Coast Guard: Civil Rights Directorate Can Enhance Workforce Restructuring Efforts

The United States Coast Guard's (USCG) Civil Rights Directorate's (CRD) principal functions are to provide Equal Opportunity (EO) services to its approximately 50,000 active duty military, and Equal Employment Opportunity (EEO) services to its 8,000 civilian employees. We reported in April 2010 that CRD had taken action to help resolve its management challenges, such as dissatisfaction among USCG personnel and to improve its civil rights program, primarily guided by recommendations resulting from a 2009 Booz Allen Hamilton (BAH) study that CRD commissioned. Among these recommendations were that CRD centralize its organizational structure and institute a full-time equal employment workforce, which BAH expected would help significantly enhance program components, such as organizational cohesion. According to CRD officials, they implemented these recommendations in July 2009, and at the time of our last review continued to build on the organizational restructuring. In response to BAH recommendations, in July 2009 CRD: (1) Reorganized its field operations to deliver civil rights services by specialists through a centrally managed national structure divided into three national regions headed by regional managers. Regions are further divided into 14 subordinate zones. (2) Staffed the civil rights regions and zones with full-time field Civil Rights Service Providers (CRSPs) and discontinued the use of part-time (collateral duty) personnel. (3) Established a centralized reporting structure for all CRSPs to report to three regional civil rights managers who in turn report directly to CRD headquarters, rather than the previous practice of reporting to a local command structure. CRD relies on a blended workforce of full-time military and civilian CRSPs to provide USCG personnel with EO/EEO counseling, complaint investigation/processing, and EO/EEO training. CRD uses the same discrimination complaint processing procedures for military personnel as it does for civilians, except, unlike civilian employees, military personnel do not have standing at the Equal Employment Opportunity Commission (EEOC). However, military personnel may appeal their complaints to the Department of Homeland Security. Because of the importance of the role that CRSPs have in implementing CRD's civil rights program, and congressional interest in how the current structure enables CRD to meet the needs of USGC personnel, Congress requested that we determine what CRD has done to help ensure that the reorganization of its workforce improves civil rights services. In particular, we examined workforce structure changes related to: (1) The reorganization of field operations (e.g., use of full-time staff, rather than collateral-duty staff, geographic distribution of USCG personnel, staff workload, and ratios of civil rights service providers to USCG personnel in different regions and zones where USCG personnel serve), and (2) CRSP's qualifications (i.e., work experience, educational requirements, performance standards and qualifications, and training).

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