Coast Guard: Civil Rights Directorate's Action Plans to Improve Its Operations Could Be Strengthened by Implementing Several Aspects of Project Planning and Implementation Practices
Published: 2010-04-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Allegations of management weaknesses, unsecured personal information, and employee dissatisfaction have been made against U.S. Coast Guard's Civil Rights Directorate (CRD). To address these allegations, the Director of CRD commissioned an external review of civil rights operations. In February 2009, the review made 53 recommendations to improve the civil rights operations. CRD developed action plans to address these recommendations. As requested, GAO reviewed (1) how Coast Guard's action plans align with EEOC's elements of a model equal employment opportunity program (2) how Coast Guard developed and reviewed its action plans, and (3) the extent to which Coast Guard's action plans align with generally accepted project management practices. To conduct this work GAO reviewed documentation from CRD, EEOC, internal control standards, and literature on project management. We also interviewed CRD officials.
section_title: What GAO Found
paragraphs: Of the Equal Employment Opportunity Commission's (EEOC) six equal employment opportunity program model elements, CRD's action plans focus mainly on the first--agency leadership. Of the 29 action plans developed and implemented by CRD to address the 53 recommendations in the recent external review, almost half center on the leadership element. For example, one action plan involved scheduling training for headquarters and field staff. CRD took several steps to develop and review action plans to address recommendations from the external review, such as developing a functional review team, assigning project officers, meeting with the Commandant and agency leadership, and consulting the agency financial officer. However, CRD did not consistently document key decisions related to the development and review of the action plans as recommended in federal internal control standards. As a result, CRD lacks transparency and accountability to stakeholders. Lack of documentation also impedes the ability to track progress, make mid-course corrections, and illustrate to stakeholders that it is effectively solving these issues. According to CRD officials, their priority was to complete the action plans in a timely manner rather than ensure that development and review processes were documented. GAO reviewed four of CRD's action plans in relation to generally accepted project management practices to determine the extent to which recommended practices were followed. The recommended practices are: (1) identifying measurable performance goals, (2) defining specific tasks, (3)identifying the person(s) accountable, (4) identifying interim milestones and checkpoints, (5) identifying the needed resources, (6)consulting stakeholders, and (7) defining how to evaluate success. The selected action plans showed some elements of the project management practices, such as identifying accountable individuals, but fell short in relation to other elements. Specifically, performance goals were identified in the form of a product, such as development of a manual, rather than in relation to a desired outcome, such as demonstrating an increase in the number of staff who know how to properly safeguard personal information. All four action plans we reviewed lacked plans for evaluating their success. CDR officials stated that they were more focused on completing the plans rather than evaluating them, but early evaluation can identify and guide mid-course corrections to ensure positive change.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the approach the Civil Rights  Directorate (CRD) of the U.S. Coast Guard has taken to improve the  operations of its civil rights program. According to CRD, their mission is to  foster and maintain a model workplace which supports mission execution.  To accomplish this mission, CRD manages the Coast Guard Equal  Employment Opportunity (EEO) program for civilian employees and the  Equal Opportunity (EO) program for its military members. In advancement  of these programs, CRD provides services such as an intake, mediation,  and review process for military and civilian complaints for all Coast Guard  personnel.
Under a prior Director, two separate external reviews of the civil rights  operations made recommendations for improvement related to the CRD’s  organizational structure, complaint processes, and program effectiveness.  More recently, allegations of management weaknesses, unsecured  personal information, and employee dissatisfaction have been made  against CRD. The current CRD Director commissioned a third external  review and evaluation in September 2008 to improve the operations of the  civil rights program. In February 2009, Booz Allen Hamilton (BAH)  completed this review and made 53 recommendations, which were similar  to those of the previous reports. The Director of CRD subsequently  developed action plans to address these recommendations.
As requested, my testimony today will describe (1) how Coast Guard’s  action plans align with the elements of a model equal employment  opportunity program, (2) how Coast Guard developed and reviewed its  action plans, and (3) the extent to which Coast Guard’s action plans align  with generally accepted project management practices.
To address all of the objectives, we reviewed the 2009 BAH report and  recommendations and selected CRD action plans and supporting  documentation to address the recommendations. In addition, to identify  how Coast Guard’s action plans focus on the elements of a model EEO  program, we reviewed the Equal Employment Opportunity Commission’s  (EEOC) Management Directive-715 (MD-715), which established the  elements. In the absence of an EO framework of model elements, and  given that CRD stated they apply the EEO model elements to all Coast  Guard personnel, including military, we have used the EEO model  elements framework to organize the actions plans.
To describe how the Coast Guard developed and established a project  management process for its action plans, we obtained documentation from  CRD officials on their organizational structure and review processes and  interviewed CRD officials to supplement the documentation. To determine  the extent to which Coast Guard’s action plans are aligned with generally  accepted project management practices, we reviewed prior GAO reports  and the Government Performance and Results Act (GPRA) of 1993, and  also conducted an external literature review to identify elements of  successful project planning and implementation. Subsequently, we  identified and adapted seven practices that are associated with generally  accepted project management practices. We analyzed the extent to which  selected action plans contained seven practices associated with generally  accepted project management practices. We also reviewed our prior work  on the Coast Guard’s modernization program for context regarding the  Civil Rights Directorate’s restructuring action plan. We conducted semi- structured interviews with Coast Guard officials responsible for the  design, implementation, and approval of action plans to address the  recommendations.
As part of our assessment, we selected and reviewed four action plans that  are related to key issues identified in the external review. For example, the  first three action plans relate to improving the consistency of EO/EEO  service delivery throughout Coast Guard—a major issue identified in the  third party review. The selected plans encompass actions on 13 of the 53  recommendations and address major concerns with CRD’s operations. We  selected the following action plans:    Completing a New Personally Identifiable Information (PII) Handbook;    Restructuring Civil Rights Operations;    Revising the EO Manual; and    Training to Address Office Climate.
We conducted this performance audit from November 2009 through April  2010, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
In brief, nearly half of the action plans align with strengthening the  demonstrated commitment from leadership. Leadership commitment is an  essential element of a model EEO program. While action plans and  leadership commitment are critical, only effective implementation of  solutions will resolve the CRD’s long-standing issues. According to CRD  officials, their priority was to address the recommendations and complete  the planning and implementation of action plans in a timely manner.  Although CRD established a planning and process management control  group and focused on implementing and completing the action plans  quickly, in many cases the CRD action plans lack documentation  important to internal controls, and these plans could be improved by  defining measurable outcome goals and plans for evaluation of action plan  results. Without internal controls, such as timely and reliable  documentation, CRD weakens transparency to stakeholders and loses a  historical record of its implementation approach. Based on our review of  the selected action plans, we recommend that, going forward, CRD:   (1) ensure internal controls are in place to maintain the documentation  necessary to facilitate oversight and course corrections as plans are  designed and implemented, (2) establish measurable performance goals  for the action plans to support the management decision as to the  completion status of the action plans, and (3) define an evaluation plan for  each action plan to assess the degree to which the plan yielded the  intended outcomes.
subsections: section_title: Background
paragraphs: The Coast Guard is one of the five armed forces of the United States and  the only military organization within the Department of Homeland  Security. Coast Guard is charged with carrying out 11 statutory missions  with approximately 50,000 personnel: 42,000 active duty military and 8,000  civilians.
CRD’s mission is to foster and maintain a model EO/EEO workplace that  supports mission execution. CRD’s principal functions are to facilitate the  Coast Guard’s (1) EEO program for its civilian employees and (2) EO  program for its military members. Under the EEO program, CRD is  responsible for ensuring Coast Guard compliance with the federal statutes  prohibiting employment discrimination as well as EEOC’s regulations and  directives, including MD-715, which explains the basic elements necessary  to create and maintain a model EEO program. Under the EO program,  while military members are not covered by the antidiscrimination statutes  and EEOC regulations and directives, Coast Guard policy provides that  military equal opportunity policies are generally based upon principles set  forth in civilian EEO policy, including affording military members with  discrimination complaint procedures that mirror the EEO process to the  extent possible.
CRD is led by a Director who reports to the Commandant of the Coast  Guard and is responsible for all EEO/EO activities within the Coast Guard.  The Chief of the Office of Policy, Planning, and Resources reports directly  to the Director of the CRD and serves as the acting Director in the  Director’s absence. The Office of Policy, Planning, and Resources also  acquires, allocates, and oversees resources for CRD in compliance with  the Chief Financial Office’s policies. The Chief of the Office of Civil Rights  Operations reports to the Director of CRD and oversees and manages all  full-time 45 Coast Guard civil rights service providers through three Civil  Rights Regional offices.
As stated previously, EEOC’s MD-715 provides guidance to federal  agencies to identify the basic elements necessary to create and maintain a  model EEO program. EEOC instructions state that an agency should  review its EEO and personnel programs, policies, and performance  standards against six elements to identify where their EEO program can  become more effective. The six essential elements EEOC describes for a  model EEO program are:    Demonstrated commitment from agency leadership,   Integration of EEO into the agency’s strategic mission,    Management and program accountability,    Proactive prevention of unlawful discrimination,    Efficiency, and    Responsiveness and legal compliance.
section_title: Agency Leadership Is the Primary EEOC Model Program Element Addressed by Coast Guard Action Plans
paragraphs: Over one-third of the 2009 recommendations dealt with agency leadership  issues, as did the recommendations of the prior reviews. CRD developed  29 action plans to address the recent 53 recommendations, with 13  focusing on leadership. Table 1 shows a summary of the distribution of  these action plans across EEOC’s six model elements.
The priority given by CRD to address agency leadership is based on the  most recent recommendations they received and is also consistent with  the focus of earlier third-party recommendations provided to the Coast  Guard on EO/EEO issues. According to EEOC, the leadership element of  a model program includes allocating sufficient resources to the EEO  program, such as personnel with training and experience, staff with  relevant knowledge and skills, adequate data collection and analysis  systems, and training programs for all employees. Issuing an effective EEO  program policy statement and ensuring that all employees are informed of  EEO programs are also part of the demonstrated commitment element.  Examples of the action plans that focus on demonstrated commitment  from agency leadership include:    Develop a comprehensive training program for Civil Rights Service    Schedule Office of Civil Rights headquarters and field-level senior staff for  the Center for Creative Leadership North America Leadership workshops;  and    Task regional managers with identifying skills and managing the training  needs of their staffs.
section_title: Although CRD Established Processes to Develop and Review Selected Action Plans, Documentation of Key Decisions and Outcomes Needs Improvement
paragraphs: CRD took several steps to develop and review action plans to address  recommendations from the most recent external review, such as  developing a functional review team, assigning project officers, meeting  with the Commandant and agency leadership, and consulting the agency  financial officer. CRD officials stated that they organized with a sense of  urgency to address the recommendations and complete their planning and  implementation of action plans. The key players in the planning and  implementation of action plans were:    Functional Review Team: According to CRD staff, a team of senior CRD  staff, called the “Tiger Team,” was created to serve as the functional  review team. This team aimed to effectively and efficiently address the  recommendations with limited resources. Members of the Tiger Team  included the Director of CRD, the executive assistant, the Chief of the  Office of Policy and Planning, and Chief of the Office of Civil Rights  Operations. The Tiger Team guided the development of the action plans  and also reviewed and approved the implementation of the action plans.  The Tiger Team formulated strategies to implement action plans, assigned  project officers, set deadlines for project officers to complete action plans,  and reviewed documentation submitted by project officers to support their  position that an action plan was complete.
Project Officers: Project officers, appointed by the Tiger Team, were  responsible for providing weekly updates to the Tiger Team and for  overseeing the execution of the action plans. CRD told us that the project  officers were chosen based on their job responsibilities and knowledge of  the subject matter. The project officers reported to the Tiger Team  through an appointed lead project officer.
Commandant: CRD staff told us that the Director and executive assistant  met regularly with the Commandant to provide updates and receive  feedback on the action plans. According to CRD staff, during these  meetings the Commandant provided guidance on the action plans and  helped formulate the decision on time frames to complete the action plans.
Agency Leadership: Coast Guard leadership, including the Commandant,  was involved mainly with the action plan to restructure civil rights  operations. The Commandant charged the Leadership Council, an advisory  body of the Coast Guard’s senior leadership, with evaluating CRD’s  organizational structure, human resource practices, and needs related to  their EEO program, diversity, and climate, among other related  responsibilities. CRD briefed the Leadership Council twice and the council  provided guidance and feedback to CRD on aspects of the restructuring  action plan.
Coast Guard’s Restructuring Team: The Commandant’s Intent Action  Order Reorganization Review Team is an intra-agency body that reviews  organizational restructuring proposals for compliance with rules of  engagement and conformity to overall Coast Guard organizational rules  and policies. The review team’s approval was necessary for CRD to  restructure its operations; CRD completed a checklist that was required to  gain the review team’s approval.
Coast Guard Directorates: CRD staff also met with senior officials in  other directorates for feedback on action plans that related to their  respective offices. For example, the Director and executive assistant met  with Planning, Resources, and Procurement Directorate staff to review all  the action plans for financial implications and to receive status updates  from CRD on the execution of the action plans. The Planning, Resources,  and Procurement Directorate staff advised the Commandant on the budget  implications of the proposed action plans and recommended budget- related decisions. Although the Chief Financial Officer did not have  approval responsibilities, he received periodic status updates from CRD  on the execution of the action plans. CRD officials also stated that the  Engineering and Logistics Directorate and the Command, Control,  Communications, Computers and Information Technology Directorate  reviewed the restructuring action plan.
subsections: section_title: CRD Did Not Consistently Document Key Decisions Related to the Development and Review of the Action Plans
paragraphs: When developing and reviewing the action plans, CRD did not maintain  documentation as recommended in federal internal control standards. As  a result, CRD lacks transparency and accountability to stakeholders. Lack  of documentation also impedes the ability to track progress, make  midcourse corrections, and illustrate to stakeholders that it is effectively  solving these issues. According to the internal control standards, accurate  and timely documentation of actions and events is necessary for the  management of an organization and for making effective decisions.
CRD was not able to provide documentation for recording minutes and  decisions made at internal meetings, meetings with the Commandant,  briefings to the Leadership Council, or meetings related to the action  plans. They primarily tracked the action plans and the status of their  completion through the functional review recommendation sheet. In  addition, they used memos and e-mails to document some decisions and as  a way to delegate responsibility.
The Functional Review Recommendation (FRR) Spreadsheet: The  FRR spreadsheet was the primary tool that CRD used to update the  Commandant and CRD leadership on action plan development and  implementation. The Tiger Team designed the FRR spreadsheet using the  Commandant’s guidance on important elements to track. For each  recommendation, this spreadsheet included the responsible project  officer, actions taken, the priority of the action plan, deadlines, days until  deadlines, and completion status. After receiving status notes from the  project officers through the CRD executive assistant, the lead project  officer would update the FRR sheet by deleting previous entries in the  “Action Taken” columns. As a result, CRD only has documentation of the  most recent actions taken and in the future will not be able to assess the  effectiveness of their approach to the action plans. Decisions or  directions from the Commandant as a result of these status reviews were  not recorded.
Memos: CRD used memos to document some decisions, such as the  rationale behind restructuring the directorate, the assignment of a  modernization officer to oversee the logistics of CRD’s modernization, the  Commandant’s approval of resources for training, staffing, and other  program support, and the assignment of a PII privacy officer to ensure that  safeguards are in place for proper handling of complaint records.
E-mails: CRD used e-mails to document when meetings were held and  who was invited to meetings. CRD provided e-mails as the sole  documentation of certain actions related to the planning and  implementation of the action plans, such as the designation of tasks to  staff, outreach to stakeholders, and submission of action plan status  updates.
CRD officials stated that their priority was to complete the action plans in  a timely manner rather than assure that development and review  processes were documented. However, without timely and reliable  documentation of decisions and actions, CRD cannot communicate or  provide a historical track of its approach to the action plans. Ultimately,  this lack of documentation may weaken CRD’s transparency. When an  organization is undergoing change, as is the case with CRD and Coast  Guard, transparency becomes even more important as it can increase the  staff’s confidence in the changes.
According to CRD officials, the CRD executive assistant—an integral part  of the action plan implementation process—serves at CRD on a rotating  basis and will leave the position in June of 2010. Without documentation of  the decisions made in the design, implementation, and review of the action  plans, the knowledge the official has may leave with him.
Documentation of decisions may also allow CRD to demonstrate to Coast  Guard leadership and other stakeholders its progress in addressing long- standing issues identified in the two previous external reviews of CRD.  Both the reviews of CRD highlighted issues related to the office’s  organizational structure, complaint process, and effectiveness, among  other issues. Clear documentation is necessary so that the directorate can  track progress, make midcourse corrections, and illustrate to stakeholders  that it is effectively solving long-standing issues.
The following are examples of the types of records that CRD could have  maintained:    Documentation of the action plan development process and its products,  such as minutes from the internal CRD meetings. Minutes from these  meetings could have included concerns that were raised, decisions that  were made, follow-up issues, and individuals in attendance. Decisions  from the Commandant, Leadership Council, and other directorates should  also have been documented.
Documentation of the review process, such as the individuals tasked with  reviewing the action plans, dates when completed action plans were  approved or denied, and criteria for approving the completion of the  action plans.
Historical record of the weekly status updates of the action plans on the  FRR spreadsheet, without which CRD officials may not be able to  determine if they are on track to meet their goals or course-correct if  necessary. They also cannot use this historical record to fine-tune action  planning in the future.
section_title: Selected Action Plans Implemented Some Project Planning Practices, but Did Not Fully Implement Other Practices
paragraphs: According to the Project Management Institute, a project plan is used to  guide the execution and the internal controls for a project. The plan  documents planning assumptions, project decisions, approved scope, cost,  and schedules. Among other benefits, this facilitates communication  among stakeholders. The following seven practices are adapted from  generally accepted project management practices:  1.  Identifying measurable performance goals;  2.  Defining specific tasks to complete the action plan;  3.  Identifying the person(s) accountable for completing the tasks to  complete the action plan;  4.  Identifying interim milestones/checkpoints to gauge the completion of  5.  Identifying the needed resources to complete the action plan;  6.  Consulting stakeholders; and  7.  Defining how to evaluate the success of completing the action plan.
We reviewed the following four action plans that are related to key issues  identified in the external review. These action plans encompass 13 of the  53 recommendations that were made to CRD.
Complete a New PII Handbook. This action plan was intended to create  a PII handbook. To do so, CRD needed to complete a number of complex  tasks including developing Standard Operating Procedures for personal  and confidential information, developing a records management system  for EEO/EO-related records, instituting a privacy and records management  program, and assigning a privacy officer in Coast Guard headquarters.
Train Senior Staff to Address Office Climate. This action plan was  intended to improve the interpersonal dynamics of CRD’s senior staff.  Elements of the action plan included using workshops to help senior staff  understand their own and others’ underlying interests and concerns,  guiding the Director, Deputy Director, and senior staff to pursue more  collaborative methods of working with each other, and strengthening  leadership effectiveness in group dynamics.
Restructure Civil Rights Operations. This action plan was intended to  centralize the management of the EEO/EO services. Formerly, the civil  rights service providers who receive EEO/EO complaints were  geographically dispersed and reported to their command leader within the  geography in which they were located. In the centralized structure, full- time civil rights service providers report to three civil rights regional  managers, each responsible for a multistate region. As the regional  managers report to CRD rather than Field Commanders, they are in the  direct line of command of CRD headquarters.
Revise the EO Manual. This action plan was intended to address the  recommendation to revise the manual and add content that addresses the  roles of field and headquarters personnel throughout the complaint  process and the appropriate statutory references and citations. CRD  contracted this undertaking to a third party to complete while providing  the oversight intended to achieve a standardized administration of  complaints throughout the commands.
subsections: section_title: Action Plans Only Partially Identified Measurable Performance Goals and Did Not Define How to Evaluate the Success of Completing a Plan
paragraphs: We analyzed the four selected action plans to determine the extent to  which generally accepted project management practices have been  integrated in their development and implementation process. Table 2  shows the results of our assessment of the extent to which each action  plan implemented the practices. For purposes of our analysis, fully means  all of the conditions of the project management practices were met,  partially means the criteria did not meet all of the conditions of the project  management practice, and did not implement means CRD did not provide  evidence to meet any of the conditions of the project management practice  or the evidence provided was inadequate.
Identifying Measurable Performance Goals. All the selected action  plans describe an output goal, such as revising the EO manual or attending  training, but do not identify measurable objectives or identify the intended  results of completing the action plans. In order to fully meet the criteria,  CRD needed to define an outcome goal for each of the selected action  plans that had measurable objectives against which actual achievements  can be compared. For example, conducting training to address office  climate is an output goal, but also establishing an outcome goal, such as  improving the results of CRD’s organizational assessment survey—a  measure of personnel attitudes across Coast Guard—would more fully  measure the success of the action plan in achieving its intent.
Defined Specific Tasks to Complete the Action Plan. Three of the  four action plans defined specific tasks to complete the action plan;  however, the action plan related to attending training to address CRD’s  office climate did not. CRD’s senior officials attended six 45-minute  training sessions over the course of two months. CRD officials stated that  since this action plan was undertaken, a training manager has been  appointed to plan longer-term training for CRD.
Identified the Person(s) Accountable for Completing the Action  Plan. All four selected action plans fully implemented the project planning  practice of identifying a person or persons accountable for completing the  action plan. CRD designated a project officer, or person accountable for  the completion of the action plan, at the beginning of the action plan  implementation process. Each project officer was responsible for updating  the lead project officer on the week’s progress, as part of the process CRD  had established.
Identified Interim Milestones and Checkpoints to Gauge the  Completion of the Action Plan. The contract to revise the EO manual  was the only action plan that fully implemented checkpoints and  milestones to gauge the completion of the manual. The remaining three  action plans, creating the PII handbook, restructuring civil rights  operations, and training to address office climate, used their weekly status  reporting system to judge process. Establishing milestones for the action  plans before or during the planning process would have allowed CRD not  only to judge weekly progress, but also to benchmark where weekly  progress stood against where they intended. Further, CRD did not keep a  record of the weekly status reports or checkpoints; instead, they replaced  the prior week’s status with the newest status, thus reducing their ability  to track the action plans’ long-term progress.
Identified the Needed Resources to Complete the Action Plan. The  action plan to create a PII handbook was the only plan that did not identify  the needed resources to complete the specific action plan. Although CRD  officials stated that all of the action plans were reviewed by Coast Guard  directorates responsible for Budget, Information Technology, and  Infrastructure to determine needed resources, CRD was unable to provide  documentation of any of the directorate reviews. Training to address  office climate partially implemented this practice. CRD provided  documentation of the financial cost of training; however, the  documentation did not discuss any other training resources, such as staff  time and equipment or training materials. The other two selected action  plans, restructuring civil rights operations and revising the EO manual,  fully implemented the practice of identifying all of the needed resources to  complete action plans. CRD used approved funding and staffing requests  to document the identification of resources needed for both of these  action plans.
Consulted Stakeholders. For two of the selected action plans, creating  the PII handbook and restructuring civil rights operations, CRD provided  documentation demonstrating that they consulted the stakeholders they  deemed relevant—civil rights service providers and unions respectively.  One of the action plans, related to training to address office climate, did  not have any documentation of stakeholder consultation. According to  CRD officials, the action plan to revise the EO manual will consult all  directorates once it is complete. We assessed this action plan as partially  implemented because the end users of the manual were not consulted  while the manual was being drafted.
Evaluated the Success of Completing the Action Plan. None of the  selected action plans that we reviewed identified how CRD would evaluate  the success of completing the action plan. CRD officials stated that they  were primarily focused on completing the action plans to address the  recommendations to improve the EO/EEO program, and if they had more  time, they would have planned to evaluate the action plans. This planning  practice—planning to evaluate success—is linked to the earlier planning  practice of identifying performance goals. Outcome measures as  performance goals, as opposed to output measures, would provide the  basis for evaluating the success of the action plans in achieving the  intended improvements in CRD. While it is too early to evaluate the  effectiveness of the action plans, strategizing about how they would be  evaluated is a key step in identifying any necessary midcourse corrections  and ensuring that change will go in the right direction.
section_title: Conclusions and Observations
paragraphs: Nearly half of the CRD action plans address issues focused on agency  leadership. Coast Guard has received recommendations for addressing  these issues in previous years but the issues continue to be identified by  external reviews as needing improvement. Although the current CRD  action plans are intended to address these longstanding issues, effective  implementation of the action plans is key to achieving measurable  outcomes and making progress to resolve long-standing issues.
CRD established an internal organization and process to address all the  recommendations for improvement. When developing and implementing  action plans, it is important to incorporate a systematic approach to  documenting decisions, outcomes, and actions. Without reliable  documentation, CRD cannot demonstrate the clear purpose, planning,  actions, and outcomes of its efforts. In addition, documentation provides  an opportunity for transparency and facilitates the transfer of knowledge  when employees leave the office to serve in other roles, which is  especially important in military organizations.
Generally accepted project planning practices include identifying  measurable objectives and the intended results of completing action plans.  Although all of the selected action plans identified output goals, the plans  consistently lacked evidence of planning in relation to outcomes. Without  measurable performance goals, CRD cannot know if an action plan  achieves its intended goals. Additionally, the application of generally  accepted project management practices facilitates the evaluation of  success and completion of the action plan. By not systematically  evaluating success, CRD risks using time and resources ineffectively. More  importantly, it also could be more difficult for CRD to know when it has  arrived at its overall intended goal—achieving a productive and effective  EEO/EO program that will work to ensure a workplace free from  discrimination.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of the Department of Homeland  Security direct the Commandant of the Coast Guard to take the following  three actions:    Going forward, ensure internal controls are in place to maintain the  documentation necessary to facilitate oversight and course corrections as  plans are designed and implemented.
Establish measurable performance goals for the action plans to support  the management decision as to the completion status of the action plans.
Define an evaluation plan for each action plan to assess the degree to  which the plan yielded the intended outcomes.
section_title: Agency Comments
paragraphs: We provided a draft of this testimony to the Secretary of the Department  of Homeland Security for review and comment. In written comments,  which are reprinted in appendix V, the Director of DHS’s Departmental  GAO/OIG Liaison Office concurred with our recommendations. Coast  Guard also provided technical comments, which we incorporated as  appropriate.
Mr. Chairman, this concludes my prepared statement. I would be pleased  to respond to any questions that you or other Members of the  Subcommittee might have.
section_title: Contact and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact Laurie E.  Ekstrand on (202) 512-6806 or by email esktrandl@gao.gov. Contact points  for our Offices of Congressional Relations and Public Affairs may be found  on the last page of this statement. Individuals making key contributions to  this testimony included William J. Doherty, Assistant Director, Amber G.  Edwards, analyst-in-charge, Karin Fangman, Robert Gebhart, Juliann  Gorse, David Maurer, Tamara F. Stenzel, and Gregory Wilmoth.
section_title: Appendix I: Third-Party Recommendations to the Coast Guard’s Civil Rights Directorate
paragraphs: Equal Opportunity Review—Design and implement metrics to measure process efficiency and for valuing benefits  of Equal Opportunity Review process. Develop and implement a mechanism to track and report these metrics  against performance targets.
Equal Opportunity Manual Revision—To provide specificity regarding the purpose, format, and structure of Equal  Opportunity reviews.
Training Requirements—Assess Office of Civil Right’s current training program and develop a training suite for  Civil Rights Service Providers, supervisors, and managers that is tailored to the specific audience.
Workload Analysis—Maximize workflow efficiencies and workforce planning by basing staffing decisions and  training requirements on valid and reliable data. This would include developing a Work Breakdown Structure  (WBS) that delineates the discrete work elements of Office of Civil Rights operations.
Conduct a training needs assessment of the U.S. Coast Guard civil rights organization to assess current training  programs and knowledge gaps. This assessment should also consider regulatory requirements, business drivers,  and the skills and abilities of Civil Rights Service Providers.
Use facilitated workshops to help Office of Civil Rights senior staff members to understand their own and other  stakeholders’ underlying interests and concerns and thereafter to focus on those interests rather than on stated  positions and demands.
Through coaching sessions, guide the Director, Deputy Director, and senior staff to pursue more collaborative  methods of working with each other. This could be accomplished through the strategic planning process and  other Office of Civil Rights initiatives such as the Management Directive-715 Report.
Conduct a skills inventory of current staff to measure skills versus organizational need, and to identify skill sets  required for the job.
Conduct a skills assessment to identify core competencies by assessing existing job descriptions and key skills  required to support each programmatic function. Refine job vacancy announcements to ensure that candidates  have the required skills.
Skills Assessment—Determine whether an adequately skilled civil rights workforce is available, trained, and  prepared to achieve the Office of Civil Rights and U.S. Coast Guard’s civil rights objectives.
Develop a Training Course for Equal Opportunity Review team members on various data collection methods and  the process of applying statistical techniques to analyze, describe, and evaluate trend data.
Ensure that all Civil Rights Service Providers receive training on intake and complaint processing at both the  Informal and Formal stages. This would include training designed to ensure that Civil Rights Service Providers  understand their role of neutrality throughout the counseling process.
Training—Provide Strategic Plans and Resources Management Team Lead with additional training in budget  development and justifications.
Ensure Office of Civil Rights Budget Personnel undergo training in statutory and regulatory obligations of the  office.
Assess and take appropriate action regarding Equal Opportunity Review Team participants training needs.
Restructure U.S. Coast Guard Civil Rights Operations—This restructuring can be accomplished by placing the  Field Civil Rights Service Providers under the direct oversight of the Director of Office of Civil Rights with Area  Equal Opportunity Managers reporting to the Director instead of directly to Field Commanders.
Convert the Instructional Systems Specialist position currently residing in the Policy and Plans Division to an  Operations Manager position reporting to the Deputy. This position would, among other duties, be responsible for  operations management and training requirements oversight.
Transition training oversight responsibilities from the Policy and Plans Division to a newly created Operations  Manager (reporting to the Deputy) who will manage all aspects of OCR training processes.
Create a Senior Advisor Position—This position will provide programmatic guidance to the Director.
Designate Privacy and Records Manager—Assign to CG-00H one GS-14 billet.
Leverage 0-6 Deputy Responsibility—Responsible for operational and nonstatutory activities including budgeting,  resource management, strategic planning, and oversight. Align the Strategic Plans and Resource Management  Team and the Policy and Plans Division under the Deputy.
Establish a solid-line reporting relationship of field Civil Right Service Providers—have all Civil Rights Service  Providers report to the Director.
Develop an integrated strategic plan to better enable the organization to execute and deliver on its mission. This  strategic plan should incorporate input from key stakeholders, be well communicated to employees, and  cascaded across Office of Civil Rights and throughout the Field to ensure consistency of focus across all areas of  the U.S. Coast Guard civil rights organization.
Move CG-00H-3 Program Analyst billet to CG-00H-2—to assist with Equal Opportunity Reviews.
Move Administrative Specialist from CG-00H-2 to CG-00H-4—to assist with administrative functions.
Standard Operating Procedures—Develop Standard Operating Procedures for CG-00H-3 to handle all aspects of  budget requests for Office of Civil Rights.
Revise the Equal Opportunity Manual to include statutory references and citations so that a reader can cross- reference relevant statutory language with the guidance provided. In addition, add content that addresses the  roles of Field and Office of Civil Rights personnel throughout the complaint process.
Institute a privacy and records management program—based on Department of Homeland Security policies and  procedures.
Redesign the Equal Opportunity Review process to increase the value and effectiveness of this function.
Strategic Planning—Ensure that each division develops a strategic plan that feeds into the Director’s overall  strategic plan.
Develop Standard Operating Procedures for handling Personally Identifiable Information and Confidential  information.
Develop a records management system that describes, for each type of record, where it should be retained, the  various classifications of records, the applicable policies, and how the complaint records should be maintained.
Equal Opportunity Manual Revision—Enter detailed Instruction for handling Personally Identifiable Information.  Also, revise the Equal Opportunity Manual such that it provides a step-by-step process to determine whether the  release of documents is appropriate.
Institute a mandatory annual training requirement for supervisors and managers through which participants are  taught their responsibilities with respect to Equal Employment Opportunity and affirmative employment. Provide  refresher training in a computer-based format that can be used in any location.
Develop a business case for Equal Opportunity Reviews. This analysis should consider the specific reasons for  an established number of Equal Opportunity Reviews, the rationale for particular site selections, quantifiable  measures of success, available dedicated resources, and any other strategic or regulatory drivers that would  necessitate Equal Opportunity Reviews.
Equal Opportunity Reviews—redesign position requirements for individuals participating in the Equal Opportunity  Review process to reflect the specific skills and abilities required to conduct substantive analysis and high-level  technical writing.
Revise the U.S. Coast Guard service-specific portion of the Defense Equal Opportunity Management Institute  Equal Opportunity Advisors Program to include training by civilian Equal Employment Opportunity Commission  certified trainers who would provide instruction in the areas of Equal Employment Opportunity Counseling and  complaint processing. This training curriculum would include, among other topics, instruction in basic Equal  Employment Opportunity Counseling and other related activities, such as writing reports of counseling, identifying  issues, conducting inquiries, and pursuing resolution options.
Training Program—Professionalized Equal Employment Opportunity Counseling training program to include  mandatory training required by Equal Employment Opportunity Commission, including the eight-hour Refresher  and the 32-hour training requirement for new federal Equal Employment Opportunity Counselors. In addition,  require counselors to fulfill a bi-annual training requirement by taking an Interviewing Techniques, Conflict  Resolution, or Facilitation course.
Equal Opportunity Manual—Revise the Equal Opportunity Manual such that it effectively serves as the guiding  document for enterprise-wide civil rights operations.
Standard Operating Procedures—Develop Comprehensive Standard Operating Procedures to standardize Office  of Civil Rights operations. This would include Standard Operating Procedures for each team/division within the  Office of Civil Rights and the compilation of an accessible master volume.
Perform gap analysis to determine where the current staff meet core competencies and identify where  competency gaps exist by comparing the core competencies required to support the Office of Civil Rights roles  with the results of the skills inventory of the current staff.
Determine whether current program functions are statutorily required or necessary to support the Office of Civil  Rights mission and to determine resource needs.
Hire or contract for final agency decision (FAD) analysts.
Create a Separate spend plan for Training Needs Assessment.
Identify “strategic initiatives”—that would be drivers of the Office of Civil Rights strategy as well as that of U.S.  Coast Guard. These initiatives should then be prioritized for funding and implementation in any given fiscal year  based on their expected impact.
Use Office of Civil Rights Strategic Plan to advocate for resource requirements by demonstrating how  performance goals align with budget requests.
Recruit and hire full-time experienced Equal Employment Opportunity Counselors and Civil Rights Service  Providers and discontinue the use of collateral duty staff.
Assess CG-00H-4 funding needs.
Use the Official U.S. Coast Guard Blog to refute misinformation and protect the credibility of the U.S. Coast Guard  workforce.
Establish an Official U.S. Coast Guard Blog to convey key message and to minimize confusion and  misinformation   Disable access to negative unofficial blog sites at U.S. Coast Guard work locations.
Strengthen leadership effectiveness in group dynamics and find tools to address effectiveness.
Ensure that individuals are held accountable for acts of insubordination.
section_title: Appendix II: Summary of the Equal Employment Opportunity Commission Model Elements
paragraphs: Commitment to equal opportunity should be embraced by agency leadership and  communicated through the ranks from the top down. Among other things, an agency shall  provide sufficient staffing and resources to operate the Equal Employment Opportunity (EEO)  program in an effective manner. For example, staff and resources should also be sufficient to  enable accurate collection and analysis of data and other employment factors, including  applicant information, to enable the efficient identification of barriers. This will necessarily  require staff beyond the EEO office, particularly information management/services.
This model element provides that the agency’s EEO program should be organized and  structured in such a manner as to maintain a work place that is free from discrimination in any  of its management policies, practices or procedures and supports the agency’s strategic  mission. Agency leadership should fully utilize EEO staff as a consultant prior to making  decisions which effect workplace opportunities. The EEO Director should be a regular  participant in senior staff meetings and regularly consulted on workplace issues and not  solely delegated to responding to discrimination complaints.
This model element provides that agencies should hire, develop, and retain supervisors and  managers who have effective managerial, communication, and interpersonal skills in order to  supervise most effectively in a workplace with diverse employees and avoid disputes arising  from ineffective communications. Also, the agency should meaningfully evaluate managers  and supervisors on efforts to ensure equality of opportunity for all employees.
This model element provides that as part of its ongoing obligation to prevent discrimination on  the bases of race, color, national origin, religion, sex, age, reprisal and disability, and to  eliminate barriers that impede free and open competition in the workplace, an agency must  conduct a self-assessment on at least an annual basis to monitor progress, identify areas  where barriers may operate to exclude certain groups, and develop strategic plans to  eliminate identified barriers.
This model element provides that an agency must evaluate its EEO complaint resolution  process to ensure it is efficient, fair, and impartial. It also provides that an agency’s complaint  process must provide for neutral adjudication; consequently, the agency’s EEO office must  be kept separate from the legal defense arm of the agency (i.e., the Office of General  Counsel) or other agency offices having conflicting or competing interests.
Responsiveness and legal compliance  This model element provides that the head of the agency or agency head designee shall  certify to the Equal Employment Opportunity Commission (EEOC) that the agency is in full  compliance with the EEO laws and EEOC regulations, policy guidance, and other written  instructions. It also provides that all agencies shall report their EEO program efforts and  accomplishments to the EEOC and respond to EEOC directives and orders, including final  orders contained in administrative decisions, in accordance with instructions, time frames,  and deadlines.
section_title: Appendix III: Excerpt from Coast Guard Civil Rights Directorate Functional Review Recommendation Sheet
paragraphs: Restructure U.S.  Coast Guard Civil  Rights Program – This  restructuring can be  accomplished by  placing the Field Civil  Rights Service  Providers under the  direct oversight of the  Director of Office of  Civil Rights with Area  Equal Opportunity  Managers reporting to  the Director instead of  directly to Field  Commanders.
section_title: Appendix IV: Summary of Generally Accepted Project Management Practices
paragraphs: This practice defines the project’s goals, describing how they will be achieved and defines  measures of performance. The Government Performance Results Act of 1993 (GPRA)  defines performance goals and measures with the intention of improving the effectiveness,  accountability, and service delivery of federal programs This framework informs federal  practice and describes measures as either output or outcome measures. Outcomes describe  the intended result of carrying out the activity while outputs describe the level of activity that  will be provided over time including the characteristics established as standards for the  activity, such as timeliness.
This practice identifies and documents the specific activities that must be performed in order  to complete the project. This aids project completion by facilitating such activities as  identifying the resource requirements, developing an appropriate time table for completion,  and necessary stakeholder involvement in the project.
This practice identifies and documents who is assigned and responsible for the completion of  project tasks. This aids project completion by facilitating internal controls and reporting  processes.
This practice identifies and documents interim milestones and checkpoints to gauge the  completion of the project. A milestone is a significant event in the project that marks the  completion of a deliverable or phase. A checkpoint is a point at which the status check is  performed. This aids project completion by identifying not only the distance the team has  traveled toward completing the project, but the direction traveled.
This practice identifies and documents the determination of what resources (people,  equipment, materials, and money) are needed to complete an action plan. This aids project  completion by assuring that resource availability can be assured or alternate plans  established to reach the goal of the action plan.
This practice identifies stakeholders—individuals and organizations that are involved in or  may be affected by project activities—and ensures that they are included in developing and  executing the project plan allowing them contribute appropriately. This aids project  completion by ensuring that employees understand and are committed to the goals.
This practice establishes and documents quantifiable criteria that must be met for the project  to be considered successful. Prior GAO work on designing evaluations discusses the  importance of evaluating actions because it is a safeguard against using time and resources  ineffectively. Evaluating the success of completing the action plan also increases the  likelihood that a person, a team, or an agency will know when an action is complete and one  has arrived at the intended goal, which should be attaining the results the action plans were  intended to accomplish.  nce nd Result Act of 199 (GPRA), Pub. L. No. 10-62, 107 St. 285   (Ag. , 199).  igning Evuation, GAO/PEMD-10.1.4, (Washington, D.C.: My 1991).
section_title: Appendix V: Comments from the Department of Homeland Security
paragraphs: This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.