Total integration of equal employment opportunity (EEO) into every aspect of human resource management policy and practice in the selection, placement, training, and advancement of civilian employees of the federal government is vital to creating and maintaining a federal workforce that is truly reflective of our nation's diverse citizenry. In order to accomplish this integration, there must be effective collaboration among federal supervisors, managers, personnel professionals, civil rights professionals, and equal opportunity professionals.
EEO and Affirmative Employment Reporting. "Strong EEO and Affirmative Action plans play vital roles in the management of diversity. They are stepping stones to valuing diversity wherein differences are identified and an atmosphere is created that promotes respect for these differences as well as ways to benefit from them."(1) However, current EEO and affirmative employment (AE) reporting requirements are fragmented. While agencies must submit data to the Office of Personnel Management (OPM) Central Personnel Data File (CPDF), similar data must be submitted to the Equal Employment Opportunity Commission (EEOC).
The Civil Service Reform Act of 1978 created the Federal Equal Opportunity Recruitment Program (FEORP), which requires agencies to conduct affirmative recruitment for those occupations and grades in which women and minorities are underrepresented. The act assigned to OPM the responsibility for assisting agencies in their affirmative recruitment efforts and for overseeing FEORP.(2)
Executive Order 12067 (June 30, 1978) assigned to EEOC responsibility for providing coherence and direction to the government's EEO efforts. It also provided for standardized data collection procedures.
EEOC requires federal agencies to submit multi-year AE plans and annual accomplishment reports to evaluate the representation of minorities, females, and disabled persons in the federal workforce. In addition, OPM requires agencies to submit FEORP plans and reports, as well as disabled veterans affirmative action program plans and reports. There needs to be one comprehensive assessment of agency EEO/AE goals, objectives, and accomplishments.
Agencies must integrate EEO/AE into their overall strategic business plans, which are developed, evaluated, and monitored by management. Agencies must build their plans around barrier analysis, develop goals, implement strategies to achieve these goals in a specified time frame, and hold managers and supervisors accountable for results.
Cross-Training. Cross-training is the first step to creating a competent federal human resource management team. Personnel professionals must understand and adhere to basic EEO and civil rights guidelines in order to ensure that personnel functions and actions are fair and equitable for all employees and applicants. Likewise, EEO and civil rights professionals must understand and adhere to the basic personnel guidelines.
The roles and responsibilities of EEOC and OPM present an opportunity for them to work together to provide leadership and training necessary to integrate EEO into every aspect of human resource management policy and practice. These two agencies must make a concentrated effort to ensure ongoing communications and understanding of EEO and AE efforts to achieve a diverse, competent, and productive federal work force. They must provide joint leadership to EEO, civil rights, and personnel professionals to create, develop, review, and improve effective ongoing governmentwide efforts.
Need for Change
It is imperative that EEOC and OPM collaborate to jointly provide the necessary leadership and cross-training to ensure an effective approach to and outcome of federal human resource management efforts. These efforts must include effective EEO and AE initiatives.
EEO/AE plans and accomplishment reports foster agency commitment to and awareness of EEO/AE efforts within organizations and guide the way to increased employment opportunities for qualified women, minorities, and disabled persons.
However, there needs to be one comprehensive, automated EEO/AE report for federal agencies. An inordinate amount of resources are devoted to preparing duplicative reports. More importantly, treating the four groups (women, minorities, disabled persons, and disabled veterans) separately is contradictory to the vital mission of accomplishing overall workforce diversity and streamlining government functions.
Although each agency must be personally responsible for internal EEO/AE goals and accomplishments, EEOC must continue to fulfill its responsibility under Executive Order 12067--to provide coherence and direction to the government's EEO efforts. EEOC must seek out, identify, recognize, and reward best EEO and AE practices in federal agencies. EEOC must perpetuate those best practices throughout the federal government.
In addition, OPM must ensure that the CPDF can generate necessary data and that the capabilities of the CPDF are fully used. For example, the collection of minority college and university information in the CPDF is essential for conducting affirmative employment analysis.(3)
1. Establish an Interagency Equal Employment Opportunity and Affirmative Employment Steering Group under the joint chair of EEOC and OPM. (2)
The President, by memorandum, should direct the Chair of EEOC and the director of OPM to establish an Interagency Equal Employment Opportunity and Affirmative Employment Steering Group. The purpose of the group should be to:
--- provide to human resource professionals governmentwide equal opportunity and affirmative employment leadership, communication, and coordination in workforce diversity planning;
--- identify and perpetuate best EEO/AE practices throughout the federal government; and
--- aid, among equal opportunity, civil rights, and personnel professionals, communication that focuses on EEO/AE concerns and issues and shares successful initiatives.
This steering group will comprise directors of equal employment opportunity, personnel, and civil rights from a cross- section of federal agencies, including small agencies. The committee will convene monthly for the first 6 months. After that, the EEOC chair and OPM director will establish the appropriate schedule for meetings, conferences, and seminars.
2. Require appropriate cross-training for human resource management professionals. (1)
The first and most important purpose of the EEO/AE Steering Group should be to advocate effective cross-training and rotational assignments for EEO, civil rights, and personnel professionals. Agency heads should be required to ensure that federal EEO and civil rights professionals receive cross-training and rotational assignments in federal personnel management before being promoted to supervisory and management positions. They should also ensure that personnel professionals receive cross-training and rotational assignments in federal EEO and civil rights before they are promoted to supervisory and management positions. EEOC and OPM should jointly identify the appropriate core training, as well as the time frame in which the training should be obtained, to foster human resource management competence throughout federal agencies.
Collaboration between EEO, civil rights, and personnel professionals will assist agencies in understanding, evaluating, and preventing practices that give rise to EEO complaints.
3. Combine all equal opportunity and affirmative employment reports into one comprehensive assessment of the total workforce EEO/AE data. (2)
By memorandum, the President should direct the Chair of EEOC, in coordination with the director of OPM, to blend the reporting requirements for agencies to compile one comprehensive assessment of their equal employment opportunity and affirmative employment efforts, including specific actions needed to eradicate barriers and increase representation of minorities, women, and disabled persons at all levels, including middle and upper management levels. EEOC and OPM should conduct a thorough examination of all current EEO/AE reporting requirements to ensure the appropriateness and effectiveness of the new comprehensive agency assessment report. These changes should be effective with the fiscal year 1995 submission requirements.
4. Modify the Central Personnel Data File to enable total automation of the EEO/AE data reporting requirements. (2)
By memorandum, the President should direct the director of OPM, in coordination with the Chair of EEOC and a working group of agency officials, to ensure that the necessary data resources, including any appropriate changes to the CPDF, are used to generate all data needed to meet EEO/AE reporting requirements. All current EEO/AE data reporting requirements should be examined for necessity and value. This examination of requirements and subsequent redesign of the CPDF should begin immediately and should be completed during fiscal year 1995.
Implementation of these actions will decrease duplicated efforts and redundancy within and across federal agencies. It will reduce, simplify, and automate the reporting requirements, while maintaining the requirement for agencies to submit the necessary information. There will be a substantial reduction in the administrative costs of EEO and AE programs. This will be tremendously beneficial to the overall federal EEO/AE efforts since agencies will be able to spend more time and effort focusing on results rather than on paper processes.
In addition, implementation of these actions will foster coordinated, governmentwide commitment to creating, implementing, and accomplishing equal opportunity and affirmative employment goals to create a federal workforce that is reflective of the American citizenry.
Implementation of these actions will require ongoing commitment and coordination between EEOC and OPM. This partnership is critical to the accomplishment of a competent, productive, and diverse federal workforce.(4)
1. The National Treasury Employees Union, "Strategic Plan for Agency Diversity Management," Washington, D.C., p. 3.
2. U.S. General Accounting Office, Federal Workforce: Continuing Need for Federal Affirmative Employment, GAO/GGD-92-27BR (Washington, D.C.: U.S. General Accounting Office, November 1991), p. 1.
3. Personal Interview with Dick Whitford, Acting Assistant Director, Affirmative Recruitment and Employment, Office of Personnel Management, Washington, D.C., August 1993.
4. The following individuals made significant contributions to this section: Nilda I. Aponte, Director, Civil Rights Office, General Accounting Office; Ronnie Blumenthal, Director, Office of Federal Operations, Equal Employment Opportunity Commission (EEOC); Barbara Burdge, Leader, Career Opportunities, Department of Health and Human Services; Arthur E. Cizek, Chief, Compliance Division, Department of Commerce; Robert Franco, Acting Director, Office of Advocacy and Enterprise, Department of Agriculture; Dr. Yvonne Blanchard Freeman, Associate Administrator, Equal Opportunity, National Aeronautics and Space Administration (NASA); Kathleen M. Gause, Head of Affirmative Employment, Department of the Navy; Oceola Hall, Director, Discrimination Complaints, NASA; Harriett G. Jenkins, Director, Office of Senate Fair Employment Practices; Fran Lopes, former Assistant Director, Affirmative Recruiting and Employment; Office of Personnel Management (OPM); Gerald R. Lucas, Director of Civil Rights, Department of Commerce; Alfonso J. Ludi, Special Assistant to the Associate Administrator, NASA; Lynne McGlew, Executive Assistant to Director of Civil Rights, Department of Labor; Constance Berry Newman (Former Director of OPM), Under Secretary, Smithsonian Institution; Valerie Olsen, Counsellor/Mediator, Office of Senate Fair Employment Practices; Luther L. Santiful, Director, EEO, Department of the Army; Jim Troy, Director, Office of Program Operations; EEOC; Dick Whitford, Acting Assistant Director, Affirmative Recruiting and Employment, OPM; and Grant B. Williams, Jr., Director, Civil Rights, General Services Administration.
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