal departments  and agencies and partnering organizations. The USAJOBS Web site  provides information in both English and Spanish.
section_title: Student Employment Programs
paragraphs: According to OPM, student employment programs can help agencies  recruit and develop talented employees to support agency missions; ensure  that they can meet their professional, technical, and administrative needs;  and achieve a diverse, quality workforce. OPM assists agencies on the use  of student employment programs by issuing regulations and providing  technical assistance through its Web site. There are three federal student  employment hiring programs that can lead to noncompetitive conversion to  permanent employment—the Student Career Experience Program (SCEP),  Federal Career Intern Program (FCIP), and Presidential Management  Fellows Program (PMF).
Under SCEP, agencies may hire students as interns while they are pursuing  high school diplomas or equivalent vocational or technical certificates, and  associate’s, bachelor’s, graduate, or professional degrees. Upon completion  of their degree program and SCEP requirements, agencies may  noncompetitively convert participants to permanent employment. Recently  revised SCEP regulations allow agencies to credit up to 320 hours of the  640 hours of career-related work experience required for conversion from  active duty military service or from comparable nonfederal internship,  work-study, or student volunteer programs where work is performed at  federal agencies. Comparable work experience can include those  internships sponsored by the Hispanic Association of Colleges and  Universities’ (HACU) National Internship Program. The regulations also  permit agencies to waive up to 320 SCEP hours of required work  experience for students who have demonstrated exceptional job  performance and outstanding academic achievement.
Under FCIP, agencies may appoint individuals to 2-year internships in  entry-level positions that would lend themselves to internal formal  training/developmental programs. After 2 years, if program requirements  are met, an agency can noncompetitively convert them to competitive civil  service status. OPM issued final regulations on FCIP in 2005.
The Presidential Management Fellows (PMF) Program is a 2-year  internship program open to students who have completed graduate degree  programs, been nominated by their school officials, and passed OPM’s  assessment. In 2005, OPM issued final regulations implementing Executive  Order No. 13318, issued in 2003, removing the cap on the number of PMF  appointments, providing agencies greater flexibility in promoting fellows,  and establishing training and development requirements.
Other organizations have also realized that various intern programs provide  valuable recruitment sources. According to the Partnership for Public  Service, a nonpartisan organization dedicated to revitalizing public service,  internship programs such as SCEP provide agencies a pool of diverse,  tested, and easy-to-hire potential employees. Yet, the Partnership found  that very few are drawn from the pool into permanent federal jobs. On the  basis of the Partnership’s analysis of the rates at which SCEP program  participants are converted to permanent federal employment, agencies  may not be realizing the full potential of this program. The Partnership  reported that in 2001, agencies converted 17 percent of SCEP participants  to permanent federal employment, and in 2000, 11 percent. In contrast, the  Partnership’s report stated that more than 35 percent of interns in the  private sector accepted jobs with the companies for which they interned.
While OPM has reported data on SCEP participants governmentwide by  racial/ethnic group in its Fact Book and on SCEP new hires by agency in its  statistical reports on Hispanic employment, OPM does not report  demographic data on SCEP participants by agency and on FCIP and PMF  participants governmentwide or by agency, or rates of conversion to  permanent positions for SCEP, FCIP, and PMF either governmentwide or  by agency. According to OPM, data on conversions to permanent  employment by racial/ethnic group for SCEP and FCIP are available from  the Central Personnel Data File (CPDF). Currently, OPM does not analyze  these data. Similar data are available for the PMF. Analyzing data on  conversion rates could provide OPM with valuable information on agencies  that appear to be maximizing their use of these programs as well as those  that are not fully utilizing them. With this information, OPM could then  provide assistance to agencies to help them incorporate student  employment programs into their strategic workforce planning as they seek  to recruit and develop talented employees to support agency missions;  ensure that they can meet their professional, technical, and administrative  needs; and achieve a diverse, quality workforce. Such information from  OPM could also enable agencies to perform more complete assessments of  their programs.
section_title: Leading Practices
paragraphs: OPM disseminates leading-practices information through the reports it  issues pursuant to FEORP and Executive Order No. 13171 and through the  Interagency Task Force on Hispanic employment, chaired by the Director  of OPM. In its annual FEORP reports, OPM presents a summary of agency  practices on workforce planning, recruitment and outreach, mentoring,  and career development based on the information agencies submit to OPM  in their annual FEORP reports. In its Annual Report to the President on  Hispanic Employment, OPM presents what agencies report as effective  recruitment, outreach, career development, and accountability practices.  To prepare the reports pursuant to the order, OPM annually asks agencies  to submit information concerning steps taken related to these areas. OPM  also shares information on leading practices at meetings of the Interagency  Task Force. Through this guidance, OPM promotes broad outreach to all  groups and encourages agencies to establish relationships with colleges  and universities as a means to attract qualified candidates.
section_title: Training and Development
paragraphs: Once onboard, training and development programs can assist employees in  further developing skills and helping them qualify for higher-level positions.  OPM provides guidance to agencies on its training and development Web  page and has issued regulations on training and development tools  available to agencies, such as academic degree and other employee training  programs. In 2004, OPM finalized regulations on a training provision of  the Chief Human Capital Officers Act of 2002 (Title XIII of the Homeland  Security Act), which expanded agency authority to pay or reimburse  employees for the cost of academic degree training when such training  contributes significantly to meeting an identified agency training need,  resolving an identified agency staffing problem, or accomplishing goals in  an agency’s human capital management strategic plan.
section_title: Agencies Take Steps to Recruit and Develop Hispanics in the Federal Workforce
paragraphs: The five agencies in our review have taken a variety of approaches to  address issues concerning Hispanic representation in their workforces,  particularly in competing for a limited number of qualified candidates and  addressing Hispanic representation at higher levels. At NASA, where  Hispanics represented 5.3 percent of the workforce in 2005, one of the  major occupations is aerospace engineering. There, Hispanics  represented 5.0 percent of aerospace engineers, according to EEOC’s  Annual Report on the Federal Workforce, 2004. In the CLF, Hispanics  represented 4.6 percent of aerospace engineers, according to the Census  2000 Special EEO File. NASA said it must compete with the private sector  for the pool of Hispanics qualified for aerospace engineering positions,  which is often attracted by more-lucrative employment opportunities in the  private sector in more-preferable locations. FNS, where Hispanics  represented 7 percent of the workforce in 2005, reports that its ability to  successfully recruit Hispanics was affected by low Hispanic representation  in areas where some of its regional offices are located. Similarly, the USAF,  with 7.4 percent of its workforce Hispanic in 2005, also reported difficulties  in recruiting Hispanics at Wright-Patterson Air Force Base in Dayton, Ohio,  where Hispanics represent approximately 2 percent of the local CLF,  according to the USAF. Moreover, the USAF attributes, in part, the decrease  in overall Hispanic representation levels (from 7.7 percent in 2000 to 7.4  percent in 2005) to the closure of Air Force bases in the southwestern  United States where Hispanics were more highly represented than at other  bases. Finally, agencies also reported that Hispanic representation in mid-  and upper-level positions was an issue they were addressing. While both  SSA, where Hispanics represented 12.5 percent of the workforce in 2005,  and the SBA, where Hispanics represented 10.8 percent in 2005, reported  success recruiting Hispanics for lower-level positions, each noted that  Hispanic representation in certain mid- or upper-level positions was lower.
subsections: section_title: Steps Agencies Have Taken
paragraphs: The agencies reported using a variety of approaches that enhanced their  ability to recruit and develop Hispanic employees. These included outreach  to the Hispanic community and Hispanic-serving organizations, including  participating in conferences sponsored by LULAC and others; recruiting at  Hispanic-Serving Institutions—defined by statute as an eligible institution  having an undergraduate enrollment of at least 25 percent Hispanic full- time students and at least 50 percent of the institution’s Hispanics students  qualifying as low income; sponsoring interns through the HACU National  Internship Program; use of student employment programs such as SCEP  and FCIP; advertising in both English- and Spanish-language Hispanic  media; and career development and training programs. Below we describe  some of the specific approaches agencies in our study used to recruit and  provide training and development opportunities for Hispanics. While data  on the outcomes are limited and we have not assessed the effectiveness of  these programs, the agencies reported that these approaches have  enhanced their ability to recruit and develop qualified Hispanics.
subsections: section_title: Outreach to the Hispanic Community
paragraphs: NASA—Part of NASA’s strategy to recruit Hispanics centers on increasing  educational attainment, beginning in kindergarten and continuing into  college and graduate school, with the goal of attracting students into the  NASA workforce and aerospace community. NASA centers sponsor, and its  employees participate in, mentoring, tutoring, and other programs to  encourage Hispanic and other students to pursue careers in science,  engineering, technology, and math.  For example, the Marshall Space  Center in Huntsville, Alabama, annually sponsors a Hispanic Youth  Conference attended by students from across Alabama that includes  workshops on leadership development and pursuing NASA career fields  and provides opportunities to establish mentoring relationships.  NASA  also provides grants to fund educational support programs including in  locations where there are high concentrations of Hispanics.  For example,  the Ames Research Center in Moffett Field, California, provided a grant for  the development and implementation of a K-12 technology-awareness  program designed to expose students to NASA and higher education  through competitive team activities based on key aeronautic concepts.  The  program has been implemented in schools throughout California that have  a high percentage of Hispanic students.  Various centers also participate in  high school and college internship programs, such as the Summer High  School Apprenticeship Research Program where high school students  spend 8 weeks working with engineers on scientific, engineering,  mathematical, and technical projects.  NASA centers also provide  scholarships and research grants.  For example, Ames provides  scholarships to Hispanic college students at a community college and the  Dryden Flight Research Center sponsors fellowships for students in  engineering and science to continue their graduate studies.  In addition,  NASA has recently developed the Motivating Undergraduates in Science  and Technology scholarship program designed to stimulate a continued  interest in science, technology, engineering, and mathematics.
USAF—To reach potentially qualified Hispanics from all areas of the  country, the USAF outreach strategy focuses on partnering and improving  working relationships with Hispanic-serving organizations at the national,  regional, and local levels. At the national level, the USAF has established  relationships with professional, educational, and broad-based Hispanic- serving organizations. For example, it signed a memorandum of  understanding with LULAC agreeing to collaborate on, among other things,  increasing USAF career opportunities. Through the Department of Defense  partnership with HACU, the USAF participates in a national working group  that meets semiannually to develop initiatives to expand recruitment at  Hispanic-Serving Institutions. At the local and regional levels, the USAF has  a variety of outreach efforts that involve both providing information to, and  gaining feedback from, the Hispanic community. It works with  organizations to educate potential employees on the application process.  For example, Kirtland Air Force Base in New Mexico has sponsored “train  the trainer” workshops with area organizations, high schools, and colleges  and universities. The USAF also participates in programs working directly  with local students, such as serving as mentors for Hispanic students. In  addition, the USAF regularly provides vacancy announcements to, and has  ongoing dialogues with, local Hispanic community organizations.
Use of Student Hiring Authorities NASA—During fiscal year 2004, NASA implemented the corporate college  recruitment initiative using FCIP hiring authority to recruit individuals to  mission-critical positions. As part of this strategy, NASA participates in  recruitment events at colleges and universities and conferences around the  country, which it selects based on academic programs, diversity of  attendee population, or involvement in NASA research. For each  recruitment site, it invites academic institutions within reasonable  geographical proximity, allowing it to maximize opportunities to reach  students at Hispanic-Serving Institutions. In fiscal year 2004, 15 Hispanic- Serving Institutions participated from Arizona, California, Florida, New  Mexico, New York, Puerto Rico, and Texas, which included universities  with well-established engineering, science, and technology curricula. Prior  to each event, NASA publishes event-specific vacancies and encourages  students to apply in advance in order to create a pool of applicants from  which to schedule interviews at the site. NASA reported that it was most  successful in competing for top talent and filling critical competency  positions at the earliest possible time when it extended job offers at the  recruitment site or within 30 days after the conclusion of the recruitment  visit.
USAF—The USAF uses student employment programs to attract Hispanics  and other qualified applicants for positions ranging from those requiring  training at the vocational-technical schools to the graduate level. The  USAF—which employs approximately half of the federal government’s  civilian aircraft maintenance workers—has implemented the “Grow Your  Own” aircraft maintenance program at three of its Texas bases. In  partnership with vocational-technical schools, the program includes both  on-the-job training and classroom education. It provides the USAF with a  pool of trained candidates to replace retiring federal employees and a  vehicle to increase Hispanic representation. Students are initially  appointed through SCEP, and upon completion of the educational program  and 640 hours of career-related work, students may be converted to  permanent employment within 120-days without further competition.
Using FCIP authority, the USAF hires recent college graduates into its  PALACE Acquire and Copper Cap internship programs. The Copper Cap  program is designed to train college graduates as contract specialists by  assigning them to work with professional contracting officers. The  PALACE Acquire program fills a variety of positions in approximately 20  career fields including logistics, civilian personnel, scientists and  engineers, criminal investigator, intelligence specialists, public affairs, and  education specialists. Participants may be promoted in 1-year intervals up  to a certain level based on satisfactory or successful performance and are  eligible for student loan repayment and tuition assistance for graduate  school.
section_title: Career Development Programs
paragraphs: SBA—The SBA’s District Director Candidate Development Program  (DDCDP) is designed to recruit and develop a diverse group of highly  qualified and trained managers at the General Schedule grade 13, 14, and 15  levels to fill district director positions on a noncompetitive basis as they  become vacant. At the SBA, district director positions are key managerial  career positions responsible for providing agency services to the small  business community. The program is a 6- to 18-month development  program and candidates who are competitively selected for, and  successfully complete, the DDCDP program are eligible for noncompetitive  selection for a period of 3 years from the time they have successfully  completed the program.
FNS—Since 2000, FNS has sponsored the Leadership Institute, which is a  15-month full-time leadership training program. The program focuses on  five core competencies: leading change, leading people, achieving results,  business acumen, and building coalitions/communications. Participants,  who are competitively selected from grades 11–14, attend core seminars on  such topics as leading teams, problem solving, and decision making and  participate in individual and team projects. As of February 2006, there were  98 graduates from five classes.
SSA—SSA sponsors national, headquarters, and regional career  development programs for employees in grades 5 to 15. At the national  level, the Leadership Development Program is an 18-month program  designed to provide employees in grades 9 to 12 with developmental  experiences through placement in designated trainee positions. The  Advanced Leadership Program is an 18-month program designed to provide  employees in grades 13 and 14 experience to become future agency leaders  through rotational assignments, training, and other developmental  experiences. Upon successful completion of these programs, participants  receive a 3-year Certificate of Eligibility for a onetime, noncompetitive  promotion, used at the discretion of SSA management. SSA also has a 12- to  18-month Senior Executive Service Candidate Development Program to  prepare individuals in grade 15 or equivalent to assume senior executive- level responsibilities and develop their executive core qualifications. For  employees in grades 5 through 8, SSA offers career development programs  in its Office of Central Operations based in Baltimore and Office of  Disability Adjudication and Review, which has regional and local hearing  offices throughout the country. These, as well as other regional and  headquarters component career development programs, are modeled after  its three national programs for which employees are competitively  selected.
section_title: Educational Assistance Programs
paragraphs: USAF—The USAF provides a variety of opportunities for current  employees to increase their educational attainment through tuition  assistance and degree completion programs, in-residence and distance- learning educational programs, and long-term academic programs. Its  tuition assistance program covers mission-related coursework for  designated positions toward degrees at a higher-level than the employee  has already attained. Employees attend courses on a voluntary off-duty  basis. Degree completion programs offer selected employees in designated  career fields the opportunity to complete their degree during duty hours on  a full- or part-time basis. In addition, the USAF also provides opportunities  for employees to earn graduate degrees from its academic institutions,  such as the Air Force Institute of Technology. Moreover, its professional  military education programs—such as the Squadron Officer College and Air  War College—are available for civilian employees depending upon grade  level. These programs are offered in residence and by correspondence.  Both provide opportunities for participants to earn credits toward degree  programs.
The USAF has obtained the recommendations on college credit for these  and other courses and training programs from the American Council on  Education’s (ACE) College Credit Recommendation service. ACE is an  association of approximately 1,800 accredited, degree-granting colleges  and universities as well as higher-education-related associations,  organizations, and corporations. It reviews training programs and courses  offered by government agencies and corporations and other training  providers at the providers’ request and makes recommendations  concerning the type of academic credit, if any, appropriate for the program.  Approximately 1,200 accredited colleges or universities have agreed to  consider ACE recommendations for courses, apprenticeship programs, and  examinations, including community colleges and universities such as the  University of California at Berkeley, George Washington University, and  Indiana University, Bloomington. ACE has also recommended credit for  various courses from NASA’s Academy of Program and Project Leadership  that may be used toward a graduate degree.
section_title: Agencies Identify Lessons- learned in Addressing Hispanic Representation
paragraphs: In response to our inquiry, the agencies included in our review reported  three primary lessons important to the success of their efforts— commitment of agency leadership, taking a strategic workforce planning  approach, and working with the Hispanic community:  Commitment of agency leadership: Agencies reported that their  programs were most successful when agency leadership was committed  to addressing Hispanic representation. As we found in our prior work on  diversity management, 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. For example, SSA included diversity as part of its strategic  and human capital plans and developed an agencywide marketing and  recruitment strategy to address the representation of any  underrepresented group, including Hispanics. Additionally, it tracks the  outcomes of its recruitment and hiring initiatives.
Strategic workforce planning: Agencies also recognized the importance  of taking a strategic workforce planning approach in their efforts to  recruit a diverse workforce. Strategic workforce planning addresses two  critical needs: (1) aligning an organization’s human capital program with  its current and emerging mission and programmatic goals and   (2) developing long-term strategies for acquiring, developing, and  retaining staff to achieve programmatic goals. For example, NASA’s  recruitment strategy focuses on both developing the pipeline to fill its  mission-critical occupations by encouraging students to pursue degrees  in science, technology, engineering, and math and attracting graduates  into the NASA workforce and aerospace community. Additionally, SSA  developed a business case for bilingual public contact employees in its  field offices and bicultural employees in policy-making staff positions in  its regional offices and headquarters components. Similarly, FNS said it  began to realize the need for bilingual professionals, and as a result, has  advertised positions requiring fluency in Spanish.
Working with Hispanic communities: Finally, agencies told us that it is  important to work with Hispanic communities to understand one  another’s needs and find mutually beneficial solutions. The USAF at  Kirtland Air Force Base in Albuquerque, New Mexico, has taken steps in  this regard. In this geographic area where Hispanics represented 41.6  percent of the population according to the 2000 Census, the base has an  alliance with the local public schools and colleges and universities to  ensure that it is providing career and mentoring opportunities for area  students and that schools are producing a pipeline of qualified students  to meet base needs. Base representatives also work with the Hispanic  Chamber of Commerce on issues pertaining to Hispanic communities.
section_title: Conclusions
paragraphs: Providing federal agencies with benchmarks that consider citizenship  would allow agencies to get a more accurate picture of differences in  representation levels and more effectively identify and address barriers to  equal employment opportunity. Current CLF benchmarks do not include  citizenship; however, two annual official data sources—the CPS and ACS— are available that would allow EEOC and OPM to separate citizens and  noncitizens in analyzing federal workforce representation by racial, ethnic,  and gender groups. Additionally, agencies analyze their workforces using  the Census Special EEO Files prepared at the direction of the consortium  of agencies—EEOC, OPM, DOJ, and DOL. Although the 2000 Special EEO  File did not contain citizenship data, EEOC and DOJ have expressed  interest in and the need for including such data in the 2010 Special EEO  File but must address issues including cost and privacy.
As part of their barrier analyses, where representation differences between  occupations in their workforces and similar ones in the CLF exist, agencies  are to determine whether the qualifications established for those  occupations are appropriate. Additionally, agencies are required to  determine whether they have considered all sources of qualified  individuals. OPM currently provides guidance to federal agencies on  recruiting at colleges and universities. Because the majority of Hispanics  enrolled in postsecondary education attend community colleges and  vocational schools, identifying effective outreach practices to such schools  could help those agencies that have occupations requiring the education  and training provided at these institutions to meet workforce needs and  further equal employment opportunity. OPM already shares effective  recruiting practices through its Annual Report to the President under  Executive Order No. 13171.
OPM has recognized the importance of student employment programs, in  particular SCEP, in providing a unique opportunity for agencies to recruit  students from high school through graduate school, depending on agencies’  needs. These programs not only serve as a mechanism to address future  federal workforce needs, they offer students the incentive to complete  their education as well. OPM has provided data on SCEP new hires in its  statistical reports on Hispanic employment and SCEP participants  governmentwide in its Fact Book. While data on conversation rates for  SCEP and FCIP are available from the CPDF, OPM does not analyze these  data by agency or governmentwide. Such analyses could provide OPM with  valuable information to help agencies maximize their use of these  programs as part of their overall strategic workforce planning. Additionally,  such information from OPM could enable agencies to perform more  complete assessments of their programs.
While federal agencies are taking steps to address Hispanic representation  issues, as an employer, the federal government is limited in its ability to  address the effects of citizenship and education on Hispanic representation  throughout the federal workforce. As these are multifaceted issues,  developing strategies to address them will require partnerships between  Hispanic-serving organizations, federal agencies, state and local  governments, educational institutions, and other interest groups.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Director of OPM and the Chair of EEOC do the  following:  Include citizenship in their annual comparisons of representation in the  federal workforce to the CLF. To help ensure consistency, both agencies  should agree upon a single source of citizenship data.
Work with other Consortium agencies and the Census Bureau to  incorporate citizenship data into the 2010 Census Special EEO File and  incorporate such data into analyses under MD-715, FEORP, and  Executive Order No. 13171.
We recommend that the Director of OPM do the following:  Assess the extent of participation by racial and ethnic groups in student  employment programs—SCEP, FCIP, and PMF—to help agencies  maximize the use of these programs in their overall strategic workforce  plan. This effort should include:  analyzing participation in, and conversion rates to, permanent  positions from these programs and  reporting governmentwide and agency-specific demographic data for  the different racial and ethnic groups reflecting participation in, and  rates of conversion to, permanent employment from these programs.  These data are in addition to the data already reported on these  programs in its reports, such as in its statistical reports on Hispanic  employment and in the Fact Book.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the Chair of EEOC, the Director of OPM, the Attorney  General, and the Secretary of Commerce with a draft of this report for their  review and comment. In an e-mail, DOJ said it had no comments. In a  written response, the Department of Commerce said it had no comments.  (See app. V.) In its written comments, EEOC said it found the report to be  an extremely interesting and useful addition to the ongoing examination of  Hispanic representation in the federal workforce and indicated its plans to  use the report as a resource. EEOC agreed that citizenship data are an  important aspect that appears applicable not only to Hispanics, but to other  census population groups as well. In this regard, EEOC has requested that  the Census Bureau review the possibility of including citizenship data in  the 2010 Special EEO File. The availability of citizenship data would  enhance the analyses required under MD-715. However, EEOC did not  address our recommendation that it include citizenship data in its annual  comparisons of representation in the federal workforce to the CLF, which  can be based on currently available CPS or ACS data. EEOC also said that  while citizenship data are a useful benchmark for broad trending, more  refined analyses are necessary, including analyses of applicant pools and  participation rates for specific occupations. EEOC also said that analysis of  the on-board federal workforce, such as analysis of promotions and  participation in career development, employee recognition, and awards  programs, is important in assessing equality of opportunity. We agree with  EEOC that more refined analyses are necessary to assess equality of  opportunity. EEOC’s comments are reprinted in appendix VI. OPM  provided minor technical comments via e-mail, which we incorporated as  appropriate, but did not otherwise comment on the report or our  recommendations.
As agreed with your offices, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after its  issue date. We will then send copies of this report to the Chair of EEOC, the  Director of OPM, the Attorney General, the Secretary of Commerce, and  other interested parties. Copies will be made available to others upon  request. This report will also be available at no charge on GAO’s Web site at  http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-9490. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Staff who made major contributions to this report are listed  in appendix VII.
section_title: Objectives, Scope, and Methodology
paragraphs: Our objectives were to (1) identify and analyze the factors that are affecting  Hispanic representation in the federal workforce, (2) examine the steps  that the Equal Employment Opportunity Commission (EEOC) and the  Office of Personnel Management (OPM), in their oversight roles, are taking  related to Hispanic representation, and (3) illustrate the efforts within  selected federal agencies related to Hispanic representation.
To answer our first objective, we interviewed representatives from  Hispanic-serving and other relevant organizations, and federal agency  officials; reviewed previous studies; and obtained the opinions of experts  identified by the National Academy of Sciences to identify possible factors  that affect Hispanic representation in the federal workforce.  Next, we  researched available data sources that included sufficiently detailed data  on Hispanic ethnicity, employer (federal or nonfederal), and the identified  factors that could be reliably measured.  We concluded that the 2000  Decennial Census Public Use Microdata Sample (PUMS) 5-Percent File was  the best data source for our purposes.  We conducted bivariate and  multivariate analyses of data from the 2000 Decennial Census PUMS to  determine the effect of the identified factors that could be reliably  measured in this dataset on Hispanic representation in the federal  workforce.  Our methodology and results of these analyses are more  specifically described in appendix II.  We obtained opinions on our  methodology from EEOC, OPM, the Census Bureau, and the Department of  Justice (DOJ). The experts identified by the National Academy of Sciences  also reviewed and provided comments on both our methodology for  conducting these analyses and our preliminary results.  Our analyses are  not designed to prove or disprove discrimination in a court of law like  analyses conducted by EEOC or DOJ, nor do they establish whether the  differences would require corrective action by any federal agency.  Rather,  our analyses use a standard statistical method designed to provide  information at an aggregate level about factors that explain levels of  Hispanic representation in the federal workforce, relative to the nonfederal  workforce.
To determine steps EEOC and OPM have taken related to Hispanic  representation, we reviewed the statutes, regulations, executive orders,  policies, guidance, program information, and reports issued related to  Hispanic representation in the federal government.  At EEOC, we met with  officials and representatives, including from its Office of Federal  Operations, Office of General Counsel-—Research and Analytic Services,  and Office of Legal Counsel.  At OPM, we met with officials, including from  the Human Capital Leadership and Merit System Accountability Division,  Strategic Human Resources Policy Division, and the Office of General  Counsel.
To illustrate the efforts of federal agencies, we selected five Chief Financial  Officer (CFO) Act agencies or their subagencies of different sizes,  geographic locations, concentrations of jobs by grade level, and OPM’s  occupational categories.  They were the United States Air Force, Food and  Nutrition Service of the U.S. Department of Agriculture, National  Aeronautics and Space Administration, Small Business Administration, and  Social Security Administration.  We provided written questions and  document requests to agency officials and reviewed the responses received  from each of the five agencies.  We also had discussions at each agency  with officials that oversee offices and programs related to Hispanic  representation.  We also reviewed documents provided by, and spoke with  officials from, the White House Initiative on Educational Excellence for  Hispanic Americans.
In addition, we analyzed Hispanic representation in the federal workforce  governmentwide (1) compared to the Civilian Labor Force (CLF), including  and excluding noncitizens; (2) in federal occupations compared to similar  occupations in the CLF; and (3) by pay plan/grade.
To compare Hispanic representation in the federal workforce  governmentwide to the CLF, we used data from 1994 to 2005.  For the  federal workforce, we used data reported by OPM on the permanent  federal workforce.  For the CLF, which includes both permanent and  nonpermanent employees, we analyzed the March supplements to the  Current Population Survey (CPS)—the 1994–2002 Annual Demographic  Files and the 2003–2005 Annual Social and Economic Supplements  (ASEC).
To compare Hispanic representation in federal occupations to similar  occupations in the CLF, we selected the occupations which in  September 2004 had 10,000 or more federal employees, 47 occupations  in total (see app. IV).  For this analysis, we included both permanent and  nonpermanent federal employees for comparability to the CLF.  For  Hispanic representation in these occupations in the federal workforce,  we analyzed the Central Personnel Data File (CPDF) for 2000–2005.  For  Hispanic representation in these occupations in the CLF, we analyzed  the Census 2000 Special EEO File, which was created from the 2000  Census. To determine occupations that are similar in the CLF and the  federal workforce, we used the crosswalk for 2000 provided to us by  EEOC to match federal occupations with similar occupations in the CLF.
To examine Hispanic representation by grade governmentwide, we  analyzed 1990–2005 CPDF data for permanent and nonpermanent  employees in groupings of General Schedule grades 1–4, 5–8, and 9–12,  separately for grades 13, 14, and 15, and separately for those in the  Senior Executive Service, in Senior Level/Senior Technical positions,  and under the Executive Schedule. (See app. IV.)
We believe the CPDF, CPS, and Census 2000 Special EEO File are  sufficiently reliable for the purposes of this study.  Regarding the CPDF, we  have previously reported that governmentwide data from the CPDF for the  key variables in this study—race/Hispanic origin, occupation, and pay  plan/grade—were 97 percent or more accurate.  We believe the CPDF data  are sufficiently reliable for purposes of this study.  Regarding the CPS, to  assess the reliability of its data, we reviewed the technical documentation  for these data files, including the coding and definition of variables of  interest, the procedures for handling missing data, coding checks, and  imputation procedures for missing data.  We also interviewed Bureau of  Labor Statistics (BLS) staff about how federal employment and  race/ethnicity are reported and imputed and to determine how this would  affect our analyses.  We considered the response rate, allocation rate (or  the rate at which responses are imputed for unanswered questions), and  size of confidence intervals.  Because the CPS had a very high response  rate, a low allocation rate, and narrow confidence intervals, the 1994–2005  CPS data were sufficiently reliable. Regarding the Census 2000 Special  EEO File, although we and others have cited a number of limitations of  Census 2000 data, we believe these data are sufficiently reliable for the  purposes of this study (see app. II for a full description of what we did to  assess the reliability of Census data).
We conducted our work from October 2004 to June 2006 in accordance  with generally accepted government auditing standards.
section_title: Logistic Regression Analyses of Factors Affecting Hispanic Representation in the Federal Workforce
paragraphs: This appendix describes our analyses of factors that are affecting Hispanic  representation in the federal workforce.  We included those factors  identified by representatives of Hispanic-serving organizations, agency  officials, outside experts, and previous studies, which could be reliably  measured in the data set we used.  These factors were citizenship, gender,  education, veteran’s status, race, English proficiency, age, disability status,  in-school status, employment status (full- or part-time), and geography  (state where employed).  To assess the effect of these factors on Hispanic  representation in the federal workforce, we analyzed how these factors  affect the likelihood of Hispanics and non-Hispanics being employed in the  federal workforce as opposed to the nonfederal workforce.  We used  logistic regression models to estimate likelihood of federal employment.   This is a widely accepted method of analyzing dichotomous or binomial  outcomes—like being in the federal versus nonfederal workforce—when  the interest is in determining the effects of multiple factors that may be  related to one another.  In developing the model, we solicited the opinions  of experts identified by the National Academy of Sciences as well as  officials from OPM, EEOC, DOJ, and the Census Bureau.  We also sought  the experts’ views on the preliminary results of our analysis.
subsections: section_title: Data Sets Used
paragraphs: We analyzed data from the 2000 Decennial Census Public Use Microdata  Sample (PUMS) 5-Percent File because it (1) included variables needed for  our analyses and (2) had the largest sample size of the datasets containing  the variables in our analyses.  To confirm our results, we also analyzed  data from the 2004 American Community Survey (ACS) because it contains  more recent data.  In this appendix, however, we present only the results  using the PUMS data because its larger sample size makes it less prone to  sampling error than the ACS data.  In addition, the results of the analyses  of the ACS data were largely consistent with the results using the PUMS  data.
To assess the reliability of the PUMS and ACS, we reviewed the technical  documentation for these data files, including the coding and definition of  variables of interest, the procedures for handling missing data, coding  checks, and imputation procedures for missing data.  We also interviewed  Census Bureau staff about how federal employment and race/ethnicity are  reported and imputed and to determine how this would affect our analyses.   We considered the response rate, allocation rate (or the rate at which  responses are imputed for unanswered questions), and size of confidence  intervals.  Because PUMS and ACS both had a very high response rate, a  low allocation rate, and narrow confidence intervals, the 2000 PUMS and  2004 ACS were sufficiently reliable for our objectives.
The PUMS and ACS both contain self-reported data on whether someone is  part of the CLF.  The Bureau of Labor Statistics (BLS) defines the CLF as  including persons 16 years of age and older residing in the 50 states and the  District of Columbia, who are not institutionalized (i.e., in penal and mental  facilities, or homes for the aged) and who are not on active duty in the  Armed Forces.  For purposes of our logistic regression models, we divided  the CLF into two groups—the federal workforce and the nonfederal  workforce.  Further, we restricted our analyses to individuals 18 and older  because, with a few exceptions, 18 years is the minimum age for federal  employment and our analysis of the government’s official personnel data— the Central Personnel Data File (CPDF)—showed that in September 2004  individuals under 18 years of age constituted only 0.10 percent of the  federal workforce.
section_title: Methodology
paragraphs: We used bivariate and multivariate logistic regression models to estimate  the likelihood of Hispanics and non-Hispanics being in the federal  workforce relative to being in the nonfederal workforce.  There were four  steps to these analyses. 1. For the first step, we used bivariate logistic regression models to  estimate the difference between Hispanics and non-Hispanics in the  likelihood of being employed in the federal workforce, relative to the  nonfederal workforce, before controlling for any of the identified  factors.    2. For the second step, we used bivariate logistic regression models to  determine how our estimated difference in likelihood of Hispanics and  non-Hispanics being employed in the federal workforce relative to the  nonfederal workforce was affected by U.S. citizenship.  We estimated  the difference in likelihood between Hispanic citizens and non- Hispanic citizens being employed in the federal workforce relative to  the nonfederal workforce and compared it to the difference in  likelihood of federal employment among both citizens and noncitizens  combined, obtained in step 1. We analyzed the effect of citizenship  before all other factors because the federal government has a general  policy and practice of restricting hiring to U.S. citizens and nationals. 3. For the third step, we restricted our analyses to citizens only and used a  series of multivariate logistic regression models, controlling for each  factor one at a time, to estimate how each of the other factors affected  the difference in the likelihood of Hispanic citizens and non-Hispanic  citizens being in the federal workforce relative to the nonfederal  workforce.  Because of the large effect of education on the difference  between Hispanics and non-Hispanics that was revealed in this step, we  ran a bivariate model that estimated the effect of education among all  individuals—citizens and noncitizens combined—on the likelihood of  being in the federal workforce relative to the nonfederal workforce.
4.
In the fourth step, we used a multivariate logistic regression model that  estimated the difference in the likelihood of Hispanic and non-Hispanic  citizens being employed in the federal workforce versus the nonfederal  workforce after controlling for all other factors simultaneously.  Among  citizens, we controlled simultaneously for gender, education, veteran’s  status, race, English proficiency, age, disability status, school  attendance (enrolled or not enrolled), employment status (full- or part- time), and geography (state where employed).
In our analyses, we express differences in the likelihoods of being in the  federal workforce rather than the nonfederal workforce using odds ratios.   An odds ratio is generally defined as the ratio of the odds of an event  occurring in one group compared to the odds of it occurring in another  group—the reference or comparision group.  In our analyses, the event of  interest to us was employment in the federal workforce versus employment  in the nonfederal workforce.  We computed odds ratios to indicate the  difference between Hispanics and non-Hispanics in the likelihood of being  employed in the federal workforce (1) before controlling for any of the  other factors, (2) after controlling for all of the factors one at a time, and  (3) controlling for all factors simultaneously.
In our analyses, an odds ratio of 1.0 would indicate that Hispanics and non- Hispanics were equally likely to be employed in the federal workforce as in  the nonfederal workforce, or that the ratio of Hispanics to non-Hispanics  was the same in the two workforces.  An odds ratio of less than 1.0 would  imply that Hispanics were less likely than non-Hispanics to be in the federal  workforce as opposed to the nonfederal workforce, while an odds ratio  greater than 1.0 would imply that Hispanics were more likely.  For example,  an odds ratio of 0.5 would indicate that Hispanics were only half or 50  percent as likely as non-Hispanics to be in the federal workforce as  opposed to the nonfederal workforce.  An odds ratio of 2.0 would indicate  that Hispanics were twice as likely as non-Hispanics to be in the federal  workforce as opposed to the nonfederal workforce.  We also use odds  ratios to indicate the effects of the other factors we considered (i.e.,  education, race, etc.), and they can be similarly interpreted.
Given the large sample size of the PUMS file, all of the results reported are  statistically significant at the 95 percent confidence level.  Thus, we  concentrated our analysis on the size or magnitude of the odds ratio—that  is, how much smaller or larger than 1.0 they were—rather than the  statistical significance of the odds ratios.
section_title: The Difference between Hispanics’ and Non-Hispanics’ Likelihood of Employment in the Federal Workforce versus the Nonfederal Workforce
paragraphs: We initially estimated the difference in the likelihood of Hispanics and non- Hispanics being employed in the federal workforce versus the nonfederal  workforce before controlling for any of the identified factors.  Table 4  shows the numbers, odds, and odds ratio derived from the PUMS to  estimate the likelihood of Hispanics and non-Hispanics being employed in  the federal workforce relative to being in the nonfederal workforce.  The  odds ratio of 0.698 indicates that the odds of Hispanics being in the federal  workforce rather than the nonfederal workforce were about 30 percent  lower than the corresponding odds for non-Hispanics.
We calculated the odds ratio of 0.698 by first deriving the odds of being a  federal employee rather than a nonfederal employee for both Hispanics and  non-Hispanics.  For Hispanics, we divided the number of the Hispanic  federal employees by the number of Hispanic nonfederal employees, or  219,893/15,228,215, which equals 0.0144.  This implies that the odds of being  a federal employee among Hispanics were 0.0144; that is, there were 14.4  Hispanics who are federal employees for every 1,000 Hispanics who were  nonfederal employees.  For non-Hispanics, by comparison, the odds were  2,438,122/117,921,113 = 0.0207, which means that there were 20.7 non- Hispanics who were federal employees for every 1,000 non-Hispanics who  are nonfederal employees.  The odds ratio, or ratio of these two odds,  which is 0.0144/0.0207 = 0.698, indicates that the odds on being a federal  employee (i.e., represented in the federal workforce) were lower for  Hispanics than non-Hispanics, by a factor of 0.698.
section_title: The Effect of Citizenship on the Difference between Hispanics’ and Non- Hispanics’ Likelihood of Employment in the Federal Workforce versus the Nonfederal Workforce
paragraphs: We examined the effect of citizenship on the difference in the likelihood of  Hispanics and non-Hispanics being employed in the federal workforce,  relative to the nonfederal workforce, before examining the effect of all  other factors because the federal government has a general policy and  practice of restricting hiring to U.S. citizens and nationals.  Table 5 shows  the odds and odds ratio that are obtained when citizens only are used to  estimate the likelihood of Hispanics and non-Hispanics being employed in  the federal workforce relative to being in the nonfederal workforce.  When  these same odds and odds ratio were calculated for citizens only, the odds  were similar (0.0200 and 0.0210), and the odds ratio of 0.953 implies that  the odds of being a federal employee, among Hispanic citizens, were lower  than for non-Hispanic citizens by about 5 percent.  Comparing this to the  odds ratio indicating the difference in the likelihood of Hispanics and non- Hispanics being employed in the federal workforce among the both citizens  and non-citizens—0.698—indicates that citizenship accounts for much of  the difference in the likelihood of federal employment between Hispanics  and non-Hispanics, since the difference in the odds changes from about 30  percent to roughly 5 percent.
section_title: Effect of Remaining Factors among Citizens on the Difference between Hispanics’ and Non-Hispanics’ Likelihood of Employment in the Federal Workforce versus the Nonfederal Workforce
paragraphs: To determine the effect of the remaining factors on likelihood of Hispanics  and non-Hispanics being in the federal workforce relative to being in the  nonfederal workforce, we restricted our analysis to U.S. citizens because  the federal government has a general policy and practice of hiring only U.S.  citizens.  We then controlled for each of the other factors one at a time  among U.S. citizens in a series of multivariate logistic regression models.   Table 6 shows the odds ratios representing the difference between  Hispanics and non-Hispanics in the likelihood of being employed in the  federal workforce relative to the nonfederal workforce, when the other  factors are controlled one at a time.  The effect that each factor has on the  difference between Hispanics and non-Hispanics in the likelihood of being  in the federal workforce as opposed to the nonfederal workforce can be  discerned by comparing each of the odds ratios in Table 6 to 0.95—the odds  ratio indicating the likelihood of Hispanic and non-Hispanic citizens being  employed in the federal workforce before controlling for the other factors.   For example, as table 6 shows, controlling for differences in education—or  estimating the effect of being Hispanic on the likelihood of being in the  federal workforce after allowing for the differences in education between  Hispanics and non-Hispanics—changes the odds ratio from 0.95 to 1.16.   That is, among similarly educated workers, Hispanic citizens were more  likely than non-Hispanic citizens, by a factor of 1.16, or 16 percent, to be in  the federal workforce as opposed to the nonfederal workforce.  Controlling  for race, veteran status, and to a lesser extent age also changed slightly the  estimated difference between Hispanic and non-Hispanics in the likelihood  of being a federal employee.
Because of the large effect of education on the difference between  Hispanics and non-Hispanics, we also analyzed the effect of education  among all individuals.  The odds ratios indicating the differences in the  likelihood of being in the federal workforce between workers who have  some college, a bachelor’s degree, and more than a bachelor’s degree,  relative to workers with a high school diploma, were 1.74, 2.15, and 2.69,  respectively.  In other words, each of those three categories of workers was  almost twice as likely (1.74) or more than twice as likely (2.15 and 2.69) to  be employed in the federal workforce relative to the nonfederal workforce  as workers with only a high school diploma.  Persons with less than a high  school degree, by contrast, were less than half as likely as persons with a  high school degree to be employed in the federal workforce relative to the  nonfederal workforce.
section_title: Effect of All Factors Considered Simultaneously on the Difference between Hispanics’ and Non- Hispanics’ Likelihood of Employment in the Federal Workforce versus the Nonfederal Workforce
paragraphs: When we estimated the difference in the likelihood of being in the federal  workforce between Hispanics and non-Hispanics using a multivariate  model that accounted for all of the factors simultaneously among citizens,  we found that the odds of being a federal rather than a nonfederal  employee were higher for Hispanic citizens than for non-Hispanic citizens,  by a factor of 1.24.  That is, when all other factors we examined were  controlled, the odds of being in the federal workforce relative to the  nonfederal workforce were 24 percent higher for Hispanics than non- Hispanics.
section_title: Additional Explanatory Analyses
paragraphs: In response to comments from expert reviewers on a preliminary draft of  these results, we conducted additional analyses to determine whether  (1) our results were affected by the method we used to control for  citizenship, (2) there was any difference between the effect of education  for Hispanics and non-Hispanics, and (3) Hispanics’ odds of federal  employment were affected by changing the reference group from all non- Hispanics to white non-Hispanics.
First, we analyzed whether controlling for citizenship by excluding  noncitizens produced different results than controlling for citizenship by  including both groups in our model and introducing a control variable for  citizenship status.  We used a multivariate logistic regression model  controlling for all the factors simultaneously among both citizens and  noncitizens and controlled for citizenship status using a dummy variable  (rather than excluding them).  When we controlled for citizenship status  using a dummy variable for citizenship status, the odds ratio indicating the  difference between Hispanics and non-Hispanics in the likelihood of being  in the federal workforce was 1.22, not appreciably different from the odds  ratio of 1.24 reported above.
Second, we analyzed whether the effect of education on being employed in  the federal workforce was different for Hispanics and non-Hispanics. We  used an interaction model, which allowed us to assess whether the effect of  education on the odds of federal employment varied between Hispanics  and non-Hispanics.  This model revealed that while education affected the  odds of federal employment for both Hispanics and non-Hispanics, the  effect of education was generally more pronounced for Hispanics than non- Hispanics.  For example, Hispanics with a bachelor’s degree were 2.27  times more likely to be employed in the federal workforce than Hispanics  with a high school diploma.  Among non-Hispanics, those with a bachelor’s  degree were 2.04 times more likely than those with only a high school  diploma to be employed in the federal workforce.
Third, to analyze whether Hispanics’ odds of federal employment were  affected by changing the reference group from all non-Hispanics to white  non-Hispanics, we used dummy variables for race and ethnicity when  comparing Hispanics, black non-Hispanics, and other nonwhite non- Hispanics, to white non-Hispanics as opposed to comparing Hispanics to  non-Hispanics when controlling for all other factors.  Including dummy  variables for race and ethnicity yielded an odds ratio distinguishing  Hispanics from white non-Hispanics of 1.55, which is greater than the odds  ratio of 1.24 distinguishing Hispanics and non-Hispanics.  The greater odds  ratio resulted from black non-Hispanics and other nonwhite non- Hispanics—who were 1.82 and 1.89 times more likely to be employed in the  federal workforce than white non-Hispanics—being taken out of the  reference category.  We did not analyze the effect of the interaction  between race and Hispanic ethnicity; that is, comparing odds of federal  employment among white Hispanics, black Hispanics, and other Hispanics  because of differences in the reporting of race between Hispanics and non- Hispanics.
section_title: Limitations
paragraphs: Due to limitations in the data and the methods we used, we did not include  in our analyses some variables that were identified during the course of our  research that could potentially affect Hispanic representation in the federal  workforce.   We did not analyze whether discrimination against or attitudes  towards Hispanics or any other group affected representation in either the  federal or nonfederal workforces because, using our data sources, it was  not possible to conduct such an analysis.  We did not analyze Hispanic  subgroup data because of concerns we expressed in our prior work and those expressed by the Census Bureau and outside researchers.   Additionally, some factors identified were not asked on the Census and we  could not identify an adequate proxy suitable for our methodology; we  cannot say how, or if, these factors would affect the results of our analyses.   Variables for which we could not control include experience in a particular  occupation, number of years naturalized U.S. citizens have been citizens of  the United States, and an individual’s preference for employment in either  the federal or nonfederal workforce.  Additionally, we did not control for  Standard Metropolitan Statistical Area or other geographical units smaller  than states because these would result in sample sizes too small to control  for the full range of factors.  For foreign-born respondents, we did not  control for years since arrival in the United States because the data were  insufficiently reliable. Finally, we could not control for how unemployment  affects the likelihood of being in the federal workforce because  unemployment perfectly predicts not being in the federal workforce;  however, unemployed individuals are considered part of the CLF.
Additionally, with respect to race—one of the factors for which we  controlled—some have suggested that many Hispanics view race  differently than non-Hispanics and consider their ethnicity as a separate  racial category.  Such differences in the perception of race could affect our  estimates on the effect of race on the likelihood of Hispanics and non- Hispanics being employed in the federal workforce relative to the  nonfederal workforce.  According to the U.S. Census Bureau, among  Hispanics in the 2000 Decennial Census, 47.9 percent reported themselves  as white, 2.0 percent as black, 1.2 percent as American Indian/Alaska  Native, 0.3 percent as Asian, 0.1 percent as native Hawaiian and Other  Pacific Islander, 6.3 percent as two or more races, and 42.2 percent as some  other race.  Among non-Hispanics, 79.1 percent reported themselves as  white, 13.8 percent as black, 0.8 percent as American Indian/Alaska Native,  4.1 percent as Asian, 0.1 percent as native Hawaiian and Other Pacific  Islander, 1.9 percent as two or more races, and 0.2 percent as some other  race.  Some studies suggest that the difference in the percentage of “other  race” responses between Hispanics and non-Hispanics—42.2 and 0.2— reflects many Hispanics’ view that their race is Hispanic, rather than one of  the racial categories listed in the Census.
Additionally, while assessing the reliability of the PUMS for our analysis,  we found that the number of federal employees reflected in the PUMS was  larger than the number reported in either OPM’s Central Personnel Data  File (CPDF) as of September 2000 or OPM’s report Employment and  Trends (March 2000).  In the PUMS there were about 2,658,000 federal  employees (excluding the Postal Service) compared to slightly less than 2  million reported by OPM for 2000 in either of its sources.  There was also a  similar discrepancy in 2004, with nearly 2 million federal employees  reported by OPM (CPDF as of September 2004, Employment and Trends,  March 2004) compared to about 2,757,000 identified in the ACS.
Although we were unable to fully account for these differences, we did  identify some known sources for lower numbers of federal employees  reported by OPM.  Neither of OPM’s data sources include (1) federal  employees working for the intelligence agencies such as the Central  Intelligence Agency, National Security Agency, National Geospatial- Intelligence Agency, and Defense Intelligence Agency; (2) most personnel  on federal installations paid from non-appropriated funds, such as workers  in military commissaries; and (3) those in the Commissioned Corps of the  Public Health Service and National Oceanic and Atmospheric  Administration.  In addition, OPM’s CPDF data do not include judicial and  some legislative branch employees and employees of the Tennessee Valley  Authority.  Another potential source of the difference in the number of  federal employees is that employees of federal contractors who work at  federal agencies or on military installations might have responded on the  Census that they were employees of the federal government.  Several  experts who commented on our methodology and results expressed a  similar view.
To assess whether our results were affected by the difference in the  number of federal employees in the PUMS and CPDF datasets, we  substituted the federal employees from the CPDF for the federal employees  in the PUMS.  Our analysis, using the combined CPDF and PUMS data,  confirmed that citizenship and education accounted for the difference in  likelihood of Hispanics and non-Hispanics being employed in the federal  workforce.  Given these, the large sample size of PUMS, the high response  rate to the Census 2000 long form that is the basis for PUMS, and the  quality control measures Census uses in collecting the PUMS data, we  believe our reported results are sound and the conclusions we reached are  reasonable.
Like reported federal employment in PUMS, reports of citizenship in self- reporting surveys may be inflated.  As we lacked benchmark data to assess  the potential effect of misreporting of citizenship, we cannot say if or how  the results would be affected by such misreports.  Additionally, because we  used data from a single census, we cannot make statements regarding  future trends in the estimates.  For example, changes in the number or  geographic distribution of Hispanics might affect the likelihood of federal  employment in future censuses.
Finally, our results are limited and intended to only reflect the effect of  selected factors on Hispanic employment in the overall federal workforce  and cannot be applied to individual occupations, grades, agencies, or other  subsets of the federal government.  We attempted to analyze the effect of  selected factors on the federal occupations that employed 10,000 or more  federal employees in 2004 and similar occupations in the nonfederal  workforce, but we found that our results were not reliable.  First, sample  size within job categories is much smaller and subject to much greater  sampling variability than in the full data set.  Sample sizes this small  preclude controlling for the full range of factors considered in our model.   Second, PUMS data and our models cannot account for specific skills and  certification, which might be particularly relevant for a given occupation.   For example, the education categories do not distinguish between a  bachelor’s degree in chemistry or in English literature.  Third, we could not  account for the specific career paths required for certain occupations or  those that can only be obtained on the job.  For example, job seekers with a  background in policing may be more qualified to be a federal officer.
Fourth, we could not account for individuals who may be qualified for a  given occupation, but holding a different one.  For example, some of the  individuals coded as accountants may be qualified to be financial  specialists, a separate occupation.  Restricting the sample to financial  specialists might result in an understated pool of qualified workers.
section_title: Authorities Related to the Hiring of U.S. Citizens and Nationals
paragraphs: Various authorities have restricted hiring for most federal employment to  U.S. citizens and nationals.  Under Executive Order No. 11935, only U.S.  citizens and nationals may be appointed into competitive service  positions.  In 2005, 72 percent of executive branch employees were in the  competitive service.  In rare cases, noncitizens may be appointed when  necessary to promote the efficiency of the service, such as if an agency is  unable to find a qualified citizen to fill a position (5 C.F.R. §7.3(c) and  §338.101).  Such appointments, however, must also be in compliance with  other laws on federal hiring of noncitizens.
For decades, Congress has passed an annual ban on the use of  appropriated funds for compensating federal employees who are not U.S.  citizens or nationals.  Broader in scope than the Executive Order, the  appropriation ban applies to all compensable positions within the federal  government, not just to competitive service positions.  There are  exceptions to this ban that permit the compensation of non-U.S. citizens  who are from certain countries or under special circumstances. For  example, South Vietnamese, Cambodian, or Laotian refugees paroled in the  United States after January 1, 1975, are excluded from the ban.  Also,  citizens from Ireland, Israel, or the Republic of the Philippines, or nationals  of countries “allied with the United States in a current defense effort” are  excluded from coverage of the appropriation ban.  Even though the  appropriation ban may not apply under a particular circumstance, the  hiring of a noncitizen may nevertheless be prohibited because the position  is within the competitive service and covered by the Executive Order ban.
Congress has excluded some agencies (or certain types of positions within  some agencies) from the restrictions on hiring or compensating  noncitizens.  For example, the Department of Defense is excluded from  restrictions on employment and payment of noncitizens.
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section_title: Comments from the Department of Commerce
section_title: Comments from the Equal Employment Opportunity Commission
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact named above, Belva M. Martin, Assistant  Director; Carl S. Barden; Jeffrey A. Bass; Benjamin A. Bolitzer; Karin K.  Fangman; Anthony P. Lofaro; Anna Maria Ortiz; Rebecca Shea; Douglas M.  Sloane; Tamara F. Stenzel; and Gregory H. Wilmoth made major  contributions to this report.