The U.S. Department of Education’s OCR is a law enforcement agency. Its primary responsibility is to ensure that recipients of federal financial assistance do not discriminate—on the basis of race, color, national origin, sex, disability, or age—against students, faculty, or other individuals in educational programs and activities. OCR is responsible for enforcing the following federal civil rights laws as they relate to schools at all levels: title VI of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, or national origin; title IX of the Education Amendments of 1972, which prohibits discrimination on the basis of sex in education programs and activities; section 504 of the Rehabilitation Act of 1973, which prohibits discrimination on the basis of disability; the Age Discrimination Act of 1975, which prohibits discrimination on the basis of age; and title II of the Americans With Disabilities Act of 1990, which prohibits public entities from discriminating on the basis of disability. The civil rights laws OCR enforces extend to a wide range of recipients of federal funds. These recipients include all state education and rehabilitation agencies as well as nearly every school district and postsecondary school; thousands of proprietary schools, libraries, museums, and correctional facilities; and other institutions that receive federal financial assistance from Education. To ensure equal opportunity in the nation’s schools, OCR carries out its civil rights responsibilities through a variety of compliance activities. OCR’s principal activity is the resolution of discrimination complaints. Most of OCR’s staff resources are devoted to such activities as processing, conciliating, and investigating complaints. In an effort to ensure that recipients of federal financial assistance meet their civil rights compliance responsibilities, OCR also conducts compliance reviews, monitors corrective action plans, and provides technical assistance. Compliance reviews differ from complaint investigations in that they are initiated by OCR; they usually cover broader issues; and they affect significantly larger numbers of individuals. OCR selects review sites on the basis of information from various sources that indicates potential compliance problems, including survey data and information provided by complainants, interest groups, the media, and the general public. In fiscal year 1995, OCR’s staff ceiling was 833 full-time-equivalent positions and its total funding level was $58.2 million. During fiscal year 1994, about 5,300 complaints were filed with OCR. Of these, 27 percent were filed against postsecondary schools. Until fiscal year 1994, the number of compliance reviews that OCR was able to conduct was inversely related to the number of complaints received and the workload engendered. Because OCR’s complaint workload increased from fiscal years 1988 to 1993, the number of compliance reviews OCR initiated declined from 247 in fiscal year 1988 to 138, 32, 41, 77, and 101 in succeeding years. During fiscal year 1994, OCR started 153 compliance reviews, with about 25 percent directed at postsecondary schools. Of the 153, 62 percent involved race or national origin issues; 17 percent involved gender issues; 8 percent involved disability and other issues; 7 percent involved other issues; and 6 percent involved solely disability issues. In fiscal year 1995, OCR started about 100 compliance reviews. Our review of the 13 identified cases was hampered by the absence of complete documentation in OCR’s official case files. OCR has policies in place delineating the documents that should be included in the official case files in the regional offices. OCR had no similar policies with regard to the official case files in headquarters. Actions that took place in headquarters were not always documented and included in regional case files. According to OCR officials, records pertaining to headquarters activity for these 13 cases were maintained in a chronological filing system—rather than a case file system—that suited the needs of headquarters staff. The lack of documentation hindered our ability to determine the reasons for delays in completing complaint investigations and compliance reviews. Generally, while the 13 cases were in the OCR regional offices, the official case files were relatively complete, with documents periodically updated to describe investigation and review activities and the results of these efforts. When an investigation or review reached the point at which OCR headquarters became actively involved, however, the official regional files were seldom updated with pertinent notations or documents. Furthermore, official case files were not developed or maintained in OCR headquarters. As a result, we could not trace the full chronology of events for these cases by examining case files. In addition, even when the official case files were updated with documents, we could not always determine what decisions were made or why extended delays occurred because the documents often did not include such information. Because of such gaps in knowledge, the full chronology of many of the cases could not be developed. (See app. II for a brief description of each of the 13 cases; see table II.1 for a summary of the 13 cases.) Eleven of the 13 cases involved Asian-American men and women; one was a complaint by a white woman; and another was a complaint by a white man. In addition, several of the cases, although focusing primarily on Asian-Americans or Asian-Indians, also dealt with other minority groups. In analyzing how these 13 cases were investigated and resolved, we found that OCR generally followed its established policies and procedures. But OCR did not always meet timeliness standards, which is discussed in detail in appendix II. As of September 1995, two complaint investigations remained open. Of the 13 cases, only 4 were closed within OCR’s time frames. The cases that took the most time to complete were admissions compliance reviews, which generally involve complex issues and take more resources to complete, or complaints that dealt with complicated or controversial issues, such as admissions or race-targeted financial aid. Two admissions cases demonstrate the demands that individual cases can make on resources because of the volume of data that must be gathered and analyzed: (1) the compliance review of the University of California at Los Angeles (UCLA) undergraduate schools concerning discrimination against Asian-Americans and the affirmative action program, and (2) the complaint investigation of the University of California at Berkeley undergraduate programs concerning discrimination against white students. Both cases involved premier schools of the University of California system. The two schools enroll, between them, 67,000 students annually. Both investigations entailed several site visits, comprehensive statistical analyses of data for tens of thousands of applicants, and extensive interviewing and reviews of applicant files. Both schools completely changed their admissions processes during the course of the investigations, necessitating additional extensive investigation. The same regional office that conducted both investigations also completed, during the same time, a compliance review involving admission to the UCLA graduate schools. To complete that review, the regional office investigated, in detail, 40 individual admissions programs; reviewed 2,000 applicant files; and interviewed more than 200 witnesses. The demands of class admissions cases, such as these, impose unique challenges. During fiscal years 1988 to 1994, OCR’s overall workload, as well as that for complaints under title VI of the Civil Rights Act of 1964, increased. During this period, OCR resolved complaints and completed compliance reviews in less than 180 days on average. OCR does not have a standard definition of an “overage” case, but it uses 180 days as a benchmark for assessing timeliness. However, the average time to resolve complaints and complete compliance reviews concerning Asian-Americans in postsecondary schools generally was longer than the averages for cases concerning other minority groups. For complaint investigations, Asian-American cases took longer to complete, on average, than those for any other minority group. For compliance reviews, only cases involving class actions (cases affecting groups of students) and multiple title VI issues (one complaint alleging multiple issues, namely race and national origin) took more time, on average, to complete than Asian-American cases. Data indicated that this occurred partly because (1) Asian-Americans were involved with admissions cases more often than other minority groups and (2) admissions cases generally require more resources and time to complete than other types of cases. In addition, according to the data, OCR’s investigations and reviews involving Asian-Americans resulted in relatively more violation findings leading to remedial action or changes by postsecondary schools. In providing the information and statistics concerning these complaint investigations and compliance reviews, OCR cautioned that the data do not represent the various factors that may affect case resolution. These factors include the volume of data that must be collected and data analyses that must be conducted; the scope, complexity, and number of issues in a case; and the availability of information needed to resolve the issues. The statistical profile also does not reflect the extent to which any average may be unduly influenced by a single case of unusual duration. For fiscal years 1988-94, OCR completed 1,511 complaint investigations in an average of 128 days each (see table III.1). The 114 cases involving Asian-Americans took an average of 175 days to complete. In contrast, the 931 cases involving African-Americans averaged 125 days to complete, and the 165 cases involving Hispanics averaged 137 days to complete. The 106 cases for minority whites (those from Eastern Europe, Southern Europe, and the Middle East) averaged 98 days to complete. During fiscal years 1988-94, 248 of the 1,511 complaint investigations were admissions cases; that is, the complaints involved allegations that people applying for admission to postsecondary schools were turned down for discriminatory reasons. The 248 admissions cases, on average, took longer to complete—specifically, 174 days—OCR officials said and the statistics documented. The 40 admissions cases involving Asian-Americans took 297 days, on average, to complete. The 115 admissions cases involving African-Americans took 129 days, on average, to complete. The 31 admissions cases involving Hispanics took 276 days, on average, to complete. During this period, OCR took an average of 119 days to resolve 1,263 non-admissions complaints.