The Equal Employment Opportunity Commission needs to more systematically evaluate recommendations given to it by an outside consultant to meet restructuring requirements set by the Office of Management and Budget, the Government Accountability Office said in a report released Oct. 28.

At issue are OMB restructuring actions required of the EEOC and other federal agencies and whether EEOC has made progress implementing them. The GAO report centers on restructuring recommendations given to EEOC by the National Academy of Public Administration. EEOC had contracted NAPA to produce a study of EEOC operations, which it planned to use as the basis for its OMB-mandated restructuring. GAO found that NAPA had created an extensive list of recommendations for the EEOC, but that the agency "has no organized approach" to consider them.

"Without such an approach, EEOC lacks assurance that each recommendation has been fully considered. As a result, EEOC may miss an opportunity to fully benefit from NAPA's work, become more efficient and effective, and further improve its ability to enforce the nation's civil rights laws," the GAO concluded in its report.

EEOC and other federal agencies were to develop and submit workforce analyses to OMB by 2001 and restructuring plans by 2003. Those analyses and plans were part of a larger OMB initiative to restructure the federal government to make it more responsive. EEOC neither developed nor submitted a restructuring plan as ordered by the OMB directive, the GAO said, "but took actions OMB officials have found to be acceptable," such as commissioning the NAPA study.

Study Identified 64 Measures to Implement

EEOC commissioned that study in June 2002, and NAPA issued its report in February 2003, OMB said. NAPA spotlighted three major initiatives EEOC needed to perform and identified 64 specific measures it said EEOC should implement.

GAO found that "EEOC did not have an organized strategy to consider all of NAPA's 64 recommendations for agency restructuring. For example, EEOC did not establish a group to oversee the implementation of the NAPA recommendations, as NAPA suggested. Instead, EEOC considers addressing the three major initiatives as the completion of its restructuring efforts."

GAO also reported that the EEOC disagreed with its conclusions and that it had problems getting the documents it needed from the EEOC to see whether it was implementing or considering NAPA's recommendations.

"In general, EEOC disagreed with our findings, conclusion, and recommendation regarding the agency's lack of an organized approach to consider all of NAPA's recommendations. EEOC's assertion that it has developed an organized and comprehensive framework for considering and implementing NAPA's recommendations does not correspond with the results of our review," GAO said. "More specifically, over the course of our review, we sought documentation supporting the agency's strategy for reviewing and implementing the NAPA recommendations; however, EEOC officials told us on several occasions that such documentation did not exist."

Only after GAO completed its review and discussed its preliminary findings did EEOC provide a document discussing its implementation of the NAPA recommendations. Further, EEOC did not provide any documents listing the progress of those recommendations until faced with a draft of the report, the GAO said.

"Neither of these documents contained, nor could we obtain from the agency, evidence of the strategy EEOC said it developed to evaluate the NAPA recommendations, or evidence of the kind of strategic approach that we continue to recommend," GAO said.

In its recommendations to the EEOC chair, GAO said the agency should:

Examine each recommendation from the perspective of its potential to aid in achieving the strategic goals and objectives of the agency.

Evaluate the costs associated with their implementation.

Develop a means of measuring the impact of any recommendations that are implemented.

In conducting its research, GAO interviewed EEOC officials in Washington, D.C., and in district offices in Chicago, San Antonio, Atlanta, Detroit, Philadelphia, Phoenix, and San Francisco. Researchers also interviewed representatives from a NAPA advisory panel and the American Federation of Government Employees, EEOC Local 216. The research was conducted between October 2004 and September 2005; staff of the House Subcommittee on Science, the departments of State, Justice, and Commerce, and related agencies were briefed on the final report on Sept. 19.

Text of the full GAO report is available at http://www.gao.gov/new.items/d0610.pdf