oversight

Report 2005-002- AMR - The EEOC's National Contact Center: An Evaluation of its Impacts

Published by the Equal Employment Opportunity Commission, Office of Inspector General on 2006-07-01.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

I. INTRODUCTION
Background

The Equal Employment Opportunity Commission (EEOC) established a National Contact Center
(NCC) to accomplish three objectives: upgrade its customer service based on 21st Century
technology, improve human capital effectiveness, and deliver accurate and consistent service to
its customers. In February 2003, the National Academy of Public Administration (NAPA)
submitted a report recommending, among other things, that the EEOC establish a national call
center. In June 2003, an internal EEOC work group completed a review of how the EEOC
handles calls and issued a report that recommended implementation of a contact center - the
Assessment of a National Contact Center Solution for EEOC (2003 Assessment Report).

2003 Assessment Report Conclusions and Proposed Solution. The 2003 Assessment Report
concluded that implementing a contact center would be instrumental in resolving concerns about
system capacity to effectively handle unsolicited calls and in ensuring consistent and accurate
customer service across all EEOC offices. A contact center was seen as an option that would
benefit all EEOC offices rather than hiring staff, which would benefit only a few offices. In
addition, a contact center addresses requirements in the President's Management Agenda and the
E-Government Act of 2002.

NCC Contract. In September 2004, the EEOC contracted with NCS Pearson, Inc. (Pearson) to
develop, implement, and operate the NCC as a two-year pilot project, with an option to extend
the term for three additional years.[4] Contractually, the Commission can obligate funds only
one year at a time. The EEOC can exercise this option by giving Pearson 60 days' advance
written notice of its intention to renew the contract, and then written notice of renewal within 30
days prior to expiration. The total term of the contract, including the pilot and option, is not to
exceed 60 months.

The NCC implemented a program to provide the following new services:

      Capability for the public to communicate on first contact in more than 150 languages,
       increasing meaningful access to people with limited English proficiency
      Twelve hours of operation - 8 a.m. to 8 p.m. Eastern Standard Time (EST), longer than
       business hours for EEOC field offices
      A live person should answer calls within 30 seconds
      FAQs on the EEOC's website
      An Interactive Voice Response (IVR) system accessible to all callers 24 hours per day,
       365 days per year
      Text Telephone (TTY) service attended by trained staff available 12 hours a day
      Email access that does not require knowing the name or email address of a specific
       EEOC employee

Contract to Evaluate the NCC. In November 2003, the EEOC Commission unanimously
approved implementation of a two-year pilot phase of the NCC, to include an independent audit
of the NCC prior to committing to a multi-year contract. After discussions between the Inspector
General and other senior executives, the EEOC transferred to the Office of Inspector General
(OIG) the funding to evaluate the NCC. OIG then conducted research, formed a project team,
obtained input from Agency officials and selected stakeholders, developed a statement of work,
and held a competition to award the contract. In September 2005, the OIG contracted with Job
Performance Systems, Inc. (JPS) to evaluate the impact of the NCC on the EEOC's staff,
operations, and customers. JPS and its subcontractor Convergys conducted its evaluation from
October 2005 through April 2006. The purpose of the evaluation was to provide EEOC
management with information to aid in a decision on whether to exercise the option to renew the
Pearson contract and inform stakeholders on how the NCC has affected the EEOC and its
customers.

Since the purpose of the NCC is to improve efficiency in field offices and enhance customer
service, the JPS evaluation focused upon the following topics:

       NCC implementation and operations
       NCC impact on efficiency and effectiveness of EEOC operations
       NCC impact on field staff
       NCC impact on EEOC customers

The EEOC expected the NCC to have a significant effect on customers and field offices, with a
minimal impact on Headquarters; therefore, the JPS Team placed more emphasis on the NCC
and its impact on field offices than the impact on Headquarters activities.

Context for the Evaluation

The 2003 Assessment Report recommended that there be at least a two-year pilot phase of
operations. The first year (September 2004-2005) was to be dedicated to start-up operations,
including the following:

       Developing accurate baseline data on the volume and nature of calls
       Developing and refining scripts based on actual requests for information and their
        frequency
       Developing and refining standard operating procedures and business rules
       Developing effective working relationships between the NCC and EEOC offices in the
        field

The second year (September 2005-2006) was to be the time to assess vendor performance. To
meet the required notices to renew the Pearson contract in September 2006, the evaluation
started seven months after officially launching the NCC (March 21, 2005). This meant that the
JPS Team evaluated the impact of the NCC on EEOC Headquarters and field operations while
the NCC was still in its first year of actual operations and the new processes were still being
implemented and refined.[5] Thus, to some degree, the evaluation was of a new program while
it was still in the development phase and operations were not yet stabilized. To allow time to
stabilize operations before a high call volume, the EEOC initially decided to have only the calls
to the two toll-free numbers directed to the NCC rather than all unsolicited calls to field offices.
Then from November 2005 through March 2006 the Office of Field Programs (OFP) gradually
authorized all offices to redirect their unsolicited calls to the NCC.
The NCC commenced initial pilot operations with seven field offices in February 2005. On
March 21, 2005, the NCC started accepting all calls on the EEOC's general inquiry lines, which
includes two national toll-free lines serving voice and TTY calls. The EEOC has not yet phased
in the option to have the NCC respond to requests for all EEOC publications.

Throughout the NCC pilot, OFP has made operational changes. In December 2005, they
increased the time employees in the field have to respond to NCC requests from two to four
days. They have also shifted responsibility for hot line calls (callers at risk of losing their rights
to file a charge) from all district offices to four offices (three hours per day for each office) in
different time zones across the country. In addition, the EEOC has revised scripts to include new
information, and made them easier for the Customer Service Representatives (CSRs) to
understand and use. After receiving results of the customer satisfaction survey, the EEOC added
a closing line to emails and web inquiries advising customers to contact the NCC with any
additional questions and providing the TTY number. Further, the EEOC is planning a
nationwide outreach campaign in July 2006 to encourage use of the toll-free telephone numbers.
The EEOC has not yet required that the NCC fulfill requests for publications or answer calls for
any offices in Headquarters.

In addition, the EEOC and NCC have been pilot testing the EEOC Assessment System (EAS).
Once tested, the EAS will become a web-based e-government application to help on-line users
determine whether the EEOC is the appropriate agency to provide assistance. The NCC is using
the EAS and the related EEOC Assessment Questionnaire (EASQ) to help filter out non-
jurisdictional inquiries and, when appropriate, electronically submit basic information about the
inquiry to the proper EEOC office.[6] During the NCC pilot, changes have been made to the
EASQ, most notably providing look-up tables based on post office data to derive the county code
and thus ensure questionnaires are directed to the proper EEOC office.

The amount of time it takes to launch a program at a new contact center varies by the type and
size of the program. The EEOC contact center operation is considered small compared to
industry standards. Similar programs may take from six to nine weeks to launch and standardize;
however, this pilot is more complex because of the work required to streamline processes
between the NCC and the EEOC offices. Since all EEOC field offices follow different
processes, it is difficult to estimate the time it would take to streamline such activities.

II. METHODOLOGY
A. EEOC HEADQUARTERS AND FIELD LOCATIONS

The scope of the JPS Team's work included evaluating the impact of the NCC on operations at
Headquarters and in the field; however, the EEOC never anticipated that the NCC would have a
significant, direct impact on Headquarters. Therefore, the team devoted most of its resources to
determining the impact of the NCC on offices in the field.

1. The Search for Baseline Data and a Control Group
Traditional evaluations often rely upon a combination of quantitative and qualitative data. One
strategy to assess the NCC's impact is to compare changes in variables of interest before and
after program implementation. The JPS Team searched for pre-NCC baseline data to evaluate
empirically the impact of the NCC on EEOC operations; however, there were only limited
quantitative data available, partially because offices follow different intake procedures, which
made it impossible to isolate the impact of variables related to NCC activities. This led the JPS
Team to draw many findings and conclusions from subject matter experts. The team gathered
this information through interviews, focus groups, and survey data. Where possible, the team
compared data collected from different sources to ensure consistent findings.

The JPS Team was unable to identify any pre-NCC data on costs related to handling inquiries, so
it was not possible to compare pre- to post-NCC costs. However, the team did provide an
analysis of the current estimated impact on an Investigator Full-Time Equivalent (FTE), and
projected possible future impact on Investigator FTE based upon certain assumptions.

Telephone Calls. To investigate whether the JPS Team could compare telephone call data for
offices pre- and post-NCC implementation, the team explored the possibility that field offices
may have been using their telephone systems to automatically track calls to their offices. There
is presently no systematic process in place to collect data on the number of calls made to EEOC
offices. As a result, there is no automated way to track the number of calls to all or many
individual offices pre- and/or post-NCC. The JPS Team did identify that two offices have
tracked telephone calls on their public number since October 2004 (pre-NCC). The team
evaluated the impact of the NCC on the telephone calls to those offices.

The JPS Team investigated the possibility of replicating the telephone survey conducted as part
of the 2003 Assessment Report in order to compare pre- and post-NCC data.[7] As part of this
effort, the team inquired with members of various offices at Headquarters and determined that
the field office-level electronic and raw data used to develop the conclusions and
recommendations in the 2003 Assessment Report no longer exist. These data included volume
and types of telephone calls as well as staff time required to answer calls to offices in the field.
The team considered repeating the data collection effort for randomly selected offices to
determine what changes have transpired.[8] This strategy would have been efficient and
practical to compare data across a sample of offices given the available time and resources, but
the EEOC and JPS Team could not find the raw telephone data collected in 2003. The team
made searches at Headquarters, at field sites, and with the data entry vendor. With no office-level
baseline data, it was impractical to replicate this study for selected offices.[9]

Lacking historical data across offices, the team included some items in the electronic survey sent
to all employees located in the field, asking them to estimate the average number of calls they
received pre- and post-NCC implementation. The drawback is that these data are only as reliable
as the survey respondents' memory.

Productivity Measures. The JPS Team also investigated evaluating traditional performance
metrics such as productivity, merit factor, and cause rate, but these data were not good measures
to use in the evaluation because of confounds[10] over the past several years that have affected
many offices. For example, many offices have experienced attrition (staff have left and not been
replaced) and/or undertaken changes in intake procedures.

The JPS Team specifically evaluated merit factor pre- and post-NCC, as it has long been an
important EEOC measure of positive resolutions, cause finding, withdrawals, mediations, and
conciliations. To use merit factor as a relevant measure, one must assume that all of the
following occur: the NCC frees up Investigator time; Investigators spend that time conducting
more thorough and higher quality investigations; and those investigations lead to increased
benefits. OFP indicated that merit factor is relevant given the current environment, in which
Investigators are managing a heavy workload. The team evaluated the trend of discrete quarterly
merit factor for all 51 offices from October 1, 2003 through December 31, 2005.[11] For the
same period, the team also evaluated the merit factor for only those offices indicating that the
NCC had enabled them to redirect Investigator resources to spending more time on
investigations.

The JPS Team could not identify any change in the merit factor other than a trend toward a very
small increase across time. It is possible that, because the analysis included only nine months of
NCC operations, there has not been sufficient time to realize an impact on merit factor.

Integrated Mission System (IMS) Data. The JPS Team initially considered a comparison
between inquiries generated from the NCC and those from all other sources reported in the IMS.
The team considered this as a means to measure the NCC's impact on increasing EEOC
efficiency, but the team later identified major data input errors on one of the critical variables,
finding a wide range of differences between the percent of EASQs received from the NCC and
the number entered into the IMS. Percentages of EASQs entered into the IMS ranged from 1
percent (2 entries in the IMS with an EAS/NCC source coding compared to 249 EASQ sent by
the NCC) to 754% (1666 entries in the IMS with an EAS/NCC source coding compared to 221
actual EASQs sent by the NCC).

The team found that different offices enter EASQ information into the IMS at different times
during the intake process; some immediately enter the information upon receiving it from the
NCC, while others enter it after they mail their office intake questionnaire and receive it from the
PCP. These differences introduce confounding factors that will affect any analysis comparing
offices.

Close examination of one office showed that 19.5 percent (28 of 143) of the EASQs sent by the
NCC were entered into the IMS in error (2 were duplicate entries and the remaining 26 indicated
that the EASQ originated from a non-NCC source). This finding indicated that any further
analyses of these data would be unreliable and therefore invalid, so the team stopped at this
point.

Due to the coding errors identified above, the JPS Team did not use any IMS data related to the
coding of inquiries and charges, but the team did use IMS data to evaluate accuracy and
completeness of EASQs sent to EEOC offices.
Treatment/Control Groups. The JPS Team also explored whether it could identify some offices
as control groups. This was only an appropriate strategy if other important confounding factors
could be held constant so that the treatment (in this case implementation of the NCC, or even
implementation of redirecting telephone calls to the NCC) and control groups were similar. This
procedure would help to isolate and quantify the treatment effect; therefore, it would be
important to put “like” offices in the treatment and control groups and try to hold other
confounding factors (such as turnover) constant across the treatment and control groups.

Using treatment and control groups proved impossible due to the manner in which the EEOC
rolled the NCC out. The EEOC initially set up seven offices to pilot the NCC for one month,
and then commenced implementation across all remaining offices on March 21, 2005. This one-
month initial pilot did not give sufficient time to stabilize operations and measure the NCC's
impact. Then, beginning November 29, 2005, the EEOC gradually authorized (but did not
require) offices to change their telephone voice message to redirect all first time callers to the
NCC.[12] This initiative started with eight local offices and has since gradually expanded to
include all offices. In both instances, there was no effort to create treatment and control groups
and, as a result, there are no comparative groups to evaluate impact.

2. Document Review

The JPS Team began this project by reviewing background documents related to the EEOC's
decision to implement the NCC. This review included the initial study conducted by NAPA that
recommended a contact center. The team also reviewed the 2003 Assessment Report and the
transcripts of the Commissioners' meeting reviewing those findings. The team also reviewed the
Pearson Contract as well as documents related to the field-repositioning plan and other
documents related to operations. A list of key documents is provided in Appendix B.

3. Data Analysis

For three offices (two district and one area office), the JPS Team compared information in the
EASQs with data in the IMS for the period April 1, 2005 through March 31, 2006 to evaluate
accuracy and completeness of the EASQs. The team also analyzed NCC-related GroupWise
emails for one district office for the period January 1, 2006 through March 31, 2006.

Headquarters Interviews

The JPS Team interviewed the Chair, 3 Commissioners,[13] 17 additional officials and staff in
Headquarters, and the President of the Union. The team conducted nearly all interviews in
person; a few were conducted by telephone. The team performed most interviews during the
weeks of October 31, November 7, and 14, 2005, with the intention of collecting employees'
impressions of the NCC's impact on Headquarters and field operations. The team also wanted to
identify areas to pursue when conducting visits to field offices.

The interviews generally took from 60 to 90 minutes to complete. The team began most
interviews by describing the team's project responsibilities and asking the interviewees to
provide a brief description of their job. Then, depending upon their role, the team asked a series
of prepared questions. Most of the questions related to their expectations of the NCC and its
impact. The Interview Protocol is attached as Appendix C.

In addition to these formal interviews, the team met several times throughout the evaluation, on a
less formal basis, with certain employees in the OFP to obtain information on field operations,
relevant statistics, and other issues related to the Pearson Contract and operations.

4. Field Site Visits

The JPS Team visited seven offices in the field, including five district offices (New York,
Charlotte, St. Louis, Dallas, and Los Angeles) and two area offices (Raleigh and Cincinnati).
The visits took place during the weeks of December 5 and 12, 2005. The criteria the team used
to select offices included geographic and size diversity; offices that the team understood to be
positive, neutral, or negative toward the NCC; and offices with different levels of performance.
The team also desired an office that provided a representative on the technical evaluation panel
that generated the 2003 Assessment Report.

Due to the number of criteria and budget and time limitations, the selected seven offices
generally addressed the criteria, but not all offices met all criteria; for example, the visits
included district and area offices, but no local offices, mostly because they have only a few
professionals, limiting the team's ability to collect meaningful data. A description of the
procedures followed during these visits is provided in Appendix D.

Surveys

The JPS Team conducted two surveys; one was sent to Office Directors, and the other, an
electronic survey, was sent to everyone in the field. The team developed these questions based
upon document reviews, interviews at Headquarters, and visits to the seven field sites as well as
the NCC (described next). Descriptions of the Office Director Survey and the Electronic Survey
are provided in Appendix D. The Director Survey is provided in Appendix E and the Electronic
Survey to all field staff and responses are provided in Appendix F.[14]

B. NCC EVALUATION

1. Document Review and Headquarters Interviews

JPS team members began this effort by reviewing many of the documents described earlier in
this report.[15]

2. NCC Site Management Interviews

The JPS Team conducted interviews with the NCC Site Director and management team prior to
its visit to the NCC. The purpose of these interviews was to gain an initial understanding of
NCC operations, clarify the manner in which the NCC and EEOC communicated, and identify
important areas to assess during the site visit.
The interviews took from 60 to 75 minutes. The team began by describing its project
responsibilities, and then asked respondents to provide a brief description of their day-to-day
responsibilities. The team followed up with questions regarding the NCC's organization and
operations. The Interview Protocol is attached as Appendix G.

3. Initial Data Gathering

Prior to the team's visit, it sent the NCC Site Director and the EEOC Project Manager a data
request document pertaining to typical call center operations (e.g., workforce management, call
handling techniques, call metrics, agent performance management, and customer satisfaction)
stats. The team followed up with a phone call to the Site Director and the contract administrator
to explain the details of the requirement, and received data in the form of monthly reports that
the NCC sends to the EEOC. The team conducted some basic trending and correlation analyses
on call volume, call duration, and primary reasons for calls using Microsoft Excel and SAS.[16]

4. Remote Call Monitoring

The JPS Team obtained a remote calling number from the NCC. Remote calling numbers are
established so that a third party (other than the caller and CSR) can dial into the call and listen to
the conversation. A team of four people dialed into the remote calling number and monitored
several calls to gain a high-level understanding of the call flow and gather call statistics. The
team used a proprietary call observation tool to conduct the call monitoring exercise. This tool
enabled the team to capture information such as call start and end time, amount of time spent in
caller identification, amount of time spent in problem identification and resolution, call reason,
call disposition, whether the call was transferred, number of holds, caller questions, and CSR
answers.

The team dialed into the remote monitoring number during different times of the day and
different days of the week in order to capture a sufficient cross section of calls. The team
monitored 411 calls over a four-week period from October 26, 2005 to November 17, 2005.

The team compared its results with the EEOC reports and found the numbers from both sources
were comparable. The information the team collected during this exercise therefore served as
the primary source of data for most of the team's NCC assessment analyses.

5. NCC Site Visit

The team prepared an agenda for focus groups and interviews. It also prepared interview guides
and a focus group protocol. The team sent the agenda and interview/focus group protocol to the
site director a week in advance of the site visit. The site director responded with the names of
the personnel who would participate in the focus groups and interviews. The team made a few
changes based on knowledge acquired during the remote call monitoring sessions. The Interview
Guide is attached as Appendix G, and the Focus Group Protocol, as Appendix H.

The JPS Team spent the week of November 7, 2005 at the NCC, assessing its operations. The
team asked NCC employees in the interviews and focus groups about their job description, their
understanding of NCC objectives, metrics the EEOC uses to measure the effectiveness of the
NCC, and potential improvement opportunities. When meeting with management personnel, the
team inquired about management and coaching techniques. The team also met with the
reporting, technical, and training subject matter experts who explained their current processes,
issues, and opportunities for improvements.

The JPS Team conducted interviews with the Site Leader, Team Leaders, and the Quality
Manager. The team also led focus groups with the CSRs and conducted side-by-side
observations of CSR English calls, TTY calls, faxes, and emails. In addition, the team reviewed
monthly reports, scripts, and training manuals. The team also reviewed the NCC processes for
call handling, reporting, training, and call monitoring.

Because the NCC is in the pilot phase and in transition, many things have changed since the
beginning of the evaluation the NCC. The team based most of its evaluation on the detailed
analysis and the situation during its site visit in November and December 2005.

6. Data Analysis

While visiting the NCC, the JPS Team collected scripts used in answering the calls, data on call
flows, training quizzes and answer keys, call monitoring forms, and EASQs. The team analyzed
this information, along with other data collected during all of the above listed activities, with
quantitative analysis techniques. The team used qualitative data collected during the interviews
and focus groups to develop hypotheses. The team used the quantitative data collected during
the remote call monitoring sessions and from the NCC reports to quantify the impacts.

7. Customer Satisfaction Data Analysis

The NCC had no data on customer satisfaction when the team began its work; therefore, the team
attempted to collect customer satisfaction information as a part of its call monitoring exercise.
The team tried to capture CSR empathy, professionalism, and subject knowledge, as well as
overall customer satisfaction with each call; however, because a small group of individuals
monitored most of the calls, there was no variation, and, therefore, the team could not use the
data in its analysis.

During the course of the project, the EEOC contracted with CFI Group to collect customer
satisfaction data. The JPS Team conducted an initial benchmarking analysis comparing their
initial customer satisfaction index to the best practices with Federal agencies and in general to
service industries in the private sector. The team also compared the results between channels and
reviewed the detail analysis to understand other aspects of satisfaction.

III. FINDINGS AND CONCLUSIONS
A. THE NCC IMPLEMENTATION

The JPS Team compared the 2003 Assessment Report with the NCC implementation as well as
the metrics required in the Pearson Contract with the metrics that are submitted to the EEOC.
  1. 2003 Assessment Report recommendations implemented.

  The EEOC has successfully implemented several of the recommendations in the 2003
  Assessment Report. The Report included a number of recommendations pertaining to
  establishing an NCC. As shown in Table 2 on the following page, the NCC and EEOC have
  followed each of the recommendations.



               Table 2. Implementation of the 2003 Assessment Report Recommendations
                 2003 Recommendations                              Findings of Current Evaluation
1. Establish an NCC to handle all unsolicited public To establish the NCC, the EEOC signed a
   inquiries received by all field offices. At this time, contract with NCS Pearson, Inc., dated
   do not include Office of Federal Operations or         September 20, 2004 that was amended on
   Field Management Programs in the NCC.                  September 28, 2005. The contract includes the
                                                          consolidation of two toll-free phone lines
                                                          (voice and TTY) for general inquiries and
                                                          centralized email access via the Internet.
2. Competitively outsource the NCC to get the best        The contract was competitively bid: full and
   value for start-up and operations; use the Statement open procurement, best value award.
   of Objectives procurement process to expedite
   implementation.
3. Start operations with a pilot phase for at least two Initial contract is for two years with an option
   years. Collect baseline data on performance            to renew for three years (annually or for all
   metrics and costs during the first 12 months and       three years). The NCC is serving all 51 offices
   assess vendor performance. The pilot should be         in the field.
   national in scope.
4. NCC services should cover the spectrum of basic The NCC handles calls and other
   inquiries, Frequently Asked Questions (FAQs),          correspondence about basic inquiries,
   information on laws and procedures, the EEOC           including: EEOC Overview, contact
   Report series, office hours, locations, staff          information for EEOC offices as well as for
   directories, and case information, with caller         other Federal agencies, hours of operation, how
   authentication. The NCC should respond to              to file charges, eligibility criteria, and Charge
   inquiries from Potential Charging Parties (PCPs) status. The NCC also updates the FAQs on the
   and assist in completing on-line charge                website and handles TTY calls, emails, faxes,
   questionnaires, if appropriate. Other services to      and other formats of correspondence. They
   phase in later include handling email, facsimile,      take Spanish and English calls and use a tele-
   postal mail, and fulfilling requests for publications interpreter for other language calls. The NCC
   and printed materials. The NCC should not handle does not handle filing of charges.
   filing charges.
5. Modify EEOC Order 150.005 to allow for                 Effective January 14, 2005, a paragraph was
   monitoring/recording of calls of contact center        added to EEOC Order 150.005 to permit
   employees for quality assurance purposes.              monitoring and recording calls between NCC
                                                          employees and the public for purposes of
                                                          quality assurance.
6. Develop internal and external marketing strategies National Contact Center Outreach Plan,
to communicate the compelling case for a national Version 2.0, dated February 2, 2005. For each
contact center to the EEOC's staff, customers and external and internal action item there are target
stakeholders to solidify support for this initiative. completion dates, responsible groups, and an
                                                      indication of any funds needed.

2. Pearson is meeting most contractual metrics.

The JPS Team compared performance targets to actual performance from September 2005
through April 2006. As Table 3 shows, most of the contractual metrics and objectives set forth
in the Pearson Contract are being measured. Customer Satisfaction was originally intended to be
measured by a third party and monitored on a regular basis by the NCC Quality Manager.
However, due to the long approval processes required by the Office of Management and Budget
(OMB), the EEOC determined that the results would not be available in time for the decision on
whether to renew the Pearson Contract. As a result, the EEOC contracted with CFI Group to
conduct a one-time customer satisfaction survey. The survey was completed in the month of
February, 2006, for all of the contact types (eg. Fax, telephone calls, written correspondence)
handled by the NCC.

NCC is meeting most of the performance metrics specified in the contract, except for Average
Speed of Answer, which they met five of eight months (September 2005 through April 2006).
Due to technology issues related to recent increased volume, the wait times have been high since
the middle of April 2006 (up to 25 minutes before the CSR comes on the line). As of June 19,
2006, this problem was resolved.

       Table 3. Comparison of Contractual Performance Metrics and Reporting Status
 Performance Metric in Pearson       Expected Target in        Extent the NCC Met or
             Contract                 Pearson Contract          Exceeded the Target
Call Monitoring Scores           90% - 95% of monitored 100%
                                 calls
Accuracy of Information Provided 95% - 97%                  100%

(Measured through Call Monitoring)
Accuracy of Information Captured 95% - 97%                        100%

(Measured through Call Monitoring)
Customer Satisfaction              70% - 75% satisfied or         Customer Satisfaction Index is
                                   extremely satisfied            77*
Service Level - Average Speed of   70% to 80% in 30 seconds       62.5%
Answer                             or less
Average Speed to Respond to Email 70% - 80% in one business       100%
                                   day
Average Speed to Respond to Fax 70% - 80% in two business         100%
                                   days
Average Speed to Respond to        70% - 80% in two business      100%
Written Correspondence             days
Blocked Calls                         1% - 3%                      100%

* Gathered for the week of February 7-13 by an independent contractor. The index is not a
percentage. See Section IIIG8.

B. COMPARISON OF NCC ESTIMATES VERSUS ACTUAL STATISTICS

1. The actual call volume and savings in staff hours are less than projected.

The JPS Team reviewed and compared several estimates of NCC activity contained in the 2003
Assessment Report with 2005 actual statistics. Based upon NCC reports and call monitoring
analyses, call volume is lower than 2003 estimates, which has resulted in less EEOC field staff
time saved compared to projections. During the first year of pilot operations (April 2005 -
March 2006), the NCC received 269,693 calls.

The 2003 Assessment Report estimated all unsolicited calls to offices in the field (toll-free and
local). According to comments from OFP, prior to implementation, the decision was made to
route only toll-free calls to the NCC, with unsolicited calls to each office in the field handled
locally. Therefore, the baseline 86,824 calls identified in the 2003 Assessment Report (1.2
million calls annually) will be higher than the anticipated number of calls to the NCC until the
EEOC decides to require that offices direct all unsolicited calls to the NCC. The present call
volume to the NCC is also low because call volume to the EEOC's toll-free numbers has
decreased 17.5 percent (when comparing March 2003 to March 2006). This is consistent with
reduced annual charge receipts since fiscal year 2003 (see Figure 2).

The NCC handles a variety of different types of communication, including calls handled by
CSRs, calls handled by IVR, and other forms of written communication. Figure 1 below shows
the call volume (English, Spanish, and TTY calls handled by CSRs) by month as well as the
trend of calls. As the figure shows, there is not a significant variation month over month (except
from December 2005 to January 2006 and February to March 2006) or a clear trend showing an
increase in the number of calls received by the NCC.

Figure 1. English, Spanish and TTY Calls Handled by the CSRs, April 2005-April 2006
In addition to calls handled by a live person, Table 4 shows the number of calls handled by the
IVR during the first 13 months of operations. There is no particular pattern evident in the
number of calls terminating at the IVR.

                               Table 4. IVR Calls Handled by the
                                            NCC
                                    Month            IVR Calls
                            April-05              8,739
                            May-05                8,342
                            June-05               7,981
                            July-05               6,708
                            August-05*            8,300
                            September-05          7,812
                            October-05            8,705
                            November-05           7,207
                            December-05           6,014
                            January-06            8,363
                            February-06           7,885
                            March-06              8,564
                            April-06              8,028
*Estimate due to NCC equipment malfunction

The NCC also handles other forms of communication, including emails, written correspondence,
web inquiries, and faxes. As shown in Table 5, the NCC receives and processes significantly
more emails than other forms of communication.

                  Table 5: Other Forms of Correspondence Handled by CSRs
   Month      Email         Written              Web      Fax         Total Other
                        Correspondence         Inquiries            Correspondence
April-05      1,436 52                       209          36 1,733
May-05        1,436 46                       264          45 1,791
June-05       1,417 67                       267          72 1,823
July-05       1,296 51                       265          64 1,676
August-05     1,549 75                       292          48 1,964
September-    1,551 62                       348          63 2,024
05
October-05 1,476     68                        293            74   1,911
November-05 1,254    75                        274            73   1,676
December-05 1,247    58                        221            62   1,588
January-06 1,540     71                        257            84   1,952
February-06 1,379    44                        359            69   1,851
March-06    1,363    62                        865            64   2,354
April-06    1,313    51                        719            76   2,159

Since the 2003 Assessment Report was based on actual calls answered by EEOC employees and
not calls handled by message machines, the JPS Team's evaluation will consider only actual calls
handled by the CSRs so that the numbers are comparable. The evaluation does not use calls
handled by the IVR to compare estimates with actual results, as they could include misdialed
numbers; further, if a call can be answered by an IVR at the NCC, it can also be handled by an
IVR at any EEOC office. It is difficult to determine whether callers obtain useful information
from the IVR without an in-depth analysis of the IVR. Calls handled by the IVR are not
equivalent to calls handled by EEOC employees, because no matter where they are handled, they
would not require an EEOC employee.

During the first full year of operations (April 2005-March 2006), the CSRs handled 269,693
calls. During the second full year of operations, the JPS Team projects that the NCC will receive
between 273,804 (annualized based on the average of the 13 past months) and 319,020
(annualized based on the March 2006, the month with the highest call volume) total calls. The
higher projection must increase four times to reach the volume anticipated in the 2003
Assessment Report.

Based on the estimated annualized volume of 273,804 calls per annum and the 51 percent
resolution rate achieved by the NCC,[17] the team estimates that the NCC saves the EEOC
13,964 staff hours.
           Table 6. Comparison of 2003 Survey Data to 2005 Evaluation Findings
        Measure           Estimates from 2003             Current Report Findings
                           Assessment Report
Call Volume             Projection of 1.2 million 269,693 calls handled by CSRs
                        calls

                                  Based upon
                                   86,824 calls
                                   received by the
                                   field and
                                   Headquarters in
                                   20 working days

Contact Channels                  EEOC Field              EEOC Field Offices
                                   Offices                 EEOC Headquarters
                                  EEOC                    NCC
                                   Headquarters               o English Calls
                                                              o Spanish Calls
                                                              o Language Support
                                                              o TTY
                                                              o Fax
                                                              o Email
                                                              o Written Correspondence
                                                              o Web Inquiries

Call Duration*                    69% - Up to 3   Average handle time for calls is six
                                   minutes         minutes. Calls vary between 2 and 15
                                  16% - Between 3 minutes, depending upon the call type.
                                   and 5 minutes
                                  9% Between 5
                                   and 10 minutes
                                  4% Between 10
                                   and 20 minutes
                                  2% Above 20
                                   minutes
                                  A significant
                                   percent of the
                                   calls were less
                                   than 3 minutes.

Time freed up for EEOC Estimated savings of           Estimated savings of 13,964 hours per year
employees to engage in      43,224 hours for GS 5, 7, based on data collected from the NCC.
investigations, outreach, 9, 11, 12, and13
and support activities with
implementation of the
NCC.
*Call duration for contact center operations are typically reported in averages

The JPS Team compared the NCC estimates listed in the Pearson Contract with actual statistics.
The Pearson Contract contains estimates for the first six months of NCC operations. As shown
in Table 7, the NCC has received substantially more emails than expected and significantly
fewer calls and faxes.

Table 7. Six Month Estimates in Pearson Contract Compared to Actual Statistics, April through
                                      September 2005
  Estimates in Pearson Contract                              Actual
    English IVR - 719,554               English IVR - 47,882 (the numbers for August
                                           2005 are estimates as the actual numbers were not
    English CSR- 306,332                  available due to malfunction of the IVR)
    Fax - 4,500                         English CSR - 130,822
    TTY English - 3,245                 Fax - 327
    English Email - 2,381               TTY English - 1,139
                                         English Email - 8,616



C. NCC IMPACT ON HEADQUARTERS OPERATIONS AND STAFF

The JPS Team reviewed written and telephone communication, website activity, charge
statistics, and outreach efforts at Headquarters. The team found little impact attributed to the
NCC. The fiscal year data presented below was provided by the EEOC.

1. Written and telephone communications to Headquarters decreased. There may be a
relationship between reduced communications and implementation of the NCC; however,
there are no data indicating the decrease is attributed to the NCC.

Controlled Correspondence

Congressional Correspondence and Correspondence to the Chair decreased over the past three
years. The reduction in Congressional Correspondence (generally pertaining to status of Federal
Sector complaints) typically relates to inquiries about case status and may be the result of the
normal fluctuation of appeals in the Federal sector. It is also possible that the 29.5 percent
reduction in correspondence from 2004 to 2005 reflects better service by offices in the field as
well as the Office of Federal Operations due to the NCC answering calls, thus enabling
employees to manage their workload more effectively, resulting in fewer complaints.

                Table 8. Congressional Correspondence to Headquarters, 2003-
                                            2005
              Fiscal Year Congressional Correspondence Percent Reduction
              2003        1,407                           -
              2004        1,403                           .28
              2005*       988                             29.50
*NCC implemented 3/21/05

As shown in Table 9 below, Correspondence to the Chair increased in relation to operations in
the field during the first six months of NCC operations, and then decreased. When comparing
equivalent periods pre- and post-NCC implementation (October through March), there is an 8
percent decrease in correspondence related to Headquarters operations and a 16 percent decrease
related to field operations. The combination of better customer service, increased outreach,
establishment of the NCC, and increased information on the EEOC's website (including the
FAQs developed by the NCC) may have resolved concerns that in previous years would have
resulted in written correspondence to the Chair.

              Table 9. Correspondence to the Chair, October 2004-March 2006
                                Percent                     Percent             Percent
                                increase                    increase            increase
                               (decrease)                  (decrease)          (decrease)
               Headquarters from previous      Field     from previous       from previous
 Fiscal Year    Operations       period     Operations       period    Total     period
 st
1 Half 2005 129              -              150         -              279 -
(October-
March)
2nd Half 2005 206            59.7           180         20.0           386 38.4
(April-
September)*
1st Half 2006 119            (42.2)         126         (30.0)         245 (36.5)
(October-
March)

*NCC implemented March 21, 2005

Telephone calls to the main EEOC public number

Table 10 on the next page shows available data for telephone calls to the public EEOC telephone
number (202/663-4900). Over the past four calendar years, there has been a steady reduction in
total calls. Data for the 2004 and 2005 calendar years are incomplete, but four months are
comparable. There is a similar reduction in total calls pre- (February 2005) and post- (May and
June 2005) NCC implementation. There is a larger percentage reduction in total November
calls. When considering just the calls related to the field offices, there was a larger reduction in
calls pre-NCC (February) than post-NCC (May). It is possible that some of the call reduction
can be attributed to the NCC.

      Table 10. Comparison of Four Years of Telephone Contacts to EEOC Headquarters
                                                       Calls to Headquarters Regarding
                   Total Headquarters Calls                        Field Offices
   Month 2002 2003 2004 2005 Percent Reduction 2004 2005 Percent Reduction
                                      2004-2005
 January 6,423 8,877 2,897 *     -                     *      *      -
 February 7,831 7,246 2,994 1,812 39.5                     811    308    62.0
 March     9,977 *    3,595 *     -                        963    *      -
 April     6,834 *    *     *     -                        *      *      -
 May       9,753 *    1,943 1,342 30.9                     500    261    47.8
 June      8,316 *    2,502 1,616 35.4                     *      371    -
 July      6,838 *    *     996 -                          *      417    -
 August    11,841 *   *     *     -                        *      *      -
 September 8,738 *    *     *     -                        *      *      -
 October 8,843 *      *     *     -                        *      *      -
 November 9,398 *     2,268 1,124 50.4                     *      308    -
 December 6,287 *     *     *     -                        *      *      -

*Missing or incomplete

Office of Field Programs (OFP)

OFP Management has a general sense that telephone complaints from the public to OFP
regarding an inability to reach an EEOC employee in the field by telephone have diminished, but
there is no tracking system to show numbers or types of complaints.

2. Website activity has increased and it is possible that some of the increase is attributable
to the NCC.

The total number of visitors to the EEOC website has increased over the past five years. During
the first seven months of Fiscal Year 2006, average monthly user sessions have continued to
increase to 551,490. According to the Web Site Content Manager, this reflects a typical growth
pattern for Federal websites.

                  Table 11. Average Monthly Website Hits, Fiscal Years 2001-
                                           2005
                Fiscal Year Average User Sessions/Month Percent Increase
                2001        208,534                         -
                2002        246,756                         18
                2003        340,706                         38
                2004        360,000                         6
                2005        444,533                         23

For the last six months of fiscal year 2005, the NCC's IVR provided the NCC web site address,
and NCC staff also informed customers about information available on the web site; therefore,
some of the increase from 2004 to 2005 may be attributable to the NCC. It is also possible that
customers who visited the website when they were unable to get through to field offices are now
contacting the NCC and getting their questions answered before visiting the web site.
The EEOC developed the FAQ page on its website in conjunction with the formation of the
NCC, and the NCC manages the order of the questions on the page (the most frequently asked
questions appear first). There was an average of 11,285 visits to the FAQs over the 12 months
from April 2005 through March 2006, with a range from 9,234 to 15,440 visits. Nearly 45
percent of the total FAQ web hits were related to intake and charge filing.

3. Post-NCC implementation, the pattern of annual and monthly charge statistics remains
consistent with prior years.

Charge Statistics - Annual and Monthly

Over the past 13 years, the volume of charge statistics has varied. As shown in Figure 2 on the
next page, the general change across time appears to be cyclical.[18]

Figure 2. Annual Charge Receipts, Fiscal Years 1992-2005




Following is a comparison of the monthly individual charge receipts for four fiscal years (2002-
2005) and October through April of the current year. While there are monthly differences in
total receipts, the overall pattern of receipts across each of the 12 months has remained
consistent. There have been no significant fluctuations since the inception of the NCC.

Figure 3. Monthly Charge Receipts, Fiscal Years 2003-2006
4. Employees perceive a need for increased awareness of the NCC, and efforts are
underway to broaden publicity.

Managers and employees interviewed at field sites as well as respondents to both the director and
employee surveys indicated that they believe the EEOC needs more visibility and that it is not
sufficiently publicizing its mission or its toll-free number. They suggest that current outreach
events inform human resources groups, but that most employees in small-to-medium sized
companies do not know about the mission or work of the EEOC. The national outreach group at
Headquarters conducts 5,000 to 6,000 outreach events per year, as well as 500 to 600 media
events that reach hundreds of thousands of people. As a result, many employers know about the
EEOC; further, in an effort to reach more employee groups, the EEOC is continuing to expand
their advisory councils and partner with other agencies.

EEOC/NCC Awareness. Specific to the NCC, a few survey respondents commented that many
potential EEOC customers do not know about the toll-free number, even though it has been in
existence since 1991. Interviewees suggest developing an advertising campaign similar to the
Freedom to Compete and Youth at Work initiatives. Survey respondents recommended
providing pamphlets about the NCC to each individual coming into the offices, having every
office redirect callers receiving voicemail to the NCC's 800 number, and contacting civil rights
organizations (e.g., National Hispanic Civil Rights) to provide awareness of the NCC's services
in their communities. The EEOC anticipates launching a major new advertising campaign in July
2006 to link the NCC and the 800 number. The plan currently includes a theme and logos to
increase awareness of the 800 number. This effort will include developing and distributing
brochures, handouts, and promotional giveaways. There will also be press releases and stories
for field offices to send to local print media contacts including ethnic and minority publications.
In addition, there are plans for radio and Internet Public Service Announcements. This campaign
is intended to create awareness among target audiences of the EEOC's readiness to help, position
the 800 number as the preferred method to access the EEOC, and increase inbound calls to the
NCC. The EEOC ordered promotional materials for this campaign on June 15, 2006, and plans
to distribute them to field offices a few weeks thereafter.

Telephone Listings. Headquarters is currently responsible for entering and updating all
telephone listings in local telephone books. Listings are submitted to GSA for entry into the
Blue Page (Federal) section of local telephone directories. The EEOC provides GSA with both
the toll-free and local numbers. Therefore, the toll-free number should be listed in all local
directories, but a review of local telephone directories by field personnel revealed that the NCC
toll-free number is listed in the government listings section of printed telephone directories for
36 cities across the country, but not listed in another 27 cities.

In addition, the on-line blue pages directory (http://www.usbluepages.gov/index.html) lists the
local telephone number for EEOC offices under “discrimination” but does not list the NCC toll-
free number. It also does not list the EEOC under the category “Agencies and Services.” The
EEOC has recently made a decision to publish the numbers under “discrimination” and Equal
Employment Opportunity Commission and to work with GSA to ensure the toll-free numbers are
published in local directories.

The EEOC has made a policy decision to continue to publish local telephone numbers in the blue
pages. This policy limits the number of calls going to the NCC and the potential number of
customers served by the NCC, particularly since not all offices redirect first-time callers to the
NCC (discussed later).

D. NCC IMPACT ON EFFICIENCY AND EFFECTIVENESS OF FIELD
OPERATIONS

There have been some reductions in unsolicited calls to the field offices. The CSRs are not
resolving as many calls as they could.

1. Field employees have mixed perceptions of the impact of the NCC on call volume to
offices.

Comparing call volume pre- and post-NCC, employees in focus groups indicated a perceived
decrease in calls in an average week, ranging from a 0 to 60 percent. Respondents to the director
survey who reported reduced call volume thought their employees were better able to answer and
return phone calls on a timely basis. This has relieved pressure on people answering phones, and
now fewer people must answer “cold calls” (initial calls from the public).

A few respondents to the director survey indicated they have not experienced a drop in call
volume. As suggested by some employees in focus groups, one reason may be that the NCC is
picking up calls that have been previously dropped or lost due to telephone technology, thus
increasing the workload.

The electronic survey asked employees who answer and/or return unsolicited calls to their office
public number to estimate the number of calls they received in an average week before and after
NCC implementation. The data showed a clear break in the distribution between 400 and 600
total calls. Cases reporting more than 400 calls were considered outliers and removed.[19] The
results show that employees in Pay Grade 4 perceived a 76.9 percent reduction in calls and that
employees in Pay Grade 8 perceived a 44.7 percent reduction. Respondents in Pay Grades 5, 7,
and 12 perceived an approximate 25 percent reduction. The mean increase in calls reported in
Pay Grade 15 is largely attributable to one person who indicated 150 more calls post-NCC versus
pre-NCC.[20]

  Table 12. Mean Change in Calls to Office Public Telephone Numbers in the Field, Pre/Post-
                                            NCC
  Pay      Mean Mean Calls           Mean Call              Percent         Number of
 Grade Calls Pre- Post-NCC (Reduction) Increase           (Decrease)        Employees
           NCC                        per week             Increase         Responding
4       32.5      7.5         (25.0)                   (76.9)          2
5       79.6      58.8        (20.8)                   (26.1)          39
6       23.3      14.7        (8.6)                    (36.9)          16
7       87.8      66.3        (21.5)                   (24.5)          43
8       63.3      35.0        (28.3)                   (44.7)          6
9       44.0      34.3        (9.8)                    (22.3)          24
11      16.5      15.9        (0.5)                    (3.0)           15
12      43.0      31.6        (11.5)                   (26.7)          251
13      33.6      30.3        (3.3)                    (9.8)           81
14      16.7      14.0        (2.6)                    (15.6)          73
15      17.5      26.7        9.3                      53.1            11
SES     15.0      10.7        (4.3)                    (28.7)          3

Comments from some survey respondents indicated that they perceive no reduction in calls. It is
likely that some offices are receiving more calls, perhaps due to increased outreach, and some
offices receive fewer calls. It is also possible that some employees have the same number or
more calls because of other factors, such as attrition.

Support staff in one field office mentioned that PCPs have said that the NCC is telling them to
call offices directly, which may be another reason why employees do not perceive reduced
telephone calls to their public number. In part, this is occurring because of NCC business rules
requiring that the CSRs advise some callers to contact the EEOC office directly. Callers directed
to the field offices are those who specifically request to contact the office, have complex or
unusual questions for which the NCC has no approved scripts, or insist on speaking with the
office even though the EEOC does not have jurisdictional coverage or time limits have expired.
Another possible reason that calls have not decreased more significantly may be related to NCC
operations. The NCC does not measure or monitor call resolution, and the CSRs take very little
ownership of the call. During the JPS Team's call monitoring and side-by-side observations, it
observed that some CSRs subtly push the callers to contact the EEOC offices directly when they
should take time to answer their questions and/or fill out the EASQ. The NCC's focus on
Average Handle Time (AHT) may be pushing the CSRs to get off the phone to meet their AHT
goal. This combination of business rules and CSR practices may account for reports from many
employees in the field that the NCC has had little positive impact on them.

The JPS Team was able to identify the impact of the NCC on the call volume for the Dallas and
Charlotte District Offices because they tracked the number of telephone calls received on their
public line pre- and post-NCC.[21] As shown in Table 13, the impact of the NCC on telephone
calls differed for each office. The Charlotte Office realized increased telephone calls and,
therefore, a net increase in contacts (telephone calls and NCC forms) after implementation of the
NCC. During the team's site visit, the Charlotte District Director indicated they may be
receiving increased calls due to outreach efforts. Commencing in January 2006, callers to the
Charlotte Office received a recorded message to contact the NCC if they were calling during
specific times before or after regular business hours (8:00 a.m. to 8:30 a.m. and 5:30 p.m. to 8:00
p.m. EST).

The Dallas Office experienced a net decrease in calls to their public number, for an average
monthly savings of 489 contacts for the months of October through December 2005 and 302
contacts for the months of January and February 2006. The relatively larger number of NCC
forms in January/February 2006 over the previous quarter is likely due to two factors: in January,
the Dallas office started redirecting overflow calls during the day to the NCC, and also received
some duplicate GroupWise emails during this period.

   Table 13. Comparison of Charlotte and Dallas District Office Telephone and NCC Forms
                        Telephone Calls                                     Net Increase /
               Average Average         Average           Average No.         (Decrease) in
    Office /   Calls Pre- Calls Post- Increase        EAS/GroupWise average contacts
    Months       NCC         NCC      (Decrease)        sent to Office     to EEOC Office
 Charlotte
 May-         495         878        383           59                    442
 September
 (2004 and
 2005)
 January-     537         839        302           174                   476
 February
 (2005 and
 2006)
 Dallas
 October-     1,798       1,135      (663)         174                   (489)
 December
 (2004 and
 2005)
 January-       1,754       936         (818)          516                    (302)
 February
 (2005 and
 2006)

The JPS Team also compared the first two months of NCC operations with two recent
comparable months.[22] As shown in Table 14, both offices are realizing decreased telephone
calls. This may be because both offices are redirecting overflow calls on their intake lines during
the day. The Charlotte office experienced a net decrease in contacts from the public, whereas the
Dallas Office experienced a net increase. EASQs sent to the Dallas Office for March and April
2006 increased by 50 percent. The increase in contacts at the Dallas Office may be related to
their decision in January to redirect those callers who reach voice mail during the day to the
NCC.

       Table 14. Comparison of Dallas District Office Telephone Calls and NCC Forms
                    Telephone Calls                  Average Increase        Net Increase
            Average    Average Net Increase            (Decrease) in         (Decrease) in
           March and March and (Decrease)          EAS/GroupWise per          Number of
 Office April 2005 April 2006                              Month                Contacts
Charlotte 963        712          (251)          188                       (63)
Dallas 1,390         1,064        (326)          457                       131

2. The NCC receives low call volume, and the NCC is not resolving as many calls as it
could. Therefore, the NCC has had minimal impact on the call volume received by EEOC
offices.

Call Volume

According to the NCC reports sent to the EEOC, over the first 13 months of operations, the NCC
handled an average of 22,695 calls and 1,879 other forms of correspondence per month. As
discussed earlier, this is substantially lower than the estimates in the 2003 reports.

One factor affecting total calls to the NCC is changes in EEOC policies during the timeframe of
this analysis. From April through most of November 2005, customers called either the toll-free
number (answered by the NCC) or the local number (answered by the EEOC offices). From
November 2005 through March 2006, the EEOC gradually authorized, but did not require,
offices to put a message on their voicemail redirecting first-time callers to the NCC.

In May 2006, the JPS Team called each office during and after business hours to determine the
extent to which offices presently redirect callers to the NCC. As Table 15 shows, 28 of 51
offices redirect callers to the NCC after normal business hours.

During business hours, the team reached 19 live people and 32 message machines. One of the
EEOC Receptionists redirected the team to the NCC. The Receptionist for that office answers
general questions such as location and office hours and refers all other “cold calls” to the NCC.
According to the Office Director, customers have not objected to calling the NCC after talking
with the Receptionist.

Of the 32 message machines the team accessed during business hours, 19 redirected callers to the
NCC. Twelve of those offices also redirect callers after business hours.

                  Table15. Calls to Offices During and After Business Hours
                                                          During Business Hours
                   Office Response          After Hours Message Machine Person
            No answer after three tries*    2           -                 -
            Redirect Callers to NCC         28          19                1
            Do Not Redirect Callers to NCC 21           13                18
            Total Number of Offices         51          32                19

*The first time the JPS team called offices after hours, it received no answer or an indication of a
full message box for five offices.

As Table 16 shows, there has not been a significant increase in either call volume or other forms
of correspondence for the month of April 2006 when compared to the other months, and,
particularly, April 2005. The increases shown in January through April 2006 may reflect the
normal increase in inquiries during the second fiscal quarter (see Figure 3); therefore, the team
does not expect a significant change in volumes unless the EEOC develops a policy requiring all
field offices to redirect their unsolicited calls to the NCC.

                             Table 16: Contacts Handled by NCC
                                              CSR Contacts
                                Total Calls        Total Other
                  Month/Year     Handled         Correspondence           Total
                  April-05    25,490         1,733                        27,223
                  May-05      23,561         1,791                        25,352
                  June-05     23,574         1,823                        25,397
                  July-05     21,561         1,676                        23,237
                  August-05 24,899           1,964                        26,863
                  September- 20,043          2,024                        22,067
                  05
                  October-05 21,119          1,911                        23,030
                  November- 19,368           1,676                        21,044
                  05
                  December-05 18,046         1,588                        19,634
                  January-06 23,388          1,952                        25,340
                  February-06 22,059         1,851                        23,910
                  March-06    26,585         2,354                        28,939
                  April-06    25,336         2,159                        27,495
Call Resolution

The JPS Team captured information indicating the extent that CSRs resolve calls during its
remote call monitoring. The team recorded a call as “resolved” when, upon hanging up with the
CSR, the caller would not have to contact or be contacted by an EEOC office; for example, non-
jurisdictional calls, PCPs requesting general information, and CPs inquiring about charge status
were considered resolved at the NCC. The team's analysis shows that the NCC is successful in
resolving 51 percent of its calls. These calls relate mostly to general inquiries or information
about other Federal agencies. The other 49 percent of the calls to the NCC are either referred
(the caller is asked to contact the local EEOC office) or forwarded via an EASQ to the EEOC
office.

              Table 17: Call Types by Resolution at NCC for Calls Handled by NCC
                                                                                     Percent
                                                               Percent Forwarded / Handled by
   Call Type                      Description                   Referred to EEOC      NCC
Eligibility       Call relating to general overviews,          43                 57
Criteria          inquiring to understand their rights, etc.
Charge Status     Caller has already filed a charge and        59                41
                  wants to know the status
File a Charge     Caller is interested in filing a charge      70                30
Non EEOC          Caller is seeking information about other    0                 100
Related           Federal agencies
EEOC Office       Caller is seeking information about an       20                80
Information       EEOC office
Other             Other types, e.g. caller wants a             42                58
                  publication, an employer calling,
                  complaints about the EEOC, etc.
Total             All Calls                                    49                51

As shown in Table 18, the 51 percent of calls that are resolved at the NCC equate to
approximately 13,964 staff hours per year, which is equivalent to 6.7 Full Time Equivalent
(FTE) Investigators.[23]

                           Table 18. Average Hours Saved per Month
                                                    Projected
                       Current Value (Based on Average Best Case (Based on Call Volume
                       Call Volume for first 13 months of for March 2006, claimed as the
        Metric                 NCC Operations)                 busiest month for NCC)
Projected annual      273,804                             319,020
calls (1)
Percent of calls   51%                                          51%
resolved by CSRs
Annual call volume 139,638                                      162,700
handled by the
CSRs (2)
Call duration in       6                                       6
minutes
Staff hours saved      13,964                                  16,270
per year
Staff hours saved      1,164                                   1,356
per month
FTE                    6.71                                    7.82

(1) Actual total calls for April 2005 through March 2006 was 269,693

(2) Excludes IVR calls

This hourly savings per month is consistent with employee comments that they perceive little
savings resulting from the NCC taking calls to their office public number.

E. NCC IMPACT ON FIELD STAFF

The NCC is beginning to create additional time for field staff, but some factors are limiting
further improvement. Both organizations are duplicating work, and the NCC is creating more
work by sending EASQs and GroupWise emails that are often inaccurate and incomplete. The
NCC also inconsistently forwards “hot line” callers (those at risk of losing their right to file
under the Statute of Limitations (SOL)). Comments about the NCC (by EEOC management and
employees) were generally similar across all visited offices.

1. The NCC has created some additional time for field staff to perform other
duties.
Redirecting Office Resources

Fourteen respondents to the director survey indicated that the NCC has helped address some of
their office staffing resource challenges (Investigators, 6 offices; Support Staff, 8 offices), as
shown in Table 19,. Six respondents indicated that the NCC has saved Investigators time
because they no longer have to answer unsolicited calls on their office public number or return
calls that are not in the EEOC's jurisdiction. Eight respondents said that the NCC has improved
the efficiency and effectiveness of their support staff, and some Directors have been able to
redirect their support staff to help Investigators. Eleven of these fourteen offices are redirecting
callers to the NCC after business hours. The JPS Team found no relationship between these 14
offices and Merit Factor or Non-ADR Resolutions per available Investigator.

Two respondents to the director survey indicated no ability to redirect resources, which they
attributed to an increased number of inquiries since launching the NCC. Five respondents
reported that the NCC has increased their workload, particularly at the supervisory level, largely
because supervisors review and track the NCC forms to ensure that staff handle them
appropriately, which causes them to get behind in other duties. All remaining offices reported no
ability to redirect resources. Reasons cited included increased paper and follow-up work related
to EASQ and GroupWise emails, and attrition over the past few years (people are still behind in
their duties).

                           Table 19. Impact of the NCC on EEOC Offices
                                                               Number of Offices
                                                     District Field Area Local              Total
                   Impact on Offices                  Office Office Office Office          Offices
   Some positive impact for Investigators due to 2           -      1      3              6
   no longer answering unsolicited calls (savings
   of 1-3 days per month)
   Some positive impact for support staff           -        1      2      5              8
   (Receptionist, Investigator Support Assistant);
   instead of answering phones, they are more
   efficient at their job or are handling NCC paper
   work
   Resource allocation the same, partially due to 1          -      -      1              2
   perceived increased number of inquiries
   (possible reasons include NCC)
   There is more work because they are handling 1            2      2      -              5
   more calls and NCC paper work requires more
   Supervisor / Investigator time
   No change. Everyone is doing what they did 3              -      -      -              3
   before and/or phone time savings have shifted
   to NCC paper work
   Do not know or same amount of work so have 8              6      10     3              27
   not redirected any resources

The net staff savings for the 6 offices that realized the greatest benefit is equivalent to 5.2 FTE
Investigators. The savings for the eight offices that realized benefits in support staff are difficult
to quantify, because the improvement ranged from enabling Receptionists, Office Automation
Assistants, and Investigator Support Assistants to do their own job better to helping support
intake and/or help with NCC related forms. The team assumes that the support staff savings
equate to approximately 1.5 FTE Investigators, yielding the same 6.7 FTE Investigators as
described earlier.

One District Director commented that it is difficult to assess the NCC's overall impact because of
possible confounding factors. As reported, this is partially because offices have no baseline data
on number of calls or volume of email and regular mail. As a result, there are no objective data
describing the NCC's impact on the workload in the field. In this district, offices were unable to
handle their call volume, which resulted in many unanswered calls or people calling the office
again. The NCC is picking up the slack on the unanswered calls, but since those calls were not
absorbing office resources, the NCC has not significantly freed up staff members to perform
additional duties or reduce assigned workload.

Investigator Work
During field site visits, Investigators indicated they still have the same duties as they did before
NCC implementation, assertions that have been confirmed by Enforcement Managers who
reviewed the specific duties and Attorneys who said the Investigators have no more time since
NCC implementation. Attorneys who spoke with the JPS team indicated that the quality of cases
has improved over the past five years, but there are no data suggesting that this is attributable to
the NCC.[24]

Some survey respondents commented that the NCC has not reduced their workload . Employees
in focus groups and survey respondents indicated that one reason may be that the NCC is
providing only limited support by taking phone messages and relaying information unless the
call is blatantly non-jurisdictional. Survey respondents commented that the NCC functions like a
glorified answering machine.

Comments by Investigators and other staff that the NCC has not created additional time for
investigations may suggest a lack of communication about expectations related to the NCC.

A main purpose of the NCC was to relieve Investigators from answering unsolicited calls, which
was expected to increase time available to conduct investigations - not to relieve staff of intake
duties. As shown in Table 19 above, six respondents to the director survey reported that
Investigators are no longer answering and/or returning unsolicited calls.

However, even with the support of the NCC, one office is still receiving around 100-115 pieces
of direct mail inquiries a week, 45-50 EAS/GroupWise emails from the NCC, 60-80 messages on
their phone intake line a week, and an untracked number of calls on their public telephone
number. If an average intake inquiry takes 45 minutes, they estimate that Investigators would
spend 25% of their time on intake; and management estimates that it actually takes over 30%;
therefore, Investigator workload remains high. The JPS Team has no empirical data with which
to judge changes in workload. At the sites the team visited, Investigators indicated that they are
no less busy now than prior to the NCC. One of the Regional Attorneys noted that the
Investigators need more people and relief on their workload, and that there is presently hostility
because Investigators perceive that the NCC is receiving a high amount of money when money is
tight.

Other Staffing

Attorneys reported that they performed their own clerical work because some of their support
staff are helping with intake (answering phones and other duties), which they anticipated the
NCC would handle. Some offices report no noticeable change in workload for Office
Automation Assistant and Investigator Support Assistants and the Secretaries/Receptionists
indicate new duties as result of the NCC, such as downloading the EASQs and GroupWise
emails and tracking disposition.

2. The NCC is creating inefficiencies by duplicating/creating more work for offices in the
field and/or performing insufficient screening.

Duplicating Work
The NCC is collecting and forwarding basic information on the EASQ to the EEOC offices.
Intake employees are repeating some of the process, which is causing a duplication of work.
Office supervisors and survey respondents reported that they have to start the intake process over
and obtain basic information from PCPs who call or come to their office through the NCC. One
office has started screening all NCC contacts for all EEOC jurisdictional issues because it does
not appear as though the calls are screened by the NCC. One respondent to the director survey
wrote:

“The NCC has actually increased the work for [this] office by taking duplicate calls, capturing
and forwarding incorrect information about the individual's contact information and providing
incorrect information to callers.”

The NCC also creates duplicate work when it does not sufficiently crosscheck the IMS, which
occurs for the EASQs as well as the GroupWise emails. One director explained that often the
“Notes” section in the IMS may already contain information stating that the office has left a
message for the PCP when the office receives a GroupWise email that no one has returned the
PCP's calls. As one respondent to the director survey wrote:

“It seems like a duplication of effort when we have made contact with a PCP [to] then get
information from the NCC that we need to call the person (who has already been called).”

As described above, some survey respondents and employees in focus groups in several offices
reported that the NCC is not checking to determine whether an individual has an existing charge
or looking up case status. Thirty-nine percent of survey respondents involved in intake reported
that many (more than twenty percent) of the EASQs that they review are for PCPs who already
have an inquiry in the IMS and therefore should not have been forwarded as an EASQ. This
duplicates work and frustrates the Investigators when they invest time discussing the potential
charge and then, upon entering the inquiry in the IMS, discover that another Investigator had
already entered the information a week earlier. Of the 238 survey respondents involved in
intake, 46 percent reported that many of the GroupWise emails that they reviewed were for
people inquiring about charge status, which could possibly have been resolved at the NCC. The
2003 Assessment Report indicated calls related to case status as one of the types of calls that the
NCC could handle; however, to ensure CP privacy, NCC business rules require that the CP
provide the EEOC charge number and one other piece of identifying information. This means
that CSRs should forward some calls inquiring about case status to the EEOC office for
handling, but because CSRs think that they must have a charge number to look up a case in the
IMS, they do not use the IMS to identify whether callers have previously filed an inquiry with
the EEOC.

Creating More Work

The NCC may be creating more work for EEOC employees under the current processes. During
JPS Team site visits, office managers and supervisors reported that the NCC has created another
avenue for customers to complain if issues are not handled as quickly as they think they should
or if they do not agree with the determination. This results in offices having to reopen previously
closed cases. Twenty-seven percent of survey respondents involved in intake reported that many
(more than twenty percent) of the GroupWise emails that they reviewed were complaints about
the processing or outcome of a closed case. Employees commented that callers appear to
perceive the NCC as another avenue to contact the EEOC, often creating more work. One
survey respondent wrote:

“A CP that is not satisfied with a Predetermination interview or anything else the field office
does, simply calls the NCC who now generates a customer complaint [that the field is already
aware of] but now must [stop other work and] respond to within 48hrs.”

In addition, by not fully disclosing their role in the intake process, the NCC may be creating
confusion about the difference between the NCC and EEOC. For example, one comment in the
responses to our office director survey explained that a CP would often call the Investigator,
leave a voice mail message, and then dial the NCC. In a similar vein, 42 percent of survey
respondents indicated that many PCPs they talked with had the impression that they filed a
charge with the NCC. One office is trying to eliminate this confusion by requesting that staff
discuss the NCC's role during charge counseling to assure the CP that the NCC is part of the
EEOC.

 Table 20. Field Staff Opinion about whether Potential Charging Parties Thought they Filed a
                                   Charge with the NCC
 Potential Charging Parties who thought they Filed a Charge           Percent of Survey
                        with the NCC                                     Respondents
None                                                            33
Relatively few (1-20%)                                          25
Relatively many (>20%)                                          42

Focus group participants indicated that some PCPs do not want to answer questions from
Investigators because they already gave most of the same information to the NCC and ask why
they had to talk with the NCC. This perception by PCPs can affect Investigators and the PCP
because it takes Investigators extra time to backtrack and explain the limited role of the NCC.
Survey respondents wrote that CPs indicate frustration when they have to retell their “story” to
another person.

NCC Screening

The field survey respondents indicated that the NCC is screening out many non-jurisdictional
cases. Table 21 shows that the NCC is effectively screening most of the categories listed. For
example, 62 percent of respondents (involved in intake) said that no EASQs inquiring only about
age discrimination were from people less than 40 years old, and were therefore appropriately
screened; however, screening related to the EEOC bases of discrimination shows that 38 percent
of respondents indicated that many of the EASQs they received should have been screened out.
This number may be somewhat high compared to the other categories if survey respondents
indicate that the basis recorded on the EASQ was incorrect (one office indicated that it looks like
the CSRs are randomly picking a basis). In support of these survey responses, the JPS Team
observed that CSRs read the list and let the caller pick the issue, often without asking why the
caller thought the basis was discriminatory (for example, if age discrimination, the CSR often
does not ask the person's age/date of birth).
             Table 21. Effectiveness of NCC Screening for Non-Jurisdictional Calls
                                            Percent of Survey Respondents Believe
                                                          A few EASQs Many EASQs
                                        All EASQs were should have should have
           Categories the NCC is         appropriately been screened been screened
                   Screening                screened      out (1-20%) out (>20%)
       Not job related                 43                36             21
       Federal complaints              67                27             6
       Not national origin, race,      27                35             38
       sex/gender/pregnancy, religion,
       age, color, disability or
       retaliation
       Company with 14 or fewer        43                41             16
       employees
       Age only and in companies       63                26             11
       with 19 or fewer employees
       Age only and less than 40       62                27             11
       years old

A few survey respondents also commented that it would be helpful if the NCC would screen out
or identify repeat callers and frequent filers.

3. EASQs and GroupWise emails provide limited useful information.

The EASQ was designed to provide only basic information to submit an inquiry to the EEOC,
including who, what, where, when, and why a PCP believes an action was discriminatory. Its
purpose is to provide intake staff sufficient information to prepare for the formal interview, not
to relieve field staff of intake responsibilities.

During the pilot phase of operations, the number of EASQs sent by the NCC to the EEOC offices
has continued to increase. One year after implementation, the number of EASQs has more than
doubled since the NCC's initial month of full operations.

                           Table 22. Number of EASQs sent to EEOC
                                           Offices
                                                      No. EASQs
                                                     sent to EEOC
                             Month/Year                 Offices
                       April-05                1,979
                       May-05                  1,676
                       June-05                 1,923
                       July-05                 1,748
                       August-05               1,950
                       September-05            1,578
                       October-05               1,612
                       November-05              1,788
                       December-05              1,843
                       January-06               2,668
                       February-06              2,472
                       March-06                 3,821
                       April-06                 4,276

Inaccurate or Incomplete EASQs

The EEOC Project Manager encourages EEOC staff to report any NCC related problems to him
or his staff. He indicated that he often works with field management staff to handle complaints
regarding accuracy of EASQs. OFP reported that EEOC staff forward misdirected EASQs,
misspellings, and any other problems to Headquarters and the EEOC Project Manager discusses
them with NCC managers. These NCC Managers counsel CSRs who have made errors.

Survey respondents commented in February that NCC forms often have errors. Investigators
from one office agreed that EASQs are “threadbare” (inaccurate and/or incomplete) 85 percent to
95 percent of the time. One Office Director wrote:

“More often than not, there are major errors in the information that has been provided by the
NCC. Just two examples: 1) Shondra Weager is really Sondra Yeager. 2) PCP's Religion is
Musselman. There are so many more examples. Addresses, telephone #s, and general
information are often incorrect. We spend numerous hours receiving, responding, correcting and
then re-entering information from EAS to IMS.”

During the JPS Team's focus groups, intake staff from several different offices reported that the
NCC usually provides the name correctly, but that sometimes the phone number is wrong and
that they often receive little useful information on the form.

Inaccurate or incomplete EASQs may limit the extent of their usefulness. Survey respondents
indicated that they use varying types of information on the EASQs, which may be related to
inaccurate and incomplete EASQs and/or different intake methods in respective offices.

                 Table 23. Extent Intake Staff Uses Information on the EASQ
               Information used on the EASQ Percent of Survey Respondents
               User information                73
               Employer information            57
               Complaint information           61
               Never use the EASQ              24

As shown in Table 24, survey respondents reported that many of the EASQs are inaccurate, thus
requiring more work by the EEOC office to fix the error. Twenty-four to forty percent of survey
respondents involved in intake reported inaccuracies on many of the EASQs they reviewed over
the previous three months.
                                  Table 24. Inaccurate EASQs
                                                  Percent of Survey Respondents Believe
                                              All EASQs A few EASQs         Many EASQs
                                                 were          were not        were not
       Types of EASQ Information               accurate accurate (1-20%) accurate (>20%)
User Information
       Name                                  38           36              26
       Address                               35           35              30
       Zip code                              40           36              24
       Phone number                          38           38              24
Employer Information
       Full name                             25           35              40
       Full address                          24           36              40
Complaint Information
       Description of action against person 38            37              25
       in the Complaint Information section
       was not employment related
       Issue in the Complaint Information 29              41              30
       section was not one of the bases
       covered by the EEOC

Focus group participants in four of the seven offices that the JPS Team visited indicated they
receive many incomplete EASQs. Survey respondents reported that they receive incomplete PCP
information, employment information, and details about the basis of discrimination. As shown
in Table 25 below, 25 percent to 47 percent of the survey respondents involved in intake reported
that many of the EASQs that they have reviewed over the previous three months are incomplete.

                                Table 25. Incomplete EASQs
                                     Percent of Survey Respondents Believe
  Types of EASQ         All EASQs were A few EASQs were not Many EASQs were not
     information            complete         complete (1-20%)       complete (>20%)
User Information
       Name            51                 24                          25
       Address         36                 30                          34
       Zip code        37                 32                          31
       Phone number    40                 31                          29
Employer Information
       Full name       23                 33                          44
       Full address    20                 33                          47

The JPS Team independently audited 12 months (April 1, 2005-March 31, 2006) of EASQs sent
to 3 offices to determine the accuracy and completeness of the user and employer information.
The team was only able to compare those EASQs for which there was a matching record in the
IMS. On average, 37 percent of the EASQs had errors in the PCP and/or Respondent fields
(range 24 to 59 percent), and 20 percent of the forms had errors in just the user information fields
(range 16.4 to 25.7 percent). There is no indication that accuracy has improved over time.

In addition to user and employer information, focus group participants indicated that the
complaint information is often incomplete, which has led office intake staff and supervisors to
suggest that CSRs need to ask a few simple questions to provide some descriptive information on
the form. Employees indicated that the issue in the allegation is often not clear on the forms and
there is less information than staff expected. For example, if the form indicates that the basis is
race, it does not indicate why the PCP thought it was discriminatory.

As shown in Table 26, survey respondents indicated that they would particularly like to receive
more information relevant to the basis for discrimination.

                          Table 26. More Complaint Information Desired
                                                                                Percent of Survey
                        Complaint Information                                     Respondents*
More details regarding what happened to the customer and why they 67
believe it to be discriminatory
Specific behavior/conduct prompting the complaint                          58
If the basis for discrimination is race, then provide the person's race 71
If the basis for discrimination is age, then provide the date of birth 73
If the basis for discrimination is disability, then provide the disability 70
If the basis for discrimination is retaliation, as on what basis they      72
were retaliated

*Respondents checked all that apply

Focus group participants suggested that if the CSRs asked just a few questions, the Investigators
could make a decision as to whether to send a questionnaire, thereby weeding out cases that will
not lead to a charge. One survey respondent wrote:

“If a complaint is about national origin, do not go into race, but discuss what the issue is!!”

As reported in one site visit, as the system is presently working, the EASQs often provide less
information than a typical mail receipt and require additional time for Investigators to resolve the
inaccuracies.

Validating the above EEOC staff observations, while monitoring calls at the NCC, the JPS Team
observed that the CSRs do little to inquire about and understand the nature of the charge. For
example, if the basis that the caller selected for discrimination is age, the CSRs do not ask for
age or date of birth to make sure the callers qualifies under that category. They leave it
completely up to the PCP to determine whether his/her situation is discriminatory.

Additional Information Needed
As shown in in Table 27, survey respondents indicated they would like additional information on
the EASQs.

                         Table 27. New Information Desired in EASQ
         Types of New EASQ Information Desired Percent of Survey Respondents*
        Date of most recent incident of discrimination 77
        Convenient time to contact the customer        56
        Number of employees in company                 71
        Who the customer is using for comparison       61

*Respondents checked all that apply

In addition, survey respondents wrote that they would like the following new information on the
forms:

      PCP's Date of Birth and Social Security Number
      Language requirements if not English

Staff in one office stated that the EASQs are of minimal value since they do not contain
sufficient information to begin an intake interview (e.g., the alleged harm, when it occurred,
PCP's date of birth, bases/issues involved, and why the PCP believes it is discrimination).

GroupWise Email Forms

The CSRs do not provide sufficient information on the nature of the complaint in the email. The
GroupWise email forms only state that the PCP/CP cannot reach the office. The offices need
more information, including who and when the person called, the reason they were calling, what
happened when they called, and whether they called the Investigator directly. Because of this
lack of information, EEOC supervisors do not know if there is a problem that needs to be
corrected and what actions/procedures to correct. As shown in Table 28, more than 60 percent of
the survey respondents involved in intake reported that the GroupWise emails they receive from
the NCC are inaccurate and/or incomplete.

               Table 28. Accuracy and Completeness of GroupWise Emails
                               Percent of Survey Respondents Believe
                                           A few GroupWise        Many GroupWise
 GroupWise      All GroupWise Emails     Emails have problems Emails have problems
    Email      were accurate/complete          (1-20%)                 (>20%)
Accuracy     8                          24                     68
Completeness 12                         25                     63

The JPS Team analyzed NCC-related GroupWise emails to one district office for January-
March, 2006.[25] The team was unable to assess accuracy or completeness because many of the
emails related either to information not in the IMS or to EASQs that were not yet updated in the
IMS. The team did, however, identify that approximately 40 percent of the emails were from
PCPs who were calling the NCC before allowing offices the allotted four to six days to process
the EASQ. Receiving these emails and having to track down information adds no value to the
end-to-end process and creates extra work for the office staff.

                        Table 29. Content Analysis of GroupWise Emails
                           GroupWise Email Subject                                 Number Percent
Transmit letter/fax/email                                                          13     6.4
Complaints about office/Investigators                                              13     6.4
Language needs                                                                     5      2.4
Convey message to office (e.g., to set up appointment, change address, request     11     5.4
forms)
Questions the NCC cannot answer (ADA, training, employer rights/questions,         19       9.3
attorney questions, insist on filing charge)
Cannot call long distance                                                          12       5.9
PCP/CP uses the NCC to leave message for Investigator instead of calling           13       6.4
directly
Complaint — tried but cannot reach Investigator (usually do not explain what       10       4.9
happened e.g. how many times tried, whether left a message)
EAS sent to wrong office (2 emails from NCC, 4 directly from other offices)        6        2.9
Case status                                                                        21       10.3
Second call before office response time elapsed (within 1-4 days of initial        81       39.7
contact to NCC)
Total GroupWise Emails                                                             204      100

4. “Hot line” transfers of callers (when the date of harm is within the 60-day window of the
SOL expiring) are handled inconsistently.

Procedures for callers at risk of losing their rights to file a charge (because they are close to the
end of the SOL) differ from procedures for callers not at risk. When a PCP indicates a date of
harm that is within a 60-day window of the SOL expiring (30 days on either side of the projected
deadline for filing a charge), the CSR transfers the caller directly to the office designated to
handle these “hot line” calls.

Effective January 1, 2006 two EEOC offices were designated to receive hot line transfers. The
EEOC added two offices to help with these calls on April 17, 2006. The four offices are in three
different time zones across the United States and each is supposed to handle calls within a
designated three-hour period, starting at 8 a.m. and ending at 8 p.m. EST; however, managers in
two offices indicated they receive hot line calls all day long.

To ensure only callers within the 60-day window are “hot” transferred, the EAS has a built-in
calculator that automatically notifies the CSR when a caller should be “hot line” transferred to
the appropriate EEOC office. When the EAS is not used, the CSRs use a desktop calculator to
determine if the caller should be “hot” transferred to the designated EEOC office.
Nevertheless, one office stated that 30 percent of the calls they received from January through
April were outside the 60-day window, and 5 percent to 10 percent of the calls were not truly hot
line calls (PCPs were inquiring about the status of a case that had a date of harm close to the
expiration window). Managers in one EEOC office said that transferring these calls outside the
designated window can create unrealistic expectations on the part of the caller and create extra
work for the office because employees must stop everything to address an issue that is not truly
urgent.

There are presently no written procedures for how EEOC offices should handle hot line calls,
and procedures vary across the offices. For example, Headquarters requires that a non-
bargaining employee answer the initial call from the NCC. Three of the offices have a dedicated
cell phone for the hot line calls, but in one office, the calls come in all day long on their regular
office number and are answered by whoever picks up their main number. If their two extensions
are busy, the call rolls to the next available person in the office. Some managers believe they are
personally responsible for handling everything related to the call, which is very time consuming.
Others take down basic contact information and pass the information to a bargaining unit
employee to follow up.

5. Not all calls forwarded or referred to EEOC offices are related to filing charges.

EEOC Workload

Call volumes, types of calls, and call resolution (calls handled entirely by NCC) have an impact
on the EEOC's workload. As discussed previously, current call volumes to the NCC are lower
than anticipated and are not having a major positive impact on EEOC workloads compared to
EEOC expectations.

Forty nine percent of calls received by the NCC are sent (directly or indirectly referred or
forwarded) to EEOC offices. Of these calls, 61 percent consist of people who wish to file a
charge, and the remaining 39 percent are related to general inquiries, EEOC overviews, or
questions about charge status

Figure 4. Types of Calls Forwarded to EEOC Offices
Numbers in the chart do not total 100 due to rounding.

Streamlining processes and integrating technologies can help reduce the number of calls (38
percent of all calls) forwarded to EEOC offices that are not related to filing charges.

Of the total calls forwarded to the EEOC related to filing charges, 38 percent are forwarded to
EEOC offices by an EASQ and the remaining 62 percent of callers are asked to contact the
EEOC office directly. When CSRs ask callers to contact the EEOC office directly, they send no
information to the offices; therefore, the time spent by the EEOC in handling these calls is a
duplication of work. These calls are handled by the EEOC as if they were first-time callers and
all of the information collected by the NCC is collected again.

The CSRs' practice of telling people to contact the EEOC office may create problems for PCPs
who visit the office and desire to file a Charge. For example, particularly in the smaller offices
and depending upon the staffing and the workload, Investigators may not be available when the
person shows up, wasting the PCP's time.

Overall, there remains an opportunity to reduce the number of calls sent to EEOC offices even if
the volume remains constant. As stated previously, the NCC currently sends 49 percent of calls
to EEOC offices. Following are areas where the NCC can further reduce these calls:

      Thirty nine percent (of the 49 percent) of calls that NCC sends to EEOC are issues not
       related to filing a charge.[26] Streamlining processes and integrating technologies would
       substantially reduce these calls.
      Another 38 percent (of the 49 percent) of the calls sent to EEOC offices relate to callers
       who inquired about filing a charge and made the first contact with NCC but were asked to
       contact the EEOC directly. The CSRs enter data regarding every call into RightNow
       software, a Customer Relationship Management (CRM) technology that documents all
       information related to calls. If the EEOC were to use the NCC's RightNow system, they
       would be able to access the preliminary information about the contact and thus reduce
       this duplication of work.
The NCC is not resolving as many calls as they could, and therefore is having minimal impact on
EEOC workload (1,164 hours saved per month, as shown in Table 18).

F. INTEGRATION OF THE NCC AND EEOC

Operationally, there is minimal direct communication between the NCC and EEOC field offices,
as their technologies are incompatible. The NCC has provided some recent support to EEOC
offices in identifying trends. EEOC staff experiences with the NCC, coupled with minimal
change management practices, have resulted in unrealized expectations.

1. There is minimal direct communication/knowledge sharing between EEOC offices and
the NCC, which inhibits integration of the organizations and processes.

Supervisors in the field indicate that they receive little or no useful information generated by the
NCC, NCC processes are not transparent, and there is no process for the Investigators to feel
vested in the NCC. Prior to February 2006, the only regular written communication to the field
about the NCC had been a monthly report to directors (this monthly report was also sent to all
staff in the field in February 2006) describing the following statistics:

      Total calls handled, average handle time, IVR calls, and other types of transactions.
      The largest number of customer contacts, the number and type of foreign language calls,
       peak calling time, and number of hot line calls.
      Number of EASQs sent and to which offices, the number of customer
       concerns/complaints forwarded to offices, and the number of people whom the NCC
       provided with information about contacting the appropriate EEOC office.
      Number of visits to the FAQ page on the EEOC's website and most frequently visited
       topics.

The EEOC circulated the inaugural issue of the EEOC National Contact Center Newsletter to all
EEOC employees in February 2006. The newsletter included a section describing results to date,
positive comments from a few field offices, training activities at the NCC, personal stories about
two people who contacted the NCC, and a picture and short biographical description of two
CSRs.

Communication exists between the NCC Project Manager at Headquarters and Office Directors,
Deputy Directors, Enforcement Managers, Intake Supervisors, and a few others. One District
Director said that the EEOC Project Manager often contacts them with requests for feedback.
The EEOC Project Manager regularly briefs District Directors and other field personnel when
they have occasion to visit Headquarters. From time to time, OFP responds to inquiries from
office managers and supervisors regarding the NCC.

There is no formal process for EEOC employees to ask questions directly of CSRs or give
feedback on how the NCC can better serve the offices. When a recent concern arose, one Office
Director notified the district office of an urgent problem caused by the NCC but two weeks later
had not receive feedback on how or whether the issue was ever addressed. To date there has been
minimal direct communication between one EEOC office and the NCC when the office sent an
email request for more information about incident reports, even though there was no established
process for this direct communication. In another office, a manager would like to communicate
directly with the NCC to ask more questions about information in EASQ/GroupWise emails.
Investigators would also like to communicate directly with CSRs rather than through the formal
system (Headquarters and GroupWise Email). For example, the NCC uses the GroupWise
emails simply to convey that a party is returning the call of an Investigator (perhaps avoiding a
long distance call), adding a layer of communication and disrupting the normal workflow. One
office director and survey respondents indicated that they believe that the NCC adds another
layer of bureaucracy for customers.

Further complicating the relationship between EEOC offices and the NCC is that the GroupWise
emails contain phrases suggesting that the offices are not doing their job properly. Survey
respondents indicate that it appears the CSRs do not understand what is happening in the offices.
Following is a written comment from one EEOC Office Director:

“The emails come through auto-assigned to wording that says the office failed to do something.
The standard language is ‘fail to respond.' This creates misunderstanding and is frustrating for
the offices because usually they are in the process of trying to reach the person and for one
reason or another have not yet connected. First, the NCC should cross-reference with the IMS to
see what is happening on the case. The language in the form and process should be revisited.”

There is no direct communication process between the NCC and EEOC offices; most
communications are presently routed through the EEOC Project Manager. This inhibits the
ability of employees in each organization to understand the activities and requirements in other
organization.

2. NCC knowledge about EEOC offices is minimal, and the information flow is sporadic
and inaccurate.

NCC Staff Understanding of EEOC Objectives and Operations

Interviews with NCC team leaders and focus groups with CSRs revealed that there is no
common understanding of the NCC's program objectives. One Team Leader stated that the
mission of the NCC is to “provide a general overview about the EEOC, information on
discrimination, and forward escalations.” Another Team Leader stated that it is to “handle 70
percent of the calls that the EEOC was receiving and document the types of calls received for
trending purposes.”

While these two mission statements seem similar, their focus is completely different. The first
one focuses on providing general information and forwarding escalations, and therefore does not
put a great deal of emphasis on documenting the call so that the EEOC can identify trends. A
CSR taking direction from this Team Leader will be more focused on listening to the customer.
The second Team Leader focuses on providing information and documenting the types of calls.
A CSR taking direction from this Team Leader will be more focused on documenting
information than listening to the caller. This presents two very different customer experiences.
While these two Team Leaders have different roles, they should have the same views on the
mission of the NCC. The issue is that, throughout the day, CSRs may ask questions of one or the
other Team Leader and get different instructions on how to handle calls.

NCC management staff and CSRs said they had little insight into EEOC operations. They have
regular visitors from Headquarters; however, few people from the field have ever visited the
NCC. There are no standardized processes across the EEOC field offices. According to the team
leaders, having contact with the field operations through either visits or regular phone meetings
could improve the effectiveness of operations at the NCC.

NCC/EEOC Communication

Interviews and focus groups at the NCC have also revealed that the CSRs have little insight into
the use and validity of information that they provide to EEOC offices. Several CSRs stated that
there is no feedback from the field and that they would like to hear when there are inaccuracies
in the information they send so they can make improvements. The only feedback these CSRs
mentioned related to spell checks, and so they had the perception that everything else in terms of
accuracy was fine, but, as discussed earlier, the JPS Team's findings contradict this impression.

3. Many EEOC and NCC technologies are incompatible, which adds to the workload of
EEOC offices.

There is no integration of technologies between the NCC and EEOC. The CSRs capture a great
deal of relevant information about the transaction into RightNow. If the caller wishes to file an
EASQ, the CSR must transfer the information to the EEOC Assessment System (EAS). The
NCC presently has “read only” access to the EEOC's IMS. This fact, combined with a lack of
integration between IMS and/or RightNow and EAS, results in the requirement that EEOC staff
enter information from the EASQ into the IMS.

When callers want to get a message to offices or have a complaint, the NCC puts the information
into the RightNow software and then separately sends a GroupWise email to EEOC offices. The
EEOC offices send information back to the NCC describing disposition of the complaint, which
the NCC then records in the RightNow software. Further complicating this issue is that some
EEOC offices respond to the NCC with the disposition of each specific issue, and others send
back an almost automatic response indicating that the general issue was addressed. In the latter
instance, the CSRs never record correct information into RightNow and never have an
opportunity to understand or, if the caller contacts the NCC again, explain what is happening at
the EEOC office to the customer. The two organizations are maintaining parallel information
systems that are not communicating with one another.

As a result, inefficiencies exist at NCC and the EEOC. There is duplication of data entry for the
NCC (RightNow and EAS), duplication between NCC and the EEOC (EAS and IMS), and the
EEOC cannot see the string of information maintained by the NCC in RightNow. This causes
the EEOC to have callers who have already spoken to the NCC repeat their entire story, since the
EEOC does not have the benefit of information recorded in RightNow, creating a frustrating
experience for the customer.
The lack of integrated technology between the NCC and EEOC has led to a duplication of work
and added to the reasons that the NCC has not reduced the workload on EEOC employees. The
EEOC's Office of Information Technology (OIT) plans to develop a link between the EAS and
IMS in the near future so that the EEOC's field offices will not have to continue performing
double entry of data for inquiries referred by the NCC.

Escalations

The lack of technology integration also prohibits the NCC from viewing the status of inquiries
until they become a charge, leading to emails that escalate issues that EEOC offices are already
handling. This causes duplication of work because EEOC employees now have to attend to these
emails and provide an explanation back to the NCC, which the NCC then records in the
RightNow software.

As described earlier, EEOC business rules prohibit the NCC from disclosing information about
charge status unless the caller can provide the charge number and one other piece of identifying
information such as home address, phone number, or date of birth. During the team's site visit to
the NCC, the CSRs indicated that they require a charge number to look up information in the
IMS. If the caller does not have a charge number, which occurs often, the CSR must refer
him/her to the EEOC offices; therefore, the NCC forwards many calls related to charge status to
EEOC offices.

Communication with the staff at Headquarters indicated that the NCC has exactly the same
access as the EEOC offices in terms of looking up information in the IMS, i.e., they can look up
charges several different ways including by CP first and last names, Social Security Number,
receiving office, and Investigator name. CSRs have the same “read” access to the IMS as the
field offices, but under EEOC business rules, they are not allowed to reveal any information to
callers without their charge number and one other piece of identifying information such as home
address, phone number, or date of birth.

Since CSRs do not have access to any other system the EEOC uses or any way of knowing
EEOC information that the EEOC has not recorded in the IMS, they sometimes send escalations
that are truly duplication of work. This adds to the EEOC workload.

Integration of all of the EEOC's data systems has been a long-time goal, and the EEOC plans for
integration of the EAS and IMS for late 2006. The JPS Team is not aware of any discussions to
integrate the RightNow software into EEOC systems.

4. The NCC processes are not adequately set up to identify trends.

One of the NCC's objectives is to provide the EEOC with trends such as geographic and
demographic information about the callers and reasons for their calls. One Office Directors
reported that the NCC reports they currently receive are not much help and that they need data
relevant to their region. They also indicated concern about any trends due to inaccuracies in
forms they receive from the NCC. Assuming inaccuracies are corrected, the trend information
the offices would like to receive is provided in Appendix I. Some of the trends directors
requested are currently available by querying the IMS or in monthly NCC reporting. Some
directors were not aware that they have access to some of the information that they requested.

Over the past year, the NCC has identified a new trend: the NCC forwarded pre-employment
discrimination to the EEOC as a new type of call for which there was no previous information
within either the FAQs or the scripts. This led to the EEOC developing FAQs for its website and
scripts for CSRs.

Review of the reports generated by the NCC shows that there is no automated method to identify
trends. The NCC sends monthly reports to the EEOC that are a snapshot of that month. There is
no month-by-month data analysis to identify trends in terms of callers, reasons for calls, or call
dispositions.

Collecting and reporting demographics were important trends cited by most of the NCC staff.
CSRs collect demographic information on all calls; however, none of the reports show these
data. The NCC recently began providing some demographic information, but even these reports
are not set up to identify trends proactively. Even though the EEOC has identified some trends
based on questions raised by CSRs, there is presently no methodology or logical approach to
identifying trends.

5. EEOC employees have concerns and unrealized expectations about the NCC

Change Management

During the JPS Team's site visits, office management reported that there was not enough up-front
communication about why the business decision was made to implement the NCC, so initially
the role of the NCC seemed undefined. One Office Director commented that the NCC should
have field staff concentrate on identifying low priority Category C cases that are usually
dismissed after only minimal investigation. Identifying Category C cases before Investigators
spend time investigating should increase their efficiency and effectiveness.

Survey respondents confirmed that they recollect hearing information about the goal to reduce
office calls. One survey respondent wrote:

“I can't remember ever having been advised on the major goals of the NCC, other than to reduce
the calls that come in to EEOC offices.”

As shown in Table 30, survey respondents indicated that they generally understand that the
purpose of the NCC is to reduce call volume to offices in the field and provide general
information to callers. Fewer respondents believe that the NCC is supposed to refer calls not in
the EEOC's jurisdiction and less than one third understand that another purpose of the NCC is to
gather trend information.

             Table 30. Survey Respondents who Understand the Role of the NCC
            NCC Role in Enforcement and Outreach                      Percent Survey
                                                                      Respondents*
Reduce calls requiring field office attention                         81
Provide general information about EEOC law, and potential             83
charging party's options
Handle calls not in EEOC's jurisdiction                               58
Gather trend information on employment issues affecting the public    31

*Respondents checked all that apply

Even though employees understand the NCC's purpose, focus group participants and survey
respondents indicated that they still do not understand why the EEOC believes that the NCC is a
better business decision than allocating the money to hiring staff and upgrading the
infrastructure, such as the telephone technology. Field office management staff and survey
respondents also indicated that it would be more helpful to have additional staff than to spend the
money on the NCC.

Unmet Expectations

Office managers believe that the concept of the NCC has been “watered down” and would like
confirmation that the NCC is only supposed to provide “bare bones” support.

The JPS Team's survey and interview data suggest that staff in the field expected more from the
NCC than is presently being delivered. The staff may have expected more from the EASQ than
it was designed to deliver. Management and staff anticipated that the CSRs would conduct more
extensive screening, provide better quality of information in the EASQs/emails, and require less
from field staff due to the NCC handling initial screening. They also expected that inquiries
generated by the NCC would take less time and that the completed EASQ would be a step above
the intake questionnaire (once the questionnaire is completed, PCPs could essentially write their
own charge). Since the EEOC never meant for the EASQ to replace the intake questionnaire,
some EEOC staff may have misinterpreted the reason for the EASQ.

Training

CSRs receive two weeks of classroom and on-the-job training on EEOC jurisdiction (including
application and interpretation of laws enforced by the EEOC), repositioning, antidiscrimination
laws, identification of issues and basis for discrimination, Title VII and other statutes, and
Federal sector cases, as well as how to handle irate customers. Survey respondents indicated a
belief that CSRs need more training on these issues. In addition, respondents to the director
survey wrote that the CSRs need more training on the application and interpretation of laws
enforced by the EEOC.

On the JPS Team's EEOC site visits, managers and supervisors indicated concern that the CSRs
need to understand what they are talking about; anyone can read a script. Managers also would
like assurance that CSRs understand what they should and should not do so that they do not
jeopardize the EEOC's ability to expand the charge and do not turn customers away because they
do not ask the right questions.
Survey respondents also suggested refresher training on common issues such as geography; as an
example of this need, CSRs have sent information to the wrong offices due to confusion of AR
(Arkansas) with Arizona (AZ) and the State of Louisiana (LA) with the City of Los Angeles.

G. NCC IMPACT ON EEOC CUSTOMERS

With the launch of the NCC, customer experience has improved, particularly in areas related to
access. EEOC offices have modified procedures to reflect the NCC activities, driving an
increased focus on customer service. There is an opportunity to improve customer satisfaction
further by streamlining existing and adding new procedures. The EEOC's Customer Satisfaction
Index of 77 is strong.

1. While field office intake procedures vary, they provide timely customer service.

EEOC policy is to give offices flexibility to establish their own intake procedures that meet
staffing needs and other unique demands of their respective offices. As a result, there is a wide
variety of intake methods across the EEOC offices.

Walk-in Customers with No Risk of the SOL Expiring

Most offices (46) provide initial screening by an Investigator or supervisor, if available, while
the PCP is in their office or later the same day, although respondents to the director survey
acknowledge that this is not always possible. The remaining five offices do not have sufficient
staff to see all walk-in customers, so they provide initial screening by an Investigator Support
Assistant, give the PCP a questionnaire to complete, and/or make an appointment for them to
return on another day for screening by an Investigator.

Telephone Calls to EEOC Offices

For people calling the EEOC office to file a charge, 39 offices provide screening by an
Investigator Support Assistant or an Investigator. The remaining offices may perform a quick
screening by the Receptionist and then send an intake questionnaire and/or have an Investigator
return the call within 24-48 hours for more thorough screening.

2. Post-NCC, service to customers has improved in some areas.

NCC as a Customer Service Initiative

Respondents to the office director survey reported best practices related to the NCC including
tacking all NCC forms, making personal telephone calls to NCC contacts and in one instance,
ensuring customers are called and information is entered into the IMS within 24 hours after
receipt. According to one District Director, the NCC has institutionalized the delivery of
customer service, and now the customer service orientation happens every day; rather than being
a one-time initiative. For example, before the NCC, Investigators in one office would take up to
eight workdays to respond to an inquiry. Now Investigators in that office are required to make
two attempts to contact the PCP within 48 hours after receiving the EAS, each at different times
of the day (e.g. morning and afternoon).
Foreign Language Service

The NCC provides multi-lingual availability on the initial call. Spanish speaking customers can
immediately reach someone who speaks their language and are given the direct line of the
bilingual person in the EEOC offices, adding focus to the outreach and supporting underserved
populations. In the future, the NCC's multi-lingual service could potentially help Investigators
with translation services.

Complaints about Offices

Though offices can accept collect calls to ascertain callback information and then return the call,
some offices reported that no longer having a toll-free number is a concern, since some
customers do not want to pay for or cannot afford to place a long distance telephone call. This
issue is relevant to investigations and litigation. Several survey respondents commented that not
having access to a toll-free number has created a barrier between the EEOC and CPs because of
the long distance expense. One Office Director reported no differences in general complaints
pre- and post-NCC, mostly due to antiquated telephone technology.

OFP is exploring the feasibility of establishing unpublished toll-free telephone numbers for use
by CPs and witnesses involved in cases. OFP is presently evaluating the cost and potential
impact on the NCC.

3. While offices have different intake procedures, some say they have modified and
improved their procedures because of the NCC.

With the NCC as the initial step in the intake process, offices have reviewed their intake
procedures and provide back-up systems to front line people, creating an employee sense of
urgency in responding to the public.

Offices have also improved the method by which they track PCPs by recording receipt and
disposition of EASQs and GroupWise emails, either in an electronic (IMS and/or the GroupWise
log assignment system) or paper form.

4. Customers have significantly improved access to the EEOC.

Launching the NCC has added the following new channels (ways) for customers to contact the
EEOC:

      English Line
      Spanish Line
      Tele Interpreter
      TTY Line
      Web Inquiry
      Email
      Fax
      Written Correspondence
EEOC employees report another benefit of the NCC is that customers have access to a live
person on their initial call for more hours of the day rather than having to leave a voice mail and
not receiving a return call until the next day. In addition, each PCP immediately hears from an
office by phone or mail.[27] CSRs can also listen to callers who want to vent their frustrations.

The team identified an opportunity to improve the average speed of answer, as the contractual
metric of answering 70% - 80% of the calls in the first 30 seconds was only met 5 out of the past
8 months.

The improvement in customer access is limited to those customers contacting the NCC.

5. Customer experience is not consistent when they call the NCC. It depends upon the CSR
reached.

Customer Experience

Due to the lack of integrated procedures, customers may sometimes end up confused about their
interaction with the NCC. For example, when customers call the NCC, they do not understand
that it is a separate organization; they perceive their communication as ‘contacting the EEOC.' If
the transaction is not properly documented and not everyone (within the EEOC and NCC)
interacting with the customer has access to that information, there may be possible lost customer
information or confusion about the charge filing status. As described earlier, callers who
explained their situation at length to a CSR have indicated to Investigators that they are confused
about having to repeat the same information.

Differences in how CSRs view their roles also create a widely varying customer experience.
Some CSRs believe their role is to act as a sounding board and listen patiently to the callers
about their discrimination stories while others think their role is to take the preliminary
information and move on to the next call. Those who feel they have to listen to the customer are
patient and attend to all details, focusing on the customer. This provides a very different
customer experience from a caller who reaches a CSR who is solely focused on collecting initial
information.

While monitoring calls, the JPS Team noticed that some CSRs were empathetic and patiently
listened to their customers. Other CSRs were focused on capturing and documenting information
and not on listening to the caller. The latter experience, as we observed, felt as though the phone
call was just a routine process to fill out a form.

Customers calling for general and/or EEOC overview information also have varied experiences,
depending on their particular questions. If the CSR is able to locate the answers easily, he or she
gives the customer the information and the process ends; however, if the CSR is unable to locate
the answers easily, he or she asks the customer to call the EEOC office directly, at which point
the experience becomes the same as pre-NCC.

Figure 5 shows the types of calls received by the NCC and where they ended (EEOC offices or
NCC). The NCC could handle all of the calls related to Eligibility Criteria, Charge Status, and
Filing a Charge, but, as can be seen in Figure 5, the NCC is handling only a portion of these
calls. For example, only 57% of the calls relating to EEOC overview and/or eligibility criteria
are completely answered by CSRs; the remaining 43% are asked to contact an EEOC office.

Figure 5. Call Types by the Organization that Resolved the Call




Customers calling to file a charge also have varied experiences. Some CSRs lead customers to
fill out EASQs, while others lead customers to contact the EEOC office. Only 35 percent of the
customers who called to file a charge actually completed the EASQ. All they have to do after
the call is wait four to six days for a contact from an office. The remaining 65 percent were
asked to contact the EEOC office directly. These customers must continue to try to contact an
EEOC office and find someone to help them.

These customers may believe that they have filed a charge with the NCC. According to the
customer satisfaction survey conducted by CFI (Claes Fornell International) Group in February
2006, 34 percent of the respondents indicated they thought they had actually filed a charge
because of their communication with the NCC.

OFP recently advised the JPS Team that they had changed CSR scripts to include language
advising callers that they cannot file a charge over the telephone. The JPS Team listened to call
records from the NCC and did not hear a CSR convey this information. This may be because
CSRs sometimes do not follow the correct scripts, as reported during the live call monitoring
(discussed later).

Customers who do not complete the EASQ have to contact the EEOC offices directly. Their
experience would be no different than it would have been pre-NCC, e.g., calls not answered by a
live person, mailboxes may be full, etc.

6. Call handling methods are usually consistent, but not soft skills.[28]
CSRs are given call flows for public and private sector calls, and they consistently follow them;
however, the soft skills side of handling calls is not consistent (e.g. courteously answering
questions while maintaining call control, asking the right questions depending upon the customer
tone, and steering the conversation). For support professionals, soft skills refer to anything that
falls outside of the traditional product and development skill set. Soft skills are the ability to
communicate effectively, present ideas, solve problems, and provide excellent customer care.

Some CSRs are patient, listen to the customer for a long time without controlling the call, while
others are impatient, and cut off their callers. In both cases, the CSRs have not mastered how to
control calls. The NCC has pushed for the handle time (length of the call) to be under six
minutes, but provides little coaching and/or training on how to control the call. There is minimal
focus on improving the CSRs' soft skills.

7. Information about general overviews and inquiries is fairly consistent and accurate;
however, other specific information is not consistent or accurate.

The NCC uses standard operating procedures to update the script content, which ensures
information accuracy, but there is no focus on ease of use by the CSRs.

CSRs provide customers with consistent, accurate information regarding charges and other
general inquiries, but specific information relating to infrequently asked questions is
inconsistent. Most CSRs perceive that they have 800 scripts to reference, but, in reality, they
have a subset depending upon the type of call that they are handling. According to the Site
Director, there are 400 Spanish Language scripts and FAQs and 400 English Language scripts
and FAQs.

Unfortunately, in this case, perception is reality. Since CSRs perceive that there are 800 scripts,
they do not take time to understand and use all of them; instead, they select a few scripts that
they use most often and refer only to those for all answers. The result is that, when a customer
has an infrequently asked question, some CSRs try to fit one of the answers into their most
frequently used script, while others refer the customer to field offices. CSRs and one of the
Team Leaders stated that the key word searches are not efficient; for example, during a side-by-
side observation, one CSR said that when she typed ‘Right to Sue,' nothing appeared.

8. The Customer Satisfaction Index is very strong.

The EEOC recently contracted with CFI Group to collect customer satisfaction data on NCC
calls. According to the results, the overall Customer Satisfaction Index is 77. The JPS Team
conducted a benchmarking analysis by comparing this index to the American Customer
Satisfaction Index (ACSI) scores for the Federal government. The overall Federal government
score ranges from the high 60's to low 70's. A few low 80's exist, but they are rare, making the
EEOC's score of 77 relatively strong. Service industries in general tend to score in the 70's,
unless they are premier companies (e.g. Nordstrom's or LL Bean) that base their overall
reputation on a superior service model. For comparison purposes, the overall ACSI score across
numerous service industries stands at 73.5 through the fourth quarter of 2005, putting the EEOC
above both the national average and the average for the Federal government.
As shown in Figure 6, the EEOC's Customer Satisfaction Index of 77 is above the satisfaction
indices for the total Federal government and the overall ASCI Index. Calls coming into the NCC
are more comparable to calls coming into Federal Trade Commission (FTC) and Federal Citizen
Information Center (FCIC) than CMS-Medicare, and the EEOC's score is less than those two
indices.

Figure 6. 2006 ASCI Index and Federal Benchmarks[29]




The satisfaction index for other forms of correspondence is significantly lower than the
satisfaction index for calls.

Figure 7. EEOC Customer Satisfaction Index
In summary, the overall Customer Satisfaction Index for the EEOC is 77, higher than some
Federal agencies. The satisfaction index varies by channel,[30] with the web channels having
significantly lower scores. An overall score of 77 is good, but, since there are no baseline data,
there is no way to know whether this is an improvement over pre-NCC.

In addition, these data reflect only the customer experience with the NCC, a narrow measure of
the overall EEOC customer experience. It does not reflect satisfaction with the EEOC in general
or with everyone in the end-to-end process. Examining customer experience at the NCC
evaluates only the initial step in the customer experience, and does not reflect, for example, any
dissatisfaction from customers who misunderstand the NCC's role. As described earlier,
Investigators indicated that PCPs have thought that they filed a charge with the NCC and
experienced frustration at having to repeat their information to Investigators.

9. Some of the contact center operational procedures at NCC are not optimal. This is not
having a significant impact on the customer experience at the current volumes; however,
with increased call volumes, customer experience can be affected.

As stated earlier, there have been changes to operating procedures at the NCC and EEOC offices
since the beginning of this project. Most of the assessment of the NCC is based on the findings
identified in November and December 2005.

Work Environment and CSR turnover rate (attrition)

The work environment for CSRs at the NCC is very good. All the CSRs have their own
workstations. The floor is well lit and spacious. The team leaders are readily available to the
CSRs.
The current CSR rate of turnover at the NCC is 36%. Industry averages vary by the type of
industry served by the call center (e.g., technical support, customer service, and sales) and the
nature of the call. According to a Pearson Study, the CSR turnover rate in Government call
centers averages 29 percent.

The NCC has access to state of the art technology in terms of scheduling, forecasting, and
timekeeping, but they do not use these technologies efficiently. Table 31 provides an overview
of each of the relevant technologies, with in-depth descriptions below.

                            Table 31. NCC Processes and Technology
             Process                                      Technology
Scheduling                        Blue Pumpkin/Aspect
Time Keeping                      Deltek
Call Management                   Avaya - CMS
Contact Management                RightNow
General Reporting                 No particular tool. NCC uses reporting from the source
                                  systems
Agent Performance                 No particular tool. NCC uses reporting from the source
Management                        systems
Call Monitoring                   NICE Recording Software[31]

Scheduling—Blue Pumpkin/Aspect

The NCC used Blue Pumpkin for scheduling purposes until recently, and are in the process of
converting to Aspect. The NCC does not use all the capabilities of these technologies.
Information is manually recorded on Excel spreadsheets and then entered into the system. With
the current size of the NCC, this is not a large concern, but this is not an efficient way to
schedule CSRs and it will pose many problems if the program expands.

Timekeeping - Deltek

The NCC uses Deltek for timekeeping purposes, but the current process requires a significant
amount of manual entry and is recorded in three different places: an Excel spreadsheet, the
timekeeping system, and paper copies. The NCC was unable to provide a valid reason for these
manual activities. Aux codes (codes generally used on switches to track CSR time) are not used,
resulting in manual tracking of CSR times. The duplication of this process adds inefficiencies to
NCC operations.

Call and Contact Management/General Reporting - Avaya and RightNow

The NCC does not use a special reporting tool. Reports are produced from the source systems:
RightNow (CRM), Avaya (Switch), and tele-interpreter reports from the web. Reporting is
provided as follows.

      Switch Reports - Daily, weekly, and monthly reports on call attributes, such as speed of
       answer and abandoned calls. The EEOC receives these metrics on a monthly basis.
       Interval reports (call metrics for every half hour) are produced and used to manage the
       floor in a typical call center, but these reports were not available for this program until
       recently.
      CRM Reports from RightNow - These reports show contact by State, channel, action
       taken, topic, etc. The EEOC receives these reports on a monthly basis. Analysis across
       months would allow the NCC to identify trends, but no such analysis is currently
       performed. In addition, the NCC collects demographics but did not report them until
       recently, when it began sending demographic reports to the EEOC; however, even these
       are snapshots and do not present any trends.
      Other Reports - IVR reports and reports on correspondence and emails are available.

Agent Performance Management - No tool is used

Agent performance management is not standardized. The Site Director said that team leaders
and staff members have meetings once a week to discuss monitoring scores, changes, and
general questions, but CSRs denied this.

CSRs also said they do not have any one-on-one coaching sessions. Their coaching is more like
refresher training.

There is also no reporting relationship between CSRs and team leaders; CSRs can approach any
team leader with any questions. The NCC does not use any agent scorecards or other
performance metrics to review CSR performance. The only measurement used is through call
monitoring, which the CSRs say they receive once every two months.

Call Monitoring

Call monitoring is an essential and important process for any call center. Call monitoring
ensures consistent quality service to customers by regularly coaching CSRs on findings from call
monitoring. At the NCC, the call monitoring process consists of three distinct activities: NCC
call monitoring, EEOC live call monitoring, and NCC and EEOC call calibration meetings.

NCC Call Monitoring. The NCC uses two tools for call monitoring: CMS Supervisor and NICE
The NCC quality manager and supervisors monitor the calls of each CSR four times a month (as
required per the contract). They use a specific form to grade each call that they monitor. These
grades are then summarized and shared with the CSRs; however, according to the CSRs,
information from the monitoring sessions is not consistently shared with them. During focus
groups, some CSRs said they get one form per month, while others said they have been there for
a few months and only received one. There is no documented process to show that CSRs have
been provided with feedback.

The quality monitoring forms include performance measure terminology that is not defined on
the form. Standard definitions exist, but neither management staff nor CSRs could provide any
definitions for the measures during interviews and focus groups.

EEOC Call Monitoring. The EEOC conducts live call monitoring. The live call monitoring
process started in December 2005 (technology problems precluded starting earlier). The EEOC
has a remote call monitoring number. Depending upon the time that the EEOC connects to the
call, they could be waiting on the line for the CSR to answer as long as the caller waits, or the
caller could be waiting longer. The EEOC monitors 15 to 20 calls per week, and an average of 3
to 5 calls at different times throughout the day.

When the EEOC identifies problems, they forward the information to NCC managers and
supervisors for feedback to CSRs and appropriate corrective action. The EEOC Project Manager
also discusses issues with the NCC content and training manager when it is appropriate to revise
scripts or provide additional training. The EEOC has occasionally recommended that CSRs call
customers back to correct information.

As shown in Table 32, during live call monitoring from January through May 2006, EEOC staff
identified errors in technical information (e.g., errors in the law or other substantive matters) in
22.5 percent of the 285 live calls monitored. In addition, during 11.2 percent of the total calls
monitored, CSRs created unnecessary barriers for customers. Following are a few examples of
such barriers:

      CSRs have told callers that they cannot hire an attorney until they file a charge with the
       EEOC
      CSRs have told callers that certain EEOC offices are not taking calls from the public,
       which was independently verified as incorrect
      CSRs require the complete and exact address of the employer to proceed with the phone
       interview when, by EEOC regulations, the employer's address is not required to file a
       charge

Live call monitoring also identified an issue in the complaint policy. If customers complain
three times that a field office did not contact them, the NCC must notify OFP. This has delayed
filing charges for more than 34 days.

In addition, when verifying repeat callers, CSRs do not follow any “confidentiality” procedures.
The CSR may read from the file and ask the caller if the address in the file is correct, rather than
asking the caller to provide his/her address.

CSRs also enforce a “30 second hold rule,” whereby they tell customers they cannot hold more
than 30 seconds to allow the caller to retrieve additional information. The rationale is based on
the performance metric that CSRs must answer calls within 30 seconds, which is not always the
case.

                         Table 32. Live Call Monitoring Results
                                   Percent of Live Calls Monitored
                 Errors in     Customer Complaints Script not Call more CSRs
                 Technical      Service     about Field Followed than 6        create
 Month      No. Information (CSR rude,         Offices              minutes* barriers)
 (2006)    Calls Provided      not polite)
January    43 27.0           11.6          4.7           7.0       41.0      4.7
February   60 15.0           11.7          6.7           5.0       48.3      13.3
March     75    21.3             22.7           8.0             13.3       36.0        9.3
April     60    33.3             25.0           18.3            25.0       38.3        11.7
May       47    14.9             8.5            10.6            38.3       48.9        14.9
Total     285   22.5             16.8           9.8             17.2       42.1        11.2

*Excludes wait time. April through part of June 2006, a technology problem caused a customer
to have to wait to talk with a CSR. The time ranged from 7-25 minutes. The problem has been
resolved.

EEOC and NCC Call Calibration Meetings. Each week the NCC and EEOC hold calibration
sessions to understand quality performance metrics. This information is then loaded to an
Access database to produce reports. The JPS Team requested but did not see any examples of the
quality monitoring reports, although, according to management, these reports do exist.
According to the reporting analyst, there is no good reporting from this quality monitoring. The
only metric that is used is the number of times each CSR is monitored.

H. SUMMARY

1. Implementation of the NCC has created some benefits, but not to the extent anticipated
in the 2003 Assessment Report.

As shown in Table 33, the NCC has made some progress in a few areas toward meeting the
anticipated benefits set forth in the 2003 Assessment Report. As a state-of-the-art customer
service solution, the NCC provides another channel for the public to contact the EEOC and
customers have reported above average satisfaction with the NCC.

The NCC, however, has not realized many other proposed benefits. As described earlier, this is
partially due to the JPS Team conducting the evaluation during the pilot year of operations when
new processes were being refined. In addition, initial business rules limited the calls to the NCC
to only the two general information toll-free lines.

The reduced benefits are also related to operational factors. The standard forms from the NCC
are often inaccurate and incomplete, causing extra work for intake staff. There has been some
positive impact on Investigator work, but less than anticipated.

      Table 33. Comparison of Benefits in the 2003 Assessment Report to Current Findings
     Anticipated Benefits Cited in the 2003
               Assessment Report                         Findings of Current Evaluation
1 Provide a centralized point of contact for the The NCC can handle calls, faxes, emails, TTY
  EEOC, using multiple modes of                  calls, and mail correspondence; however, the
  communication.                                 EEOC offices still take calls directly.
2 Improve the quality and effectiveness of       A recent study reports the EEOC's customer
  customer service.                              satisfaction is above average, but without
                                                 baseline data, there is no way to know if this is
                                                 an improvement compared to pre-NCC.
3 Answer calls immediately by live bodies.        CSRs answer calls to the NCC immediately;
                                                  however, most of the callers desiring to file a
                                                  charge are referred to the EEOC offices,
                                                  relegating them into the same pre-NCC process.
4 Spot trends and emerging issues (i.e., logging, NCC reporting does not show significant
  tracking, and monitoring of inquiry nature,     identification of trends. There were no monthly
  volume, duration and resolution coupled with trending reports.
  extensive reporting on demographics).
5 Meet e-government expectations.                 The EEOC has implemented the NCC;
                                                  however, the technology across the NCC and
                                                  EEOC is not integrated, and some of the
                                                  reporting at the NCC is manual.

An additional, albeit unanticipated, benefit has been that the NCC provided the EEOC with the
capability to communicate with employees and PCPs/CPs after Hurricane Katrina in the Gulf
States and with parties during the transportation strike in New York City in December 2005.

The pilot phase of the NCC has not resolved the question as to whether the NCC is an effective
customer service solution for the EEOC, though there are some indications that it is beginning to
have a positive impact. It is clear that:

      NCC operations are not as efficient or as effective as they could be, largely because
       EEOC and NCC systems and processes are not integrated
      The EEOC has yet to obtain many of the anticipated key benefits

The JPS Team's electronic survey, sent to all staff in field offices, provided two opportunities for
respondents to write in comments. On the item that asked for suggestions to improve the NCC,
approximately 18 percent of the 377 respondents writing in comments stated that the NCC is a
waste of money and should be disbanded. At the end of the survey, respondents were given a
final opportunity to enter any thoughts related to the NCC. Approximately 24.5 percent of the
267 write-in comments indicated that the NCC is ineffective and has not reduced workload or
telephone calls, and that they would rather have more staff in the field.[32] Employees also
indicated that if this is not possible, it is important to improve the processes and eliminate the
duplication of work. Two of the most commonly suggested methods for achieving this goal
included providing training to the CSRs and ensuring that CSRs transmit more accurate and
complete information to EEOC offices.

During the team's visits to EEOC offices, many managers and Investigators said that they would
rather have more staff than the NCC; however, if that is not possible, they expressed a desire to
make the NCC work more effectively. Respondents to the director survey suggested that the
NCC issue intake questionnaires and take charges. One director wrote the following comment:

“To simply refer PCPs to servicing offices for Investigators to speak with them or to send EAS
questionnaires that are not detailed enough to be considered minimally sufficient charge
information is not as helpful as the NCC could/should be. If a PCP wishes to speak with an
Investigator, there should be someone on staff to handle that. If they wish to file a charge,
questionnaires should be mailed out with self-addressed envelope to servicing office. There is
great potential for the NCC to relieve workload for field offices.”

During the team's site visit to the NCC, the managers indicated they are aware that they are not
as effective as they could be (the volume of telephone calls is significantly less than they
anticipated). They also indicated a desire to communicate directly with EEOC offices to learn
what they can do to help the offices. The CSRs also have a keen interest in learning more about
how they can better serve the EEOC offices.

2. NCC Costs

The JPS Team attempted to quantify the NCC's benefits; however, it is very difficult to conduct a
cost/benefit analysis, since no initial business case was made for the NCC. The team developed
a high-level comparison of costs (associated with the NCC's operations) with time saved at
EEOC offices, but the financial element is only one component of the analysis. It is also
important to understand the qualitative benefits offered by the NCC, because some of the
EEOC's anticipated benefits cannot be quantified. For example, it is very difficult to quantify
benefits resulting from customer satisfaction or the ability to identify trends that enable the
EEOC to better serve future customers. In addition, there may be indirect savings over the
current operations resulting from standardizing processes and making other improvements. The
EEOC can redirect these savings to other mission critical activities, such as enhancing the
efficiency and effectiveness of filing charges and the quality of investigations, mediation, and
litigation, as well as preventing discrimination through outreach and training.

The team estimated the amount of time the NCC is saving EEOC staff by combining the
resolution rates estimated from its call observation analysis, average talk time from NCC reports,
and the number of worked hours. Based on this estimation, the NCC is currently saving the
EEOC approximately 13,964 hours per annum, the equivalent of 6.71 FTEs. The value of the
current savings is $489,830.[33]

Following are the NCC costs for taking calls in English, Language support, and TTY.

                          Table 34. Costs of Calls Handled by CSRs
                                    Description             Costs
                         English Calls                    $1,145,300
                         Language Support                 $82,109
                         TTY Calls                        $3,802
                         Total Cost for CSR-Handled Calls $1,231,212

IV. RECOMMENDATIONS
The JPS Team believes that the NCC has the potential to make a significant contribution to the
EEOC; however, as presently operated, it is not effective. The team recommends that the EEOC
continue with the NCC, but only if significant changes are made to improve call volume,
optimize customer satisfaction and operational efficiencies, measure on-going performance, and
ensure readiness for the future.

The JPS Team's study found that the NCC is not achieving many of the benefits originally
anticipated in the 2003 Assessment Report, partially due to business rules developed after the
Report was created, which has led to a call volume that is much less than originally estimated.
The NCC has freed up some field staff time, but not to the extent anticipated. Significant issues
remain concerning the quality and value of the information that the NCC provides to the field;
therefore, the team believes that it would be a mistake for the EEOC to simply renew the contract
and continue current operations.

One option is for the EEOC to abandon the NCC, as some of the changes that the team
recommends will require the EEOC to commit time and resources to achieve a successful
outcome. The largest negative result of eliminating the NCC would be its impact on customer
service. The largest positive impact of eliminating the NCC would be that of potentially freeing
up money for other uses, including upgrading telephone technology in field offices, hiring more
professional staff to help with investigations, and hiring more clerical staff to help answer
unsolicited telephone calls and perform other intake duties.

If the EEOC does not hire additional staff and does not upgrade telephone technology, customer
service may deteriorate to conditions at the time of the 2003 Assessment Report. Calls may be
dropped, customers may have to leave a voice mail message and wait to have their questions
answered, and customers will have fewer hours during the day to talk with an EEOC
representative. Further, office efficiency and effectiveness may suffer if professional staff is
again required to support clerical staff, diverting them from other mission critical tasks. As a
result, office complaints may increase, which will take more time from Office Directors. In
addition, the ability to quickly identify and react to trends may be limited.

Recommendations to Improve Operations Quickly

1. Increase the NCC's call volume by routing all initial calls through NCC and increasing
customer awareness.

Route all initial calls through NCC.

One of the main reasons that the NCC is not having a more significant impact on the EEOC's
workload is low call volume; to increase this volume, the team recommends that the EEOC route
all unsolicited calls to the NCC. This would involve making local numbers available only to
people who have existing relationships with the EEOC offices. The purpose is to reduce call
volume to EEOC offices and lighten the workload. This would also ensure that callers have a
similar customer experience, since services provided by the NCC are regularly monitored for
quality service. Customers calling about matters related to existing charges and cases would still
have the local office telephone number and continue to be able to reach the appropriate person
directly.

Develop methods to increase awareness of NCC.
Increasing public awareness of the NCC would likely increase NCC call volume. The planned
advertising campaign will be important to increasing awareness of the toll-free number, and
plans to implement this campaign in early July should proceed.

The EEOC should update its marketing plan (National Contact Center Outreach Plan updated
February 28, 2005) to incorporate planned activities for the current and upcoming fiscal years.
The EEOC should also track this document for progress. In the present version, action items
have an “end date,” but it is not clear whether those action items have been implemented. One
item is indicated as “done”, while the others simply state dates, and not whether they have been
completed.

The EEOC should also modify its home page to display clearly the NCC's importance and
relevance to customers. The website presently shows the NCC under the banner and under the
link for “Contact Us.” Showing customers the benefits of contacting the NCC will encourage
them to do so.

It is important that the EEOC follow through with GSA to ensure that all telephone directories
list the toll-free number as the EEOC contact number. The team recommends that the EEOC
consider publishing only the toll-free number in the blue pages. Offices or the NCC can give the
local number to CPs and other customers who have existing relationships with local offices. If
this is not practical due to other policy decisions, it is essential that all technology, including the
NCC's RightNow software, be integrated to ensure smooth operations.

Table 35 shows some assumptions and projected possible future call volumes and benefits of
routing all unsolicited calls through the NCC. The only financial cost to implement this
recommendation relates to the advertising campaign to increase awareness of the NCC.

                   Table 35. Potential Savings Due to Increased Call Volume
          Factors          Current Best Case (100%) Most Likely (50%) Worst Case (25%)
Annual call volume         273,804 547,608             410,706            342,255
NCC resolution rate*       51.0% 51.0%                 51.0%              51.0%
Total calls resolved       139,640 279,280             209,460            174,550
Call duration (minutes) 6           6                  6                  6
Total hours saved per year 13,964 27,928               20,946             17,455
FTE saved per year**       6.71     13.43              10.07              8.39
Value of FTE               $73,000 $73,000             $73,000            $73,000
Annual Savings             $490,083 $980,166           $735,124           $612,604
Improvement                NA       100.0%             50.0%              25.0%

*Rounded to the nearest tenth of a percent.

** Rounded to two decimal points
2. Improve call resolution at the NCC by clearly defining the NCC's role. The NCC should
make an effort to train the CSRs to more effectively screen and take information from
Potential Charging Parties, including asking initial basic questions.

The NCC and EEOC should clearly define their respective roles and responsibilities. At a high
level, the NCC should provide the primary customer contact until an Investigator is assigned to
the case; then the EEOC should be the primary contact.

The NCC should also train CSRs to ask effective initial questions so that they can screen out
cases that clearly do not have a basis of discrimination. The JPS Team recommends that the
NCC devise a pilot program in collaboration with a few offices. The offices should detail an
Investigator to the NCC to coach the CSRs in regards to relevant questions that will allow CSRs
to screen more effectively and send fewer calls to EEOC offices. The Investigators should then
evaluate and be ready to intervene as needed in calls to their office. The EEOC should develop
methods to document CSR effectiveness in this additional screening. If CSRs can attain a high,
consistent level of performance, then the EEOC should expand the pilot program throughout the
organization.

Table 36 shows the assumptions and possible improved benefits if the NCC fully implements
this recommendation. Training the CSRs is the only cost to implement this recommendation.

     Table 36. Improvements in EEOC Workload Savings Due to Improved Call Resolution
                                                      Best Case Most Likely Worst Case
                  Factors                  Current     (15%)        (10%)        (5%)
Annual call volume                         273,804 273,804      273,804     273,804
Additional calls resolved due to increased NA       5,298       3,532       1,766
resolution
Additional time saved                      NA       1,325       883         442
Total hours saved per year (13,964 base 13,964 15,289           14,847      14,406
plus additional time saved)
FTE saved per year*                        6.71     7.35        7.14        6.93
Value of FTE                               $73,000 $73,000      $73,000     $73,000
Annual Savings                             $490,083 $536,568    $521,073    $505,577
Improvement                                NA       9.5%        6.4%        3.3%



* Rounded to two decimal points

3. Improve the resolution of non-charge related issues by integrating processes and
technology across the EEOC and NCC.

Only 66 percent of calls not related to filing a charge are resolved at the NCC. Integrating
processes and technology would afford an opportunity to increase the resolution of this call type
 as well as provide qualitative benefits such as reduce duplication of work and increase
 efficiency.

 From a field operations perspective, the two organizations are operating in parallel and nearly
 autonomously from one another. The NCC and EEOC should use the same or integrated
 technologies to capture and maintain customer information. This would include integrating the
 NCC's RightNow technology with the EAS and the IMS, and to the extent possible, the
 GroupWise email system. Making information transparent across the two organizations will
 promote communication and enable a more effective customer experience. Customers should
 not perceive a difference between the NCC and EEOC when inquiring about issues.

 The EEOC should also develop processes for regular, direct communications between EEOC
 offices and the NCC. This will provide each group with a better understanding of the other and
 help sustain an ongoing working relationship to resolve issues at the “local” level before they
 become problems that require intervention from Headquarters.

 The NCC and EEOC should set up a process for EEOC offices and the NCC to regularly share
 knowledge, communicate questions, and provide feedback. This could include periodic
 meetings, designating CSRs to be responsible for coordination and communication with certain
 districts/offices, and/or other means of exchanging information, such as participating in each
 other's staff meetings. The NCC should be treated as an extension of the EEOC offices. One
 model that can be tested is assigning a single point of contact from the NCC to a group of
 offices.

 Integrating processes across the two organizations as well as regularly sharing knowledge and
 information will help the NCC employees feel more a part of the EEOC and help them resolve
 more calls because they will better understand field office operations. In typical call centers,
 when CSRs have an understanding of how they contribute to the sponsor's success, they gain a
 sense of brand loyalty to that organization rather than to the call center operator.

 The following table shows the potential benefits of integrating technologies and processes. The
 benefits shown here are only the portion that could be quantified. Other benefits, such as
 improved customer satisfaction and improved efficiencies, cannot be reliably quantified at this
 time.

   Table 37. Improvements in EEOC Workload Savings due to Improved Resolution in Calls not
                                Related to Filing a Charge.
                                               Best Case       Most Likely    Worst Case
               Factors            Current       (15%)            (10%)            (0%)
Annual call volume               273,804 273,804            273,804         273,804
Calls resolved due to increased  139,640 153,604            146,622         139,640
resolution
Total hours saved per year       13,964 15,360              14,662          13,964
FTE saved per year*              6.71      7.38             7.05            6.71
Value of FTE                     $73,000 $73,000            $73,000         $73,000
Annual Savings                   $490,083 $539,091          $514,587        $490,083
Improvement                         NA         10.0%           5.0%               0.0%

 *Rounded to two decimal points

 Summary - Recommendations 1-3. Each of the above recommendations provides opportunities
 for the EEOC to improve call volume and operating efficiencies. The team expects the current
 year call volume will continue if the NCC continues as it is currently operated.

 The team made some assumptions to estimate the possible improvement in number of staff hours
 saved for the EEOC if all of the above recommendations are implemented. As shown in Table
 38, there are synergistic benefits to implementing recommendations two through four. The
 team's estimate shows that the NCC can save the EEOC between 23,705 hours per annum
 (possible worst case) to 56,164 hours per annum (possible best case), or from 11 to 27 FTEs,[34]
 respectively. This is an improvement over the estimated savings in the 2003 Assessment Report
 (43,224 hours per annum, which equates to 20.73 FTEs).

 The quantifiable benefits of implementing all of the above recommendations might increase the
 likelihood of obtaining the savings estimated in the 2003 Assessment Report. There will also be
 non-quantifiable benefits, such as customer satisfaction.

        Table 38. Quantifiable Benefits of Implementing Recommendations One through
                                              Four
                 Factors               Current Best Case Most Likely Worst Case
      Annual Call Volume             273,804 547,608        410,706     342,255
      NCC Resolution Rate*           51.0%      57.9%       55.3%       52.6%
      Total Hours Saved per Year     13,964     56,164      34,715      23,705
      FTE Saved per Annum**          6.71       27.00       16.69       11.40
      Value of FTE                   $73,000 $73,000        $73,000     $73,000
      Annual Savings                 $490,083 $1,971,142 $1,218,360     $831,970
      Improvement                    NA         302.4%      148.7%      69.8%

 *Rounded to the nearest tenth of a percent.

 **Rounded to two decimal points

 Recommendations to Optimize Customer Satisfaction and Operational
 Efficiencies

 After implementing the above recommendations, the following recommendations should be
 implemented to optimize NCC and EEOC operations.

 4. Make significant changes to the operating model in order to realize any additional
 positive impact on EEOC operations and customer experience/satisfaction.
The EEOC should standardize the citizen contact process into one seamless process across the
EEOC and NCC. Clear standard operating policies, procedures and methods should be defined
and set up for each step of the process. Before implementing this process across all offices, it
should be tested with a few different types of offices to identify potential gaps.

The JPS Team understands that the idea of standard intake processes across all EEOC offices
runs counter to the current philosophy of allowing offices discretion in how they conduct their
initial client contact and intake procedures. The EEOC could standardize the initial stages of the
intake process and then give offices discretion in how they conduct the rest of the intake process.
The goal is to create efficiencies in which the NCC relieves more of the clerical burden from
offices than it currently does. One option advanced by survey respondents and managers during
team interviews was to have the NCC issue intake questionnaires. This would eliminate some of
the clerical work currently performed at the offices and enable managers to redirect resources to
other mission critical activities. The NCC could accommodate a standardized EEOC
questionnaire or a different one for each office.

Longer term, the EEOC may also wish to evaluate the option of the NCC taking charges under
close supervision and communication with EEOC offices. The JPS Team understands that
taking charges has been identified as an inherently governmental responsibility; therefore, such
outsourcing would require careful evaluation, consideration, and compliance with all relevant
regulations.

In order to evaluate, establish, and implement this and other recommendations, the EEOC and
NCC should also establish a combined “EEOC/NCC Steering Committee.” This Steering
Committee should have representation from all stakeholders, including the field (management
and Union employees), Headquarters, and NCC. This group should establish processes to
integrate the systems and procedures of the EEOC offices and the NCC, increasing operating
efficiencies and improving end-to-end customer satisfaction. This could lead to an expansion of
the Intake Services Workgroup if membership is broadened to include all NCC stakeholders.

5. Provide training and feedback to CSRs on soft skills[35] and improve the quality of
information sent to EEOC offices.

CSRs need training on soft skills, which are very important in driving consistent customer
experience and improved customer satisfaction. Examples of soft skills include being able to
answer customer questions courteously while maintaining call control, being able to ask the right
questions depending on customer tone, and steering the conversation.

CSRs also need training to improve the quality and quantity of information they provide to
EEOC offices. This training should help CSRs understand the data that EEOC offices require.
Providing a view into uses of the data will help CSRs understand the reasons that offices need
the information.

The NCC should also provide regular feedback and mentoring to maintain high quality calls.
This will indirectly influence customer satisfaction, because regular feedback and training will
enable CSRs to provide consistent quality service.
6. The NCC should standardize and automate internal processes to achieve better
efficiency, consistency, and quality of service. Part of this involves better use of available
technologies.

The NCC should set up, standardize, and automate their processes so that they are ready to
handle increased call volume. The NCC should standardize operations, including workforce
management, coaching, and training, to readily identify issues. Process automation and
standardization will reduce the number of errors and force all CSRs to follow the same
processes. This will make communication and training easier and provide a consistent customer
experience.

The JPS Team rejects the notion that the NCC should expect CSRs to be proficient users of a
large number of scripts in communicating with the public. As this report documents, CSRs are
unable to find the right script most of the time; they instead select the handful of scripts that they
find easy to utilize and/or understand. The team recommends that the NCC create a more user-
friendly engine for its knowledge base and reduce the number of scripts to those few pertaining
to opening the call, closing the call, and disclaimer information. Actual product information
should be available in the knowledge base. The NCC can implement this recommendation if its
roles and responsibilities are clearly defined. .

Recommendations to Measure On-going Performance and Optimize Readiness
for the Future

7. Develop reports and other processes to identify trends proactively.

The NCC should set up reporting processes to identify issues and trends. The NCC can
accomplish this by understanding the EEOC's mission, operations in field offices, and the
EEOC's need for information, and then linking these elements with information captured at the
NCC. Call monitoring sessions should also focus on identifying potential trends and issues,
which can then be tracked through reporting.

8. Implement a process to measure customer satisfaction.

The NCC should implement an ongoing customer satisfaction measurement process. The NCC
and EEOC should also use information obtained through satisfaction surveys to make operating
model changes that positively impact customer experience and gain more efficiencies in terms of
overall EEOC and NCC effectiveness.

The NCC should conduct surveys on an ongoing basis, not as a one-time project. Customer
expectations change from time and time, and it is important to measure and monitor them on an
ongoing basis. The NCC should utilize the current methodology that the CFI Group uses to
collect satisfaction information. Using an IVR option after each call is not effective for
collecting this information, as customers have the option to self-select whether they participate.
This can bias the results.

9. Develop baseline EEOC metrics to measure performance and monitor periodically.
There are presently no reliable baseline operational metrics to evaluate the NCC's impact on the
EEOC's efficiency and effectiveness. It is essential to develop baseline metrics in order to
evaluate the NCC's future impacts. The team recognizes that metrics specific to measuring the
NCC's impact may have broad application across the EEOC, but this team's only purpose is to
recommend development of metrics that measure the NCC's impact. The performance metrics
upon which the EEOC measures the NCC's success should be based on key desired operational
outcomes that will indicate increased efficiency and effectiveness of EEOC field and
Headquarters operations. The EEOC's live call monitoring is a good source to evaluate the
quality and consistency of technical information provided to customers.

The JPS Team recommends that the Steering Committee be responsible for establishing key
goals and desired outcomes related to how the NCC affects the EEOC. Once these are identified,
the EEOC can develop metrics. If these metrics are developed in terms of desired outcomes,
they can also be used to drive operations. Table 39 shows possible key goals, desired outcomes,
and metrics. The chart is provided for illustrative purposes only.

                Table 39. EEOC Metrics to Measure Impact of the NCC
 Key Goals      Desired Outcomes                            Metric
Customer   Customers receive accurate Customer satisfaction via post card mailed to
Service    and timely service.        customers one week after the charge is filed or
                                      dismissed.

                                             Fewer customer complaints.
Operations     Increase field efficiency and Reduced number of Class C cases. Increased
               effectiveness.                benefits per charge.
Business       Reduce charge-processing Reduce time from the initial contact to when the
Processes      time.                         charge is filed.

In addition to the above, the Government Accountability Office (GAO) recommends the
following regular oversight practices in its February 2006 report on Federal Contact Centers:

      Regular knowledge database management - at least annually review information CSRs
       use to respond to inquiries.
      Regular contact monitoring - at least weekly review information provided in calls/emails
       to evaluate how well CSRs handle inquiries by using a scoring sheet and rating CSRs in
       multiple areas including courtesy, accuracy, completeness of information provided to the
       customer, and timeliness.
      Post-contact customer satisfaction survey - ask customers about the level of service
       received from the contact center and, to a limited extent, opinions about the accuracy of
       information received.
      Validation of contractor reports - validate data to ensure accuracy in prepared reports,
       including operational information such as the center's workload volumes, transaction
       handling times, and results of the contractor's monitoring.

If future measures rely upon source coding in the IMS, the EEOC should review existing coding,
correct errors and inconsistencies across offices and establish standardized procedures to ensure
that all offices are following the same guidelines in coding future inquiries. In addition, if the
EEOC considers telephone calls to offices in the field and Headquarters an important measure of
future progress, then it should establish procedures for all offices and Headquarters to capture the
important information.

10. Implement Change Management practices.

The implementation of a contact center is a significant change for any system. EEOC employees
must become engaged in the process of implementing the NCC in order to become vested. The
EEOC can accomplish this goal by developing a change management process. This should
include defining and making visible the reasons that the NCC is important, articulating the vision
of the NCC, removing some of the obstacles encountered to date (implementing the
recommendations above), and celebrating and building on short term wins. The JPS Team
recommends establishing a core advisory group responsible for managing the change process.
Through communication and training, they can ensure that the decision-making process related
to the NCC is transparent to EEOC employees.

It is important to communicate with employees on a regular basis. This communication could
come in the form of a web page on the EEOC's intranet that would also be accessible to CSRs.
The EEOC should articulate the business case and urgency for continuing the pilot, as well as the
NCC's mission, goals, and objectives. Communication could include information about the
upcoming advertising campaign, as well as progress toward implementing recommendations.
The EEOC and NCC metrics should be visible and shared with all staff on a regular basis. Other
information may include new FAQs and trends developed by the NCC. Offices could also share
their successes and best practices. The existing NCC Newsletter should evolve into a means of
communicating information in addition to successes.

Staff at the NCC and EEOC will need training regarding the integrated processes and their
respective roles and responsibilities. They will also need training on communication policies and
procedures in order to increase effectiveness. This training will give each organization a better
understanding of how to help the other, resulting in synergies that will benefit all (EEOC and
NCC staff as well as EEOC customers).




[1] The separate effects of the variables cannot be isolated.

[2] Investigators and other staff that have left EEOC offices.

[3] Soft skills relate to how CSRs handle transactions, e.g. professionalism in the way they
handle the transaction, controlling the call flow, taking ownership of the call, and being
empathetic with the caller. Hard skills relate to the product, in this case understanding and
knowledge of EEOC laws.
[4] The contract provides for three one-year options, which may be exercised annually, or the
Commission can vote to extend the contract for three years; however, because the EEOC only
has one year funding, contractually the option exercises are limited to one year at a time.

[5] Field work was conducted from October 2005 through February 2006.

[6] The EASQ provides basic information (who, what, when where and why an action is
discriminatory), which is then used by the investigator to prepare for the follow-up interview.

[7] Conducting a telephone survey was not in the team's original scope of work; however, upon
learning about the telephone survey, the team considered replicating the survey on a smaller
scale.

[8] In order to do this we required historical office level data.

[9] Even if the team could have located the data, given the deadline for the report draft, the team
would have had to replicate the telephone survey in December 2005 or January 2006, which
would have introduced confounds related to collecting data in dissimilar months (e.g.
vacations/holidays in December and January).

[10] Variables that obscure or make it impossible to identify and interpret the effect of the NCC
on EEOC field office operations.

[11] Because of the repositioning, equivalent data for the period January 1-March 31, 2006 were
not available.

[12] OFP authorized and encouraged but did not require offices to redirect unsolicited calls to the
NCC. Whether and the extent to which offices implemented this change was left to the
discretion of each individual office.

[13] One of the five commissioner positions was vacant at the time the team conducted its
interviews.

[14] The Director Survey responses were compiled manually and therefore are not available with
the survey instrument.

[15] Convergys took the lead in evaluating the operation of the NCC.

[16] SAS Institute, Inc., Statistical Software Version 9.1

[17] Based on Call Observation analysis

[18] There were insufficient data to model the charge behavior or explain the change across time.

[19] Outliers are typically a few extreme cases that can distort the interpretation of summary
statistics.
[20] This person's responses did not meet the 400-call cut-off for outliers, so the case was
retained.

[21] The months reported for the respective offices are somewhat different due to missing data.

[22] Both offices were in the one-month pilot study during March 2005.

[23] Per the Office of Personnel Management, 1 FTE=2,080 hours
(http://www.opm.gov/feddata/html/2004/november/intro.asp)

[24] As described in the Methodology section, the data to analyze NCC impact on case quality
had major input errors on one of the critical variables, rendering results unreliable and invalid.

[25] The JPS Team selected this period to ensure that findings would reflect current activities.

[26] Calls where the caller wants to file a charge.

[27] The NCC requirement is that offices respond to EASQs and GroupWise emails within four
to six days; some offices have an internal requirement to respond within 48 hours.

[28] Soft skills relate to the manner in which a CSR handles a transaction, such as
professionalism in handling the transaction, controlling call flow, taking ownership of the call,
and being empathetic with the caller. Hard skills are skills related to the product; in this case,
understanding and knowledge of EEOC laws.

[29] Customer satisfaction indexes were only available for FCIC, FTC, and CMS

[30] Type of communication, e.g. web, email, calls handled by CSRs.

[31] NICE is not an acronym.

[32] It is possible that some responses across the two questions are from the same people.

[33] Based upon an Average Investigator FTE equal to $73,000 (excluding benefits).

[34] The team divided the total hours saved per annum by 2080.

[35] Soft skills relate to the manner in which a CSR handles a transaction, such as
professionalism in handling the transaction, controlling call flow, taking ownership of the call,
and being empathetic with the caller. Hard skills are skills related to the product; in this case,
understanding and knowledge of EEOC laws.