FDICís Equal Employment Opportunity Discrimination Complaint Process

November 2005
Report No. 06-001

EVALUATION REPORT

FDIC OIG, Office of Audits

Background and
Purpose of Evaluation


The Office of Diversity and Economic Opportunity (ODEO) implements the discrimination complaint resolution process in accordance with Title 29 of the Code of Federal Regulations, Part 1614, Federal Sector Equal Employment Opportunity, effective November 9, 1999, which mandates specific time frames for federal agencies to process, investigate, and issue agency decisions on discrimination complaints.

We conducted this review as a follow-up to evaluations of the FDICís Equal Employment Opportunity (EEO) discrimination complaint resolution process that we performed in 1998 and in 2000 with the FDICís Office of Enterprise Risk Management, formerly the Office of Internal Control Management.

The objective of this review was to evaluate the FDICís discrimination complaint resolution process and management of the FDICís formal complaint case load. However, we were unable to accomplish our objective due to data reliability issues associated with ODEOís case tracking system. We focused, instead, on ODEOís conversion to a new complaint tracking system. We limited our scope to presenting, not validating, ODEOís case processing statistics and ODEOís perspective on the statistics.

FDIC, Federal Deposit Insurance Corporation


Results of Evaluation


ODEO reported that the volume of discrimination complaints filed annually and the discrimination complaints case load have significantly decreased. ODEO management attributes these decreases to a combination of factors, including corporate downsizing and the implementation of an alternative dispute resolution program. However, we noted that ODEOís overall average case processing time frames have increased by 39 percent since 1996 to 986 days, whereas other federal agencies have experienced a 24-percent increase in case processing time frames over this same period, averaging 469 days. While ODEO management has expressed that a number of factors in the process are outside of its control, those factors are not unique to the FDIC and may not explain why the Corporationís case processing time frames exceed the federal sector average.

Additionally, ODEO is currently without reliable data in its discrimination complaint case tracking system. During 2004, ODEO converted discrimination complaint data from a legacy system to a new commercial-off-the-shelf system. We concluded that the data conversion effort was not adequately managed, resulting in unreliable data in the new system. The lack of a reliable case tracking system could hamper ODEOís ability to effectively manage its complaint case load and to efficiently meet internal and external reporting requirements. Further, ODEO cannot readily respond to ad hoc requests for information, and there is an increased vulnerability for reporting errors using manually gathered information.

ODEO maintained that reliable data could be extracted from the new case tracking system to produce accurate, required reports in a reasonable amount of time. Nevertheless, ODEO has initiated action to improve the reliability of the system.

We reported findings related to case processing time frames and data reliability in our prior evaluations. The FDIC needs to devote renewed and sustained management attention to this program and ensure that ODEO promptly and effectively improves the reliability of its case tracking system.

Recommendations and Management Response

We recommended that ODEO (1) develop a formal remediation plan to address data reliability of the case tracking system that establishes milestones and identifies appropriate and sufficient resources to complete the remediation in a timely and effective manner and (2) arrange for an independent follow-up review of ODEOís compliance with EEO case processing time frames, following remediation of the case tracking system data reliability issues.

Management agreed with both of our recommendations.





TABLE OF CONTENTS

BACKGROUND
EVALUATION RESULTS
Decrease in Volume of Discrimination Complaints and Case Load
Increase in Case Processing Time Frames
Tracking and Reporting Discrimination Complaints Data
   Historical Efforts to Implement a Case Tracking System
   System Development Life Cycle (SDLC) and Data Conversion
   Data Reliability and ODEO Remediation Effort
CONCLUSION
RECOMMENDATIONS
CORPORATION COMMENTS AND OIG EVALUATION
APPENDIX I: OBJECTIVE, SCOPE, AND METHODOLOGY
APPENDIX II: OVERVIEW OF THE FEDERAL SECTOR DISCRIMINATION
     COMPLAINT PROCESS
APPENDIX III: CORPORATION COMMENTS
APPENDIX IV: MANAGEMENT RESPONSE TO RECOMMENDATION
FIGURES
Figure 1: FDIC EEO Case Load and Complaints Filed
Figure 2: Average Number of Processing Days for All Complaint Closures
Figure 3: ODEO Efforts to Implement a Replacement Case Processing System


Acronyms

AJ Administrative Judge
C.F.R. Code of Federal Regulations
COTS Commercial-off-the-Shelf
DIT Division of Information Technology
EEO Equal Employment Opportunity
EEOC Equal Employment Opportunity Commission
FAD Final Agency Decision
FDIC Federal Deposit Insurance Corporation
FY Fiscal Year
GAO Government Accountability Office
HRT Human Resources Technologies, Inc.
ODEO Office of Diversity and Economic Opportunity
OERM Office of Enterprise Risk Management
OIG Office of Inspector General
SDLC System Development Life Cycle


FDIC OIG letterhead

DATE: November 4, 2005

MEMORANDUM TO: D. Michael Collins
Director, Office of Diversity and Economic Opportunity

FROM: Russell A. Rau [Electronically produced version; original signed by Russell A. Rau]
Assistant Inspector General for Audits

SUBJECT: FDICís Equal Employment Opportunity Discrimination Complaint
Process
(Report No. 06-001)

This report presents the results of our evaluation of the FDICís Equal Employment Opportunity (EEO) discrimination complaint resolution process. The objective of this review was to evaluate the FDICís discrimination complaint resolution process and management of the FDICís formal complaint case load. However, we were unable to accomplish our objective due to data reliability issues associated with the Office of Diversity and Economic Opportunityís (ODEO) discrimination complaint tracking system. We focused, instead, on ODEOís conversion to a new complaint tracking system. We limited our scope to presenting, not validating, ODEOís case processing statistics and ODEOís perspective on the statistics. Additional details on our objective, scope, and methodology are in Appendix I.

BACKGROUND

ODEO is responsible for implementing the discrimination complaint resolution process required by Title 29 of the Code of Federal Regulations, Part 1614, titled, Federal Sector Equal Employment Opportunity, effective
November 9, 1999, which mandates specific time frames for federal agencies to process, investigate, and issue agency decisions on discrimination complaints. These regulations are included in the Equal Employment Opportunity Commissionís (EEOC) policies, procedures, and guidance published in Management Directive 110
(EEO MD-110), effective November 1999, for the FDIC.

ODEO issues annual reports to the EEOC on its progress in resolving discrimination complaints and statistical information relating to the FDICís EEO complaints to the Congress on an annual fiscal year basis under the Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002 (No Fear Act). The FDICís procedures for initiating and processing EEO complaints of alleged employment discrimination are contained in FDIC Circular 2710.2, EEOC Discrimination Complaint Procedures, effective December 3, 2003. Appendix II depicts the discrimination case resolution process.

We conducted this review as a follow-up to evaluations[ 1 ] we performed of the FDICís EEO discrimination complaint resolution process in 1998 and in 2000 with the Office of Enterprise Risk Management (OERM).[ 2 ] Those evaluations reported noncompliance with EEOC complaint processing time frames and made several recommendations to improve the FDICís discrimination complaint process.

EVALUATION RESULTS

ODEO reported that the volume of discrimination complaints filed annually and the discrimination complaint case load have decreased significantly. ODEO management attributes these decreases to a combination of factors, including agency downsizing and the implementation of an alternative dispute resolution program. However, we noted that ODEOís overall average case processing time frames have increased by 39 percent since 1996 to 986 days, whereas other federal agencies have experienced a 24-percent increase in case processing time frames for the same period, averaging 469 days. While ODEO management has expressed that there are a number of factors in the process outside of its control, those factors are not unique to the FDIC and may not explain why the Corporationís case processing time frames exceed the federal sector average. The lengthy case processing time frames result in the FDIC not providing its employees with an efficient and effective process for resolving discrimination complaints and possibly not complying with EEOC policies.

We could not independently verify or perform our own analysis of the FDICís discrimination complaint statistics or case processing time frames because ODEO is currently without reliable data in its discrimination complaint case tracking system. During 2004, ODEO worked with the Division of Information Technology (DIT)[ 3 ] and a vendor to convert discrimination complaint data from a legacy case tracking system to EEONet.[ 4 ] We concluded that the data conversion effort was not adequately managed and did not accurately map the data fields between the two systems, resulting in unreliable data in EEONet.

As a result, ODEO was not able to readily provide information on open and closed cases to allow us to meet our evaluation objective. Moreover, the lack of a reliable case tracking system hampers ODEOís ability to effectively manage its complaint case load and to efficiently meet internal and external reporting requirements. Further, ODEO cannot readily respond to ad hoc requests for information, and there is an increased vulnerability for error in manually gathering information from case files and other sources of information to respond to information requests and to develop required reports.

ODEO maintained that reliable data could be extracted from EEONet to produce accurate, required reports in a reasonable amount of time. Nevertheless, ODEO has contracted with a vendor to input and validate missing data in EEONet. ODEO has not, however, developed a formal remediation plan that establishes milestones and identifies appropriate and sufficient resources to complete the remediation in a timely manner.

Decrease in Volume of Discrimination Complaints and Case Load

ODEO has reported that the volume of discrimination complaints filed annually has decreased 64 percent from 97 cases filed during 1996 to 35 cases filed in 2004. Further, the Corporationís discrimination complaints case load has decreased by 65 percent from 228 open cases in 1996 to 79 open cases in 2004. Figure 1 below details the number of EEO discrimination complaint cases filed compared to the average number of cases in process from 1996 through 2004.

Figure 1: FDIC EEO Case Load and Complaints Filed Figure 1, FDIC EEO Case Load and Complaints Filed graph
Source: EEOCís Annual Report on the Federal Work Force, Fiscal Year 1996-2004. [ D ]

ODEO management attributes these decreases to a combination of:

  • an overall reduction in FDIC staff through downsizing;
  • the implementation of an Alternative Dispute Resolution program;[ 5 ]
  • changes in corporate culture resulting from managementís commitment to the principles outlined in the FDICís Strategic and Diversity plans;
  • an increased use of grievance procedures to resolve compensation-related disputes; and
  • a November 1999 change in the EEOCís regulations[ 6 ] allowing EEO complainants to amend a previously filed complaint prior to the conclusion of an investigation into the complaint, to include issues or claims that are like or related to those raised in the previously filed complaint rather than requiring an EEO complainant to file a new complaint.

Increase in Case Processing Time Frames

ODEOís overall average case processing time frames have increased by 39 percent since 1996, from 707 days in 1996 to 986 days in 2004 despite a substantial decrease in the case load and the number of complaints filed as discussed earlier. During the same time frame, other federal agencies have experienced a 24-percent increase in case processing time frames. Figure 2 compares the average number of processing days for all EEO discrimination complaint closures for the FDIC and the federal government during fiscal year (FY) reporting periods 1996 through 2004.

Figure 2: Average Number of Processing Days for All Complaint Closures Figure 2, Average Number of Processing Days for All Complaint Closures graph
Source: EEOC's Annual Report on the Federal Work Force, Fiscal Year 1996-2004 [ D ]

ODEO management identified several factors that increase discrimination complaint processing time frames and that were out of ODEOís control:

  • Class Complaints - Class complaints of discrimination placed in abeyance and awaiting an Administrative Judgeís (AJ) decision on the parameters and definition of the class are included in the EEOCís calculation of average number of days to resolve a discrimination complaint. ODEO must also hold in abeyance other individual discrimination complaints asserting the same basis[ 7 ] of discrimination as class complaints until the EEOC rules on the certification of the class complaint. ODEO had three class complaints from 2001 through 2004.

  • Hearings Ė The complainant has the right to request a hearing before an EEOC AJ. ODEO asserts that complaints awaiting a hearing by an AJ are outside of its control. The EEOC reported that the average government wide processing time for hearings was 355 days during 2004.

  • Amended Cases Ė As discussed earlier, a 1999 change to EEOC regulations allowed complainants to amend previously filed complaints to include like or related issues and claims. ODEO asserted that while this change resulted in fewer new complaints being filed, it increased the number of days required to resolve discrimination complaints.

These factors may explain time frame increases but are not unique to the FDIC and may not explain why the FDICís case processing time frames continue to exceed the federal sector average. Lengthy case processing time frames result in an FDIC process that is not efficient and effective in resolving employee discrimination complaints and potential FDIC noncompliance with EEOC policies.

Tracking and Reporting Discrimination Complaints Data

ODEO is currently without reliable data in its discrimination complaint case tracking system due to an inadequate data conversion effort. The lack of reliable data could hamper ODEOís ability to effectively manage its complaint caseload and to efficiently meet internal and external reporting requirements. Further, ODEO cannot readily respond to ad hoc requests for information, and there is an increased vulnerability for error in manually gathering information from case files to respond to information requests and to develop required reports.

EEOC issued Management Directive (EEO MD-715), effective October 2003, to provide policy guidance and standards for establishing and maintaining effective affirmative EEO programs and affirmative action programs. EEO MD-715 presents essential elements of model agency EEO programs, including the use of a complaint tracking and monitoring system that permits the agency to identify the location, status, and length of time elapsed at each stage of the agencyís complaint resolution process and that presents information necessary to analyze complaint activity and identify trends.

EEOC also issued a federal sector report entitled, Attaining a Model Agency Program: Efficiency, which states that an accurate, accessible, verifiable, and comprehensive case tracking system is essential for managing an effective and timely complaint processing program. The report also noted that the lack of an effective and accurate data collection system increases complaint processing time, impairs management's ability to identify and correct deficiencies in complaint processing, and obscures the actual workload of the EEO staff.

Historical Efforts to Implement a Case Tracking System

In 1998, ODEO began using a commercial-off-the-shelf (COTS) product, called EEOMAS, as ODEOís discrimination complaint case tracking system. ODEO customized EEOMAS to manage the discrimination complaints process and track FDIC discrimination complaint information. In 1999, ODEO, OERM, and the Legal Division conducted an extensive 100-percent file review to ensure that data within EEOMAS were accurate. From 1999 through 2004, OERM conducted limited data reliability reviews of EEOMAS with positive results. ODEO began using standard and ad hoc EEOMAS reports to track and manage the complaint work load and report elapsed days statistics to ensure that ODEO could meet internal and external reporting requirements.

While EEOMAS provided valuable information, the system had a number of deficiencies that made it unacceptable for long-term use. For example, DIT tested EEOMAS in March 2001 for Windows 2000 compatibility and determined that EEOMAS would not operate in the new FDIC system architecture. DIT researched various tracking system options for ODEO and found that most government agencies built their own systems due to the lack of available Web-based COTS products on the market. DIT suggested in-house development of a tracking system for ODEO. However, ODEO identified a COTS product called Visual Powerfiles that met ODEOís expectations. Visual Powerfiles was purchased in 2002 and was placed into production in 2003. Due to problems with the vendor, the product was taken off line, and DIT and ODEO began researching alternative solutions. In 2004, ODEO ultimately purchased EEONet from Human Resources Technologies, Inc. (HRT), which supports the product, as ODEOís official discrimination complaint case tracking system. Figure 3 depicts events in ODEOís search for a discrimination complaints processing system.

Figure 3: ODEO Efforts to Implement a Replacement Case Processing System Figure 3, ODEO Efforts to Implement a Replacement Case Processing System graph
Source: Office of Inspector General (OIG) Analysis of ODEO and DIT Information and Interviews. [ D ]

System Development Life Cycle (SDLC) and Data Conversion

DITís June 1, 2001 Project Plan that recommended a new case tracking system stated that the search for a new case management system was being performed using the FDICís SDLC approach.[ 8 ] The SDLC approach notes that an alternative to in-house development is the procurement of commercial software, but control is necessary to ensure that selected software meets the userís needs and that it is properly placed into operation.

DIT explained that its responsibility was to test the programís functionality and determine whether the program effectively operated on the FDICís platform without impacting other FDIC programs. DIT indicated that the EEONet purchase agreement required HRT to install, customize, and provide annual technical support. DIT tested EEONet in the DIT test labs before approving EEONet for production and assisted HRT in developing user acceptance test plans for the initial version of EEONet. However, because EEONet was a COTS product, DIT was not involved in the actual conversion of data.

Data conversion started in May 2004, and EEONet was implemented in August 2004. The HRT contract required HRT to perform data analysis to ensure data reliability during the conversion and to provide the FDIC the test results. ODEO provided HRT a copy of the data files from EEOMAS for the conversion to EEONet and identified the data fields in EEOMAS that were customized for the FDIC in order for HRT to complete the conversion. However, it appears that planning for the data conversion process, including mapping of data fields from EEOMAS to EEONet, was not adequate to ensure the reliability of data in EEONet.

We verified that DIT, HRT, and ODEO participated in user acceptance testing, but we concluded that testing focused on whether EEONet would operate in the FDICís information technology environment and produce anticipated reports. Testing did not focus on whether the converted data and reports were accurate. Although data reliability testing was required by the HRT contract, neither DIT nor ODEO was able to provide documentation showing that HRT or ODEO had performed such testing.

In August 2004, ODEO accepted EEONet as the discrimination complaints processing system and operated the EEONet and EEOMAS applications in a parallel production environment. DIT again informed ODEO in November 2004 that it had to retire EEOMAS. ODEO obtained an extension to use EEOMAS through March 2005 when it was retired. ODEO indicated that it had retained a backup copy of historical complaints processing data on a CD Rom, but ODEO is unable to read the data without the EEOMAS software.

Data Reliability and ODEO Remediation Effort

ODEO characterized the data in EEONet as reliable but incomplete with respect to: (1) historical data fields that were unique to EEOMAS that did not properly convert to EEONet and (2) new data fields that were unique to EEONet for which EEOMAS did not contain corresponding data. ODEO maintained that reliable data could be extracted from EEONet to produce required reports and that reporting inaccuracies could be corrected in a matter of days.

According to guidelines published by the Government Accountability Office (GAO),[ 9 ] data reliability refers to the accuracy and completeness of computer processed data, given the intended purposes for use. Computer processed data include data (1) entered into a computer system and (2) resulting from computer processing. Data are reliable when they are complete (they contain all of the data elements and records needed for the audit engagement) and accurate (they reflect the data entered at the source or in source documents). Reliability also means that for any computer processing of the data elements used, the results are reasonably complete and accurate, meet the userís intended purposes, and are not subject to inappropriate alteration. Accordingly, because the conversion of discrimination complaint data resulted in incomplete data fields and because EEONet cannot produce accurate reports without ODEO making corrections and alterations, we concluded that the data within EEONet were unreliable for our evaluation purposes.

In late August 2005, ODEO informed us that it had contacted HRT for assistance and was pursuing a two phased approach to remediate the data reliability issues within EEONet. Under Phase I, HRT will re-convert historical data from EEOMAS to EEONet, including data fields that were unique to EEOMAS. ODEO estimated that Phase I would take about 1 month to complete. Phase II will involve reviewing ODEO source complaint files for information pertaining to the new EEONet data fields (for which EEOMAS did not maintain corresponding data) and entering that data into EEONet. ODEO did not know the extent of effort Phase II would require or whether ODEO would require HRTís assistance. Additionally, ODEO has not developed a formal remediation plan, which establishes milestones and identifies sufficient resources to complete the remediation effort in a timely manner.

CONCLUSION

ODEOís average discrimination complaints processing time frames are more than twice the federal sector case processing average. Further, we concluded that ODEO did not successfully manage the data conversion effort between EEOMAS and EEONet and is currently without reliable data in EEONet. We reported findings in both of these areas in our prior evaluations. As a result, the FDIC needs to devote renewed and sustained management attention to this program to ensure that ODEOís processing of discrimination complaints complies with EEOC requirements. In addition, the Corporation must ensure that a reliable case tracking system is in place that assists ODEO in managing its case load and complying with internal and external reporting requirements.

RECOMMENDATIONS

We recommend that the Director, ODEO:

  1. Develop a formal remediation plan to address data reliability of the case tracking system that establishes milestones and identifies appropriate and sufficient resources to complete the remediation in a timely and effective manner.

  2. Arrange for an independent follow-up review of ODEOís compliance with EEO case processing time frames, following remediation of the case tracking system data reliability issues.

CORPORATION COMMENTS AND OIG EVALUATION

The Director, ODEO, provided a written response dated October 27, 2005. ODEOís response is presented in its entirety in Appendix III. Appendix IV presents a summary of ODEOís responses to our recommendations.

ODEO concurred with recommendation 1. ODEO stated that it has developed a remediation plan to address the data reliability of the case tracking system. For Phase I of the remediation plan, ODEO contracted with HRT to identify necessary data fields left unpopulated by the data transferal process from EEOMAS to EEONet. This phase was completed on September 30, 2005. Phase II is being completed in two parts, utilizing internal resources. The data input is being split based on the date that complaints were filed. Data input for complaints filed in FYs 2000 Ė 2005 was completed on October 19, 2005, and the targeted completion date for data input and verification for complaints filed in FYs 1995 Ė 1999 is January 31, 2006.

ODEO also concurred with recommendation 2. ODEO has requested that OERM conduct a follow-up review of ODEO compliance with case processing time frames, validate the quality of the data in EEONet, and review the accuracy and integrity of reports. This review is scheduled for mid-November 2005.

In addition, ODEO responded to our finding regarding increased case processing time frames. In its response, ODEO reiterated that class action complaints and subsumed cases have significantly impacted processing times. Nevertheless, ODEO stated that it has instituted several measures associated with complaint investigations to improve the overall timeliness of case processing. ODEO also noted that the EEOC had recently issued clarifying guidance for reporting on the processing of class action and subsumed complaints which should improve case processing time frames.

The actions taken and planned by management are responsive to the recommendations. The recommendations are resolved but will remain open until we have determined that agreed-to-corrective actions have been completed and are effective.



OBJECTIVE, SCOPE, AND METHODOLOGY

APPENDIX I

The objective of this evaluation was to evaluate the FDICís discrimination complaint resolution process and management of the FDICís formal complaints case load. However, we were unable to accomplish our objective due to data reliability issues associated with ODEOís discrimination complaint tracking system. We focused, instead, on ODEOís conversion to a new complaint tracking system. We limited our scope to presenting, not validating, ODEOís case processing statistics and ODEOís perspective on the statistics.

To accomplish our objective, we:

  • Interviewed ODEO personnel responsible for the management of the FDICís discrimination complaint resolution program to identify their case load, problem areas, and/or suggestions for improvements. In addition, we interviewed OERM personnel and reviewed various OERM documents and prior OIG reports to determine the status of earlier corrective actions.
  • Assessed ODEOís efforts to procure a new case tracking system (EEONet) to replace EEOMAS.
  • Interviewed DIT staff responsible for implementation of case tracking systems to replace EEOMAS regarding data from the EEOMAS legacy database, the process of implementing a new case tracking system, the timeline for the transition from EEOMAS to the implementation of EEONet, and the problems and costs associated with the transition from EEOMAS to a new discrimination complaint case tracking system.
  • Reviewed applicable EEOC regulations, FDIC directives, and ODEO policies and procedures. Documented the discrimination complaints process for both informal and formal discrimination complaints resolution, including time frames for completing the process, staff involved, and documents produced.
  • Reviewed EEOC federal sector reports on EEO complaints processing and appeals and EEOCís Annual Report on the Federal Work Force for FYs 1996 through 2004 to assess the FDICís compliance with federal sector processing time frames in resolving discrimination complaints and to compare the FDICís processing time frames with federal sector averages.

Prior Evaluations and Reviews

On May 4, 1998, the OIG issued Evaluation Report No. 98-001, The Office of Diversity and Economic Opportunityís Discrimination Complaint Resolution Process and Caseload. We reported noncompliance with EEOC complaint processing time frames and made several recommendations to improve the FDICís discrimination complaint process.

On May 19, 2000, we issued Evaluation Memorandum No. 00-001, FDICís Equal Employment Opportunity Complaint Process, jointly with the Office of Internal Control Management (now OERM). The evaluation provided updated complaint processing statistics and a status of ODEOís efforts to implement our recommendations in Evaluation Report No. 98-001.

Reliance on Computer-based Systems, Compliance with Laws and Regulations, Government Performance and Results Act, Fraud and Illegal Acts, and Internal Control

We relied on ODEO reports to the EEOC and on statistics provided by the EEOC on the FDICís compliance with federal sector processing time frames in resolving discrimination complaints. We did not perform specific procedures to validate the reliability of data ODEO reported to the EEOC. Further, due to the data reliability issues we identified, we did not evaluate ODEOís compliance with pertinent EEO laws and regulations associated with complaint resolution or reporting requirements.

Consistent with the Government Performance and Results Act, ODEO has established goals and objectives to measure and improve performance. Because our evaluation was re-focused to address ODEOís conversion to a new complaint tracking system, we did not evaluate the adequacy or ODEOís use of those goals and objectives.

The nature of our evaluation objectives did not require that we assess the potential for fraud and illegal acts. However, throughout the evaluation, we were alert to the potential for fraud and illegal acts, and no instances came to our attention.

We evaluated the effectiveness of management controls by reviewing policies and procedures over the discrimination complaints process, organizational charts, and periodic OERM reviews of the complaints process. Our report includes findings and recommendations related to ensuring that ODEO has an effective case tracking system for managing the EEO complaint case load.

We conducted our evaluation field work from May through August 2005 in accordance with generally accepted government auditing standards.



OVERVIEW OF THE FEDERAL SECTOR DISCRIMINATION COMPLAINT PROCESS

APPENDIX II

Appendi II, Overview of the Federal Sector Discrimination Complaint Process chart
[ D ]


CORPORATION COMMENTS

APPENDIX III

Corporation Comments, page 1
[ D ]
Corporation Comments, page 2
[ D ]
Corporation Comments, page 3
[ D ]
Corporation Comments, page 4
[ D ]


MANAGEMENT RESPONSE TO RECOMMENDATIONS

APPENDIX IV


This table presents the management response to the recommendations in our report and the status of the recommendations as of the date of report issuance.

Rec. Number Corrective Action for
Recommendation: Taken or
Planned/Status
Expected Completion Date Monetary Benefits Resolved: [ a ] Yes or No
Open or Closed [ c ]
1
ODEO has developed a remediation plan to address the data reliability of the case tracking system. In Phase I of the remediation plan, ODEO contracted with HRT to identify necessary data fields left unpopulated by the data transferal process from EEOMAS to EEONet. Phase II is being completed in two parts based on the date that complaints were filed. Part A involved the input of data for complaints filed in FYs 2000 Ė 2005, and Part B will be the input and verification of data for complaints filed in FYs 1995 Ė 1999. January 31, 2006 $0   Yes   Open
2
ODEO has requested that OERM conduct a follow-up review of ODEO compliance with case processing time frames, validate the quality of the data in EEONet, and review the accuracy and integrity of reports. Scheduled to begin mid-November 2005 $0   Yes   Open
a Resolved Ė
(1) Management concurs with the recommendation, and the planned corrective action is consistent with the recommendation.
(2) Management does not concur with the recommendation, but planned alternative action is acceptable to the OIG.
(3) Management agrees to the OIG monetary benefits, or a different amount, or no ($0) amount. Monetary benefits are considered resolved as long as management provides an amount.

b Once the OIG determines that agreed-to corrective actions have been completed and are effective, the recommendation can be closed.

Last updated 11/18/2005