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. 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. 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. 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.