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 Gao ID: GAO-10-571T April 27, 2010Allegations 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.
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.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Laurie E. Ekstrand Team: Government Accountability Office: Strategic Issues Phone: (202) 512-2758GAO-10-571T, 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
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Testimony:
Before the Subcommittee on Coast Guard and Maritime Transportation,
Committee on Transportation and Infrastructure, House of
Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Tuesday, April 27, 2010:
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:
Statement of Laurie Ekstrand, Director:
Strategic Issues:
GAO-10-571T:
GAO Highlights:
Highlights of GAO-10-571T, a testimony before the Subcommittee on
Coast Guard and Maritime Transportation, Committee on Transportation
and Infrastructure, House of Representatives.
Why GAO Did This Study:
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.
What GAO Found:
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.
What GAO Recommends:
GAO recommends that the Department of Homeland Security direct the
Commandant of the Coast Guard to take the following actions: (1) going
forward, ensure internal controls are in place to maintain the
documentation necessary to facilitate oversight, (2) establish
measurable performance goals for the action plans, and (3) define an
evaluation plan for each action plan. DHS concurred with all GAO
recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-10-571T] or key
components. For more information, contact Laurie Ekstrand at (202) 512-
6806 or ekstrandl@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
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.[Footnote 1] 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.[Footnote 2] 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[Footnote 3] and the
Government Performance and Results Act (GPRA) of 1993,[Footnote 4] 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.[Footnote 5] 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[Footnote 6] 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.[Footnote 7] 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.
Background:
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.[Footnote 8]
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.
Figure 1: Organizational Chart of the Civil Rights Directorate:
[Refer to PDF for image: Organizational Chart]
Top level:
Director, Civil Rights Directorate:
* Executive Assistant.
Second level, reporting to Director, Civil Rights Directorate:
* Chief, Office of Policy, Planning, and Resources;
* Chief, Office of Civil Rights Operations:
- Solutions and Complaints Staff.
Third level, reporting to Chief, Office of Policy, Planning, and
Resources:
* Policy and Procedures Division;
* Planning and Resource Management Division.
Third level, reporting to Chief, Office of Civil Rights Operations:
* Civil Rights, Region 1, Washington, D.C.
* Civil Rights, Region 2, Portsmouth, Va.
* Civil Rights, Region 3, Alameda, Calif.
Source: GAO presentation of Coast Guard information as of September
30, 2009.
[End of figure]
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.[Footnote 9]
Agency Leadership Is the Primary EEOC Model Program Element Addressed
by Coast Guard Action Plans:
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.[Footnote 10]
Table 1: Distribution of CRD Action Plans across EEOC's Model Elements:
EEOC's model elements: Demonstrated Commitment from Agency Leadership;
Number of action plans aligned with model element[A]: 13.
EEOC's model elements: Integration of EEO into Agency's Strategic
Mission;
Number of action plans aligned with model element[A]: 5.
EEOC's model elements: Management and Program Accountability;
Number of action plans aligned with model element[A]: 2.
EEOC's model elements: Proactive Prevention of Unlawful Discrimination;
Number of action plans aligned with model element[A]: 0.
EEOC's model elements: Efficiency;
Number of action plans aligned with model element[A]: 4.
EEOC's model elements: Responsiveness and Legal Compliance;
Number of action plans aligned with model element[A]: 1.
Source: GAO analysis based on EEOC's model elements and action plan
alignment.
[A] Four of the 29 action plans did not align with any of EEOC's model
elements.
[End of table]
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.[Footnote 11] 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
Providers;
* 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.
Although CRD Established Processes to Develop and Review Selected
Action Plans, Documentation of Key Decisions and Outcomes Needs
Improvement:
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,[Footnote 12] 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.
CRD Did Not Consistently Document Key Decisions Related to the
Development and Review of the Action Plans:
When developing and reviewing the action plans, CRD did not maintain
documentation as recommended in federal internal control standards.
[Footnote 13] 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.[Footnote 14] 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.
Selected Action Plans Implemented Some Project Planning Practices, but
Did Not Fully Implement Other Practices:
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.[Footnote 15] 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 the action plan;
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.
[Footnote 16]
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.
Action Plans Only Partially Identified Measurable Performance Goals
and Did Not Define How to Evaluate the Success of Completing a Plan:
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.
Table 2: GAO Assessment of CRD's Action Plan Alignment with Generally
Accepted Project Management Practices:
Action taken to address recommendation: Create PII Handbook;
Identified measurable performance goals: Partially;
Defined specific tasks to complete the action plan: Fully;
Identified the person(s) accountable for executing the tasks to
complete the action plan: Fully;
Identified interim milestones/checkpoints to gauge the completion of
the action plan: Partially;
Identified the needed resources to complete the action plan: Did not
implement;
Consulted stakeholders: Fully;
Defined how to evaluate the success of completing the action plan: Did
not implement.
Action taken to address recommendation: Training to Address Office
Climate;
Identified measurable performance goals: Partially;
Defined specific tasks to complete the action plan: Did not implement;
Identified the person(s) accountable for executing the tasks to
complete the action plan: Fully;
Identified interim milestones/checkpoints to gauge the completion of
the action plan: Partially;
Identified the needed resources to complete the action plan: Partially;
Consulted stakeholders: Did not implement;
Defined how to evaluate the success of completing the action plan: Did
not implement.
Action taken to address recommendation: Restructuring Civil Rights
Operations;
Identified measurable performance goals: Partially;
Defined specific tasks to complete the action plan: Fully;
Identified the person(s) accountable for executing the tasks to
complete the action plan: Fully;
Identified interim milestones/checkpoints to gauge the completion of
the action plan: Partially;
Identified the needed resources to complete the action plan: Fully;
Consulted stakeholders: Fully;
Defined how to evaluate the success of completing the action plan: Did
not implement.
Action taken to address recommendation: Revising the EO Manual;
Identified measurable performance goals: Partially;
Defined specific tasks to complete the action plan: Fully;
Identified the person(s) accountable for executing the tasks to
complete the action plan: Fully;
Identified interim milestones/checkpoints to gauge the completion of
the action plan: Fully;
Identified the needed resources to complete the action plan: Fully;
Consulted stakeholders: Partially;
Defined how to evaluate the success of completing the action plan: Did
not implement.
Source: GAO analysis of CRD action plans.
[End of table]
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.[Footnote 17] 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.
Conclusions and Observations:
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.
Recommendations for Executive Action:
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.
Agency Comments:
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.
Contact and Staff Acknowledgments:
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.
[End of section]
Appendix I: Third-Party Recommendations to the Coast Guard's Civil
Rights Directorate:
Recommendation number: 1;
Recommendation: 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.
Recommendation number: 2;
Recommendation: Equal Opportunity Manual Revision--To provide
specificity regarding the purpose, format, and structure of Equal
Opportunity reviews.
Recommendation number: 3;
Recommendation: 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.
Recommendation number: 4;
Recommendation: 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.
Recommendation number: 5;
Recommendation: 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.
Recommendation number: 6;
Recommendation: 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.
Recommendation number: 7;
Recommendation: 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.
Recommendation number: 8;
Recommendation: Conduct a skills inventory of current staff to measure
skills versus organizational need, and to identify skill sets required
for the job.
Recommendation number: 9;
Recommendation: 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.
Recommendation number: 10;
Recommendation: 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.
Recommendation number: 11;
Recommendation: 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.
Recommendation number: 12;
Recommendation: 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.
Recommendation number: 13;
Recommendation: Training--Provide Strategic Plans and Resources
Management Team Lead with additional training in budget development
and justifications.
Recommendation number: 14;
Recommendation: Ensure Office of Civil Rights Budget Personnel undergo
training in statutory and regulatory obligations of the office.
Recommendation number: 15;
Recommendation: Assess and take appropriate action regarding Equal
Opportunity Review Team participants training needs.
Recommendation number: 16;
Recommendation: 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.
Recommendation number: 17;
Recommendation: 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.
Recommendation number: 18;
Recommendation: 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.
Recommendation number: 19;
Recommendation: Create a Senior Advisor Position--This position will
provide programmatic guidance to the Director.
Recommendation number: 20;
Recommendation: Designate Privacy and Records Manager--Assign to CG-
00H one GS-14 billet.
Recommendation number: 21;
Recommendation: 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.
Recommendation number: 22;
Recommendation: Establish a solid-line reporting relationship of field
Civil Right Service Providers--have all Civil Rights Service Providers
report to the Director.
Recommendation number: 23;
Recommendation: 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.
Recommendation number: 24;
Recommendation: Move CG-00H-3 Program Analyst billet to CG-00H-2--to
assist with Equal Opportunity Reviews.
Recommendation number: 25;
Recommendation: Move Administrative Specialist from CG-00H-2 to CG-00H-
4--to assist with administrative functions.
Recommendation number: 26;
Recommendation: Standard Operating Procedures--Develop Standard
Operating Procedures for CG-00H-3 to handle all aspects of budget
requests for Office of Civil Rights.
Recommendation number: 27;
Recommendation: 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.
Recommendation number: 28;
Recommendation: Institute a privacy and records management program--
based on Department of Homeland Security policies and procedures.
Recommendation number: 29;
Recommendation: Redesign the Equal Opportunity Review process to
increase the value and effectiveness of this function.
Recommendation number: 30;
Recommendation: Strategic Planning--Ensure that each division develops
a strategic plan that feeds into the Director's overall strategic plan.
Recommendation number: 31;
Recommendation: Develop Standard Operating Procedures for handling
Personally Identifiable Information and Confidential information.
Recommendation number: 32;
Recommendation: 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.
Recommendation number: 33;
Recommendation: 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.
Recommendation number: 34;
Recommendation: 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.
Recommendation number: 35;
Recommendation: 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.
Recommendation number: 36;
Recommendation: 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.
Recommendation number: 37;
Recommendation: 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.
Recommendation number: 38;
Recommendation: 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.
Recommendation number: 39;
Recommendation: Equal Opportunity Manual--Revise the Equal Opportunity
Manual such that it effectively serves as the guiding document for
enterprise-wide civil rights operations.
Recommendation number: 40;
Recommendation: 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.
Recommendation number: 41;
Recommendation: 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.
Recommendation number: 42;
Recommendation: Determine whether current program functions are
statutorily required or necessary to support the Office of Civil
Rights mission and to determine resource needs.
Recommendation number: 43;
Recommendation: Hire or contract for final agency decision (FAD)
analysts.
Recommendation number: 44;
Recommendation: Create a Separate spend plan for Training Needs
Assessment.
Recommendation number: 45;
Recommendation: 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.
Recommendation number: 46;
Recommendation: Use Office of Civil Rights Strategic Plan to advocate
for resource requirements by demonstrating how performance goals align
with budget requests.
Recommendation number: 47;
Recommendation: Recruit and hire full-time experienced Equal
Employment Opportunity Counselors and Civil Rights Service Providers
and discontinue the use of collateral duty staff.
Recommendation number: 48;
Recommendation: Assess CG-00H-4 funding needs.
Recommendation number: 49;
Recommendation: Use the Official U.S. Coast Guard Blog to refute
misinformation and protect the credibility of the U.S. Coast Guard
workforce.
Recommendation number: 50;
Recommendation: Establish an Official U.S. Coast Guard Blog to convey
key message and to minimize confusion and misinformation.
Recommendation number: 51;
Recommendation: Disable access to negative unofficial blog sites at
U.S. Coast Guard work locations.
Recommendation number: 52;
Recommendation: Strengthen leadership effectiveness in group dynamics
and find tools to address effectiveness.
Recommendation number: 53;
Recommendation: Ensure that individuals are held accountable for acts
of insubordination.
Source: GAO presentation of Booz Allen Hamilton recommendations to CRD.
[End of table]
[End of section]
Appendix II: Summary of the Equal Employment Opportunity Commission
Model Elements:
Equal Employment Opportunity Commission model elements: Demonstrated
commitment from agency leadership;
Summary: 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.
Equal Employment Opportunity Commission model elements: Integration of
EEO into the agency's strategic mission;
Summary: 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.
Equal Employment Opportunity Commission model elements: Management and
program accountability;
Summary: 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.
Equal Employment Opportunity Commission model elements: Proactive
prevention of unlawful discrimination;
Summary: 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.
Equal Employment Opportunity Commission model elements: Efficiency;
Summary: 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.
Equal Employment Opportunity Commission model elements: Responsiveness
and legal compliance;
Summary: 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.
Source: GAO summary of EEOC's Model Elements.
[End of table]
[End of section]
Appendix III: Excerpt from Coast Guard Civil Rights Directorate
Functional Review Recommendation Sheet:
Recommendation number: 16;
BAH recommendation: 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;
Project officer: Project officer 1;
Most recent action taken: Restructuring plan has been developed to
align with the Coast Guard‘s proposed Modernization Plan. This plan
will include efforts to streamline the Office of Civil Rights (OCR)
reporting restructures;
Primary due date: 4/20/2009;
Days before due: -271;
Status: Work in progress.
BAH recommendation: Present modernization to Strategic Transformation
Team;
Project officer: Project officer 2;
Most recent action taken: [Empty];
Primary due date: [Empty];
Days before due: [Empty];
Status: Complete.
BAH recommendation: Present to Commanding Officers;
Project officer: Project officer 1;
Most recent action taken: 3/16: Video teleconference scheduled with
Commandant and Area Commanders on 3/19;
Primary due date: [Empty];
Days before due: -312;
Status: Work in progress.
BAH recommendation: Present to Leadership Council;
Project officer: Project officer 1;
Most recent action taken: [Empty];
Primary due date: [Empty];
Days before due: [Empty];
Status: Complete.
BAH recommendation: Obtain approval and implement;
Project officer: Project officer 3;
Most recent action taken: [Empty];
Primary due date: [Empty];
Days before due: -307;
Status: Work in progress.
Source: GAO presentation of CRD information.
[End of section]
Appendix IV: Summary of Generally Accepted Project Management
Practices:
Project planning practice: Identifying measurable performance goals;
Summary: 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[A] 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.
Project planning practice: Defining specific tasks to complete the
action plan;
Summary: 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.
Project planning practice: Identifying the person(s) accountable for
completing the tasks to complete the action plan;
Summary: 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.
Project planning practice: Identifying interim milestones/checkpoints
to gauge the completion of the action plan;
Summary: 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.
Project planning practice: Identifying the needed resources to
complete the action plan;
Summary: 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.
Project planning practice: Consulted stakeholders;
Summary: 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.
Project planning practice: Defined how to evaluate the success of
completing the action plan;
Summary: This practice establishes and documents quantifiable criteria
that must be met for the project to be considered successful. Prior
GAO work[B] 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.
Source: GAO analysis.
[A] Government Performance and Results Act of 1993 (GPRA), Pub. L. No.
103-62, 107 Stat. 285 (Aug. 3, 1993).
[B] GAO, Designing Evaluations, GAO/PEMD-10.1.4, (Washington, D.C.:
May 1991).
[End of table]
[End of section]
Appendix V: Comments from the Department of Homeland Security:
U.S. Department or Homeland Security:
Washington, DC 20528:
April 21, 2010:
Ms. Laurie Ekstrand:
Director, Strategic Issues:
Government Accountability Office:
Washington, D.C. 20548:
Dear Ms. Ekstrand:
Thank you for the opportunity to comment on the draft report GAO-10-
571T "Coast Guard: Civil Rights Directorate's Action Plan to Improve
Its Operations Could Be Strengthened By Implementing Several Aspects
of Project Planning and Implementation Practices."
The Department of Homeland Security and the Coast Guard concurs with
the draft report's recommendations and will work to incorporate sound
project management principles in future corrective plans. We agree
that improved metrics will better enable the program to measure
success. The Coast Guard looks forward to continuing to refine its
project management efforts to ensure that they meet the requirements
of sound project planning and implementation.
The following is our response to the recommendations.
Recommendation #1: Ensure internal controls are in place to maintain
the documentation necessary to facilitate oversight and course-
correction as plans are designed and implemented.
Response: Concur. To institutionalize the practice, the Coast Guard
will imbed internal control functions into staff responsibilities.
Recommendation #2: Establish measurable performance goals for the
action plans to support the management decision as to the completion
status of the action plans.
Response: Concur. The Coast Guard will develop desired outcomes and
measurable success factors, and incorporate them into projects of this
magnitude.
Recommendation #3: Define an evaluation plan for each action plan to
assess the degree to which the plan yielded the intended outcomes.
Response: Concur. Consistent with recommendation #2. the Directorate
will develop a template to incorporate the practice in business
processes.
Thank you for the opportunity to provide comments to the draft report.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Footnotes:
[1] Booz Allen Hamilton, U.S. Coast Guard Office of Civil Rights
Program Review, 2009. See appendix I for a list of the 53
recommendations to CRD.
[2] MD-715 provides policy guidance and standards for establishing and
maintaining effective affirmative programs of equal employment
opportunity under § 717 of Title VII of the Civil Rights Act of 1964,
as amended, and effective affirmative action programs under section
501 of the Rehabilitation Act of 1973, as amended. See, 42 U.S.C. §
2000e-16 and 29 U.S.C. § 791. We did not evaluate the extent to which
CRD's action plans met the criteria for EEOC model elements.
[3] GAO, Motor Carrier Safety: The Federal Motor Carrier Safety
Administration Has Developed a Reasonable Framework for Managing and
Testing Its Comprehensive Safety Analysis 2010 Initiative, [hyperlink,
http://www.gao.gov/products/GAO-08-242R] (Washington, D.C.: Dec. 20,
2007); and GAO, Standards for Internal Control in the Federal
Government, [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.:
November 1999). Internal control standards provide the overall
framework for establishing and maintaining internal controls in the
federal government.
[4] Government Performance and Results Act of 1993 (GPRA), Pub. L. No.
103-62, 107 Stat. 285 (Aug. 3, 1993).
[5] Project Management Institute, A Guide to the Project Management
Body of Knowledge (PMBOK), First Edition (1996). We adapted the
original language from PMBOK for the purposes of the GAO testimony.
[6] GAO, Coast Guard: Observations on the Genesis and Progress of the
Service's Modernization Program, [hyperlink,
http://www.gao.gov/products/GAO-09-530R] (Washington, D.C.: Jun. 24,
2009).
[7] There are other action plans related to key issues identified in
the external review that are not included in our review.
[8] Coast Guard's 11 missions are: (1) Ports, waterways, and coastal
security, (2) Drug interdiction, (3) Aids to navigation, (4) Search
and rescue, (5) Living marine resources, (6) Marine safety, (7)
Defense readiness, (8) Migrant interdiction, (9) Marine environmental
protection, (10) Ice operations, and (11) Other law enforcement. See,
§ 888 of the Homeland Security Act of 2002 (Pub. L. No. 107-296, 116
Stat. 2135, 2249 (2002)).
[9] See appendix II for a summary of the six model elements.
[10] The EEOC categories of model elements are not mutually exclusive
and can be subject to interpretation.
[11] None of the action plans focus on proactive prevention of
unlawful discrimination because no recommendations were made
concerning this element. This does not imply that there should be
plans focusing on proactive prevention or that the Coast Guard Civil
Rights Directorate does not need to improve proactive prevention.
[12] The Leadership Council consists of the Commandant, Vice
Commandant, Commanders (Atlantic and Pacific Areas), the Chief of
Staff, and the Master Chief Petty Officer of Coast Guard.
[13] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[14] See appendix III for an excerpt from the Functional Review
Recommendation Implementation Spreadsheet.
[15] Project Management Institute, A Guide to the Project Management
Body of Knowledge, First Edition (1996).
[16] See appendix IV for a summary of the generally accepted project
management practices.
[17] We did not speak with the civil rights service providers and
unions to obtain their views on CRD's consultation.
[End of section]
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