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. Examples of the action plans that focus on demonstrated commitment  from agency leadership include:    Develop a comprehensive training program for Civil Rights Service    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 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. 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. 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. 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. The following seven practices are adapted from  generally accepted project management practices:  1. Identifying measurable performance goals;  2. Consulting stakeholders; and  7. 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. Restructure Civil Rights Operations. 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. 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. Identified the Person(s) Accountable for 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. 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 practice identifies and documents interim milestones and checkpoints to gauge the  completion of the project.
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.