	Background

Under MD-715, federal agencies are to identify and eliminate barriers that  impede free and open competition in their workplaces. EEOC defines a  barrier as an agency policy, principle, or practice that limits or tends to  limit employment opportunities for members of a particular gender, race,  ethnic background, or disability status. According to EEOC’s instructions,  many employment barriers are built into the organizational and  operational structures of an agency and are embedded in the day-to-day  procedures and practices of the agency. In its oversight role under MD- 715, EEOC provides instructions to agencies on how to complete their  barrier analyses and offers other informal assistance. Based on agency  submissions of MD-715 reports, EEOC provides assessments of agency  progress in its Annual Report on the Federal Workforce, feedback letters  addressed to individual agencies, and the EEO Program Compliance  Assessment (EPCA). DHS Has Generally Relied on Workforce Data and Has Not Regularly Included Employee Input in Identifying Potential Barriers

According to EEOC’s MD-715 instructions, barrier identification is a two- part process. First, using a variety of sources, an agency is to identify  triggers. Second, the agency is to investigate and pinpoint actual barriers  and their causes. According to DHS’s MD-715 reports, DHS  identified 13 of the 14 triggers based on its analysis of participation rates  contained in the workforce data tables. Obtaining the  input of employees in identifying triggers would provide a frontline  perspective on where potential barriers exist. Employee input can come  from a number of sources including employee groups, exit interviews, and  employee surveys. Without employee input on DHS personnel  policies and practices, DHS is missing opportunities to identify potential  barriers. 2. Overreliance on noncompetitive hiring authorities. 3. 4. Nondiverse interview panels; specifically, interview panels that did not  reflect the diversity of applicants. DHS Modified Nearly All Target Completion Dates on Planned Actions to Address Barriers

Our analysis of DHS’s MD-715 2007 and 2008 reports showed DHS  articulated 12 different planned activities to address the identified barriers,  including 1 new planned activity in 2008. According to  CRCL officials, although it has not completed any planned activities to  address identified barriers, DHS has completed some planned activities  identified in fiscal years 2007 and 2008 related to improving its EEO  program. According to DHS officials, its MD-715  reports and Human Capital Strategic Plan represent the extent of DHS  project plans and milestones for completing planned activities. These  documents include only the anticipated outcome, not the essential  activities needed to achieve the outcome. For example, in DHS’s 2007 and  2008 MD-715 reports, CRCL identifies an applicant flow tool to analyze  recruitment and hiring results as a planned activity to address the barrier  of overreliance on the use of the Internet to recruit applicants. In order to help ensure that agency programs are effectively and efficiently  implemented, it is important that agencies implement effective internal  control activities. We have previously reported that it is essential  to establish and track implementation goals and establish a timeline to  pinpoint performance shortfalls and gaps and suggest midcourse  corrections. Identifying the critical phases of each planned  activity necessary to achieve the intended outcome with interim  milestones could help DHS ensure that its efforts are moving forward and  manage any needed midcourse corrections, while minimizing  modifications of target completion dates. DHS Reports Using a Variety of Means to Oversee and Support Components

According to MD-715 and its implementing guidance, a parent agency is to  ensure that its components implement the provisions of MD-715 and make  a good faith effort to identify and remove barriers to equality of  opportunity in the workplace. Because CRCL does not regularly include employee  input from available sources, such as the FHCS and DHS’s internal  employee survey, it is missing opportunities to identify potential barriers  to EEO.
Why GAO Did This Study

Under MD-715, federal agencies are to identify and eliminate barriers that impede free and open competition in their workplaces. EEOC defines a barrier as an agency policy, principle, or practice that limits or tends to limit employment opportunities for members of a particular gender, race, ethnic background, or disability status. According to EEOC's instructions, many employment barriers are built into the organizational and operational structures of an agency and are embedded in the day-to-day procedures and practices of the agency. In its oversight role under MD-715, EEOC provides instructions to agencies on how to complete their barrier analyses and offers other informal assistance. Based on agency submissions of MD-715 reports, EEOC provides assessments of agency progress in its Annual Report on the Federal Workforce, feedback letters addressed to individual agencies, and the EEO Program Compliance Assessment (EPCA).

What GAO Found

DHS has generally relied on workforce data and has not regularly included employee input from available sources to identify "triggers," the term EEOC uses for indicators of potential barriers. GAO's analysis of DHS's MD-715 reports showed that DHS generally relied on workforce data to identify 13 of 15 triggers, such as promotion and separation rates. According to EEOC, in addition to workforce data, agencies are to regularly consult a variety of sources, such as exit interviews, employee groups, and employee surveys, to identify triggers. Involving employees helps to incorporate insights about operations from a frontline perspective in determining where potential barriers exist. DHS does not consider employee input from such sources as employee groups, exit interviews, and employee surveys in conducting its MD-715 analysis. Data from the governmentwide employee survey and DHS's internal employee survey are available, but DHS does not use these data to identify triggers. By not considering employee input on DHS personnel policies and practices, DHS is missing opportunities to identify potential barriers. Once a trigger is revealed, agencies are to investigate and pinpoint actual barriers and their causes. In 2007, through its departmentwide barrier analysis, DHS identified four barriers: (1) overreliance on the Internet to recruit applicants, (2) overreliance on noncompetitive hiring authorities, (3) lack of recruitment initiatives that were directed at Hispanics in several components, and (4) nondiverse interview panels. GAO's analysis of DHS's 2007 and 2008 MD-715 reports showed that DHS has articulated planned activities to address identified barriers, has modified nearly all of its original target completion dates by a range of 12 to 21 months, and has not completed any planned activities; although officials reported completing other activities in fiscal year 2007 and 2008 associated with its EEO program. Nearly half of the planned activities involve collaboration between the civil rights and human capital offices. DHS said that it modified the dates because of staffing shortages. In order to ensure that agency programs are effectively and efficiently implemented, it is important for agencies to implement internal control activities, such as establishing and tracking implementation goals with timelines. This allows agencies to pinpoint performance shortfalls and gaps and suggest midcourse corrections. DHS has not developed project plans with milestones beyond what is included in its MD-715 report and its Human Capital Strategic Plan. These documents include only the anticipated outcomes and target completion dates, not the essential activities needed to achieve the outcome. Identifying the critical phases of each planned activity necessary to achieve the intended outcome with interim milestones could help DHS ensure that its efforts are moving forward and manage any needed midcourse corrections, while minimizing modification of target dates. DHS uses a variety of means to oversee and support components, including providing written feedback on draft reports to components that are required to prepare their own MD-715 reports, conducting program audits, and convening a council of EEO directors from each of the components.