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US Department of Labor
Office of Audit

OFCCP

CAN DO MORE ENFORCEMENT AND

HAVE GREATER IMPACT

USING FEWER DOLLARS

REPORT TO THE DEPUTY UNDER SECRETARY

FOR EMPLOYMENT STANDARDS

ON THE RESULTS OF OIG SURVEY WORK IN

THE OFFICE OF FEDERAL CONTRACT COMPLIANCE PROGRAMS

Report Number.
Date Issued

03-3-204-04-410
SEP 30 1985

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3. COMMENTS OF DEPUTY UNDER SECRETARY ON DRAFT REPORT

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EXECUTIVE SUMMARY

OFCCP could achieve a greater impact, using fewer dollars, by correcting internal structural and operating weaknesses, by improving its enforcement procecures, and by evaluating the results of agency activities. wie noted that many of the defects created or magnified by the 1978 consolidation continue to exist today. In 1978, responsibility for contract compliance was removed from the eleven major Federal departments and centralized in OFCCP. The new centralized structure preserved most of the eleven departmental program hierarchies. This caused structural imbalances which continue to exist today, causing inefficient operations as identified in this report. In addition, certain other factors have contributed to some of the problems we identified and these are noted throughout the report.

FINDINGS, CONCLUSIONS AND RECOMMENDATIONS

OFCCP enforces statutes and Executive Orders prohibiting employment discrimination by Federal contractors on the basis of race, sex, religion, national origin, handicapped or veterans status. Our survey work revealed that OFCCP has had limited effectiveness in carrying out its mandated mission and functions because:

I. its organization and structure limit productivity and

prevent the efficient use of resources;

II. enforcement procedures prevent complete, timely and

economical enforcement; and

III.

the agency does not attempt to regularly measure or
report on the results of its activities to determine what
impact, if any, they have.

1. ORGANIZATION AND STRUCTURE (See pages 7 to 28)

Maximizing program resources is one of the goals and objectives OFCCP has established during the last several fiscal years. Our survey, however, found that OFCCP has organized and structured itself with: A. EXCESS OVERHEAD - A majority of its budget is used to support overhead

stait (managers, supervisors, technical advisors and clerks) rather than enforcement caseworkers.

B.

LARGE NUMBERS OF STAFF AT HIGH GRADES
and regional staff are at high grades.

Large percentages of national

c.

INEFFICIENT FIELD STRUCTURE - In small regions costly regional
superstructures oversee the work of few employees or offices.

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III.

PROGRAM RESULTS (See pages 44 to 46)

Establishing and maintaining program objectives, standards and procedures which focus on the achievement of results is another of the goals that OFCCP has established during the last several fiscal years. However, OFCCP does not attempt to regularly (at least annually) measure or report on the results obtained with program funds. We noted:

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NO SYSTEM IS IN FLACE TO EVALUATE PROGRAM RESULTS OFCCP has not adopted recommendations to establish a mechanism for evaluating program results. Moreover, agency managers have not obtained the necessary data (or access to it), or developed the criteria needed for an objective and periodic evaluation of program results.

C

STAFF PRODUCTIVITY STATISTICS ARE IMPROPERLY USED TO IMELY POSITIVE PROGRAM RESULTS In the absence of statistics showing program results, agency managers have reported staff productivity statistics, the implication being that staff productivity will have some positive effect on the status of protected groups among Federal contractors.

EXPECTED RESULTS ARE INCREASED EMPLOYMENT AND ADVANCEMENT OPPORTUNITIES FOR PROTECTED GROUPS AMONG FEDERAL CONTRACTORS WHERE THEIR UTILIZATION IS DEFICIENT The true results indicators for OFCCP are reduced discrimination and increased affirmative action which produce the prompt achievement of full and equal employment opportunity for protected groups among Federal contractors.

The lack of data, methodology and criteria for evaluating program results leaves the Congress, the Executive Branch and the public uninformed about the usefulness of past, present and future expenditures for OFCCP.

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ÄIDITER COMMENTS

At an exit conference held in May 1985, and subsequently in a written response dated September 13, 1985, the Deputy Under Secretary for Employment Standards generally concurred with our findings and recommendations contained in sections I and II but pointed out that she had made a policy decision to resolve many of the staffing and organizational problems through attrition rather than a reduction in force. With respect to our findings and recommendations in section III, the Deputy Under Secretary's written comments stated that management shared our concern that they should know the impact of the OFCCP program, and that they are looking for new ways to measure program results.

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