Coast Guard

In Process

CRD has improved its civil rights services in certain respects, but additional potential enhancements remain: (1) CRD continues to centralize its workforce, but lacks a disciplined and documented strategic approach for making staffing allocation decisions. In November 2009, BAH performed a workforce analysis of CRSPs' tasks, and determined that CRD needed 37 CRSPs in addition to the 41 staff already in place at that time. BAH also recommended that CRD devise a strategic growth plan to determine geographic staff allocations and to ensure that high-priority positions are considered. CRD officials said they were in agreement with BAH's assessment, and were working to increase the CRSP workforce. Nonetheless, CRD has not developed a disciplined and documented strategic approach that would promote transparency in decision making, and include criteria about geographic placements of CRSPs; nor has it identified the relative importance of priorities, including criteria for placing additional staff among its regions and zones. For example, in reviewing CRD's staffing allocation data plan for staffing 12 of the 37 positions that BAH recommended, the rationale was not clear for placing CRSPs in certain geographic locations rather than in others. CRD officials told us they rely on several factors included in BAH's Workload Analysis in making geographic staffing allocation decisions, such as distance CRSPs travel to provide training or counseling; the number of civilian personnel in the zone; and the ratio of CRSPs to USCG personnel in a zone. CRD officials said they also rely on their management knowledge and judgment, noting that these are intangibles that a workforce analysis cannot fully capture. To a lesser extent, they stated they relied on complaint data to identify zones with higher levels of complaints, because overall, complaint levels have been relatively low across their regions for military and civilian personnel. These can be appropriate considerations when making staffing decisions. However, without a disciplined and documented strategic approach, transparency is not promoted and knowledge is not institutionalized. Further, without such an approach, CRD can not be assured that staffing allocation decisions are targeting the most pressing needs, and that civil rights issues of USCG are being addressed. (2) CRD has taken steps to ensure that CRSPs are qualified to provide civil rights services, but has not been able to ensure that they meet basic training requirements, due to data and system reliability shortfalls. Regarding required training, to ensure quality counseling throughout the federal sector, EEOC MD-110 mandates an initial 32 hours of training and 8 hours of continuing training annually for all EEO service providers, which include CRSPs.