Office of Compliance:

Status of Management Control Efforts to Improve Effectiveness

GAO-04-400: Published: Feb 3, 2004. Publicly Released: Feb 3, 2004.

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The Consolidated Appropriations Resolution of 2003 Conference Report mandated that GAO review the Office of Compliance (OOC), an independent legislative branch agency created by the Congressional Accountability Act of 1995 (CAA). OOC, a 15-person office with about $2 million in expenditures during fiscal year 2003, administers and enforces various CAA provisions related to fair employment and occupational safety and health among certain legislative branch agencies. OOC's current Executive Director has been in place since April 2001 and its General Counsel joined the Office in June 2003. The mandate directed GAO to assess the OOC's overall effectiveness and efficiency and to make recommendations, as appropriate.

OOC is in the early stages of a concerted and vitally needed effort to improve and strengthen management control across the Office and to carry out its mission more effectively and efficiently while safeguarding its institutional independence. OOC's success in completing this important effort depends upon making significant progress on a number of key management control areas: Sharpen focus on results. OOC's current strategic planning initiative is beginning to address the more fundamental question of the Office's effectiveness rather than the Office's traditional focus on activities and outputs, such as the number of cases processed and inspections conducted. OOC's planning initiative can also provide a vehicle for engaging and consulting with key congressional and other stakeholders on OOC's purposes, how those purposes will be achieved, how progress will be assessed, and for sustaining feedback on what progress is being made and what additional improvement opportunities exist. The planning initiative is still very much a work in progress and continued efforts are needed in a number of key areas including developing results oriented performance measures. Ensuring an effective program structure. As OOC shifts its focus from outputs and activities to results, it must put in place a more effective program structure that includes new ways of doing business. OOC has taken a number of actions to administer the CAA, such as managing a dispute resolution process and conducting investigations and inspections to ensure compliance with safety and health standards. However, OOC is not fully in compliance with the CAA's requirement concerning biennial safety and health inspections of legislative branch agency facilities. OOC also needs to expand on recent efforts to develop programs that are based on collaboration with legislative branch agencies. Building effective communication emphasizing outreach and coordination. OOC's congressional and other stakeholders whom we interviewed said that OOC recently has used a more collaborative approach rather than the "gotcha" approach of the past. On the other hand, several agency officials said that current interactions with OOC could be improved. To facilitate more effective communications, OOC should establish congressional and agency protocols to document agreements between the Congress, legislative branch agencies, and OOC on what can be expected as OOC carries out its work. Creating and sustaining an enhanced management control environment. Since its creation, OOC has operated without having any formal performance management system for its Executive Director and General Counsel. OOC should establish an enhanced management control environment and strengthen accountability by requiring performance agreements between the Board and both the Executive Director and General Counsel, as well as expanding and improving on OOC's performance management system for all staff. Another important challenge concerns the lack of institutional continuity that may occur due to statutory term limits on OOC's leadership positions. To prevent the loss of critical organizational knowledge, the Congress should consider changing the term limits contained in the CAA.

Matters for Congressional Consideration

  1. Status: Closed - Implemented

    Comments: GAO's February 2004 report on the Office of Compliance (OOC) stated that management control requires organizations to consider the effect upon their operations if a large number of employees, including executives and other leadership, are expected to leave. OOC was facing a considerable loss of knowledge and leadership because of the impending turnover of its five-member Board of Directors, all of whom would have reached the end of their terms by May 2005. This expected loss is due to the Congressional Accountability Act (CAA) which established OOC and limits board members to a single 5-year term. As such, GAO's report stated that Congress should consider making legislative changes to the CAA to help ensure that OOC maintains institutional continuity into the future. Specifically, the Congress should consider amending the CAA to allow board members to be reappointed to an additional term. On October 21, 2004, Congress amended the CAA to permit members of OOC's Board of Directors to serve for two terms (P.L. 108-349).

    Matter: Congress may wish to consider making legislative changes to the CAA to help ensure that OOC maintains institutional continuity into the future. Specifically, the Congress may wish to consider amending the CAA to allow board members to be reappointed to an additional term.

  2. Status: Closed - Implemented

    Comments: GAO's February 2004 report on the Office of Compliance (OOC) stated that management control requires organizations to consider the effect upon their operations if a large number of employees, including executives and other leadership, are expected to leave. The Congressional Accountability Act (CAA) restricts OOC's four appointed executives to nonrenewable 5-year terms of service. In addition, this restriction also prevents the possibility of having a deputy executive director serve in the role of executive director, making the potential of succession planning among this group of executives impossible. The loss of such a large proportion of OOC's leadership within a relatively short period likely will result in a loss of leadership continuity, institutional knowledge, and expertise that has the potential of adversely impacting OOC's performance. As such, GAO's report recommended that Congress may wish to consider making legislative changes to the CAA to help ensure that OOC maintains institutional continuity into the future. On July 13, 2005, Congress passed H.R. 3071, which permits the Executive Directors, Deputy Executive Directors and the General Counsel of the Office of Compliance to serve one additional term.

    Matter: Congress may wish to consider making legislative changes to the CAA to help ensure that OOC maintains institutional continuity into the future. Specifically, the Congress may wish to consider amending the CAA to allow the Executive Director, General Counsel, and the two Deputy Executive Directors to be reappointed to serve subsequent terms in either the same or a different position, if warranted and the Congress so desires. Any reappointments should be contingent on an individual's demonstrated performance and achievement of goals as documented in executive performance agreements for OOC's Executive Director and General Counsel, as recommended below, or another performance management system in the case of OOC's two Deputy Executive Directors.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The Congressional Accountability Act (CAA) requires that the Office of Compliance (OOC) report on the total number of individuals requesting counseling or mediation as part of OOC's dispute resolution process. Although required by the CAA, this approach does not provide a complete picture of OOC's workload since the office counts each individual included as part of the large group as a separate request regardless of whether the individual personally requested or even participated in services such as counseling or mediation. During its February 2004 review, OOC officials could not provide GAO with a specific number of individuals included in these group requests who actually received counseling or mediation services in 1999 or 2001. As such, GAO recommended, and OOC officials concurred, that it could improve its tracking and reporting of single-issue large-group requests for counseling and mediation. In response, OOC officials on January 11, 2005, began using their automated tracking system to assign a common term to multiple claims that are related to a single case, which will enable staff to more closely monitor the office's actual workload.

    Recommendation: We recommend that OOC's Executive Director and General Counsel provide a more complete picture of OOC's workload by improving how it tracks and reports on single-issue large group requests for counseling and mediation.

    Agency Affected: Office of Compliance

  2. Status: Closed - Implemented

    Comments: The Congressional Accountability Act (CAA) requires that the Office of Compliance's (OOC) General Counsel enforce occupational safety and health standards by performing periodic inspections of all legislative branch facilities covered by the CAA. In our February 2004 report of OOC, we found that OOC was not fully in compliance with this CAA requirement because it did not inspect 10 out of the 46 facilities subject to inspection during 2002. OOC officials told us that the decision not to inspect these facilities was largely due to resource constraints. Our report recommended, and OOC officials agreed, that OOC work with Congress to develop a strategy to ensure that all facilities under OOC's jurisdiction and located in the Washington, D.C. area are covered as part of the biennial safety inspections required by the CAA. On July 6, 2006, OOC reported it had taken several steps to ensure that its inspections would include all legislative branch facilities under OOC's jurisdiction and located within the Washington, D.C. area. These steps include requesting a supplemental appropriation to retain an additional contractor to help conduct the inspections. OOC also will use data from its current and past inspections to identify the specific staff and contractor resources needed to conduct subsequent biennial safety inspections. In addition, OOC will continue to meet regularly with its congressional oversight and appropriations committees to discuss the resources needed for future inspections and monitoring.

    Recommendation: We recommend that OOC's Executive Director and General Counsel work with the Congress to develop a strategy to ensure that all facilities under OOC's jurisdiction and located in the Capitol Hill complex and the surrounding Washington, D.C. area--including the Senate and House page dormitories, and LOC's National Library Service for the Blind and Physically Handicapped--are covered as part of the biennial safety inspections required by the CAA.

    Agency Affected: Office of Compliance

  3. Status: Closed - Implemented

    Comments: Our work in the February 2004 report of the Office of Compliance (OOC) determined that OOC should explore the possibility of playing a more active role as a central repository for good practices covered under the Congressional Accountability Act (CAA), such as lessons learned concerning health and safety practices. Based on our work, we recommended that OOC's Executive Director and General Counsel establish a clearing house for sharing best practice information on topics covered by the CAA. In response, in fiscal year 2006, OOC implemented this recommendation by creating an online feature called, "Fast Facts," which is part of a series of newsletters, bulletins, and tools available on the OOC website. This feature on OOC's website functions as a clearinghouse for safety and health related issues on Capitol Hill. According to OOC officials, the feature is the most visited section on OOC's website and has experienced increasing use in terms of the number of the site hits and downloads.

    Recommendation: We recommend that OOC's Executive Director and General Counsel establish a clearinghouse for sharing best practice information on topics covered by the CAA.

    Agency Affected: Office of Compliance

  4. Status: Closed - Implemented

    Comments: The Office of Compliance, an independent legislative branch agency, administers and enforces various provisions of the Congressional Accountability Act (CAA) related to fair employment and occupational safety and health issues among legislative branch agencies covered by the CAA. OOC has used a variety of approaches to educate both employees and employing offices about their rights and responsibilities under the CAA, including distributing fliers and bulletins, holding briefings and seminars, and redesigning its Web site. In our February 2004 report, we found that OOC's efforts to track and report on its education efforts focused on counting products and activities rather than focusing on results. We recommended that OOC consider using other approaches for its education efforts. Specifically, we recommended that OOC work with the Congress to determine the feasibility of using feedback mechanisms, such as surveys and focus groups, to provide OOC with information on the actual level of awareness among its target populations concerning OOC's programs and activities. OOC officials agreed with this recommendation and, on June 21, 2006, signed a contract with the Congressional Management Foundation to begin a study of the level of awareness among House and Senate member offices and committee staff of their legal rights and responsibilities under the CAA and knowledge of OOC's programs and activities.

    Recommendation: We recommend that OOC's Executive Director and General Counsel work with the Congress to determine the feasibility of using such mechanisms as feedback surveys and focus groups to provide valuable information on the actual level of awareness among target populations concerning OOC's programs and activities.

    Agency Affected: Office of Compliance

  5. Status: Closed - Implemented

    Comments: Ensuring that an organization is focusing on the right activities to effectively achieve its goals is always an important part of good management control. However, focusing on the right activities is especially important in times of economic scarcity, when the benefit of having programs that deliver a maximum impact towards achieving results is particularly critical. The Office of Compliance's (OOC) leadership recognizes the importance of looking for new ways to get information about the Congressional Accountability Act and OOC out to employees. On the basis of its work, GAO determined that ample opportunities exist for OOC to continue progress in this area. Toward this end, OOC sponsored an Organizational Safety and Health Conference on February 10, 2004, which brought together congressional and agency staff involved in health and safety issues from throughout the legislative branch in order to learn about recent thinking and practice in workplace health and safety. An outgrowth of this conference is the Legislative Branch Health and Safety Group, which is open to all interested staff having safety and health responsibilities in the Legislative Branch and allows OOC to share information with the agencies on the progress of periodic inspections and common safety deficiencies discovered during inspections. The group also provides an outlet for educational information on improving safety and health conditions on Capitol Hill. OOC also sponsored a workshop for managers from legislative branch agencies on conflict management and dispute resolution on June 20, 2005, with the general purpose of improving agencies' appreciation for using alternative dispute resolution as a method of solving problems before they become adversarial.

    Recommendation: We recommend that OOC's Executive Director and General Counsel outreach to other groups and forums such as the Senate Administrative Managers-Chief Clerks Steering Committee.

    Agency Affected: Office of Compliance

  6. Status: Closed - Implemented

    Comments: Our February 2004 report on the Office of Compliance (OOC) highlighted for OOC officials the value of thinking about the office's outcomes and determining the right mix of services and activities to achieve its overall goals. We determined that OOC's efforts to educate legislative branch agencies would benefit from a better analysis of the types of complaints that have been made regarding occupational safety and health related issues. OOC management agreed with our recommendation and, in 2005, OOC's General Counsel procured an interactive data processing and tracking system to monitor all violations identified during the biennial inspections. The system enables OOC to track whether particular violations have been abated and the length of time that was required for abatement. Using data from this system, OOC can determine which occupational health and safety violations should be highlighted in its educational material, such as its "Fast Facts" newsletter. OOC routinely e-mails this newsletter, which explains and illustrates different types of violations commonly found during its inspections, to officials throughout the legislative branch.

    Recommendation: We recommend that OOC's Executive Director and General Counsel use data on the number and type of complaints received by OOC to better target education and information distribution efforts.

    Agency Affected: Office of Compliance

  7. Status: Closed - Implemented

    Comments: GAO has previously reported that, as agencies develop information systems and capacities for analysis and evaluation, they discover that having a better understanding of the facts and the relationship between their activities and desired outcomes provides them with a solid foundation for focusing their efforts and improving their performance. GAO reported in February 2004 that the Office of Compliance's (OOC) General Counsel and his staff were exploring ways of taking a more strategic and risk-based approach towards their work, including such decisions as assigning cases, determining the appropriate amount of follow-up required, and informing the selection of particular facilities for its biennial inspections. In a July 7, 2005, memo, OOC's General Counsel reported that his inspection team has developed and implemented a new Risk Assessment Code (RAC), which would be available for use during the 108th Congress inspection cycle. The RAC system enables the inspection team to determine the risks to employee health and safety by classifying the severity and probability of occurrence of the hazards identified. The system brings OOC's risk assessment approach into conformity with general industry practices. Further, the system will enable the General Counsel and his inspection team to take a more strategic and risk-based approach towards their work.

    Recommendation: We recommend that OOC's Executive Director and General Counsel develop capacity to use safety and health data to facilitate risk-based decision making.

    Agency Affected: Office of Compliance

  8. Status: Closed - Implemented

    Comments: In our February 2004 review of the Office of Compliance (OOC), we recommended that OOC's Board of Directors build trust among its stakeholders and clients by developing Congressional and agency protocols to foster an understanding of OOC's policies and procedures. Based on its experience of working with its stakeholders, OOC officials concluded that formal protocols are unrealistic because of OOC's need to adapt to different factors, including maintaining the confidentiality of sensitive matters and the availability of resources. To address the intent of this recommendation, OOC has sought to improve relations with its stakeholders by increasing the visibility of its work, opening lines of communication, and seeking more effective ways of collaboration. Specifically, OOC has implemented several initiatives, such as holding quarterly stakeholder meetings on workplace safety and health issues, conducting opening conferences with employing offices and other involved parties at the beginning of OOC investigations, and informing stakeholders on a regular basis about changes to OOC's safety and health inspection process. Through these efforts, OOC officials report improvements in relationships with stakeholders who have begun view the office as a source for technical assistance on such topics as dispute resolution procedures and workplace safety and health issues. OOC officials have stated that by increasing the office's visibility and transparency they have addressed GAO's recommendation that OOC create a basic understanding of its goals, functions, and procedures among their stakeholders.

    Recommendation: Develop congressional protocols, in close consultation with congressional stakeholders, that would document agreements between the Congress and OOC on what congressional stakeholders can expect as the Office carries out its work. Protocols help to ensure that OOC deals with its congressional stakeholders using clearly defined, consistently applied, and transparent policies and procedures. They can also help OOC reach agreement on the best mix of products and services to achieve its mission. It is important to note that consulting with stakeholders is not the same as seeking their acceptance or approval on matters where that would not be appropriate. The purpose of such protocols is to help create a basic understanding of OOC's goals, functions, and procedures; and what OOC will communicate to whom, when, and how, without compromising the independence the Congress gave OOC to enforce the CAA.

    Agency Affected: Office of Compliance

  9. Status: Closed - Implemented

    Comments: Our February 2004 report on the Office of Compliance (OOC), which conducts inspections to ensure compliance with health, safety, and disability access standards, stated that effective communication and coordination with stakeholders, such as legislative agencies, is essential for organizations to operate effectively, manage risks, and achieve results. Our review found that, according to several officials at legislative branch agencies, communications and interactions among OOC and their agencies have not been good. They said, for example, that OOC failed to always follow its own rules and procedures when conducting investigations of health and safety complaints. As such, we recommended that OOC develop agency protocols, in cooperation with legislative agencies, that would clarify and clearly communicate the procedures OOC will follow when interacting with agencies while carrying out its work. As of June 2006, OOC implemented our recommendation by establishing protocols for its key stakeholders. For instance, following completion of recent Occupational Safety and Health (OSH) and Americans with Disabilities Act (ADA) public access inspections, OOC reached an agreement with legislative branch offices to modify inspection procedures and scheduling to accommodate the needs of legislative branch offices. Additionally, OOC has issued templates governing inspection opening conferences and reports of inspection findings. OOC has also implemented procedures governing biennial inspections that set forth overall inspections schedules and monthly revisions on its website. Finally, the OOC has staggered inspections in order to issue more frequent and timely reports of hazard findings to meet the needs of legislative branch offices.

    Recommendation: Develop agency protocols, in cooperation with legislative agencies, that would clarify and clearly communicate the procedures OOC will follow when interacting with agencies while carrying out its work.

    Agency Affected: Office of Compliance

  10. Status: Closed - Implemented

    Comments: In our February 2004 review of the Office of Compliance (OOC), we recommended that OOC's Board of Directors carefully pilot its Congressional and agency protocols before they are fully implemented to ensure that they effectively communicate the procedures OOC will follow when interacting with agencies. In response, OOC developed Congressional protocols in 2008 and 2009 to inform its stakeholders about OOC's processes and procedures. OOC's Executive Director stated that based on their practical experience of interacting with OOC's external stakeholders over a number of years, they determined that using formal protocols would be unrealistic. Because of the need for OOC to adapt to different situations and take into account numerous factors, including the need for confidentiality and the availability of resources, OOC has decided not to pilot these protocols. OOC officials have sought to address the intent of the recommendation by improving relations with its stakeholders through increasing the visibility of its work, opening lines of communication, and seeking more effective ways to collaborate. Specifically, OOC has implemented several initiatives, such as holding quarterly meetings with stakeholders about safety, health and accessibility issues in the workplace, conducting opening conferences for employing offices and other involved parties at the beginning of an investigation, and informing stakeholders on a regular basis about changes to OOC's safety and health inspection process.

    Recommendation: In both cases OOC should carefully pilot the protocols before they are fully implemented so that OOC, the Congress, and legislative agencies can gain valuable experiences in their application and that appropriate adjustments can be made.

    Agency Affected: Office of Compliance

  11. Status: Closed - Not Implemented

    Comments: The Office of Compliance (OOC) has explored the prospect of developing performance measures by using benchmark data from similar federal agencies. After some consideration, OOC officials determined that such a comparative study to develop this benchmark data would drain their minimal resources and decided not to pursue fulfilling this recommendation. However, OOC officials stated that they would continue to explore improving their use of data in other ways.

    Recommendation: We recommend that OOC's Executive Director and General Counsel identify potential improvements to how the Office measures its activities and performance, including the possibility of using benchmarkdata from federal agencies with similar functions for purposes of comparison and analysis.

    Agency Affected: Office of Compliance

  12. Status: Closed - Implemented

    Comments: We found that leading organizations consistently strive to ensure that their day-to-day activities support their organizational missions and move them closer to accomplishing their strategic goals. As an outgrowth of its strategic planning effort to identify, measure, and manage toward results, in February 2004 we recommended to the Office of Compliance (OOC) that it should enhance its annual report by incorporating elements that would make it a more useful and relied-upon accountability report. OOC officials concurred with our recommendation and, in January 2006, OOC issued its FY 2005 Annual Report, which is organized according to OOC's three strategic goals and describes OOC's performance during FY 2005 on each of its strategic goals. Additionally, the report includes statistics on the use of the office by covered employees, as required by Section 301(h) of the Congressional Accountability Act.

    Recommendation: Building on the strategic planning efforts underway, we recommend that the Board of Directors, Executive Director, and General Counsel of OOC ensure that the planning effort is used as a basis for an augmented and more results-oriented annual report that provides data on the degree to which key goals are being achieved, in addition to meeting important statutory reporting requirements.

    Agency Affected: Office of Compliance

  13. Status: Closed - Implemented

    Comments: GAO reported in its February 2004 report that, before pursuing strategic and modernized system solutions, it is important that organizations first develop a description of what it wants its future IT environment to look like, based on the organization's strategic plan. Office of Compliance (OOC) officials concurred with GAO's recommendation that its planning effort make information technology planning and implementation an integral component of the process. OOC's Information Technology Task Force, created on May 30, 2003, issued a Multi-Year IT Plan with the objective of integrating IT into all aspects of OOC's management decisions. The plan, issued on June 1, 2005, outlines how every IT project should be directly related to a strategy discussed in its strategic plan, annual report or recommendation from GAO's February 2004 report. Additionally, the plan prioritizes IT funding decisions for OOC's FY 2006 budget request, as well as provides OOC with overarching guidance on IT improvements over the next three years.

    Recommendation: Building on the strategic planning efforts underway, we recommend that the Board of Directors, Executive Director, and General Counsel of OOC ensure that the planning effort makes information technology planning and implementation an integral component of the process.

    Agency Affected: Office of Compliance

  14. Status: Closed - Implemented

    Comments: Federal agencies have used performance agreements between senior political and career executives as a tool to define accountability for specific goals, monitor progress, and contribute to performance evaluations. In addition, performance agreements would provide the platform for ongoing dialogue to help ensure that the goals and priorities contained in the Office of Compliance's (OOC) strategic plan are carried out by its top executives and help ensure that the proper alignment among daily operations and activities drive towards the results OOC is striving to achieve. GAO's report recommended, and OOC officials agreed, that performance agreements between the OOC's Board of Directors and OOC's Executive Director and General Counsel would help translate OOC's strategic goals into day-to-day operations and hold these executives accountable for achieving program results. OOC's Board of Directors established performance agreements for its Executive Director and General Counsel, which were approved on December 29, 2004 and June 15, 2005, respectively. These performance agreements will increase the accountability and focus the office's performance on organizational goals contained in OOC's Strategic Plan.

    Recommendation: We recommend that OOC's Board require performance agreements between the Board of Directors andOOC's Executive Director and General Counsel to help translate the Office's strategic goals into day-to-day operations and to hold these executives accountable for achieving program results.

    Agency Affected: Office of Compliance

  15. Status: Closed - Implemented

    Comments: Our February 2004 report on the Office of Compliance (OOC) stated that effective human capital management is an important factor contributing to management control as well as an organization's ability to achieve results. We recommended that OOC's Executive Director and General Counsel establish a modern, effective, and credible performance management system with appropriate safeguards for all OOC employees. OOC should build on the first step of establishing a basic performance management system for employees reporting to the Executive Director by ensuring that all employees, including those who report to the General Counsel, participate in an individual performance management system. In addition, OOC should look for ways to develop a more robust and effective approach to individual performance management by considering key practices employed by leading organizations. According to OOC officials, in response to our recommendation, OOC established a formal performance management system in January 2007 that covers all of its employees. OOC's current performance management system assesses staff against eight performance dimensions with varying levels of performance. OOC management reports that all OOC staff are working under an evaluation system that has a "line of sight" to OOC's Strategic Plan and considered key practices employed by leading organizations in selecting its evaluation process. OGC staff develop their own benchmarks (as well as work plans) for their evaluations in collaboration with their supervisors. At the time of their ratings, moreover, they provide to their supervisor a written assessment of how they have met their goals. Employees who report to the Acting Executive Director also have an opportunity to provide input to their draft evaluations prior to the signing of the final evaluation.

    Recommendation: We recommend that OOC's Executive Director and General Counsel establish a modern, effective, and credible performance management system with appropriate safeguards for all OOC employees. OOC should build on the first step of establishing a basic performance management system for employees reporting to the Executive Director by ensuring that all employees, including those who report to the General Counsel, participate in an individual performance management system. In addition, OOC should look for ways to develop a more robust and effective approach to individual performance management byconsidering key practices employed by leading organizations.

    Agency Affected: Office of Compliance

  16. Status: Closed - Not Implemented

    Comments: Our February 2004 report on the Office of Compliance (OOC) stated that performance management systems can create a "line of sight" showing how team, unit, and individual performance can contribute to overall organizational results. We found that while OOC established a performance management system for most of its staff in 2002, some individuals continue to work without any formal system to set goals, establish individual expectations, provide feedback, and evaluate their performance. As such, we recommended that OOC actively involve all of its employees in establishing a modern, effective, and credible performance management system with appropriate safeguards, whether it entails the revision and expansion of its existing performance management system or the creation of an entirely new initiative. In discussions with OCC officials, we determined that OOC's interpretation of this recommendation does not conform with the intention of GAO's recommendation. OOC's Executive Director stated that OOC's performance management system enables employees to discuss their performance expectations with their supervisors. Although holding expectation conversations are an important component of a performance management system, the recommendation was intended to provide OOC employees with the opportunity to give input into the development of OOC's performance management system -- not simply provide input into their performance expectations. As such, this recommendation has not be implemented by OOC.

    Recommendation: We recommend that OOC's Executive Director and General Counsel actively involve all OOC's employees in this process, whether it entails the revision and expansion of its existing performance management system or the creation of an entirely new initiative.

    Agency Affected: Office of Compliance

  17. Status: Closed - Implemented

    Comments: Effective management control requires that an organization establish its organizational objectives in the form of a set of defined mission goals and objectives. As GAO has found by looking at leading results-oriented organizations, the production of the actual strategic planning document is one of the least important parts of the planning process. Leading results-oriented organizations understand that strategic planning is not a static or occasional event, but rather a dynamic and inclusive process. By working with and actively engaging key congressional and other stakeholders in its planning effort, the Office of Compliance (OOC) can better justify to stakeholders its current budget and staff resources allocation and program efforts. GAO's report recommended and OOC officials concurred that the office's planning effort be developed with extensive collaboration and input from key congressional and agency stakeholders. On February 17, 2004, OOC transmitted its draft Strategic Plan to 46 key Congressional and agency stakeholders. By April 2004, OOC issued the Strategic Plan after meeting with all interested stakeholders. To ensure that the interaction with and feedback from stakeholders are a recurring process, OOC officials will initiate another series of stakeholder consultations as part of the adoption of the next Strategic Plan.

    Recommendation: Building on the strategic planning efforts underway, we recommend that the Board of Directors, Executive Director, and General Counsel of OOC ensure that the planning effort is developed with extensive collaboration and input from key congressional and agency stakeholders to ensure that there is areasonable and appropriate degree of agreement concerning OOC's overall direction and that its programs are effectively coordinated with other efforts. To be most effective, this stakeholder and agency input should be part of an ongoing dialogue to ensure goals, objectives, and strategies are adjusted as warranted.

    Agency Affected: Office of Compliance

  18. Status: Closed - Implemented

    Comments: Our February 2004 report on the Office of Compliance (OOC) discussed that results-oriented organizations we have studied were successful in measuring their performance by developing performance measures that were tied to program goals and demonstrated the degree to which the desired results were achieved. As such, we recommended OOC management build on its current strategic planning efforts by ensuring that their efforts include performance measures that are liked to the strategic plan and resulting annual work plans. According to OOC officials, it has implemented this recommendation by completing its second strategic plan shortly after the beginning of fiscal year 2007. The strategic plan, which spans fiscal years 2007 through 2009, establishes four strategic goals, with strategic initiatives developed for each goal. Performance measures used to track progress toward each goal are included in the strategic plan and are intrinsically linked to the strategic plan. Staff work plans, which are directly derived from the strategic plan, are individually devised to support the goals and initiatives outlined in the FY 2007-2009 Strategic Plan. Work plans, developed in line-of-sight with the OOC's strategic plan, are updated annually.

    Recommendation: Building on the strategic planning efforts underway, we recommend that the Board of Directors, Executive Director, and General Counsel of OOC ensure that the planning effort includes performance measures that are linked to the strategic plan and resulting annual work plans.

    Agency Affected: Office of Compliance

  19. Status: Closed - Implemented

    Comments: We reported in our February 2004 review of the Office of Compliance (OOC) that leading results-oriented organizations understand that strategic planning is a dynamic and inclusive process. By working with and actively engaging key congressional and other stakeholders in its planning effort, OOC can better justify to stakeholders its current budget and allocation of staff resources. Additionally, we reported that OOC's strategic planning needs to include the development of results-oriented performance measures. As such, we recommended that the Board of Directors, Executive Director, and General Counsel of the OOC ensure that that its strategic planning effort becomes the basis for OOC's budget and staff requests and developing and implementing program efforts and for assessing the contributions of those efforts to results. As of June 2007, OOC had implemented our recommendation by outlining its goals, strategic initiatives, and short- and long-term measures in its FY2007-2009 Strategic Plan. OOC has used this plan to support its FY2009 budget request by linking OOC's goals and measures to OOC's rationale for changes in its program funding. OOC officials also reported that they will continue tracking the effectiveness of OOC's programs using the performance measures outlined in its Strategic Plan and continue to report on OOC's performance in future reports and budget justifications.

    Recommendation: Building on the strategic planning efforts underway, we recommend that the Board of Directors, Executive Director, and General Counsel of OOC ensure that the planning effort becomes the basis for OOC's budget and staff requests and developing and implementing program efforts and for assessing the contributions of those efforts to results.

    Agency Affected: Office of Compliance

  20. Status: Closed - Implemented

    Comments: Our February 2004 report on the Office of Compliance (OOC) stated that open and effective coordination with legislative agencies and other stakeholders including employee groups is another critical component of an effective communications strategy at OOC. We reported that several legislative branch agency officials stated that OOC was not always consistent nor did it follow its own processes and procedures when conducting investigations of occupational safety and health-related complaints. We also reported that OOC's procedure manual for handling safety and health-related complaints did not provide a clear, complete, and up-to-date source of OOC's policies and procedures for handling such complaints. In addition, the manual did not provide clear time frames on when OOC would communicate to agencies during this process. For example, the manual has not been updated since 1997 and does not contain any specific language on OOC's policy of providing agencies with opening conference as described to us by OOC's General Counsel. Therefore, we recommended that OOC's Executive Director and General Counsel review and revise OOC's case handling policies and procedures, such as OOC's procedure manual for handling safety and health-related complaints, and ensure that procedures are effectively communicated to appropriate legislative branch agency officials. In January 2013, the OOC stated that given prior funding cuts and the likelihood that these resources would not be restored in the near future it was unclear when the manuals would be revised. However, OOC's General Counsel outlined several efforts over the past three years to communicate to legislative branch agencies OOC?s processes and procedures for conducting investigations and handling complaints. These efforts include meeting with agency officials and congressional oversight committee staff to discuss in detail the OOC's processes for inspections and case handling. In addition, OOC made it a standard operating procedure to conduct "opening" and "closing" conferences with agency officials at the beginning and conclusion of workplace inspections. OCC also instituted daily close-out meetings between OOC inspectors and agency officials and union representative to review daily findings. These actions represent a consistent effort on behalf of OCC officials to communicate their inspection process and case handling policies and procedures. Although OOC officials currently do not have the resources to revise the manuals, collectively these actions implement the intent of the recommendation to encourage OOC to effectively communicate the inspection and complaint processes to the legislative branch agencies.

    Recommendation: We also recommend that the Executive Director and the General Counsel review and revise OOC's case handling policies and procedures, such as OOC's procedure manual for handling safety and health-related complaints, and ensure that they are effectively communicated to appropriate legislative agency officials.

    Agency Affected: Office of Compliance

 

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