oversight

U.S. Commission on Civil Rights: Agency Lacks Basic Management Controls

Published by the Government Accountability Office on 1997-07-08.

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

                  United States General Accounting Office

GAO               Report to the Chairman, Subcommittee
                  on the Constitution, Committee on the
                  Judiciary, House of Representatives


July 1997
                  U.S. COMMISSION ON
                  CIVIL RIGHTS
                  Agency Lacks Basic
                  Management Controls




GAO/HEHS-97-125
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division

      B-274033

      July 8, 1997

      The Honorable Charles T. Canady
      Chairman, Subcommittee on the Constitution
      Committee on the Judiciary
      House of Representatives

      Dear Mr. Chairman:

      Racially motivated church burnings across the country; racial and civil
      unrest in major metropolitan cities such as St. Petersburg, Florida; and the
      national debate over the continuing need for federal affirmative action
      programs and policies are only some of the issues the U.S. Commission on
      Civil Rights is working on today. Established by the Civil Rights Act of
      1957, the Commission had a budget of $8.75 million, 8 part-time
      commissioners, and a staff of 91 in fiscal year 1996. Its commissioners
      have two principal responsibilities—investigating claims of voting rights
      violations, and studying and disseminating information, often collected
      during specific projects, on the impact of federal civil rights laws and
      policies.

      Last year, in preparation for the Commission’s reauthorization and in
      response to complaints of mismanagement, your Subcommittee began to
      look into how the Commission carries out its responsibilities and manages
      its resources. To assist you in this effort, you asked us to provide
      information on the Commission’s management of projects during fiscal
      years 1993 through 1996 and its process for disseminating project reports
      to the public.

      To respond to your request, we interviewed all of the current
      commissioners; the Staff Director; and the Commission officials
      responsible for budgeting, personnel, projects, and dissemination to the
      public of the Commission’s project results. We reviewed Commission
      records, applicable legislation and regulations, and internal administrative
      guidance the Commission developed to carry out its operations. We also
      attended several Commission meetings to gain an understanding of the
      role of the commissioners. In addition, we reviewed the process for
      managing all projects the Commission identified as initiated, ongoing, or
      completed during fiscal years 1993 through 1996. We did not, however,
      receive all the information on project time frames, costs, and other
      Commission activities that we requested. (See app. I for details on our




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                   scope and methodology, including a discussion of the limitations in the
                   data we received.)


                   Although our review focused on the management of individual projects,
Results in Brief   we found broader management problems at the Commission on Civil
                   Rights. The Commission appears to be an agency in disarray, with limited
                   awareness of how its resources are used. For example, the Commission
                   could not provide key cost information for individual aspects of its
                   operations, such as its regional offices; its complaints referral process; the
                   clearinghouse; public service announcements; and, in one case, a project.
                   Furthermore, significant agency records documenting Commission
                   decision-making were reported lost, misplaced, or nonexistent. The
                   Commission has not established accountability for resources and does not
                   maintain appropriate documentation of agency operations. Lack of these
                   basic, well-established management controls makes the Commission
                   vulnerable to resource losses due to waste or abuse.

                   Commission records indicate that projects accounted for only about
                   10 percent of the agency’s appropriations during fiscal years 1993 through
                   1996 despite the number of civil rights issues addressed. Furthermore, our
                   work shows that management of the 12 Commission projects completed or
                   ongoing during this 4-year period appears weak or nonexistent. The
                   Commission’s guidance for carrying out projects is outdated, and the
                   process described as how projects are actually conducted—including
                   specifying anticipated costs, completion dates, and staffing—is largely
                   ignored. For example, 7 of the 12 projects had no specific proposals
                   showing their estimated time frames, costs, staffing, or completion dates.
                   Specific time frames were not set for most projects and when they were,
                   project completion dates exceeded the estimates by at least 2 years.
                   Overall, projects took a long time to complete, generally 4 years or more.
                   Some projects took so long that Commission staff proposed holding
                   additional hearings to obtain more current information. Poor project
                   implementation is likely to have contributed to the lengthy time frames.
                   Furthermore, we found no systematic monitoring of project costs or time
                   frames by Commission management to ensure project quality and
                   timeliness.

                   Finally, we found that the Commission disseminates project reports to the
                   public through three different Commission offices, none of which appears
                   to coordinate with the others to prevent duplication.




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             The Commission on Civil Rights was created to protect the civil rights of
Background   people within the United States. The Commission is an independent,
             bipartisan, fact-finding agency directed by eight part-time commissioners.
             Four commissioners are appointed by the president, two by the president
             pro tempore of the Senate, and two by the speaker of the House of
             Representatives. No more than four commissioners can be of the same
             political party, and they serve 6-year terms. The Commission accomplishes
             its mission by (1) investigating charges of citizens being deprived of voting
             rights because of color, race, religion, sex, age, disability, or national
             origin; (2) collecting and studying information concerning legal
             developments on voting rights; (3) monitoring the enforcement of federal
             laws and policies from a civil rights perspective; (4) serving as a national
             clearinghouse for information; and (5) preparing public service
             announcements and advertising campaigns on civil rights issues. The
             Commission may hold hearings and, within specific guidelines, issue
             subpoenas to obtain certain records and have witnesses appear at
             hearings. It also maintains state advisory committees and consults with
             representatives of federal, state, and local governments and private
             organizations to advance its fact-finding work.

             The Commission is required to issue reports on the findings of its
             investigations to the Congress and the president and to recommend
             legislative remedies. The Commission also must submit at least one report
             annually to the president and the Congress that monitors federal civil
             rights enforcement in the United States. In addition, because it lacks
             enforcement powers that would enable it to apply remedies in individual
             cases, the Commission refers specific complaints it receives to the
             appropriate federal, state, or local government agency for action.1

             A staff director, who is presidentially appointed with the concurrence of a
             majority of the commissioners, oversees the day-to-day operations of the
             Commission and manages the staff in its six regional offices and
             Washington, D.C. headquarters. Figure 1 shows the Commission’s current
             organizational structure, and table 1 describes the functions and staffing of
             the major components. (For additional background on the Commission,
             see app. II)



             1
              Several agencies have enforcement authority for civil rights issues. For example, the Equal
             Employment Opportunity Commission is charged with enforcing specific federal employment
             antidiscrimination statutes, such as title VII of the Civil Rights Act of 1964, the Americans With
             Disabilities Act of 1990, and the Age Discrimination in Employment Act of 1967. Also, the Assistant
             Attorney General for Civil Rights in the Department of Justice is the enforcement authority for civil
             rights issues for the nation.



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Figure 1: Commission on Civil Rights Organization Chart as of November 1996




                                         Source: Commission on Civil Rights.




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                                          As of September 30, 1996, the Commission had 8 part-time commissioners
                                          and a total of 91 staff members. Projects conducted by the Commission to
                                          study various civil rights issues are largely the responsibility of its Office
                                          of the General Counsel (OGC) with a staff of 15, and the Office of Civil
                                          Rights Evaluation (OCRE) with a staff of 12, as of fiscal year 1996. The
                                          largest component of the Commission is the Regional Programs
                                          Coordination Unit with 2 staff members in the Washington, D.C., office
                                          and 25 staff members in six regional offices. The regional offices direct the
                                          Commission’s work, which is carried out through 51 advisory
                                          committees—one in each state and the District of Columbia—composed
                                          of citizens familiar with local and state civil rights issues (see table 1).


Table 1: Commission on Civil Rights Components, Functions, and Staff as of September 30, 1996
                                                                                                                           Number of
Component                             Function                                                                                 staff
Commissioners                         Set policy and direction for the Commission; hold monthly meetings except
                                      during August; and convene several other times a year to conduct hearings,
                                      briefings, conferences, and consultations.                                                    8
Commissioners’ assistants             Assist the commissioners in carrying out their responsibilities.                              7a
Office of the Staff Director          Responsible for the day-to-day management of the Commission; enforces the
                                      policy decisions of the commissioners; plans, manages, directs, and
                                      coordinates functional operations and administrative activities of all the
                                      Commission’s offices in headquarters and the field; and liaisons with the
                                      Congress, the White House, and heads of federal agencies.                                     5
Office of the General Counsel         Responsible for advising commissioners and Commission staff on legal issues;
                                      ensuring that Commission operations are within the scope of the Commission’s
                                      statutory authority; conducting public fact-finding hearings; and drafting reports
                                      on civil rights issues from information obtained through hearings, investigations,
                                      and Commission studies, reports, or other work.                                              15
Office of Civil Rights Evaluation     Responsible for monitoring and evaluating civil rights enforcement efforts of the
                                      executive departments and agencies of the federal government; preparing
                                      appropriate documents, such as staff papers, correspondence, and reports
                                      presenting the Commission’s views and concerns regarding federal civil rights
                                      enforcement; receiving complaints alleging denial of civil rights; and referring
                                      complaints received to the appropriate federal agencies for investigation and
                                      resolution.                                                                                  12
Regional Programs Coordination Unit   Responsible for planning, directing, and monitoring the programs and policies
                                      of 51 State Advisory Committees (SAC) and coordinating SAC programs with
                                      the policies and programs of the Commission. Six regional offices, each
                                      headed by a director, located in Washington, D.C.; Atlanta; Chicago; Kansas
                                      City, Kans.; Denver; and Los Angeles coordinate SAC studies conducted on a
                                      variety of civil rights issues, report to the Commission on the results of SAC
                                      studies, and assist with follow-up on recommendations included in Commission
                                      and SAC reports. Members of SACs are volunteers appointed by the
                                      Commission.                                                                                   2
                                                                                                                           (continued)




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                                                                                                                            Number of
Component                    Function                                                                                           staff
  Regional offices           Responsible for submitting action memorandums, staff reports, project
                             concepts, and proposals to the Office of Regional Programs for approval.
                             Regional offices are directly responsible for reports submitted by state advisory
                             committees, but the SACs are responsible for program planning, receiving
                             information from scheduled speakers, and reviewing and approving their
                             reports. Regional office directors are responsible for final approval of SAC
                             reports. The Commission votes to accept or publish SAC reports, but it is the
                             Commission’s practice not to allow commissioners to change the reports.                                  25
Public Affairs Unit          Responsible for providing the public with a national clearinghouse repository for
                             civil rights information; keeping the public informed about civil rights
                             developments through the distribution of Commission reports and publications;
                             and managing the Commission’s public service announcements, media
                             releases, and the Commission’s Internet communications.                                                   6
Congressional Affairs Unit   Serves as liaison between the Commission and members of Congress and their
                             staffs, participates in the review of civil rights legislation, and keeps the
                             Commission informed of legislative developments.                                                          2
Office of Management         Consists of the Personnel, Budget and Finance, and Administrative Services
                             and Clearinghouse Divisions, which are responsible for operations.
  Personnel                  Responsible for all facets of human resource development including staffing,
                             classification, benefits, training, and compensation.                                                     5
  Budget and Finance         Responsible for budget preparation, formulation, justification, and execution;
                             financial management; and accounting, including travel for commissioners and
                             staff.                                                                                                    3
  Administrative Services    Responsible for space management, procurement, transportation, security,
  and Clearinghouse          telecommunications, supply, and duplication services.                                                     9
Total                                                                                                                                 99

                                 a
                                     One commissioner’s assistant position was vacant at the time of our review.



                                 The Commission’s authorization expired on September 30, 1996. Although
                                 the Congress did not reauthorize the Commission, it appropriated funds
                                 that allowed the Commission to continue its operations through
                                 September 30, 1997.2 The Commission’s funding, adjusted for inflation, has
                                 declined by about 58 percent since fiscal year 1980. As shown in figure 2,
                                 the largest cuts in funding occurred between fiscal years 1986 and 1988,
                                 when funding was reduced by 56 percent. Since fiscal year 1991, funding
                                 has been largely unchanged.




                                 2
                                  The Congress appropriated $8.74 million for Commission operations for fiscal year 1997 despite a lack
                                 of authorizing legislation. The Commission’s continued operation is based on a 1992 GAO decision that
                                 stands for the proposition that appropriation legislation is sufficient authority to permit an agency to
                                 continue operating pending reauthorization action. Commission Authority to Operate, 71 Comp. Gen.
                                 378 (Apr. 29, 1992).



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Figure 2: Commission Appropriations, FY 1980-97

Dollars in Millions

20




15




10




 5




 0

 1980      1981       1982     1983      1984      1985    1986      1987   1988   1989     1990   1991   1992    1993   1994   1995   1996   1997

 Fiscal Year

                Actual Appropriation
                Inflation-Adjusted Appropriation



                                                          The management of the Commission’s operations at the time of our review
Commission’s                                              showed a lack of control and coordination. The Commission had not
Management Reflects                                       updated its depiction of its organizational structure as required under the
an Agency in Disarray                                     Freedom of Information Act (FOIA) nor its administrative guidance to
                                                          reflect a major reorganization that occurred in 1986. Obsolete
                                                          documentation of the agency’s operating structure and its administrative
                                                          guidance leaves the public and Commission employees unsure of the
                                                          agency’s procedures and processes for carrying out its mission. Moreover,
                                                          Commission officials reported key records as lost, misplaced, or
                                                          nonexistent, which leaves insufficient data to accurately portray
                                                          Commission operations. Agency spending data are centralized, and
                                                          Commission officials could not provide costs for individual offices or
                                                          functions. We also found that the Commission has never requested any
                                                          audits of its operations, and information regarding Commission audits in
                                                          its fiscal year 1996 report on internal controls is misleading.




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Agency Policies and   The Commission has no documented organizational structure available to
Procedures Unclear    the public that reflects current procedures and program processes. FOIA
                      requires that federal agencies publish and keep up to date their
                      organizational structure and make available for public inspection and
                      copying the agencies’ orders, policies, and administrative staff manuals
                      and instructions. The Code of Federal Regulations, the principal document
                      for publishing the general and permanent rules of federal agencies, shows
                      the Commission’s organizational structure as of May 1985;3 but the
                      Commission’s current organizational structure is substantially different
                      because of the major reorganization in 1986.

                      Confusion also exists regarding which Commission unit has the
                      responsibility for certain organizational functions. For example, it is not
                      clear who at the Commission has responsibility for agency publications,
                      the clearinghouse, and the library. Some Commission officials believed
                      that these duties are housed within the Office of Management in the
                      Administrative Services and Clearinghouse Division. However, the
                      description of Commission component functions provided us put
                      responsibility for publications and clearinghouse duties under the Public
                      Affairs Unit. Another Commission official told us that publications and
                      clearinghouse responsibilities fall under the Regional Programs
                      Coordination Unit. In addition, the commissioners presented conflicting
                      views about the responsibilities of the staff director. Half the
                      commissioners interpreted the staff director’s role as carrying out the
                      directives of the commissioners, while the other half viewed the staff
                      director as having wider latitude to manage Commission operations.

                      In addition, the Commission’s Administrative Manual was issued in
                      May 1975 as “the official medium for administrative management of the
                      United States Commission on Civil Rights,” but the Commission has paid
                      little attention to maintaining and updating its guidance to accurately
                      reflect agency operations over the last 10 years. The purpose of the
                      manual is to translate administrative policy derived from the various
                      legislative and regulatory policies affecting the day-to-day operations into
                      procedures that the Commission staff can rely on for guidance in carrying
                      out the agency’s mission. The major reorganization that occurred at the
                      Commission in the mid-1980s, coupled with high turnover of staff in key
                      positions of the agency, makes up-to-date operating guidance especially
                      important for maintaining continuity and performing work efficiently and
                      effectively. The two office directors responsible for conducting projects,
                      however—who had been employed at the Commission for 5 and 2-1/2

                      3
                       U.S. Commission on Civil Rights mission and functions: 45 C.F.R., part VII.



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                                      years, respectively—had only the 1982 version of the Administrative
                                      Manual to rely on for official procedures for conducting projects.

                                      Commission officials told us that, although it was outdated, the guidance
                                      in the Administrative Manual still reflects the basic Commission policy for
                                      conducting projects. However, we found that projects did not follow all
                                      steps outlined in this guidance, and could not for some steps because the
                                      offices no longer existed (see table 2).

Table 2: Project Development and
Oversight Guidance From the           Administrative Manual
Administrative Manual Compared With   guidance                         Characterization of actual practice
Actual Practice                       Project teams prepare and        Largely ignored. Only 4 of 22 projects in our review had
                                      submit for approval project      concepts and proposals; only 3 had design papers.
                                      concepts, proposals, and
                                      designs.
                                      Project officials obtain         Partially followed. Projects have account codes; however,
                                      account codes at the             Commission officials could not provide completed forms
                                      appropriate point in the         for requesting, assigning, and closing out account codes
                                      planning process.                for the 22 projects reviewed.
                                      Project officials submit         Does not occur. The Office of Program Planning and
                                      monthly progress reports in      Evaluation, which was responsible for preparing monthly
                                      writing to the staff director    reports to the staff director on the status of all
                                      through the Office of Program    Commission activities, no longer exists. Commission
                                      Planning and Evaluation.         officials did not provide any monthly progress reports to
                                                                       the staff director for any of the projects. However, our
                                                                       review of completed project files for OCRE showed
                                                                       memorandums to the staff director about the status of
                                                                       projects, although not monthly. Completed project files for
                                                                       OGC were not available for our review.
                                      Budget and Fiscal Division       Data incomplete. Commission officials told us that they do
                                      maintains current records of     not maintain any information on staff time by project. They
                                      all expenditures of money        did provide fiscal year reports of expenditures for
                                      and staff time and provides      projects, and all but one included total expenditures.
                                      quarterly reports by account     Officials said that quarterly reports are made to the staff
                                      codes to staff director.         director. We requested copies of the reports but never
                                                                       received them.
                                      Publications Management          Process unclear. This division no longer exists, and it is
                                      Division edits national          not clear where this function is currently located. We
                                      publications and designs,        found three offices that were identified as performing
                                      produces, and distributes all    distribution duties, none of which coordinated distribution
                                      publications.                    lists. The list identified as the main mailing list did not
                                                                       appear to have been updated in at least 5 years.

                                      Commission officials told us that they were in the process of updating the
                                      Commission’s Administrative Manual and had updated 8 of 73
                                      administrative instructions; however, the instruction for implementing




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                          projects is not one of the 8. The Staff Director4 told us that she had
                          recently convened a task force, made up of the two office directors
                          responsible for conducting projects and the Special Assistant to the Staff
                          Director, to revamp the administrative instruction for projects. As of
                          June 16, 1997, Commission officials said that the task force has met at
                          least three times over the past several months and the Commission
                          expects to have a proposed final version of the administrative instruction
                          for projects for the new staff director’s consideration.


Key Commission Records    The Commission reported that key records—which either provided the
Missing                   basis for or documented decisions about Commission operations and
                          project management—were lost, misplaced, or nonexistent. Minutes of
                          certain Commission meetings were reported to be lost. According to
                          officials, minutes of the Commission’s meetings discussing the initiation of
                          7 of the Commission’s 22 projects were lost or misplaced. Additionally, the
                          files for these seven projects were either misplaced, misfiled, or not
                          available for review.5 Other key records outlining critical information
                          about projects did not exist, such as project proposals, or were not
                          available, such as the actual start dates for projects. Officials could not
                          locate the Commission’s log for issuing its administrative guidance and
                          could not provide issuance dates for some of its guidance, specifically,
                          that outlining the criteria for conducting projects. Finally, the Commission
                          did not have records showing the total cost of its project on funding
                          federal civil rights enforcement.


Spending Data Not         Commission officials told us that they maintain a central budget but could
Maintained by Office or   not provide the amount or percentage of the budget used by various
Function                  Commission offices or functions. Officials did not provide the costs of
                          complaint referrals, clearinghouse activities, regional operations, report
                          publication and dissemination, or public service announcements. The only
                          function Commission officials provided separate financial information on
                          was the projects’ costs. But even for project costs, records were poorly
                          maintained, and it is unclear whether they reflect the true costs for the
                          projects. For example, the Commission approved one project’s report for
                          publishing on September 9, 1994, and the report shows an issuance date of
                          September 1994, yet financial information provided to us showed costs


                          4
                          The staff director at the time of our review resigned effective Dec. 31, 1996. As of May 1997, the
                          Commission did not have a staff director.
                          5
                           These projects included six on racial and ethnic tensions in American communities that were
                          completed or ongoing and one completed project on funding federal civil rights enforcement.



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                          incurred through fiscal year 1996 for this project. A November 1, 1995,
                          letter from the Commission to the House Constitution Subcommittee
                          showed actual costs for the project of $261,529, but data Commission
                          officials provided us showed total project costs of $531,798. At the time of
                          our audit work, the Commission was not able to reconcile the difference.6


Commission’s Management   The Commission’s management controls over its operations are weak and
Controls Are Weak         do not ensure that the Commission is able to meet its statutory
                          responsibilities7 or its program objectives. Federal agencies are required
                          under the Federal Manager’s Financial Integrity Act to report on internal
                          controls annually to the president and the Congress; however, the
                          Commission did not report on the agency’s internal controls for fiscal year
                          1995. In addition, the Commission’s report on internal controls for fiscal
                          year 1996 appears to misrepresent information concerning audits of the
                          Commission. The report claims that several administrative activities are
                          randomly audited by the Department of Agriculture’s Inspector General,
                          when in fact no such audits were done. The only direct connection
                          between the Commission and the Department of Agriculture is that the
                          Commission’s financial transactions are handled through Agriculture’s
                          National Finance Center. Vendors submit invoices directly to the National
                          Finance center for payment, and the Commission does not verify the
                          accuracy of the invoices submitted. The Agriculture Inspector General is
                          responsible for auditing the automated systems of Agriculture’s National
                          Finance Center. But the Inspector General’s office told us that the
                          Commission has never requested any audits of its transactions.
                          Furthermore, we did not find that any other audits of Commission
                          expenditures had been performed.8

                          Recent reviews of the Commission’s operations by the Office of Personnel
                          Management (OPM) and a civil rights advocacy group have been critical of
                          Commission management. OPM reviewed the Commission’s personnel
                          practices and concluded in a 1996 report that the Commission is “an

                          6
                           The project evaluated the enforcement of the Fair Housing Amendments Act of 1988. In responding to
                          a draft of this report, the Office of the Staff Director said that the project produced two reports and
                          data provided to Congress reflected fiscal year 1994 cost while the GAO request represented all costs
                          on the project and adding the costs associated with the two reports reconciles the difference. Records
                          provided us during the audit do not support these comments.
                          7
                           The Subcommittee on the Constitution, House Committee on the Judiciary, reported that for fiscal
                          year 1995 the Commission did not meet its statutory requirement to submit to the Congress at least
                          one report each fiscal year that monitors federal civil rights enforcement. (104th Congress, House
                          Report 104-846, Sept. 1996).
                          8
                           The Commission is not required by statute to have an Inspector General, and its operations have not
                          been audited by an outside accounting firm.



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                      agency badly in need of managerial attention.”9 According to the report,
                      the Commission had numerous instances of poor documentation of
                      staffing actions, which made it impossible for OPM to definitively determine
                      the Commission’s compliance with OPM regulations. However, in one
                      instance, OPM did find violations of laws and regulations in the
                      Commission’s appointment of a staff member, resulting in that staff
                      member’s appointment being terminated.10 In addition, a 1995 report11 by
                      the Citizens’ Commission on Civil Rights12 reported that the Commission’s
                      performance has been “disappointing.” The report noted that projects take
                      so long to complete that they may be out of date because conditions have
                      changed by the time the project is completed, reducing the effectiveness of
                      the Commission’s work.


                      Although Commission projects address a number of civil rights issues, its
Commission Projects   project spending accounts for a small percentage of the Commission’s
Poorly Managed and    budget. Furthermore, the Commission’s efforts to manage these projects
Take Years to         fall short in areas such as following project management guidance,
                      meeting projected time frames for completing projects, and systematic
Complete              monitoring of projects. Commission projects entail collecting and
                      analyzing information on civil rights issues to appraise federal laws and
                      regulations. During fiscal years 1993 through 1996, the Commission
                      completed 5 projects, deferred 10 others, and worked on another 7 that
                      were still ongoing at the end of fiscal year l996 (see tables 3 and 4). These
                      22 projects cover a variety of issues, including racial and ethnic tensions in
                      American communities; the enforcement of fair housing, fair employment,
                      and equal education opportunity laws; economic opportunities for
                      minority youths; and naturalization and citizenship issues.



                      9
                      OPM, Office of Merit Systems Oversight and Effectiveness, Report of an Oversight Review: U.S.
                      Commission on Civil Rights-Washington, D.C. (Washington, D.C.: OPM, Nov. 1996).
                      10
                       In response to OPM’s recommendations, the Commission wrote to OPM of its planned corrective
                      actions. In a February 21, 1997, letter, OPM wrote that the Commission’s response reflects that efforts
                      are in place to promote an effective human resources management program and the changes the
                      Commission described should ensure the Commission’s adherence to merit system principles and Civil
                      Service rules and regulations.
                      11
                        Citizens’ Commission on Civil Rights, New Challenges: The Civil Rights Record of the Clinton
                      Administration Mid-Term: Interim Report on Performance of U.S. Commission on Civil Rights During
                      the Clinton Administration (Washington, D.C.: Citizens’ Commission on Civil Rights, 1995).
                      12
                       The Citizens’ Commission on Civil Rights is a private, bipartisan group of former officials who have
                      served in federal government positions with responsibility for equal opportunity. The Citizens’
                      Commission was established in 1982 to monitor the civil rights policies and practices of the federal
                      government and to seek ways to accelerate progress in the area of civil rights.




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Table 3: Completed and Ongoing Commission Projects, FY 1993-96
                              Assigned      Project                                                                        Report
Project title                 office        approval date Concept paper Proposal                         Hearing date      approval date
Completed
Racial and Ethnic Tensions in    OGC               2/91              Yes                No               5/92              3/3/95
American Communities: Poverty,
Inequality, and Discrimination—A
National Perspective
Racial and Ethnic Tensions in     OGC              2/91              Yes                No               6/92              4/21/95
American Communities: Poverty,
Inequality, and
Discrimination—Chicago
The Fair Housing Amendments       OCRE             5/90              No                 Yes              N/A               9/9/94
Act of 1988: The Enforcement
Report
Federal Title VI Enforcement to   OCRE             9/93              Yes                Yes              N/A               1/11/96
Ensure Nondiscrimination in
Federally Assisted Programs
Funding Federal Civil Rights      Staff director   No date           No                 No               N/A               6/20/95
Enforcement
Ongoing
Racial and Ethnic Tensions in    OGC               2/91              Yes                No               Hearing
American Communities: Poverty,                                                                           rescheduled
Inequality, and
Discrimination—Mississippi Delta
Federal Affirmative Action        OGC              4/95              Yes                Yes              Hearing
Programs and Policies Hearing                                                                            canceled
Racial and Ethnic Tensions in     OGC              2/91              Yes                No               6/93
American Communities: Poverty,
Inequality, and
Discrimination—Los Angeles
Racial and Ethnic Tensions in     OGC              2/91              Yes                No               9/94 and 7/95
American Communities: Poverty,
Inequality, and
Discrimination—New York
Racial and Ethnic Tensions in     OGC              2/91              Yes                No               9/95
American Communities: Poverty,
Inequality, and
Discrimination—Miami
Evaluation of Equal Education     OCRE             2/91              Yes                Yes              N/A
Opportunity Law Enforcementa
Evaluation of Fair Employment     OCRE             2/91              Yes                Yes              N/A
Law Enforcement
                                             Note: N/A means not applicable.
                                             a
                                              Volume I was completed in December 1996 and volumes II through VI are projected to be
                                             completed in FY 1997.




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Table 4: Deferred Commission
Projects, FY 1993-96                                                                                  Project
                                                                                                     approval
                               Deferred projects                            Assigned office              date       Concept paper
                               Expanding the Economic                       OCRE/OGC                                Yes
                               Opportunities of African American,
                               Asian, and Latino Youth                                                     7/94
                               Schools and Religion                         OGC                            7/94     No
                               Financial Aid for Higher Education           OGC                           10/94     No
                               Voting Rights                                OGC                           10/94     No
                               Environmental Justice                        OGC                           10/94     No
                               Enforcement of Americans With                OCRE/OGC                                Yes
                               Disabilities Act                                                            4/94
                               Naturalization and Citizenship Issues        OCRE                           4/94     No
                               Technological Change and Job                 OGC                                     No
                               Opportunities of Women, Minorities,
                               and Older Persons                                                           4/94
                               The Crisis of Young African American OGC                                             Yes
                               Males in Inner Cities                                                       3/95
                               Summary Report on Racial and                 OGC                                     No
                               Ethnic Tensions Project                                                     5/93



Project Spending Accounts      Although the Commission appears to spend about 10 percent of its
for Small Percentage of        resources annually on projects, we were unable to verify project spending
Commission Budget              because of the Commission’s poor record-keeping. According to
                               Commission records, costs incurred for individual ongoing and completed
                               projects during fiscal years 1993 through 1996 ranged from about $33,00013
                               for a completed project on funding for federal civil rights enforcement to
                               about $764,000 for a project on racial and ethnic tensions in Los Angeles
                               that had been ongoing throughout the 4-year period (see table 5).




                               13
                                The total cost of this project is not known because Commission officials did not, as they had for
                               other projects, account for staff salaries spent to conduct the project.



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                                                B-274033




Table 5: Commission Spending on Completed and Ongoing Projects, FY 1993-96
                                                                        Spending by fiscal year                                              Total
Project title                                                                      1993           1994           1995            1996    spendinga
Racial and Ethnic Tensions in American
Communities: Poverty, Inequality, and Discrimination
  National Perspectiveb                                                        $ 25,550        $ 5,991       $ 20,170                0      $ 51,711
           b
  Chicago                                                                        66,489         20,995         16,373                0      103,857
  Los Angeles                                                                   465,152         56,105         92,977       $149,498        763,732
  New York                                                                        3,038        336,947        119,529          74,400       533,914
  Miami                                                                                 0        4,789         62,050          14,087         80,926
  Mississippi Delta                                                                     0             0        52,385        162,753        215,138
Federal Affirmative Action Programs and Policies Hearing                                0             0        68,402          53,165       121,567
The Fair Housing Amendments Act of 1988: The Enforcement
Reportb                                                                         157,511        122,413           3,624          5,430       288,978
Federal Title VI Enforcement to Ensure Nondiscrimination in
Federally Assisted Programsb                                                      7,500        238,126        131,229          38,080       414,935
                                          b
Funding Federal Civil Rights Enforcement                                                0       24,057           9,052              18        33,127c
Evaluation of Equal Education Opportunity Law Enforcement                               0             0       193,704        307,969        501,673
Evaluation of Fair Employment Law Enforcement                                           0             0               0              0             0
Total project spending                                                        $725,240        $809,423      $769,495        $807,865d $3,112,023d
Total Commission appropriation for year                                                                                                       $33.3
                                                                            $7.8 million $7.8 million $9.0 million $8.7 million               million
Percentage of appropriation spent on projects                                        9.3           10.4             8.5            9.3            9.3
                                                a
                                                 Total spending on particular projects may be more if funds spent prior to fiscal year 1993 are
                                                included.
                                                b
                                                    Project completed.
                                                c
                                                Does not include salaries for this project.
                                                d
                                                 Includes $2,465 spent in fiscal year 1996 on a deferred project, Enforcement of Americans With
                                                Disabilities Act.




Project Management                              The Commission’s Administrative Manual, administrative instruction 5-1,
Guidance Often Ignored                          governs the process for conducting projects; however, the guidance has
                                                not been updated since 1982 and does not accurately reflect the current
                                                practices as they were described to us. Furthermore, our review of the
                                                projects showed that the process described was often not followed.
                                                According to Commission officials, the process that should be used to
                                                develop an idea into a project and ultimately a report includes five stages:
                                                (1) initiating an idea as a concept, (2) selecting concepts to develop into




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                                            B-274033




                                            proposals for projects, (3) conducting project research, (4) approving final
                                            publication of a report, and (5) publishing and disseminating the report
                                            (see table 6).


Table 6: Stages of Project Development at the Commission on Civil Rights
Project stage                      Staff role                    Staff director role                     Commissioners’ role
Initiation                          Staff, including regional staff,   Decides which ideas or            The Commission holds annual
                                    submit ideas or concepts for       concepts to forward to the        planning meetings in January
                                    possible projects to the staff     commissioners.                    or February. At that time, they
                                    director.                                                            vote on which concepts to
                                                                                                         return to the staff to develop
                                                                                                         into proposals for further
                                                                                                         consideration.
Selection                           Develop approved concepts         Submits proposals to the           Commissioners approve the
                                    into proposals that identify time commissioners.                     proposals as projects.
                                    frames, budget, staffing levels,
                                    scope and methodology, and
                                    type of anticipated report.
Research                            Conduct research.                  Assigns the project, usually to   Hold hearings as necessary.
                                                                       either OCRE or OGC.
Approval                            OGC reviews for legal issues.      Submits draft for legal and       Commissioners and their
                                                                       editorial reviews and transmits   assistants review the draft
                                                                       to commissioners for review       product and make changes.
                                                                       and approval.                     Commissioners vote to
                                                                                                         approve the product.
Publication and dissemination       Assist the staff director in Makes and approves all final            None.
                                    making all final report      decisions for publication and
                                    decisions for publication,   dissemination.
                                    including the number to be
                                    printed in addition to the
                                    minimum 5,000 copies of each
                                    report.

                                            Project documentation showed that this process was frequently ignored,
                                            with less than half of the projects during the period we studied following
                                            these procedures. Of the 12 completed and ongoing projects, only 4 had
                                            both concept papers and detailed proposals specifying the focus of the
                                            project, time frame, budget, and staff levels. None of the racial and ethnic
                                            tensions projects included proposals indicating the time frame for
                                            completion, proposed budget, or anticipated staff level. These six projects
                                            have absorbed years of staff time and accounted for more than 50 percent
                                            of the Commission’s total spending on projects, yet only two of these
                                            projects have been completed. Although concept papers are required for
                                            deferred projects, only 3 of the 10 deferred projects had concept papers.
                                            The funding federal civil rights enforcement project deviated from the




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                         process in the initiation stage, and the records were not available for
                         assessing the project relative to other stages of the process.


Projects Take Years to   The Commission has no overall standard for how long a project should
Complete                 take nor expectations for the length of time specific projects should take.
                         While an estimate of the time to conduct projects is required in proposals,
                         very few projects had estimated time frames for completing projects. For
                         the projects that did specify time frames, the actual time a project took to
                         complete was 2 to 3 years beyond their planned duration. Only two of the
                         five completed projects had anticipated start and finish dates, but both
                         overran their time frames. Both projects had anticipated time frames of 1
                         year, but one project took 3 years to complete (Federal Title VI
                         Enforcement to Ensure Nondiscrimination in Federally Assisted Programs,
                         issued June 1996), and one took 4 years (The Fair Housing Amendments
                         Act of 1988: The Enforcement Report, issued Sept. 1994). The Commission
                         attributed delays in meeting anticipated time frames to staff turnover,
                         limited staff resources, and the need to update factual information.

                         Although the length of the projects cannot generally be compared with the
                         expected or approved length, we found that their actual time frames
                         spanned several years. During the period of our review, projects took an
                         average of 4 years to complete from the time they were approved by the
                         commissioners.14 Four of the five completed projects had data available on
                         time frames—three of the projects took 4 or more years to complete, and
                         one was completed in about 2-1/2 years. For one project, the Commission
                         held a hearing in May 1992 and in the ensuing 3 years incurred additional
                         project costs of about $50,000. In 1995, it issued the hearing transcript,
                         accompanied by a summary of its contents without any further analysis, as
                         a final product.15 The Commission’s Staff Director reported in a
                         November 1995 letter to the House Judiciary Committee, Subcommittee on
                         the Constitution that the Commission originally scheduled publication of
                         the hearing transcript for fiscal year 1993 but “subsequently, the decision
                         was made to publish an executive summary in addition to the transcript,
                         which delayed publication of the document.”


                         14
                           Because the Commission did not have information on actual start dates, we determined our cycle
                         time calculations using the project approval date as the start date and the report issuance date as the
                         end date.
                         15
                           Commission on Civil Rights, Racial and Ethnic Tensions in American Communities: Poverty,
                         Inequality, and Discrimination-A National Perspective, executive summary and transcript of hearing
                         held in Washington, D.C. (Washington, D.C.: U.S. Commission on Civil Rights, May 21-22, 1992).
                         Commission data provided us showed that the Commission approved the transcript and executive
                         summary for publication as of March 1995, but the actual document is dated May 1992.



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                           Ongoing projects appeared likely to overrun their estimated time frames as
                           well. For six of the seven ongoing projects, nearly 6 years have elapsed
                           since their approval. Anticipated time frames were available for three of
                           the seven ongoing projects. The “Evaluation of Fair Employment Law
                           Enforcement” project was anticipated as a 2-year project approved in
                           February 1991. The Commission expected to begin the project in May 1995
                           and complete it in September 1997, but it appears that no work was done
                           on this project in fiscal years 1995 and 1996. Therefore, we believe it is
                           unlikely that this project will be completed on time. The “Evaluation of
                           Equal Education Opportunity Law Enforcement” project was also
                           approved by the commissioners in February 1991. The Commission
                           anticipated starting work on this project in February 1995 and planned to
                           complete the project and issue four reports by September 1996. In July
                           1996 the responsible project official proposed that the Commission
                           publish six separate reports and informed the staff director that the
                           project milestones had to be extended. The Commission issued the first
                           volume of the anticipated six in December 1996 and now expects to issue
                           the last of the remaining reports by December 1997, more than 1 year later
                           than initially anticipated and more than 6 years from the date the project
                           was approved. The remaining project that had a time frame, “Federal
                           Affirmative Action Programs and Policies,” approved in April 1995, was
                           expected to take 2 to 3 years, and is ongoing.

                           Problems with the quality of the work in planning and implementing
                           certain projects have apparently contributed to lengthy project time
                           frames. For example, the Commission’s General Counsel requested
                           additional hearings on three projects because of poor planning for the
                           initial hearings and the resulting inadequate data gathering. For the racial
                           and ethnic tensions projects for New York, Chicago, and Los Angeles, the
                           General Counsel determined that the information gathered at previous
                           hearings was insufficient, outdated, or too weak to support a quality
                           report. The New York project had insufficient testimony and
                           documentation in eight different areas. The Chicago project was criticized
                           by city officials as presenting an unbalanced picture, including
                           unsubstantiated testimony, mischaracterized information, inadequate or
                           nonexistent analyses, and missing certain recent city initiatives. The Los
                           Angeles report contained information that the Commission’s General
                           Counsel viewed as outdated and therefore required further investigation
                           for the Commission’s report to be current.


Projects Not               The Commission does not systematically monitor projects to ensure
Systematically Monitored   quality and timeliness of project results and to help set priorities. The only


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                   formal mechanism in place to inform the commissioners about the status
                   of projects is through the discretion of the staff director, orally or in the
                   monthly report the staff director provides to the commissioners.16 We
                   found that the commissioners only received limited updates on some
                   projects in the staff director’s monthly report. The staff director did
                   receive periodic updates about the progress of projects being conducted
                   by OCRE. However, because of frequent staff turnover and misfiled or lost
                   records, we could not determine whether the staff in the General
                   Counsel’s office similarly informed the staff director about project
                   progress.

                   Commissioners did not receive routine information on the costs of
                   projects or the personnel working on the projects. After a vote to approve
                   a project, commissioners are not aware of (1) those projects the staff
                   director decides to start, (2) when projects are actually started, (3) cost
                   adjustments for projects, (4) time frame changes, and (5) personnel
                   changes, all of which can affect the timeliness and quality of projects. All
                   of the commissioners told us that they are not involved in assigning
                   projects or specific tasks to the staff and that this is strictly a
                   responsibility of the staff director. However, most commissioners
                   expressed a desire to have routine reporting on the status of individual
                   projects, specifically, costs and time frames for completion, so they would
                   know when to expect draft reports. In fact, most of the commissioners
                   told us that they frequently have no knowledge of the status of a particular
                   project from the time they approve it until a draft report is given to them
                   for review. Some commissioners said that communication is a big problem
                   at the Commission and that improvement in communications up and down
                   staff levels could help resolve the problem.


                   The Commission uses three different offices to disseminate project
Dissemination of   reports, but a lack of coordination among these offices raises the potential
Project Reports    for duplicative work. Commission officials told us that these three
                   offices—the office responsible for conducting the project (OGC or OCRE),
                   the Congressional Affairs Unit, and the Office of Management
                   (Administrative Services and Clearinghouse Division)—maintain mailing
                   lists that are used to disseminate Commission project reports, hearing
                   transcripts, and other documents to the public. The responsible project
                   office maintains targeted lists and may develop other mailing lists of
                   routine document recipients. The Congressional Affairs Unit is responsible

                   16
                    While the Commission holds planning meetings to discuss future projects, these meetings are held
                   annually and therefore do not serve to routinely inform the commissioners about the status of
                   projects.



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              for disseminating Commission publications to the Congress. The
              Administrative Services and Clearinghouse Division maintains the
              agency’s general mailing list, coded by subject matter, and is responsible
              for sending reports to the public and other federal agencies.

              With no coordination among the offices, duplicate mailings are likely. We
              noted, for example, that the Administrative Services unit’s general mailing
              list included members of Congress, which should be the responsibility of
              the Congressional Affairs unit. Efforts to update the lists could eliminate
              duplication among the offices, but the Commission had not made such
              efforts. Our review of the agency’s general mailing list indicated that the
              list had not been updated in at least 5 years. Commission officials told us
              that they update the general mailing list annually, but did not provide
              documentation verifying the updates. In fact, the general list showed
              various individuals in specific federal positions who, at the time of our
              review, no longer served in those positions. According to a Commission
              official, a staff member had offered to purge the various lists to eliminate
              duplication and update the agency’s general mailing list, but the offer was
              refused.

              Commission officials told us that they did not know the costs for
              publishing and disseminating project reports. The officials said that they
              authorize the printing of at least 5,000 copies of each report.17 One official
              said that she did not know what the mailing costs are, but the agency has
              never “had a problem” sending out reports.


              Our overall assessment of the Commission suggests that its operations
Conclusions   lack order, control, and coordination. Management is unaware of how
              federal funds appropriated to carry out its mission are being used, lacks
              control over key functions, and has not requested independent audits of
              Commission operations. These weaknesses make the Commission
              vulnerable to misuse of its resources. The lack of attention to basic
              requirements applying to all federal agencies, such as up-to-date
              descriptions of operations and internal guidance for employees, reflects
              poorly on the overall management of the Commission.

              Projects embody a key component of the Commission’s operations, yet the
              management of projects is haphazard or nonexistent. No overall standard
              exists for assessing the timeliness of projects or the expectations of how

              17
               In comments provided on this report, Commission officials provided costs of $29,900 for 8,000 copies
              of the Federal Title VI Enforcement to Ensure Nondiscrimination in Federally Assisted Programs and a
              cost of $18,693 for 5,100 copies of volume I of the Equal Educational Opportunity project series.



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                         long projects should take. And the lack of project documentation,
                         systematic monitoring to detect delays and review priorities, and
                         coordination among offices that disseminate reports seriously hampers the
                         Commission’s ability to produce, issue, and disseminate timely reports.
                         Results from independent reviews of the Commission’s operations, such as
                         the Citizens’ Commission on Civil Rights and OPM, substantiate our
                         assessment of the Commission’s weak management and the need for
                         improvements.


                         We recommend that the Commission develop and document policies and
Recommendations to       procedures that (1) assign responsibility for management functions to the
the Commission           staff director and other Commission officials and (2) provide mechanisms
                         for holding them accountable for properly managing the Commission’s
                         day-to-day operations. This effort should include

                     •   updating the C.F.R. to provide for public access to the current
                         organizational structure, procedures, and program processes of the
                         Commission;
                     •   updating internal management guidance so that staff are assured that their
                         efforts comply with the administrative policies of the Commission,
                         applicable legislation, and federal rules and regulations; and
                     •   establishing a management information system for commissioners and
                         staff to use to plan projects and track progress using the best information
                         available about projects’ expected and actual costs, time frames, staffing
                         levels, and completion dates.


                         The U.S. Commission on Civil Rights provided us with two sets of
Agency Comments          comments on a draft of this report. We received one set of comments from
                         four commissioners and another set from the Chairperson, Vice
                         Chairperson, and the two remaining commissioners. The latter set
                         included comments from the Commission’s Office of the Staff Director.
                         The comments are printed in their entirety in appendixes IV and V.

                         In one set of comments, Commissioners Anderson, George, Horner, and
                         Redenbaugh concurred with our assessment and the recommendations on
                         management improvements needed at the Commission. These four
                         commissioners said that they will closely monitor the performance of the
                         new staff director to ensure that the report’s recommendations are
                         implemented, Commission operations are accounted for, and agency




                         Page 21                 GAO/HEHS-97-125 Management of Commission on Civil Rights
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    procedures and processes for carrying out its mission are updated. (See
    app. IV.)

    In the other set of comments, Chairperson Berry, Vice Chairperson
    Reynoso, and Commissioners Higginbotham and Lee challenged our
    report, calling it “short” on historical content, relevant context, and
    substantiated facts. These four commissioners believed that our
    recommendations only narrowly addressed aspects of the Commission’s
    management but pledged to implement the recommendations.
    Furthermore, these commissioners said that operational deficiencies cited
    in the report do not affect the Commission’s performance of its basic
    mission and that many of the findings cited may well be based on
    miscommunication during the audit. In this regard, they said that the
    Commission’s Office of the Staff Director would point out the concerns in
    detail in attached comments. The commissioners addressed four areas of
    concern that they believed caused our report to provide a distorted view
    of Commission operations. These areas are the following:

•   Update of the Commission’s Administrative Manual—The four
    commissioners said that the report does not tell the full story because it
    omits the impact of budget cuts, downsizing, and reductions-in-force that
    occurred in the 1980s.
•   Method used by the Commission to maintain its budget—The
    commissioners said that the report criticizes the Commission for not being
    able to provide the amount or percentage of the budget used by the
    Commission’s various offices or functions, which they maintained is an
    inaccurate criticism. They said that the Commission does know this
    information but we did not ask for it.
•   Characterization of the OPM report on Commission personnel
    practices—According to the four commissioners, upon receipt of the
    Commission’s response to the OPM report, OPM concluded that efforts are in
    place to promote an effective human resources management program.
•   Commissioner supervision of projects—The four commissioners said that
    commissioners do in fact monitor all projects and, upon request, are
    afforded updated information on the progress of projects.

    The four commissioners concluded that they perceived the draft report to
    be a great injustice to the Commission.

    We believe that our report contains adequate historical information and, in
    fact, includes information regarding changes in funding from 1980 to 1997.
    We also discuss in appendix I the limitations we faced in reporting on



    Page 22                 GAO/HEHS-97-125 Management of Commission on Civil Rights
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Commission operations that were caused by a lack of documentation and
the Commission’s poor record-keeping. We did not receive information we
asked for that would have provided more context for Commission
operations. We asked Commission officials repeatedly for records, files,
and other documentation about major aspects of the Commission’s
operations, including costs incurred for the Commission’s various offices,
functions, and projects, but were told that several key documents were
misplaced, lost, or did not exist. For example, we asked Commission
officials for staffing information showing when downsizing,
reductions-in-force, and reorganizations occurred. We were told in a letter
from the Commission dated December 4, 1996, and in several meetings
with Commission officials, that much of the information we requested,
including the staffing and cost information, was not available. We did not
receive all minutes requested describing the commissioners’ initial
discussions of the six racial and ethnic tension projects and the project on
Funding Civil Rights Enforcement. The minutes were particularly
important to show how these projects were initiated and planned.

We believe the Commission’s efforts to implement the OPM
recommendations regarding human resources management represent a
step in the right direction and encourage future efforts to improve its
management. We have modified our report to reflect the OPM assessment
of corrective actions the Commission took in response to the OPM review.

We are also encouraged by the statements of both the commissioners and
the Office of the Staff Director that the Commission will have a revised
management information system in place by October 1, 1997, that will
accurately track the status of Commission projects and the human and
budgetary resources committed to those projects so that, on a monthly
basis, commissioners will be in a position to evaluate the progress of
projects and assess the effectiveness of management operations.

The comments submitted by the Office of the Staff Director, which are an
attachment to the commissioners’ comments, addressed 19 points in our
report relating to our analysis of the management issues at the
Commission and recommendations for improvement. Most of the
comments generally discussed the reasons that the situations we reported
exist and actions the Commission is taking or plans to take to address
management weaknesses. For example, with regard to our statement that
Commission projects took so long that Commission staff proposed holding
additional hearings, the Office of the Staff Director agreed that some
projects take too long and said that the Commission has attempted to



Page 23                  GAO/HEHS-97-125 Management of Commission on Civil Rights
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speed up the process. It noted, however, that these efforts have been
hindered by commissioner and staff turnover.

We have incorporated, as appropriate, technical changes based on the
comments of the four commissioners critical of our report and those of the
Office of the Staff Director. For example, we are now separately reporting
the number of commissioners and the number of Commission staff and
have added that the Commission holds annual project planning meetings.
We have also modified our report to reflect comments about task force
meetings to revamp the administrative instruction for projects and to show
the costs for publishing two reports. In addition, we have added the
explanation from the Office of the Staff Director of the $270,000 difference
between the cost figure the Commission provided to the House
Constitution Subcommittee and the cost it gave us for the Fair Housing
Amendment Act project.


We are sending copies of this report to the eight commissioners and the
Commission Staff Director; the Director, Office of Management and
Budget; and other interested parties.

Please contact me on (202) 512-7014 or Sigurd R. Nilsen, Assistant
Director, on (202) 512-7003 if you have any questions about this report.
GAO contacts and staff acknowledgments are listed in appendix VI.


Sincerely yours,




Cornelia M. Blanchette
Associate Director, Education
  and Employment Issues




Page 24                  GAO/HEHS-97-125 Management of Commission on Civil Rights
Page 25   GAO/HEHS-97-125 Management of Commission on Civil Rights
Contents



Letter                                                                                             1


Appendix I                                                                                        30
                       Data Collection Strategy                                                   30
Scope and              Background Data on the Commission                                          30
Methodology            Project Management                                                         30
                       Limitations                                                                31

Appendix II                                                                                       32
                       Commission Reauthorizations                                                33
Additional             Organizational Structure                                                   34
Information on the     Staffing                                                                   34
                       Commission Spending                                                        35
U.S. Commission on
Civil Rights
Appendix III                                                                                      37

U.S. Commission on
Civil Rights
Commissioners for
the Period August
1996-May 1997
Appendix IV                                                                                       38

Comments From
Commission on Civil
Rights Commissioners
Anderson, George,
Horner, and
Redenbaugh




                       Page 26               GAO/HEHS-97-125 Management of Commission on Civil Rights
                       Contents




Appendix V                                                                                         39

Comments From the
Commission on Civil
Rights Chairperson,
Vice Chairperson,
Commissioners
Higginbotham and
Lee, and Staff
Director
Appendix VI                                                                                        74

GAO Contacts and
Staff
Acknowledgments
Related GAO Products                                                                               76


Tables                 Table 1: Commission on Civil Rights Components, Functions, and               5
                         Staff as of September 30, 1996
                       Table 2: Project Development and Oversight Guidance From the                 9
                         Administrative Manual Compared With Actual Practice
                       Table 3: Completed and Ongoing Commission Projects, FY                      13
                         1993-96
                       Table 4: Deferred Commission Projects, FY 1993-96                           14
                       Table 5: Commission Spending on Completed and Ongoing                       15
                         Projects, FY 1993-96
                       Table 6: Stages of Project Development at the Commission on                 16
                         Civil Rights
                       Table II.1: Commission Authorizations, 1957-96                              34
                       Table II.2: Commission Staffing Levels Over the 4-Year Period               35
                         Reviewed, Oct. 15, 1993-Sept. 30, 1996
                       Table II.3: Commission Spending Levels in Fiscal Year 1996                  35
                       Table II.4: Commission Actual and Inflation-Adjusted                        36
                         Appropriations




                       Page 27                GAO/HEHS-97-125 Management of Commission on Civil Rights
          Contents




Figures   Figure 1: Commission on Civil Rights Organization Chart as of                 4
            November 1996
          Figure 2: Commission Appropriations, FY 1980-97                               7




          Abbreviations

          EEO        Equal Employment Opportunity
          FOIA       Freedom of Information Act
          OCRE       Office of Civil Rights Evaluation
          OGC        Office of the General Counsel
          OPM        Office of Personnel Management
          SAC        State Advisory Committee


          Page 28                 GAO/HEHS-97-125 Management of Commission on Civil Rights
Page 29   GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix I

Scope and Methodology


                     In designing our study, we obtained all legislation and regulations
                     governing the Commission. We also gathered data on all projects initiated,
                     ongoing, and completed during fiscal years 1993 through 1996, the period
                     of our review; and we obtained data on the Commission’s budget, staffing,
                     projects, and legislative history. We conducted our work between August
                     1996 and May 1997 in accordance with generally accepted government
                     auditing standards.


                     We reviewed all applicable legislation, regulations, and historical
Data Collection      information, which included Commission appropriations for fiscal years
Strategy             1980 through 1997 and Commission reauthorizations beginning with its
                     creation in 1957 through September 30, 1996. We interviewed each
                     commissioner on the role of the Commission, management of Commission
                     projects, and overall management of the agency. To determine how and to
                     what extent the Commission manages its projects, we obtained internal
                     administrative guidance, staff listings over the 4-year period reviewed, an
                     organization chart depicting the Commission’s current organizational
                     structure, definitions of all Commission functions, and other relevant
                     documents. We attended Commission meetings, interviewed the staff
                     director, and interviewed Commission officials responsible for budget,
                     staffing, projects, and dissemination of project results to the public. We
                     obtained all documents through the Office of the Staff Director.


                     To review the role of the Commission, we obtained pertinent sections of
Background Data on   the U.S. Code, Public Laws, the Code of Federal Regulations, the
the Commission       legislative history, and other relevant documents about the Commission.
                     We synthesized the relevant sections of the legislation and regulations to
                     form a complete view of the role of the Commission.


                     To review the management of projects, the Commission provided us with a
Project Management   list of approved projects that were initiated, ongoing, or completed during
                     fiscal years 1993 through 1996. Because the Commission’s internal
                     guidance and administrative instructions for carrying out projects were
                     outdated, we reviewed agency project files to determine the process the
                     Commission followed for the projects. We also interviewed the staff
                     director and Commission officials responsible for staffing, budget,
                     projects, and dissemination of reports to the public. The Commission
                     provided a list of staff, broken out by office, but could not provide data on
                     actual staff time devoted to projects, nor could it provide budget



                     Page 30                  GAO/HEHS-97-125 Management of Commission on Civil Rights
              Appendix I
              Scope and Methodology




              information by Commission function. The Commission provided us with
              cost data for all but one project, but we are not confident that the data are
              accurate because of the Commission’s poor record-keeping.


              Our ability to accurately portray the Commission’s management of its
Limitations   projects was hampered due to inadequate Commission record-keeping, a
              lack of data, and the inability of Commission officials to generate certain
              data. In addition, we could not link budget information to specific
              activities because the Commission has a central budget and does not
              break down allocations to headquarters by unit and to regional offices.
              Nor was budget data available for Commission operations, such as the
              fiscal resources spent to carry out the Commission’s complaints referral
              process, the clearinghouse, and public service announcements.

              We were unable to examine records for three of the five projects
              completed during our review period because the Commission told us that
              documents were lost, misplaced, or nonexistent. Other data not available
              included the total cost for one project, planned budget costs for seven
              projects, concept papers for nine projects, and proposals for seven
              projects. We were unable to validate the process the Commission followed
              for projects by using the administrative guidance because the Commission
              told us the guidance was out of date and was being updated.




              Page 31                  GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix II

Additional Information on the U.S.
Commission on Civil Rights

               Established by the Civil Rights Act of 1957, the Commission on Civil Rights
               is an independent bipartisan agency created to protect the civil rights of
               people within the United States. The mission and authority of the
               Commission is to (1) investigate charges that citizens are being deprived
               of certain voting rights by reason of color, race, religion, sex,18 age,
               disability,19 or national origin; (2) relative to deprivation of voting rights,
               study and collect information concerning legal developments; and
               (3) appraise federal laws and policies; (4) serve as a national
               clearinghouse for information;20 and (5) prepare public service
               announcements and advertising campaigns.21 To accomplish its mission,
               the Commission may hold hearings and issue subpoenas within the state in
               which the hearing is being held and within a 100-mile radius of the site for
               the production of documents and the attendance of witnesses at such
               hearings. It also maintains state advisory committees, and consults with
               representatives of federal, state, and local governments, and private
               organizations in furtherance of its fact-finding functions.

               The Commission is required to issue reports and findings of its
               investigations to the Congress and the president and recommend
               legislative remedies. The Commission must submit at least one report
               annually to the president and the Congress that monitors federal civil
               rights enforcement in the United States. In addition, because it lacks
               enforcement powers that would enable it to apply specific remedies in
               individual cases, the Commission refers specific complaints it receives to
               the appropriate federal, state, or local government agency for action.

               In 1957, the Commission consisted of six commissioners appointed by the
               president, with not more than three to be from the same political party.
               There were no specified terms of office. The Commission operated for
               more than 25 years before its structure changed from the original
               formulation. In 1983, the Congress passed legislation22 creating a new Civil
               Rights Commission to succeed the presidentially appointed Commission
               established in 1957. Under the 1983 legislation, the number of
               commissioners was expanded from six to eight, with not more than four to

               18
                 Sex was added as a protected group in 1978, P.L. 92-496, section 3.
               19
                Age and Handicap were added as protected groups in 1983, P.L. 95-444, section 3. The term
               “handicap” was changed to “disability” in 1994 by P.L. 103-419.
               20
                 This duty was authorized by title V of the Civil Rights Act of 1964, P.L. 88-352.
               21
                The additional duties of public service announcements and advertising campaigns were added by the
               1994 statute, P.L. 103-419.
               22
                 P.L. 98-183.



               Page 32                             GAO/HEHS-97-125 Management of Commission on Civil Rights
                   Appendix II
                   Additional Information on the U.S.
                   Commission on Civil Rights




                   be from the same political party. The way commissioners were appointed
                   changed also, allotting four to the president, two to the president pro
                   tempore of the Senate, and two to the speaker of the House of
                   Representatives. Additionally, the commissioners now served a 6-year
                   term, with certain provisions at enactment for staggering the terms. The
                   original legislation created the position of staff director, appointed by the
                   president with the advice and consent of the Senate; the 1983 legislation
                   replaced Senate confirmation with concurrence of a majority of the
                   commissioners.


                   The Commission on Civil Rights has been in existence for 40 years even
Commission         though a sunset clause in its authorizing legislation provided that the
Reauthorizations   Commission would submit a final report to the Congress and the president
                   no more than 2 years after enactment, and that 60 days later the
                   Commission would “cease to exist.” The Commission’s authorizing
                   legislation was extended numerous times between 1959 and 1982; the
                   longest extension was for 5 years. By 1982, the debate in the Congress was
                   not over whether to extend the life of the Commission but on how best to
                   do so while enabling it to function effectively in a bipartisan manner and
                   without altering its historical structure and integrity.23

                   Before its 1983 reauthorization, the President, in his budget message to the
                   Congress in 1982 proposed that the Commission be allowed to continue its
                   work until 2003, saying, “[s]ince its inception, the Commission has focused
                   its energies on research demonstrating the existence of civil rights
                   problems. This emphasis was appropriate in the early years of the
                   Commission’s existence. However, the questions of the 1980’s involve not
                   whether civil rights problems exist, but how to most effectively resolve
                   them.” The President also proposed that commissioners serve for specified
                   terms.24 Between 1989 and 1996, the Commission was reauthorized three
                   more times, until September 30, 1996 (see table II.1). The Congress did not
                   reauthorize the Commission in 1996 but appropriated funds that allowed it
                   to continue operations through September 30, 1997.25




                   23
                     House Debate of H.R. 2230, Cong. Rec. H. 23134-23149.
                   24
                     Special Analysis J, Civil Rights Activities of the Budget, 1982.
                   25
                     Commission Authority to Operate, 71 Comp. Gen. 378 (Apr. 29, 1992).



                   Page 33                             GAO/HEHS-97-125 Management of Commission on Civil Rights
                                         Appendix II
                                         Additional Information on the U.S.
                                         Commission on Civil Rights




Table II.1: Commission Authorizations,
1957-96                                  Public Law                     Expiration                 Duration
                                         85-315                         Sept. 1959                 2 years
                                         86-383                         Sept. 1961                 2 years
                                         87-264                         Sept. 1963                 2 years
                                         88-152                         Sept. 1964                 1 year
                                         88-352                         Jan. 1968                  3-1/2 years
                                         90-198                         Jan. 1973                  5 years
                                         92-496                         Jan. 1978                  5 years
                                         95-444                         Sept. 1983                 5 years
                                         98-183                         Nov. 1989                  6 years
                                         101-180                        Sept. 1991                 2 years
                                         102-167                        Sept. 1994                 3 years
                                         103-419                        Sept. 1996                 2 years



                                         The Commission had a major reorganization in November 1986. This
Organizational                           reorganization and subsequent staff changes through November 1996
Structure                                eliminated or combined 5 of the 13 major offices, leaving 8 major offices
                                         and units in place; the 19 smaller offices, including 10 regional offices,
                                         were reduced to 9 offices, which included 6 regional offices. The
                                         Commission also eliminated the Office of Program and Policy, the Office
                                         of Research, the Planning and Coordination Unit, the Solicitor’s Unit, and
                                         the Equal Employment Opportunity Unit. It apparently merged the duties
                                         of the eliminated units or offices into existing units.


                                         As of fiscal year 1996, the staff director for the Commission managed 83
Staffing                                 employees located in six regional offices and in Washington, D.C. This
                                         staff assisted eight part-time commissioners and their assistants in
                                         carrying out Commission work. The Office of General Counsel (OGC) and
                                         the Office of Civil Rights Enforcement (OCRE) conduct the projects and
                                         had a combined total of 27 staff members who also had other
                                         responsibilities. The Regional Programs Unit is the single largest
                                         component of the Commission with 27 staff members, which include 2 at
                                         headquarters and 25 in the six regional offices (see table II.2 for the
                                         Commission’s staffing levels over the 4 years included in our review).




                                         Page 34                      GAO/HEHS-97-125 Management of Commission on Civil Rights
                                         Appendix II
                                         Additional Information on the U.S.
                                         Commission on Civil Rights




Table II.2: Commission Staffing Levels
Over the 4-Year Period Reviewed,                                                      Staff as of    Staff as of     Staff as of   Staff as of
Oct. 15, 1993-Sept. 30, 1996             Office/unit                                     9/30/96        10/1/95         10/3/94      10/15/93
                                         Commissioners                                          8             8               8              8
                                         Commissioners’ Assistants                              7             8               8              8
                                         Staff Director                                         5             6               6              5a
                                         OCRE                                                   12           13               9             11
                                                                                                               b               c
                                         OGC                                                    15                           12             15
                                         Regional Programs                                      27           28              28             27
                                         Office of Management                                   17           16              14             16
                                         Public Affairs                                         6             7               4              4
                                         Congressional Affairs                                  2             2               2              1
                                         Total                                                  99           89b             92             95
                                         a
                                          Two employees were assigned to other units but served in the roles of Acting Staff Director and
                                         Acting Deputy Staff Director.
                                         b
                                             Number of employees not provided for the office.
                                         c
                                         The positions of General Counsel and Deputy General Counsel were vacant.




                                         The Commission on Civil Rights does not maintain budget information by
Commission Spending                      component office, and Commission officials told us that they could not
                                         separately estimate the percentage of the Commission’s budget spent on
                                         each component office or on the cognizant responsibilities of the offices.
                                         On the basis of information contained in the Commission’s fiscal year 1998
                                         budget request, about 72 percent of the Commission’s spending for fiscal
                                         year 1996 was for salaries and benefits, and another 13 percent was for
                                         rent (see table II.3).

Table II.3: Commission Spending
Levels in Fiscal Year 1996                                                                                  Spending           Percentage of
                                         Category                                                        (thousands)          total spending
                                         Personnel compensation and benefits                                   $6,316                     72.4
                                         Rent                                                                      1,114                  12.7
                                         Other (utilities, reproduction,a services,
                                         supplies, and equipment)                                                   989                   11.3
                                         Travel and transportation                                                  293                     3.3
                                         Total                                                                 $8,712                     99.7
                                         a
                                          The Commission’s budget showed a line item of “printing and reproduction”; however,
                                         Commission officials told us that they did not know the cost of publishing and disseminating
                                         project reports; thus, it is not clear what amount and percentage of the funds spent in this
                                         category generally would cover printing costs for project reports as opposed to typical agency
                                         xeroxing or copying costs.




                                         Page 35                            GAO/HEHS-97-125 Management of Commission on Civil Rights
                                    Appendix II
                                    Additional Information on the U.S.
                                    Commission on Civil Rights




                                    The Commission’s appropriations ranged from a high of $12.7 million in
                                    fiscal year 1985 to a low of $5.7 million in fiscal year 1988 and has since
                                    leveled off to around $7.8 million from fiscal year 1993 to the present (see
                                    table II.4).

Table II.4: Commission Actual and
Inflation-Adjusted Appropriations   Dollars in thousands, 1996 = 100
                                                                                                                          Adjusted
                                    Fiscal year                                                 Appropriation        appropriationa
                                    1980                                                                $11,230            $20,748
                                    1981                                                                 11,719             19,749
                                    1982                                                                 12,318             19,529
                                    1983                                                                 11,626             17,747
                                    1984                                                                 11,887             17,654
                                    1985                                                                 12,747             18,294
                                    1986                                                                 12,300             17,223
                                    1987                                                                     7,500          10,277
                                    1988                                                                     5,707           7,576
                                    1989                                                                     5,707           7,323
                                    1990                                                                     5,707           7,078
                                    1991                                                                     7,075           8,318
                                    1992                                                                     7,159           8,240
                                    1993                                                                     7,776           8,606
                                    1994                                                                     7,776           8,310
                                    1995                                                                     9,000           9,224
                                    1996                                                                     8,750           8,750
                                    1997                                                                     8,740           8,763b
                                    a
                                    Amount calculated using the federal, nondefense government consumption price index.
                                    b
                                        Estimated on the basis of the amounts for the 3rd quarter of 1996.

                                    Source: Economic Report of the President, table B-3 (Washington, D.C.: Feb. 1997).




                                    Page 36                             GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix III

U.S. Commission on Civil Rights
Commissioners for the Period August
1996-May 1997

Name                            Date appointed                        Appointed by                           Political affiliation
                            a        b
Mary F. Berry, Chairperson      2/3/93                                Speaker of the House                   Independent
Cruz Reynoso, Vice Chairpersonc 4/19/93                               Senate President Pro Tempore           Democrat
Carl A. Anderson                2/8/90                                Speaker of the House                   Republican
Robert P. George                1/20/93                               President                              Independent
A. Leon Higginbotham, Jr.       11/30/95                              President                              Democrat
Constance Horner                1/20/93                               President                              Republican
Yvonne Y. Lee                   12/30/95                              President                              Democrat
Russell G. Redenbaugh           12/12/95d                             Senate President Pro Tempore           Independent
                                            a
                                             The President designated Commissioner Berry as Chairperson on Sept. 17, 1993, and a majority
                                            of commissioners concurred on Nov. 19, 1993.
                                            b
                                             The date the current term of office (6 years) began. It will expire in 1999. Commissioner Berry
                                            was first appointed to the Commission in 1980.
                                            c
                                             President designated Commissioner Reynoso as Vice Chairperson on Sept. 27, 1993, and a
                                            majority of commissioners concurred on Nov. 19, 1993.
                                            d
                                             Commissioner Redenbaugh was first appointed to the Commission in 1990 and was reappointed
                                            in 1995 for a second term.




                                            Page 37                          GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix IV

Comments From Commission on Civil
Rights Commissioners Anderson, George,
Horner, and Redenbaugh




              Page 38   GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V

Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




              Page 39   GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 41                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 42                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 43                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 44                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 45                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 46                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 47                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 48                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 49                    GAO/HEHS-97-125 Management of Commission on Civil Rights
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Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 50                    GAO/HEHS-97-125 Management of Commission on Civil Rights
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Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 52                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 53                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 54                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 55                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 59                    GAO/HEHS-97-125 Management of Commission on Civil Rights
               Appendix V
               Comments From the Commission on Civil
               Rights Chairperson, Vice Chairperson,
               Commissioners Higginbotham and Lee, and
               Staff Director




Now on p. 5.




Now on p. 2.




               Page 60                    GAO/HEHS-97-125 Management of Commission on Civil Rights
               Appendix V
               Comments From the Commission on Civil
               Rights Chairperson, Vice Chairperson,
               Commissioners Higginbotham and Lee, and
               Staff Director




Now on p. 2.




Now on p. 8.




               Page 61                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                Appendix V
                Comments From the Commission on Civil
                Rights Chairperson, Vice Chairperson,
                Commissioners Higginbotham and Lee, and
                Staff Director




Now on p. 10.




Now on p. 8.




Now on p. 8.




                Page 62                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                Appendix V
                Comments From the Commission on Civil
                Rights Chairperson, Vice Chairperson,
                Commissioners Higginbotham and Lee, and
                Staff Director




Now on p. 10.




Now on p. 10.




                Page 63                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                    Appendix V
                    Comments From the Commission on Civil
                    Rights Chairperson, Vice Chairperson,
                    Commissioners Higginbotham and Lee, and
                    Staff Director




Now on pp. 10-11.




Now on p. 11.




                    Page 64                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                    Appendix V
                    Comments From the Commission on Civil
                    Rights Chairperson, Vice Chairperson,
                    Commissioners Higginbotham and Lee, and
                    Staff Director




Now on pp. 11-12.




                    Page 65                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                Appendix V
                Comments From the Commission on Civil
                Rights Chairperson, Vice Chairperson,
                Commissioners Higginbotham and Lee, and
                Staff Director




Now on p. 15.




                Page 66                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                    Appendix V
                    Comments From the Commission on Civil
                    Rights Chairperson, Vice Chairperson,
                    Commissioners Higginbotham and Lee, and
                    Staff Director




Now on p. 17.




Now on pp. 17-18.




Now on p. 18.




                    Page 67                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                Appendix V
                Comments From the Commission on Civil
                Rights Chairperson, Vice Chairperson,
                Commissioners Higginbotham and Lee, and
                Staff Director




Now on p. 19.




Now on p. 19.




                Page 68                    GAO/HEHS-97-125 Management of Commission on Civil Rights
                Appendix V
                Comments From the Commission on Civil
                Rights Chairperson, Vice Chairperson,
                Commissioners Higginbotham and Lee, and
                Staff Director




Now on p. 20.




Now on p. 20.




                Page 69                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




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Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 72                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix V
Comments From the Commission on Civil
Rights Chairperson, Vice Chairperson,
Commissioners Higginbotham and Lee, and
Staff Director




Page 73                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix VI

GAO Contacts and Staff Acknowledgments


                  Sigurd R. Nilsen, Assistant Director, (202) 512-7003
GAO Contacts      Jacqueline Harpp, Evaluator-in-Charge, (202) 512-8380


                  Patricia M. Bundy, Evaluator
Staff             Stefanie Weldon, Senior Attorney
Acknowledgments




                  Page 74                 GAO/HEHS-97-125 Management of Commission on Civil Rights
Appendix VI
GAO Contacts and Staff Acknowledgments




Page 75                    GAO/HEHS-97-125 Management of Commission on Civil Rights
Related GAO Products


              Commission on Civil Rights: Commissioners’ Travel Activities
              (GAO/GGD-94-130, Aug. 8, 1994).

              Request for Reconsideration of Claim for Relocation Allowance
              (B-246538.4, Mar. 18, 1994).

              Civil Rights Commission Employee’s Claim for Relocation Expenses
              (B-246538.2, Jan. 27, 1993).

              U.S. Commission on Civil Rights: The Commission Has Complied With
              FY90 Appropriation Act Provisions (GAO/GGD-92-83, May 12, 1992).

              Civil Rights Commission Authority to Operate (B-246541, Apr. 29, 1992).

              U.S. Commission on Civil Rights: The Commission Has Complied With
              FY89 Appropriation Act Provisions (GAO/GGD-91-32, Feb. 8, 1991).

              U.S. Commission on Civil Rights: Compliance With Appropriation
              Provisions as of March 31, 1988 (GAO/GGD-88-91, June 2, 1988).

              U.S. Commission on Civil Rights: Concerns About Commission Operations
              (GAO/GGD-88-71, May 26, 1988).

              U.S. Commission on Civil Rights: Commission Publications During Fiscal
              Years 1978-1986 (GAO/GGD-87-117BR, Sept. 25, 1987).

              Civil Rights Commission Employees’ Claim for Severance Pay (B-217050,
              July 30, 1986).

              The Operations of the United States Commission on Civil Rights
              (Testimony, Mar. 25, 1986).




(205322)      Page 76                 GAO/HEHS-97-125 Management of Commission on Civil Rights
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