oversight

Equal Employment Opportunity: The Postal Service Needs to Better Ensure the Quality of EEO Complaint Data

Published by the Government Accountability Office on 1999-09-28.

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

                 United States General Accounting Office

GAO              Report to the Postmaster General of the
                 United States



September 1999

                 EQUAL
                 EMPLOYMENT
                 OPPORTUNITY
                 The Postal Service
                 Needs to Better
                 Ensure the Quality of
                 EEO Complaint Data




GAO/GGD-99-167
United States General Accounting Office                                                      General Government Division
Washington, D.C. 20548




                                    B-283618

                                    September 28, 1999

                                    William J. Henderson
                                    Postmaster General
                                    U.S. Postal Service

                                    Dear Mr. Henderson:

                                    During the course of our work examining trends in federal employees’
                                    discrimination complaints, we analyzed equal employment opportunity
                                    (EEO) complaint data that the Postal Service and other federal agencies
                                                                                                            1
                                    reported to the Equal Employment Opportunity Commission (EEOC). The
                                    purpose of this report is to bring to your attention certain discrepancies in
                                    the complaint data that the Postal Service reported and the need for the
                                    Service to take additional steps to ensure that such data are complete,
                                    accurate, and reliable.

                                    In our limited analyses of the data the Postal Service reported to EEOC,
Results in Brief                    we found errors in statistics on the underlying bases for EEO complaints
                                    and on the length of time complaints had been in inventory. We also found
                                    that required data on the issues raised in complaints were not completely
                                    reported. These discrepancies were generally linked to statistical reports
                                    generated by the Service’s automated complaint information system. After
                                    we brought these discrepancies to the attention of Postal Service staff,
                                    they promptly corrected them and appeared to correct the underlying
                                    causes for the errors, with one exception. That situation need not be
                                    resolved until EEOC revises its reporting form.

                                    Because we examined only a limited portion of the reported data for
                                    obvious discrepancies and because the errors we identified were related to
                                    data generated by an automated complaint information system put in place
                                    in 1995, we have concerns about the completeness, accuracy, and
                                    reliability of the data that we did not examine. Therefore, we are
                                    recommending that the Postal Service review its controls over the
                                    recording and reporting of the data that it submits to EEOC.




                                    1
                                     Equal Employment Opportunity: Rising Trends in EEO Complaint Caseloads in the Federal Sector
                                    (GAO/GGD-98-157BR, July 24, 1998) and Equal Employment Opportunity: Data Shortcomings Hinder
                                    Assessment of Conflicts in the Federal Workplace (GAO/GGD-99-75, May 4, 1999).




                                    Page 1                       GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
                       B-283618




                       Federal regulations and EEOC policy require federal agencies to report
Background             certain EEO complaint-related data annually to EEOC. Agencies report
                       these data on EEOC form 462, Annual Federal Equal Employment
                       Opportunity Statistical Report of Discrimination Complaints. EEOC
                       compiles the data from the agencies for publication in the annual Federal
                       Sector Report on EEO Complaints Processing and Appeals. According to
                       EEOC Management Directive 110, agencies should make every effort to
                       ensure accurate recordkeeping and reporting of these data. In our recent
                       report, we said that reliable data are important to program managers,
                       decisionmakers, and EEOC in identifying the nature and extent of
                                            2
                       workplace conflicts.

                       We analyzed the data contained in EEOC’s annual federal sector reports to
Scope and              prepare our reports dealing with employment discrimination complaint
Methodology            trends. Because the Postal Service accounts for a large share of complaints
                       filed by federal employees with their agencies, we analyzed forms 462
                       submitted by the Service for fiscal year 1991 through fiscal year 1998, as
                                                                             3
                       well as other complaint data provided at our request. Because our studies
                       generally focused on trends in the number and age of unresolved
                       complaints in inventory, the number of complaints filed, the bases and
                       issues cited in complaints, and complaint processing times, we did not
                       examine the full scope of data reported on form 462. Although we did not
                       examine the Service’s controls for ensuring accurate recordkeeping and
                       reporting or validate the data the Service reported, we examined the data
                       for obvious inconsistencies or irregularities.

                       We requested comments on a draft of this report from the Postmaster
                       General. The Postal Service’s oral comments are discussed near the end of
                       this letter. We performed our work in July and August 1999 in accordance
                       with generally accepted government auditing standards.

                       The most significant error that we identified in Postal Service data
Discrepancies in the   involved the number of race-based complaints filed by white postal
Postal Service’s EEO   workers. EEOC requires agencies to report the bases (e.g., race, sex,
Complaint Data         disability) for complaints that employees file. For fiscal year 1996, the
                       Postal Service had reported that 9,044 (about 68 percent) of the 13,252
                       complaints filed contained allegations by white postal workers of race
                       discrimination. For fiscal year 1997, the Service had reported that 10,040
                       (70 percent) of the 14,326 complaints filed contained such allegations.
                       2
                           GAO/GGD-99-75, May 4, 1999.
                       3
                        In fiscal year 1998, postal workers accounted for about half of the discrimination complaints filed by
                       federal employees.




                       Page 2                            GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
B-283618




These figures represented significant increases over the figures reported
for previous fiscal years. For example, in fiscal year 1995, the Service
reported to EEOC that 1,534 of the complaints filed contained allegations
by white postal workers of race discrimination. In fiscal year 1994, the
figure reported was 2,688.

We questioned Postal Service officials about the sudden increase in the
number of complaints containing allegations by white postal workers of
race discrimination. The officials said that they also had been concerned
about these data, and had discussed the data with EEOC officials. After we
raised this issue, the officials intensified their efforts to identify the true
magnitude and source of the increase and subsequently found that a
computer programming error had resulted in a significant overcounting of
these complaints. They said that the corrected figures were 1,505 for fiscal
year 1996 (or 11.4 percent of the 13,252 complaints filed) and 1,654 for
fiscal year 1997 (or 11.5 percent of the 14,326 complaints filed). They also
provided these figures to EEOC.

In explaining how the error occurred, the officials said that each
automated case record in the complaint information system contains a
data field for race, which is to be filled in with a code for the applicable
racial category when an employee alleges racial discrimination. If an
employee alleges discrimination on a basis or bases other than race, this
data field is to remain blank. According to the officials, the faulty
computer program counted each blank racial data field as indicating an
allegation by a white employee of racial discrimination. These results were
then tallied with complaints in which the data field was properly coded as
an allegation by a white employee of racial discrimination. The officials
advised us that the programming error had been corrected. Although we
did not examine the computer program, our review of the data reported on
the Postal Service’s form 462 for fiscal year 1998 appeared to confirm that
the correction had been made.

Other errors that we found in data that the Service reported on form 462
related to the age of cases in the inventory of unresolved complaints.
EEOC requires agencies to report statistics on the length of time that cases
have been in the agencies’ inventories of unresolved complaints, from the
date of complaint filing. These data are broken out by each stage of the
complaint process—acceptance/dismissal, investigation, hearing, and final
decision. We questioned figures for fiscal year 1997 about the age of (1)
cases pending acceptance/dismissal, because the reported total number of
days such cases had been in inventory seemed unusually high, and (2)
cases pending a hearing before an EEOC administrative judge, because the



Page 3                  GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
B-283618




reported average age of such cases seemed unusually low. After we
brought the questionable figures to the attention of the Postal Service EEO
Compliance and Appeals Manager, he provided corrected figures and said
that the errors, like the problem with the reporting of complaint bases
described previously, were due to a computer programming error. He said
that the faulty computer program had been corrected. In addition, the
Service provided the corrected figures to EEOC.

We also found that the Postal Service has not been reporting all issues—
the specific conditions or events that are the subjects of complaints—as
EEOC requires. Because some complaints involve more than one basis or
more than one issue, EEOC’s instructions for completing part IV of form
462 require agencies to include all bases and issues raised in complaints.
While the Postal Service’s complaint information system allows more than
one complaint basis (like racial and sexual discrimination) to be recorded,
the system’s data field allows only one “primary” issue (like an adverse
personnel action) to be recorded for each complaint, regardless of the
number of issues that a complainant raises. Although this practice results
in underreporting complainants’ issues to EEOC, the EEO Compliance and
Appeals Manager said that the Postal Service adopted this approach to give
the data more focus by identifying the primary issues driving postal
workers’ complaints.

This matter has not been resolved. In order to report more than one issue
for each complaint, the Service would have to modify the automated
complaint information system to allow for the recording of more than one
issue for a complaint. However, we have reported that part IV of form 462
for reporting statistics on bases and issues is methodologically flawed and
                                                 4
results in an overcounting of bases and issues. We have made a
recommendation to EEOC that it correct this problem, and the agency said
                                     5
that it would address our concerns. Therefore, we believe that it would be
prudent for the Postal Service to wait for EEOC to resolve this issue before
modifying its data recording and reporting practices.

In addition to the discrepancies already noted, we found that the Postal
Service’s statistical reports to EEOC for fiscal years 1996 and 1997 did not
include data for complaints involving certain categories of primary issues.
4
    GAO/GGD-99-75, May 4, 1999.
5
 EEOC, with the National Partnership for Reinventing Government, is cosponsoring the Interagency
Federal EEO Task Force. One task force team of representatives from federal agencies and
departments, in response to recommendations made in GAO/GGD-99-75, is to review and recommend
approaches to improve the type and quantity of data, the method of collection, the accuracy and
reliability of the data, and the timeliness and availability of the data.




Page 4                            GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
                    B-283618




                    The form 462, which EEOC requires agencies to complete, contains a list
                    of issues. For its own management needs, the Service supplemented
                    EEOC’s list with three additional categories of specific issues: (1) denial of
                    worker’s compensation, (2) leave, and (3) other pay. However, we found
                    that in completing part IV of EEOC form 462 for fiscal years 1996 and 1997,
                    the Service omitted the data about complaints in which these additional
                    issues were cited. After we brought our observations to the attention of
                    Service officials, they provided the omitted data to EEOC. The officials
                    explained that, for fiscal year 1998, in lieu of including data about
                    complaints involving the three additional issues on part IV of form 462,
                    they provided these data separately to EEOC. The EEO Compliance and
                    Appeals Manager explained that he did not want to “force fit” the data
                    about the three issues into one of the categories listed on the form 462,
                    such as “other,” because the issues thereby would lose their identity and
                    significance. He added that part IV of form 462 needs to be revised because
                    the categories of issues listed are too broad and do not recognize emerging
                    issues.

                    Further, we found certain underreportings of the bases and issues cited in
                    complaints for fiscal year 1995. After we brought the underreporting to the
                    attention of the Postal Service officials, they provided corrected data to
                    EEOC and us. Service officials attributed this underreporting to difficulties
                    associated with implementing a new complaint information system in
                    fiscal year 1995.

                    Both Postal Service management and EEOC need complete, accurate, and
Conclusions         reliable information to deal with EEO-related workplace conflicts.
                    Discrepancies that we found in our limited review of the Postal Service’s
                    EEO complaint data raised questions about the completeness, accuracy,
                    and reliability of the reported data, particularly data generated through the
                    automated complaint information system. All but one of the reporting
                    problems we found and their underlying causes appear to have been
                    corrected. However, because we examined only a limited portion of the
                    reported data for obvious discrepancies and because the errors we
                    identified were related to data generated by an automated complaint
                    information system put in place in 1995, we have concerns about the
                    completeness, accuracy, and reliability of the data that we did not
                    examine.

                    To help ensure that the EEO complaint data submitted to EEOC are
Recommendation to   complete, accurate, and reliable, we recommend that you review the
the Postmaster      Postal Service’s controls over the recording and reporting of these data,
General             including evaluating the computer programs that generate data to prepare



                    Page 5                 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
                      B-283618




                      the EEOC form 462, Annual Federal Equal Employment Opportunity
                      Statistical Report of Discrimination Complaints. We recognize that
                      recording and reporting issues raised in complaints are matters that
                      cannot be completely addressed until EEOC resolves the methodological
                      flaws in part IV of form 462.

                      In oral comments on a draft of this report made on August 20, 1999, the
Agency Comments and   Postal Service Manager, EEO Compliance and Appeals, generally
Our Evaluation        concurred with our observations and offered comments of a clarifying
                      nature. In response to our recommendation that the Service’s controls over
                      the recording and reporting of EEO complaint data to EEOC be reviewed,
                      this official said that the Postal Service plans to adopt more
                      comprehensive management controls to ensure that the data submitted are
                      complete, accurate, and reliable. The official further said that these
                      controls would involve (1) an analysis of trend data to identify anomalies
                      and (2) an examination of data categories in which discrepancies have
                      previously been found. He also said that complaint information system
                      controls would be examined to determine whether they ensure that data
                      recorded and reported are complete, accurate, and reliable. He said,
                      however, that because the complaint information system has been
                      certified for year 2000 compatibility and because the Service has decided
                      not to modify any computer systems until March 2000, any modifications
                      to improve the complaint system will not be made until then. We believe
                      that the actions the Postal Service proposes, if carried out, will address the
                      substance of our recommendation.

                      We are sending copies of this report to Senators Daniel K. Akaka, Thad
                      Cochran, Joseph I. Lieberman, and Fred Thompson and Representatives
                      Robert E. Andrews, John A. Boehner, Dan Burton, William L. Clay, Elijah
                      E. Cummings, Chaka Fattah, William F. Goodling, Steny H. Hoyer, Jim
                      Kolbe, John M. McHugh, David Obey, Harold Rogers, Joe Scarborough,
                      Jose E. Serrano, Henry A. Waxman, and C. W. Bill Young in their capacities
                      as Chair or Ranking Minority Member of Senate and House Committees
                      and Subcommittees. In addition, we will send a copy to Representative
                      Albert R. Wynn. We will also send copies to the Honorable Ida L. Castro,
                      Chairwoman, EEOC; the Honorable Janice R. Lachance, Director, Office of
                      Personnel Management; the Honorable Jacob Lew, Director, Office of
                      Management and Budget; and other interested parties. We will make
                      copies of this report available to others on request.

                      Because this report contains a recommendation to you, you are required
                      by 31 U.S.C. 720 to submit a written statement on actions taken on this
                      recommendation to the Senate Committee on Governmental Affairs and



                      Page 6                 GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
B-283618




the House Committee on Government Reform not later than 60 days after
the date of this report and to the House and Senate Committees on
Appropriations with the agency’s first request for appropriations made
more than 60 days after the date of this report.

If you or your staff have any questions concerning this report, please
contact me or Stephen Altman on (202) 512-8676. Other major contributors
to this report were Anthony P. Lofaro, Gary V. Lawson, and Sharon T.
Hogan.

Sincerely yours,




Michael Brostek
Associate Director, Federal Management
  and Workforce Issues




Page 7                GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
Page 8   GAO/GGD-99-167 Quality of Postal Service EEO Complaint Data
Ordering Information

The first copy of each GAO report and testimony is free.
Additional copies are $2 each. Orders should be sent to the
following address, accompanied by a check or money order made
out to the Superintendent of Documents, when necessary. VISA
and MasterCard credit cards are accepted, also. Orders for 100 or
more copies to be mailed to a single address are discounted 25
percent.

Order by mail:

U.S. General Accounting Office
P.O. Box 37050
Washington, DC 20013

or visit:

Room 1100
700 4th St. NW (corner of 4th and G Sts. NW)
U.S. General Accounting Office
Washington, DC

Orders may also be placed by calling (202) 512-6000 or by using
fax number (202) 512-6061, or TDD (202) 512-2537.

Each day, GAO issues a list of newly available reports and
testimony. To receive facsimile copies of the daily list or any list
from the past 30 days, please call (202) 512-6000 using a touch-
tone phone. A recorded menu will provide information on how to
obtain these lists.

For information on how to access GAO reports on the INTERNET,
send e-mail message with “info” in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov
United States                       Bulk Rate
General Accounting Office      Postage & Fees Paid
Washington, D.C. 20548-0001           GAO
                                Permit No. G100
Official Business
Penalty for Private Use $300

Address Correction Requested




(410445)