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.

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.

Status Legend:

Review Pending-GAO has not yet assessed implementation status.

Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.

Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.

Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.

• Review Pending
• Open
• Closed - implemented
• Closed - not implemented

Recommendations for Executive Action

Recommendation: The Secretary of the Department of Homeland Security should direct the Commandant of the Coast Guard to, 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.

Agency Affected: Department of Homeland Security

Status: Open

Comments: Coast Guard's Civil Rights Directorate (CRD) provided updated documentation in July 2011 that they reorganized the twenty-nine action plans to twelve. GAO will assess CRD's documentation of internal controls against federal internal control standards.

Recommendation: The Secretary of the Department of Homeland Security should direct the Commandant of the Coast Guard to establish measurable performance goals for the action plans to support the management decision as to the completion status of the action plans.

Agency Affected: Department of Homeland Security

Status: Open

Comments: Coast Guard's Civil Rights Directorate (CRD) provided updated documentation in July 2011 that they reorganized the twenty-nine action plans to twelve. CRD also provided performance goals for the twelve action plans. GAO is will assess the measurable objectives against which actual achievements can be compared.

Recommendation: The Secretary of the Department of Homeland Security should direct the Commandant of the Coast Guard to define an evaluation plan for each action plan to assess the degree to which the plan yielded the intended outcomes.

Agency Affected: Department of Homeland Security

Status: Open

Comments: Coast Guard's Civil Rights Directorate (CRD) provided updated documentation in July 2011 that they reorganized the twenty-nine action plans to twelve. CRD also provided an evaluation plan for each of the action plans.GAO will assess CRD's plans to know if they successfully completed the action plans.