oversight

The Results Act: Observations on the Draft Strategic Plans of Selected Department of Labor Components

Published by the Government Accountability Office on 1997-07-31.

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

      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division

      B-277573

      July 31, 1997

      The Honorable Richard K. Armey
      Majority Leader
      House of Representatives

      The Honorable John R. Kasich
      Chairman, Committee on the Budget
      House of Representatives

      The Honorable Dan Burton
      Chairman, Committee on Government
        Reform and Oversight
      House of Representatives

      The Honorable Bob Livingston
      Chairman, Committee on Appropriations
      House of Representatives

      Subject: The Results Act: Observations on the Draft Strategic Plans of
      Selected Department of Labor Components

      On June 12, 1997, you asked us to review the draft strategic plans
      submitted by the cabinet departments and selected major agencies for
      consultation with the Congress as required by the Government
      Performance and Results Act of 1993 (the Results Act). This letter
      completes our response to that request concerning the Department of
      Labor.

      Labor’s strategic plan consists of a Department-level document, which it
      designates as a “strategic plan overview,” supplemented by strategic plans
      for 15 of its component offices or units. As agreed with your offices, we
      analyzed Labor’s overview and performed selected analyses of individual
      plans. The results of our analysis of Labor’s overview were sent to you in a
      letter dated July 11, 1997.1 As you further requested, this letter provides
      additional detailed analyses on the individual draft strategic plans
      submitted by the Employment and Training Administration (ETA), the
      Occupational Safety and Health Administration (OSHA), and the
      Employment Standards Administration (ESA).



      1
       The Results Act: Observations on Department of Labor’s June 1997 Draft Strategic Plan
      (GAO/HEHS-97-172R, July 11, 1997).



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                     Our overall objective was to review and evaluate the draft strategic plans
Objectives, Scope,   for three of Labor’s components—ETA, OSHA, and ESA—as submitted by
and Methodology      Labor to congressional staff on June 11. Specifically, we (1) determined
                     whether the plans included the elements required by the Results Act and
                     assessed the strengths and weaknesses of the elements contained in them;
                     (2) discussed the components’ key statutory responsibilities and how they
                     were addressed in each of the plans; (3) identified each component’s
                     programs, activities, and functions that are crosscutting in that they are
                     similar or related to goals, activities, or functions of other agencies and the
                     extent to which the plan reflects interagency cooperation; (4) discussed
                     the extent to which management challenges were addressed in each plan;
                     and (5) described the three components’ capacities to provide reliable
                     information about performance.

                     As agreed, our assessment of the component strategic plans was based
                     generally on our previous work, our knowledge of the components’
                     operations, numerous reviews of Labor, and other information available at
                     the time of our assessment. Specifically, the criterion we used to
                     determine whether the components’ draft strategic plans complied with
                     the requirements of the Results Act was the Results Act itself,
                     supplemented by the Office of Management and Budget’s (OMB) guidance
                     on developing the plans (Circular A-11, part 2). To make judgments about
                     the overall quality of the plans, we used our May 1997 guidance for
                     congressional review of strategic plans (GAO/GGD-10.1.16) as a tool. To
                     determine whether the plans contained information on interagency
                     coordination, addressed management problems previously identified, and
                     reflected a capacity to provide reliable performance information, we relied
                     on our general knowledge of Labor’s operations and programs, and the
                     results of our previous work.

                     Although we assessed the three Labor components’ plans in terms of the
                     Results Act, individual components are not required to submit strategic
                     plans. According to the act and OMB Circular A-11, executive agencies such
                     as Labor are required to submit a plan, and the agencies can use discretion
                     as to which of their component units must submit plans. There is no
                     requirement that the component plans that are submitted include the six
                     elements specified in the act. As you requested, however, we reviewed the
                     component plans in terms of how they address the six elements
                     considered essential to a strategic plan.

                     To review the key statutory responsibilities of each of the three
                     components and how they relate to their missions and goals, we examined



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             the applicable statutes. As requested, we coordinated our work on key
             statutory authorities and the capacity to provide reliable information with
             the Congressional Research Service and Labor’s Inspector General,
             respectively.

             In passing the Results Act, the Congress anticipated that several planning
             cycles might be needed to perfect the process of developing a strategic
             plan and that the plan would be continually refined. Thus, our comments
             reflect a “snapshot” of the status of the component plans at a particular
             point. We recognize that developing a strategic plan is a dynamic process
             and that Labor and its component units are continuing to work to revise
             the draft with input from OMB, congressional staff, and other stakeholders.


             Labor administers and enforces a variety of federal labor laws
Background   guaranteeing workers’ rights to a work place free from safety and health
             hazards, a minimum hourly wage and overtime pay, family and medical
             leave, freedom from employment discrimination, and unemployment
             insurance. Labor also protects workers’ pension rights; provides job
             training programs; helps workers find jobs; works to strengthen free
             collective bargaining; and keeps track of changes in employment, prices,
             and other national economic measures. Labor’s diversity of functions is
             carried out by different offices in a decentralized organizational structure.
             It has 24 component offices or units, and over 1,000 field offices to support
             its various functional responsibilities. In fiscal year 1997, Labor has an
             estimated budget of $34.4 billion and is authorized 16,614
             full-time-equivalent staff-years.




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Figure 1: Department of Labor Organization




Employment and Training                  ETA administers a number of statutes related to employment and training
Administration                           services for the unemployed and underemployed, employment security for
                                         workers, and other programs that are directed to meeting the employment
                                         needs of the nation. A major ETA responsibility is to carry out the Job
                                         Training Partnership Act, which established a decentralized structure for
                                         the delivery of employment and training services funded through grants
                                         and administered predominantly by the states. ETA’s employment security
                                         functions are carried out by the Unemployment Insurance Service, which
                                         administers a nationwide unemployment compensation system, and the
                                         Employment Service, which administers a nationwide public employment
                                         service system. ETA has an estimated budget of $31.4 billion in fiscal year
                                         1997; $6.2 billion of this amount is for employment and training programs.
                                         The remaining $25 billion is for mandatory spending on income
                                         maintenance programs, such as the unemployment insurance program,
                                         and comes primarily from the unemployment insurance trust fund, which
                                         is financed by federal and state employer payroll taxes.




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Occupational Safety and    OSHA administers policies and programs to ensure safe and healthful
Health Administration      working conditions for over 100 million workers covered by the
                           Occupational Safety and Health Act of 1970. OSHA sets and enforces
                           national standards for work places to reduce or eliminate safety and
                           health hazards, encourages employers and employees to reduce work
                           place hazards through voluntary programs, offers training to improve the
                           competence of occupational safety and health personnel, and provides for
                           the development and approval of state occupational safety and health
                           programs. OSHA’s estimated budget for fiscal year 1997 is $325 million.


Employment Standards       ESA is responsible for administering and directing a variety of programs
Administration             that protect the basic rights of workers. These include programs dealing
                           with minimum wage and hour standards, workers’ compensation
                           programs, equal employment opportunity programs, and affirmative action
                           programs for government contract employees, and programs protecting
                           workers’ rights as union members. ESA administers these programs
                           through four offices—the Office of Federal Contract Compliance
                           Programs (OFCCP), the Office of Workers’ Compensation Programs (OWCP),
                           the Wage and Hour Division (WHD), and the Office of Labor Management
                           Standards (OLMS). In fiscal year 1997, ESA has an estimated budget of
                           $1.6 billion.

                           OFCCP is responsible for enforcing requirements governing the employment
                           practices of federal contractors and subcontractors that ensure equal
                           employment opportunity for minorities, women, individuals with
                           disabilities, and disabled and Vietnam Era veterans. OWCP administers
                           three major disability compensation programs by providing cash benefits,
                           medical treatment, vocational rehabilitation, and other benefits to certain
                           workers who have work-related injuries or diseases. WHD administers and
                           enforces a wide range of laws that collectively cover virtually all private as
                           well as state and local government employment. Its activities include
                           ensuring compliance with minimum wage, overtime, child labor, and other
                           employment standards. OLMS collects and makes available for public
                           disclosure union constitutions and financial reports, audits union financial
                           records, and investigates possible embezzlement of union funds.


Results Act Requirements   The Results Act requires virtually every executive agency to develop a
and OMB Guidance on        strategic plan covering a period of at least 5 years from the fiscal year in
Preparing and Submitting   which it is submitted. The plans are to contain the following six elements:
                           (1) an agency mission statement, (2) long-term goals and objectives,
Strategic Plans


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                          (3) approaches to achieve goals and objectives, (4) a description of the
                          relationship between annual goals and long-term goals and objectives,
                          (5) key external factors that could affect achievement of goals, and
                          (6) evaluations used in establishing the strategic plan and schedule for
                          future program evaluations.

                          The Results Act is aimed at improving program performance. It requires
                          that federal agencies consult with the Congress and other stakeholders to
                          clearly define their missions and articulate a comprehensive mission
                          statement that defines the basic purpose of the agency. It also requires
                          that they establish long-term strategic goals as well as annual goals that
                          are linked to them. Agencies must then measure their performance against
                          the goals they have set and report publicly on how well they are doing. In
                          addition to monitoring ongoing performance, agencies are expected to
                          evaluate their programs and to use information obtained from these
                          evaluations to improve their programs.

                          OMB Circular A-11 provides additional guidance on the development of
                          agency strategic plans. The Circular strongly encourages agencies to
                          submit a single, agencywide strategic plan. It states, however, that an
                          agency with disparate functions, such as Labor, may prepare several
                          strategic plans for its major components or programs. When an agency
                          does prepare multiple strategic plans for component units, Circular A-11
                          further provides that these should not be merely packaged together and
                          submitted as a single strategic plan because the size and detail of such a
                          compilation will reduce the plan’s usefulness. Moreover, the agency is to
                          prepare an agencywide strategic overview that will link individual plans by
                          giving an overall statement of the agency’s mission and goals.


Summary of Labor’s        As we reported to you on July 11, 1996, to meet the Results Act
Strategic Plan Overview   requirement for an agency strategic plan, Labor elected to submit “a
                          strategic plan overview” that addresses some Results Act requirements at
                          the Department level. It also submitted individual plans for certain agency
                          component units. However, Labor’s overview does not comply with OMB
                          guidance to integrate information from individual strategic plans of its
                          components into a single agencywide strategic overview document.
                          Furthermore, while Labor’s overview contains a mission statement for the
                          agency, as required, the statement itself does not appear to be sufficiently
                          descriptive of Labor’s basic purpose. Labor’s strategic plan overview also
                          does not meet the guidance contained in Circular A-11 that it contain an




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                    overall statement of departmental goals. Instead, Labor has excerpted and
                    listed the goals contained in the component unit plans.

                    Labor’s draft overview and supplemental unit plans cover the five areas of
                    major statutory responsibility—employment and training, health and
                    safety in the work place, pension and welfare benefits, employment
                    standards, and labor statistics. The goals stated in the plans are consistent
                    with Labor’s statutory responsibilities. In addition, the mission statements
                    cover all of Labor’s major functions and operations.

                    Labor’s strategic plan overview recognizes the roles of other organizations,
                    such as other federal agencies and state and local governments, and the
                    importance of establishing partnerships in carrying out such functions as
                    ensuring safe and healthful work places. Labor’s overview could be
                    improved, however, by recognizing the importance of other participants,
                    namely the other 14 federal agencies involved in one major area of
                    responsibility—job training. The overview does not acknowledge that the
                    nation’s federally funded employment training system is a patchwork of
                    multiple programs, many of which are in departments and agencies other
                    than Labor; nor does it set forth strategies pertaining to the development
                    of a cohesive, integrated, and coordinated system.

                    Finally, Labor’s capacity to provide reliable information for use in its
                    agencywide management is questionable. Its overview plan recognizes the
                    importance of additional information to ensure timely and sound
                    evaluations to assess agency progress in meeting goals. However, its
                    overview does not describe its strategy for ensuring that such information
                    is collected and used to assess progress and performance. In addition,
                    Labor’s overview plan does not discuss with any specificity how it will use
                    information technology to achieve its mission, goals, and objectives; nor
                    does the plan describe with sufficient clarity how Labor intends to use
                    information technology to improve performance and reduce costs. The
                    plan also does not include a discussion on the need for computer systems
                    to be changed to accommodate dates beyond the year 1999—the “year
                    2000 problem.” Furthermore, Labor’s strategic overview plan could be
                    improved by including a discussion of its technology investment control
                    process, a process that can help agencies reduce the risk and maximize
                    the net benefits from their information technology investments.


                    The strategic plans of ETA and OSHA address most of the elements in the
Overview of Three   Results Act. Improvement could be made, however, by including more
Components’ Plans

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                       detailed discussions of evaluation strategies, crosscutting activities, and
                       generating reliable performance information. In addition, both plans could
                       benefit by including more results-oriented goals and objectives. On the
                       other hand, ESA did not prepare an overall strategic plan. Rather, it
                       submitted plans for each of its four program offices. Because ESA did not
                       prepare an overall plan, it may not be in a position to address common
                       themes among its four program agencies, such as better serving
                       customers, relying on information technology, and working with reduced
                       resources.

                       A more detailed analysis of ETA’s and OSHA’s plans are included in
                       enclosures I and II, respectively. A review of the statutory requirements of
                       ESA are included in enclosure III.



ETA’s Strategic Plan   ETA’s draft strategic plan includes five of the six elements delineated in the
                       Results Act, but it does not provide the required information about
                       program evaluations. Furthermore, some of the elements, such as
                       strategies to achieve goals and the factors affecting ETA’s ability to achieve
                       the goals, are discussed in greater detail and are developed more fully than
                       others. Other useful information related to crosscutting functions and
                       management challenges is not provided. ETA’s mission statement does not
                       cover its key statutory responsibilities, but ETA’s goals do reflect these
                       responsibilities.

                       ETA’s plan provides a fairly broad mission statement; for example, it
                       generally focuses on “ensuring that Americans have access to the
                       information and resources they require to successfully manage their job
                       lives.” Its mission statement could be improved if ETA combined it with the
                       responsibilities it clearly set out in its vision statement, such as providing
                       high-quality job training, employment, and income maintenance services
                       through state and local workforce development systems.

                       ETA’s description of long-term goals and objectives, strategies to achieve
                       them, and linkage to annual goals could also be improved. The goals of the
                       plan cover the range of ETA’s responsibilities and generally allow for the
                       future assessment of whether they are being achieved. But ETA could
                       improve its strategic plan by developing objectives that are more results
                       oriented and measurable. The strategic objectives currently in the plan
                       appear to be strategies to achieve goals rather than objectives. For
                       example, the plan includes the following as a strategic objective: “Through
                       Job Corps provide alternative education and job skills preparation in a



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safe living and learning environment, for disadvantaged, low income youth
who dropped out of school or who are at risk of dropping out of school.”
However, this is essentially a strategy for achieving one of the strategic
goals, that is, “Assure that America’s youth, particularly at risk youth,
acquire the knowledge, skills and abilities they need to earn a decent
living.”

In addition, the plan would be more useful if it provided a schedule for
initiating and completing its strategies and described how it would
communicate strategic goals throughout the organization and how it plans
to hold management accountable for achieving goals.

The plan includes a brief discussion of the relationship of the annual plan
to the long-term strategic plan and cites examples of performance
measures likely to be included in the annual plan. Some examples cited
are “the number of states that demonstrate and pursue one-stop building
principles, the number of local communities which will have access to
employment and training services through an integrated one-stop career
center system,” “the number of job vacancies available on the Internet . . .,”
and “the number of Job Corps students who are placed into jobs or other
suitable outcomes.” The performance measures it finally selects would be
more useful if they included more results-oriented, outcome measures
than those now listed as possible measures.

ETA’s draft plan could also be improved by including a more detailed
discussion of external factors that could affect it and by including the
required information about program evaluations. ETA’s draft plan describes
the external factors that could affect its ability to achieve its goals, such as
pending legislation to consolidate employment and training programs,
resource availability, and changes in the economy. A strengthened
discussion of the impact of recently passed welfare legislation would be
helpful, however, given its potentially great impact on employment and
training programs at the state and local levels. The draft plan makes no
reference to program evaluations conducted or planned. It does state that
program requirements, with respect to performance measurement
information, will be assessed after the strategic plan is completed, but it is
not clear whether the reference is to discrete evaluation studies or
ongoing performance measures.

Two of the goals outlined in ETA’s plan reflect the requirements of law; the
rest do not, but are consistent with the law. For example, ETA’s goal of
assuring that America’s youth, particularly at-risk youth, acquire the



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                        knowledge, skills, and abilities they need to earn a decent living reflects a
                        requirement of law in that the very purpose of the Job Training
                        Partnership Act is to establish programs to train youths and adults facing
                        serious barriers to employment.

                        The draft plan would also be improved by a discussion of coordination
                        about crosscutting issues and acknowledgment of management challenges
                        in implementing the plan, including obtaining reliable information about
                        performance. All of these features are missing from the current draft, even
                        though there are significant crosscutting issues that should be addressed
                        (for example, the fact that multiple agencies are responsible for
                        employment training programs) and a major management challenge facing
                        ETA is the difficulty of producing reliable information to assess program
                        implementation and performance.


OSHA’s Strategic Plan   OSHA’sdraft strategic plan includes all but one of the six elements
                        delineated in the Results Act. It also addresses crosscutting issues and
                        discusses major management challenges such as obtaining reliable
                        information.

                        OSHA’s mission statement—“assure so far as possible every working man
                        and woman in the nation safe and healthful working conditions”—clearly
                        and succinctly describes why OSHA exists and how it carries out its work.
                        The goals OSHA sets forth in its plan convey its principal functions and
                        operations and are directly related to its mission. For example, the first
                        goal in OSHA’s plan is to “assure safe and healthful working conditions for
                        all workers, as evidenced by fewer hazards, reduced exposures, and fewer
                        injuries, illnesses, and fatalities.

                        OSHA’s  plan presents a broad discussion of the strategic tools that it will
                        rely on to achieve its goals. However, the strategic plan focuses more on
                        describing particular strategies rather than on articulating clear linkages
                        between the individual strategies and the achievement of the plan’s goals.
                        For example, although the plan discusses the various types of strategies
                        OSHA will use to achieve its goals (such as increased use of information
                        technology or problem analysis), OSHA did not include information about
                        how these strategies (which strive for improved data collection) can
                        facilitate achievement of its goals.

                        The plan includes strategic measures to assess whether the related goals
                        and objectives have been achieved. Although some of the plan’s



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performance measures are clearly outcome oriented, others are
ambiguous, posing measurement and interpretation problems. Other
performance measures are essentially strategies for achieving the goals,
rather than measures. For example, a measure such as “developing and
delivering training to workers and employers in the skills necessary for
effective worker involvement in safety and health” is more of a strategy for
achieving a goal rather than an indicator for measuring progress.

Also, the plan does not include a schedule for initiating or completing
significant actions nor the level of resources deemed necessary. Similarly,
the plan does not address the process to be followed to communicate
goals and objectives throughout the agency and to assign accountability to
managers and staff for achievement of objectives. OSHA’s plan does not
specifically define the annual performance goals; the plan could be
improved by identifying the appropriate data and measures OSHA will use
to monitor progress on these goals.

OSHA’s strategic plan includes a discussion of the external factors that
could influence the achievement of its strategic goals. As the plan notes,
agency performance in improving worker safety and health can be
significantly affected by general economic conditions, workforce
demographics, and changes in the economy’s job mix. However, it does
not convey the extent to which these factors might affect the achievement
of the goals. It also does not describe how program evaluations were used
in developing the plan or what future evaluations will be used for
measuring progress.

Two of the three goals laid out in OSHA’s plan reflect the purposes
delineated in the Occupational Safety and Health Act, OSHA’s enabling
legislation. For example, the first goal enunciated in OSHA’s plan, which is
to ensure healthful and safe working conditions for all workers, as
evidenced by fewer hazards and injuries, clearly reflects the purpose of
the legislation, which is to “assure so far as possible every working man
and woman in the Nation safe and healthful working conditions.” The third
goal is a general management goal that does not reflect a specific
provision of law.

OSHA’splan acknowledges the importance of coordinating with agencies
such as the Department of Transportation and ETA that have related
missions and authority. It also addresses the major management challenge
of producing reliable data to measure and track its performance. It




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                               includes as one of its strategic measures the full implementation of an
                               information system necessary to collect and analyze OSHA data.


ESA’s Strategic Planning       ESA has not developed a strategic plan or a strategic plan overview for its
Approach                       various functions and responsibilities. Rather, ESA submitted a strategic
                               plan for each of its four offices—WHD, OFCCP, OWCP, and OLMS. While the
                               Results Act and Circular A-11 do not require agency components, such as
                               ESA, to submit strategic plans, it is not clear why Labor chose to submit
                               plans for other component program offices at ESA’s level but did not
                               submit one for ESA. Labor indicated that it would explain in its revised
                               strategic plan why some components provided strategic plans and others
                               did not.

                               ESA’sdecentralized strategic planning effort, as indicated by its choosing to
                               submit individual plans for its four program operations, mirrors the
                               approach used by Labor to meet the requirements of the Results Act. As
                               we previously reported, Labor’s draft strategic plan consisted of separate
                               plans from 15 of its 24 agencies and a strategic plan overview that
                               basically consisted of excerpts from these 15 agencies’ plans rather than
                               an agencywide plan reflecting overarching goals and objectives.

                               From our review of all four plans, it was not evident that ESA provided
                               guidance or direction to its four offices on what should be included in
                               their plans. We found that the plans were uneven in their coverage of the
                               six strategic plan elements called for by the Results Act, with one office’s
                               plan omitting several elements. For example, the plans for WHD and OLMS
                               addressed all of the elements; however, the OWCP plan did not address the
                               strategies that would be used to achieve the goals, the key external factors
                               that could affect the achievement of the goals, or the evaluations to be
                               used to establish goals or that would be used to monitor progress.

                               By using a decentralized approach, ESA may have missed opportunities to
                               improve coordination among its four program offices and ensure that the
                               programs are able to achieve their goals. For example, there appeared to
                               be several common themes across the four offices’ plans in terms of

                           •   strategic goals, such as better serving customers;
                           •   strategies to achieve those goals, such as reliance on technology or the
                               development of data systems to increase program efficiency; and
                           •   key external factors that could affect the achievement of those goals, such
                               as reduced resources or diverse stakeholders with differing views.



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    Because ESA did not prepare an overall plan or provide information that
    acknowledged these commonalities, ESA may not be in a position to
    address these common themes strategically and facilitate the achievement
    of each of the offices’ goals.

    Similarly, there were commonalities in at least one of the offices’
    plans—OWCP. However, OWCP’s plan appeared to be a compilation of
    strategic goals developed by the three programs it oversees rather than an
    overall plan for OWCP as a whole. OWCP stated in its plan that “individual
    teams were responsible for developing strategic plans for each of the three
    compensation programs it operated—Federal Employees’ Compensation
    Act, Black Lung, and Longshore and Harbor Workers’ Compensation.”
    Perhaps as a result of this approach, OWCP’s plan contained similar goals
    for each of the three programs it oversees instead of delineating a single
    goal. OWCP’s plan contains the following goals related to improving
    customer service:

•   “[Ensure] injured FECA [Federal Employees’ Compensation Act] workers
    are served by a fair, swift, and people-oriented compensation system.”
•   “Insure fair, swift, cost effective and people-oriented services for Black
    Lung customers.”
•   “Provide a secure, effective, efficient and prompt compensation and
    service delivery system for the Longshore Program.”

    We recognize that strategic planning is a challenge that is made more
    difficult when, as with ESA, an organization has diverse functions, is
    authorized under several separate pieces of legislation, and has programs
    that traditionally have operated fairly autonomously. However, to derive
    the value and benefit of a strategic planning process, Labor may want to
    consider whether the development of an ESA-level plan would enhance its
    planning efforts. Such a plan could use common programmatic themes as
    a foundation to help ESA make policy decisions in terms of direction and
    operations of its programs, to evaluate whether the programs are
    achieving intended results, and to increase coordination among its
    program operations.

    Numerous statutes govern the various missions of ESA’s offices. We found
    that the strategic goals laid out in the office plans reflect specific
    requirements or general purposes of statutes, or are not based on specific
    statutes but are desirable performance goals. For example, WHD’s goal to




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                  increase customer satisfaction with the services provided is not based on a
                  specific statute but is a desirable performance goal.


                  The Department of Labor commented on a draft of this letter. Labor does
Agency Comments   not substantially disagree with our observations about the strategic plans.
                  The new Secretary of Labor takes the strategic planning process seriously,
                  acknowledges that Labor has a lot to learn about the process, and expects
                  the later versions of its plans to be significantly improved.

                  Only one of the three component units—OSHA—provided specific
                  comments on the draft. OSHA stated our observations were insightful and
                  agreed with many of them. In addition, OSHA characterized its comments as
                  “less a rebuttal than an explanation of the approaches taken in formulating
                  OSHA’s Strategic Plan.” Labor did not provide comments on the ETA and ESA
                  portions of our letter but stated that both agencies will consider our input
                  when revising their strategic plans. Labor also stated that ESA was
                  preparing an agency-level strategic plan overview in accordance with the
                  guidelines under the Results Act.


                  As arranged with your offices, unless you publicly announce its contents
                  earlier, we plan no further distribution of this correspondence until 30
                  days after its issue date. At that time, we will send copies to the Minority
                  Leader of the House of Representatives; the Ranking Minority Members of
                  your Committees; the Chairmen and Ranking Minority Members of other
                  committees that have jurisdiction over Department of Labor activities; the
                  Secretary of Labor; and the Director, Office of Management and Budget.
                  We will also send copies to others on request.




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Please contact me at (202) 512-7014 if you or your staffs have any
questions concerning this letter. Major contributors to this letter were
Harriet C. Ganson, Assistant Director; Thomas N. Medvetz,
Evaluator-in-Charge; Charles A. Jeszeck and Sigurd R. Nilsen, Assistant
Directors; Lori Rectanus, Senior Evaluator; Robert Crystal, Assistant
General Counsel; and Julian P. Klazkin, Senior Attorney.




Carlotta C. Joyner
Director, Education and
  Employment Issues

Enclosures - 3




Page 15                       GAO/HEHS-97-188R Labor Components’ Strategic Plans
Enclosure I

Observations on ETA’s Draft Strategic Plan


                          The Employment and Training Administration’s (ETA) draft strategic plan
Plan Addresses Most       addresses five of the six elements required by the Results Act, but it does
Elements in the           not contain the required information on program evaluation. Furthermore,
Results Act               other elements are incomplete or could be improved. The draft plan could
                          be improved by providing a more descriptive mission statement, indicating
                          the extent to which evaluations were used in preparing the plan and how
                          they will be used to measure progress, acknowledging the role of other
                          organizations in the employment and training area and indicating how the
                          combined efforts will be coordinated, and recognizing the importance of
                          reliable and integrated data systems in assessing program implementation
                          and performance.


Mission Statement Could   The draft strategic plan states that “ETA’s mission is to provide critical
Be More Descriptive       support to the public sector and the private sector response to changes in
                          the labor market, ensuring that Americans have access to the information
                          and resources they require to successfully manage their job lives and that
                          U.S. businesses have access to the skilled workers and training resources
                          they need to compete successfully in a global economy.” ETA’s mission
                          statement does not clearly include all aspects of its responsibilities.
                          Instead, ETA’s mission statement focuses on its role in providing
                          information to workers and employers to facilitate efficient labor
                          exchange activities—surely one of ETA’s responsibilities, but only one
                          aspect of its mission. In addition, its reference to providing information
                          and resources so that Americans can successfully manage their working
                          lives makes the mission statement process oriented rather than results
                          oriented. The mission statement could be both broader—referring to ETA’s
                          role of improving incomes for workers through job training and
                          maintaining the incomes of dislocated workers as they search for new
                          jobs—and cover more of the activities in which ETA is involved, such as job
                          training for new and dislocated workers and income maintenance for
                          unemployed workers.

                          The vision statement included in ETA’s draft strategic plan is a more
                          comprehensive articulation of its mission and could be used as a basis to
                          improve the mission statement. The vision statement provides that ETA
                          “promotes more efficient, effectively functioning U.S. labor markets by
                          providing high quality job training, employment, and income maintenance
                          services through State and local workforce development systems.”
                          Modifying this statement to include a more results-oriented focus, such as
                          to help individuals obtain jobs, would improve its basis as a mission
                          statement.



                          Page 16                       GAO/HEHS-97-188R Labor Components’ Strategic Plans
                                Enclosure I
                                Observations on ETA’s Draft Strategic Plan




Strategic Goals Cover the       The ETA draft strategic plan contains five strategic goals that appear to
Range of ETA                    cover the range of ETA’s responsibilities, with a focus on long-term goals.
Responsibilities                The goals cited in the plan are:

                            •   “Improve systems to enhance and leverage investments in service delivery
                                for youth, adults and employers, and to improve the functioning of labor
                                markets.”
                            •   “Assure that America’s youth, particularly at-risk youth, acquire the
                                knowledge, skills and abilities they need to earn a decent living.”
                            •   “Provide adult unemployed, disadvantaged and dislocated workers the
                                services which will help them find and hold good jobs at decent wages
                                with career potential.”
                            •   “Employers value the public workforce development system managed by
                                ETA and its partners as being integral to their competitiveness strategies
                                and are among its primary investors and customers.”
                            •   “In partnership with employees and their representatives, achieve greater
                                operating efficiency, provide better services at reduced costs and increase
                                customer satisfaction.”

                                The second and third goals clearly articulate populations to be assisted,
                                the kind of assistance ETA can provide, and the outcomes desired, such as
                                youths earning a decent living, and unemployed, disadvantaged, and
                                dislocated workers finding and holding good jobs at decent wages with
                                career potential. These two goals are expressed in a manner that allows
                                for future assessment of whether they are being achieved. The first and
                                fourth goals appear to be process oriented, specifying the achievement of
                                interim steps believed to be necessary to achieve certain goals, such as
                                improving systems to enhance service delivery, and having employers
                                value ETA’s work. The fifth goal deals with internal ETA operating efficiency
                                and customer satisfaction.

                                ETA could improve its strategic plan by developing strategic objectives that
                                are results oriented. The strategic objectives currently in the plan appear
                                to be strategies to achieve goals rather than objectives. For example, the
                                strategic goal that “. . . America’s youth, particularly at-risk youth, acquire
                                the knowledge, skills and abilities they need to earn a decent living”
                                contains objectives that are essentially strategies for achieving that goal,
                                such as:

                            •   “through Job Corps, provide alternative education and job skills
                                preparation in a safe living and learning environment, for disadvantaged,




                                Page 17                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
                              Enclosure I
                              Observations on ETA’s Draft Strategic Plan




                              low income youth who dropped out of school or who are at risk of
                              dropping out of school.”
                          •   “through Job Training Partnership Act [JTPA] year-round, summer and pilot
                              and demonstration programs, provide alternative education and job skills
                              preparation for youth who dropped out of school or who are at risk of
                              dropping out of school.”

                              Developing more focused, measurable objectives would enhance the
                              usefulness of the plan in communicating what ETA hopes to achieve.


Strategies Describe How       Overall, ETA’s draft strategic plan outlines the various strategies needed to
Goals Will Be Achieved        achieve its goals. The strategic goals, combined with the strategies listed
                              in the plan, provide a fairly comprehensive description of how ETA plans to
                              achieve its goals. However, the draft strategic plan does not provide a
                              schedule for initiating and completing its strategies as discussed in OMB
                              Circular A-11. Furthermore, the draft plan does not discuss how ETA will
                              communicate strategic goals throughout the organization. Also, the plan
                              could be strengthened to better indicate how ETA will hold managers and
                              staff accountable for achieving these goals. Its discussion on management
                              accountability states that ETA will “implement managerial systems . . . and
                              strengthen the relationship between performance and personnel
                              evaluation systems,” but it is not clear how managerial accountability will
                              be achieved through this strategy.


Relationship to Annual        The ETA draft plan includes a brief discussion of the relationship of the
Plan Described                strategic plan to its annual performance plan. It describes this relationship
                              through a series of examples of performance goals that are likely to be
                              included in the annual performance plan. Although examples of
                              performance goals are not required, it is a positive step toward articulating
                              how ETA will measure progress. We recognize that ETA’s annual
                              performance plan is being developed and that the performance indicators
                              listed in its current strategic plan may change. In that regard, we identified
                              several areas in which we believe ETA could improve its presentation of
                              information. For instance, the examples cited in the plan generally are
                              process oriented, such as expanding the number of states that
                              demonstrate and pursue one-stop system-building principles. This may be
                              an important aspect of building a better service delivery system, but
                              outcome measures that focus on the end results, such as reemployment at
                              higher wages, would appear to be a more meaningful measure of
                              performance.



                              Page 18                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
                          Enclosure I
                          Observations on ETA’s Draft Strategic Plan




                          Overall, ETA’s articulation of performance measures would be improved by
                          including more results-oriented measures to ensure that ETA can assess the
                          extent to which it has achieved its goals, both long-term and annual. For
                          example, the plan includes output measures that do not focus on what the
                          goal is to achieve; instead, they are process oriented, such as increasing
                          the number of agencies participating in state and local centers, increasing
                          the number of job vacancy listings available on Internet, and increasing
                          students’ perception of safety at Job Corps centers. The plan could focus
                          on results by including more measures, such as those included under the
                          job training objective—entered employment rate, follow-up employment
                          rate, average wage at placement, and follow-up weekly earnings.


Key External Factors      ETA’s draft strategic plan describes, in general, the factors outside the
Indicated                 agency’s scope and responsibility that could negatively affect its ability to
                          achieve its strategic goals. Although these factors were not explicitly
                          linked to a particular goal in accordance with OMB Circular A-11, the draft
                          plan does describe how certain external factors could affect the various
                          entities and individuals involved in the nation’s employment and training
                          system, which in turn could affect ETA’s programs, activities, and
                          resources. Examples of these factors included pending legislation to
                          consolidate and reform the nation’s employment and training programs,
                          changes in the economy that could affect the demand for employment and
                          reemployment assistance, and resource availability.


Role of Evaluations Not   The plan did not include a discussion of how evaluations were used in
Adequately Addressed      preparing the plan as well as a schedule for future evaluations as required
                          by Circular A-11. Rather, the plan states that ETA will reassess its program
                          requirements to ensure that needed information to measure performance
                          is collected and available timely.

                          Although a large number of studies on employment training have been
                          conducted or are under way, ETA made no reference to these studies in its
                          plan. For example, the Department of Labor has funded numerous studies
                          of its programs over the years, such as the long-term study of JTPA results,2
                          and we have issued a number of reports on federally funded employment
                          training programs under ETA’s purview and the problems resulting from
                          the multiple employment training programs spread across 15 federal
                          departments and independent agencies. In addition, many other studies

                          2
                          Abt Associates, Inc., The National JTPA Study: Impacts, Benefits, and Costs of Title II-A (Bethesda,
                          Md.: Abt Associates, Inc., Mar. 1994).



                          Page 19                                  GAO/HEHS-97-188R Labor Components’ Strategic Plans
                              Enclosure I
                              Observations on ETA’s Draft Strategic Plan




                              have been conducted of the assistance provided to dislocated workers
                              under JTPA, the Trade Adjustment Assistance program, and the
                              unemployment insurance system. In addition, another study, aimed at
                              analyzing the net impact of Job Corps, is under way.


                              The goals set out in ETA’s plan reflect requirements of law or are consistent
Goals Are Consistent          with the law. The first goal is consistent with the purpose of JTPA as well as
With Statutory                that of the Wagner-Peyser Act, which authorizes funding to establish local
Responsibilities              public employment offices. The second and third goals reflect the very
                              purpose of JTPA, which is “to establish programs to prepare youth and
                              adults facing serious barriers to employment for participation in the labor
                              force . . .” (29 U.S.C. 1501). The fourth goal is consistent with various
                              statutes. The fifth goal is not based on a specific statutory requirement.

                              Under titles III and IX of the Social Security Act (42 U.S.C. 501, 1101), ETA
                              administers the Federal/State Unemployment Compensation Program. The
                              Wagner-Peyser Act (29 U.S.C. 49) provides authority for grants to states to
                              establish and maintain a system of local public employment offices.
                              Workers receive training and retraining under title III of JTPA (29 U.S.C.
                              1651) and other acts. Youth, adults, and specific groups can receive
                              assistance through grants to states under JTPA.


Crosscutting Activities Not   The ETA plan does not acknowledge a key aspect of the nation’s federally
Described                     funded employment training system—that it is not a cohesive, integrated
                              or coordinated system. In 1995, we identified 163 employment training
                              programs spread across 15 federal departments and agencies, one of
                              which is ETA. However, because ETA omitted the fact that many of the
                              nation’s job training programs are outside its purview, its plan does not
                              discuss how its programs fit in with the nation’s broader job training
                              strategy. While the draft plan notes that the prospect of new legislation
                              could provide a new policy framework, this is not expanded upon nor are
                              its implications acknowledged elsewhere in the plan.

                              The plan could also be improved by including a discussion of cooperative
                              efforts with other agencies. For example, ETA and the Department of
                              Education jointly administer the school-to-work program. However,
                              reviewing these two strategic plans does not give one a sense that there
                              was coordination in developing the plans because their strategies and
                              measures or indicators are generally different. For example, the Education
                              draft plan cites as a core strategy, to “engage high schools, postsecondary



                              Page 20                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
                     Enclosure I
                     Observations on ETA’s Draft Strategic Plan




                     institutions, and adult high schools in building school-to-work systems by
                     sponsoring a national information center, creating networks that include
                     educators, employers and other key stakeholder groups, and sponsoring
                     efforts to align postsecondary admissions policies with new methods of
                     assessing high school student performance.” ETA’s plan does not include a
                     similar strategy. But it does include a strategy to “support the
                     development, testing, dissemination, and showcasing of successful efforts
                     to serve out-of-school youth in a STW [school-to-work] framework,” which
                     is not included in Education’s plan. Both ETA and Education delineated
                     measures that reflect the focus of the agencies’ roles in the program.
                     Education’s plan focuses on curriculum and number of students
                     participating, whereas ETA’s also includes a focus on skill attainment,
                     unemployment, and starting wage rate. A cooperative effort by ETA and
                     Education in developing measures would ensure that all the outcomes of
                     the program are identified and measured.

                     ETA also needs to strengthen its discussion of the impact that recently
                     passed welfare reform legislation is likely to have on the structure and
                     delivery of employment training programs at the state and local levels as
                     well as at on other federal agencies, such as the Department of Health and
                     Human Services. In developing strategies to best serve those individuals
                     transitioning from welfare to work, ETA will need to coordinate extensively
                     with state and federal organizations providing services to these individuals
                     to ensure that the appropriate mix of services is provided.


                     A major management challenge is to produce reliable information to
Producing Reliable   assess program implementation and performance. ETA has multiple data
Performance          systems that are not integrated. In its plan, ETA cites different data sources
Information Is a     and systems, some of which are not yet developed. However, the plan does
                     not include a discussion of ETA’s strategies for ensuring that these sources
Management           and systems provide the type of information it will need to assess
Challenge            programs.

                     On the basis of previous work, we know that ETA produces a significant
                     amount of information on its programs and undertakes numerous
                     evaluations to monitor and assess program implementation and
                     performance. However, the value of ETA’s data could be improved if the
                     different evaluation systems were coordinated. For example, Job Corps
                     and JTPA both have process- and results-oriented measures associated with
                     their programs. And both programs are focused on training economically
                     disadvantaged individuals and helping them obtain jobs at decent wages.



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Enclosure I
Observations on ETA’s Draft Strategic Plan




But the specific indicators used by the two programs are different. For
example, JTPA uses employment rates and weekly earnings at 13 weeks
following program termination as a measure of program performance and
Job Corps uses placement rates, average wage, and job
training-employment match at a specific point as a measure. If the
programs used similar indicators, ETA would be able to provide an overall
common measure of the extent to which its job training programs are
achieving common goals and to allow it to compare the relative
effectiveness of different strategies.

Another important issue is the need for ETA to obtain information on
long-term program outcomes such as job retention. We recognize the
difficulty of developing and collecting such information. However, the
ultimate value of employment and training programs is in their ability to
help individuals obtain and retain jobs. In that regard, the results of our
1996 study showed that while there were some positive effects of JTPA in
the years immediately following training, there were no significant effects
on participant earnings and employment rates after 5 years.3

Also, our past work has shown that ETA faces a major challenge in
obtaining reliable data. For the Job Corps, the reported information did
not provide a complete and accurate picture of program activities and
results. For example, our survey of employers who were reported as hiring
Job Corps participants showed that about 15 percent of the placements in
our sample were potentially invalid: A number of employers reported that
they had not hired students reported placed at their businesses, and other
employers could not be found.4




3
Job Training Partnership Act: Long-Term Earnings and Employment Outcomes (GAO/HEHS-96-40,
Mar. 4, 1996).
4
 Job Corps: High Costs and Mixed Results Raise Questions About Program’s Effectiveness
(GAO/HEHS-95-180, June 30, 1995).



Page 22                                GAO/HEHS-97-188R Labor Components’ Strategic Plans
Enclosure II

Observations on OSHA’s Draft Strategic Plan


                                  OSHA’s draft strategic plan includes all but one of the six elements
OSHA’s Draft Strategic            delineated in the Results Act. The plan’s long-term goals are succinct and
Plan Contains Most                logically linked to the mission statement. Our review of the three other
Elements in the                   elements—approaches to achieve goals, relationship between long-term
                                  goals and annual goals, and key factors—indicate that these could benefit
Results Act                       from more information, clarity, and context. The use of evaluations is not
                                  discussed in the strategic plan. The following is our analysis of the plan’s
                                  major components.


Plan’s Mission Statement Is       OSHA’s stated mission in its strategic plan is to “assure so far as possible
Clear and Succinct                every working man and woman in the Nation safe and healthful working
                                  conditions.” Its vision statement expands on this, stating that OSHA
                                  envisions itself to be a “world class leader in occupational safety and
                                  health by making America’s workplaces the safest in the world.” OSHA’s
                                  mission statement clearly and succinctly describes why it exists and, in
                                  conjunction with supporting narrative, explains what it does and how it
                                  performs its work. For example, the plan states that its mandate involves
                                  OSHA’s application of a set of tools (standards development, enforcement,
                                  and compliance assistance) that enable employers to maintain safe and
                                  healthful work places. Supporting information emphasizes OSHA’s shared
                                  commitment with workers and employers to fulfill its mission.


Goals Consistent With             The goals in OSHA’s strategic plan cover its main functions and operations
OSHA’s Mission                    and are consistent with several of our past agency reviews. In addition, the
                                  goals are more outcome oriented than those contained in earlier drafts of
                                  OSHA’s strategic plan. The goals are as follows:


                              •   “Assure safe and healthful working conditions for all workers, as
                                  evidenced by fewer hazards, reduced exposures, and fewer injuries,
                                  illnesses, and fatalities
                              •   “Change workplace culture to increase employer and worker awareness
                                  of, commitment to, and involvement in safety and health
                              •   “Secure public confidence through excellence in the development and
                                  delivery of OSHA’s programs and services.”

                                  OSHA’s goals are directly related to its mission of a safe and healthful work
                                  place and are consistent with the results from our past work. Two of our
                                  previous reports discuss the benefits of work place safety and health




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Enclosure II
Observations on OSHA’s Draft Strategic
Plan




programs and employee involvement.5 In addition, three other reports
stress the importance for OSHA to develop a greater service orientation
while carrying out its mission.6

In a recently issued report,7 we presented the results of our examination of
early progress under the Results Act toward results-oriented goal setting
and performance measurement in selected federal regulatory agencies,
including OSHA. In that report, we found only one of OSHA’s strategic goals
to be results oriented “to some extent” and the remaining two “to little or
no extent.” Using our criteria from this report, we consider the current
goal of—“assure safe and healthful working conditions for all workers, as
evidenced by fewer hazards, reduced exposures and fewer injuries,
illnesses and fatalities”—to be results oriented (for example, “reducing
injuries”) as well as measurable (“counting the reduced number of injuries
and illnesses”). However, the performance measures associated with this
goal seem to apply only to certain types of industries and would not
include all workers. The second goal, “change workplace culture to
increase employer and worker awareness of, commitment to, and
involvement in safety and health” is considered to be “somewhat results
oriented.” It is considered somewhat results oriented because it is not
clear how OSHA plans to measure commitment or involvement.

Some of the associated performance measures contained in OSHA’s
strategic plan are clearly outcome oriented. For example, OSHA’s first goal,
related to safe and healthful working conditions for workers, includes
specific results, such as (1) reducing three of the most prevalent types of
work place injuries and illnesses by 20 percent, (2) reducing injury and/or
illness rates in at least five high-hazard industries by 20 percent, and
(3) decreasing the total number of fatalities in the construction industry by
20 percent.

On the other hand, some of the performance measures are ambiguous,
posing measurement and interpretation problems. For example, the plan
includes a measure specifying that all proposed regulations and initiatives
contain a worker involvement component, but it does not define the

5
 Occupational Safety and Health: Options for Improving Safety and Health in the Workplace
(GAO/HRD 90-66BR Aug. 24, 1990) and Occupational Safety and Health: Worksite Safety and Health
Programs Show Promise (GAO/HRD 92-68, May 19, 1992).
6
 OSHA: Potential to Reform Regulatory Enforcement Efforts (GAO/T-HEHS-96-42, Oct. 17, 1995),
Department of Labor Rethinking the Federal Role in Worker Protection and Workforce Development
(GAO/T-HEHS-95-125, Apr. 4, 1995), and Workplace Regulation: Information on Selected Employer and
Union Experiences (GAO/HEHS-94-138, June 30, 1994).
7
 Managing for Results: Regulatory Agencies Identified Significant Barriers to Focusing on Results
(GAO/GGD-97-83, June 24, 1997).


Page 24                                  GAO/HEHS-97-188R Labor Components’ Strategic Plans
                           Enclosure II
                           Observations on OSHA’s Draft Strategic
                           Plan




                           elements of such a component. Similarly, the plan states that by fiscal year
                           2002, OSHA will ensure that 50 percent of the employers who are targeted
                           for or request an OSHA intervention will have implemented an effective
                           safety and health plan, but it does not discuss the components of such
                           effective plans nor how they would be assessed for their effectiveness.

                           The agency’s strategic plan also includes performance measures that are
                           essentially strategies for achieving the goals rather than measures. For
                           example, measures such as “develop and deliver training to workers and
                           employers in the skills necessary for effective worker involvement in
                           safety and health” and “develop and disseminate occupational safety and
                           health training and reference materials targeted to small business
                           employers and workers” are strategies for reaching the strategic goals
                           rather than indicators of progress toward achieving those goals.


Link Between Strategies    Under the Results Act, approaches or strategies should describe the way
and Achievement of Goals   an agency intends to accomplish its goals and objectives. These strategies
Unclear                    should briefly describe the operational process, staff skills, and
                           technologies as well as the human, capital, information, and other
                           resources needed. OSHA’s plan presents a broad discussion of the array of
                           strategic tools that it will rely on to achieve its goals. However, the
                           strategic plan focuses on describing particular strategies rather than
                           articulating a clear link between the individual strategies and the
                           achievement of the plan’s goals.

                           OSHA’s strategic plan states that it will increasingly use “data driven
                           approaches to direct its resources away from safer workplaces towards
                           more hazardous ones” and will “address the most prevalent types of
                           workplace injuries and illnesses and . . . high hazard industries. . .
                           identified through site specific injury and illness data.” Such improved
                           targeting, by facilitating more efficient use of scarce enforcement
                           resources, can contribute to reduced work place hazards, injuries,
                           illnesses, and fatalities as specified in the plan’s strategic goals. Improved
                           targeting is also consistent with results presented in our past work. To the
                           extent that stakeholders also perceive improved targeting as more
                           equitable and credible, it can also influence public confidence through
                           better service delivery and change work place culture by increasing
                           employer commitment to health and safety. Yet, the plan does not discuss
                           any of these potential links. The plan could also be enhanced by
                           highlighting the necessary linkages between different strategic tools that
                           can make their use more effective. For example, the plan’s discussion of



                           Page 25                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
                           Enclosure II
                           Observations on OSHA’s Draft Strategic
                           Plan




                           its information technology and problem analysis strategies does not
                           include how these strategies (for example, improved data collection) can
                           facilitate its enforcement strategy (for example, better inspection
                           targeting).

                           OSHA’s  strategic plan does not include a schedule for initiating or
                           completing significant actions, as called for in OMB Circular A-11, part 2.
                           For example, OSHA’s plan specifies that it will promulgate a rule on safety
                           and health programs in the work place. But the plan does not provide any
                           schedule for initiating or completing this action nor the level of resources
                           deemed necessary. Similarly, the plan states in its problem analysis section
                           that it will use the data collected in an ongoing manner as part of its own
                           initiatives to guide its program operations to determine the appropriate
                           mix of interventions and strategic tools to use. However, the plan does not
                           contain a description of these data collection efforts, any schedule for
                           their implementation, nor the resources needed for completion.

                           OSHA’s draft strategic plan also does not address another area called for in
                           OMB Circular A-11, part 2—the process for communicating goals and
                           objectives throughout an agency and for assigning accountability to
                           managers and staff for achievement of objectives. OSHA’s strategic plan
                           does specify that it will rely on Labor management cooperation, employee
                           participation, and the development of management and information
                           systems to assist OSHA staff in achieving the agency’s strategic goals.
                           However, while these initiatives may contribute to communicating goals
                           and objectives throughout the agency and foster staff involvement, the
                           plan is not clear about how these initiatives will facilitate the assigning of
                           accountability to management for achieving objectives.


Annual Performance Goals   OSHA’s strategic plan states that OSHA will develop annual performance
Not Specifically Defined   plans, based on the strategic plan’s goals and objectives, that will define
                           the specific programmatic activities to be accomplished such as
                           identification of the standards to be addressed during that year and the
                           national and local emphasis programs to be implemented. The agency also
                           expects that the annual plans will have a cumulative impact on achieving
                           the strategic plan’s overall goals and objectives. The plan, however, does
                           not specifically define the annual performance goals, and there is a general
                           lack of detail in identifying the appropriate data and measures OSHA will
                           use to monitor progress on its strategic goals. OSHA acknowledges this lack
                           of specificity, mentioning the general data limitations regarding safety and
                           health, the agency’s need for improved data and measurement systems,



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                             Enclosure II
                             Observations on OSHA’s Draft Strategic
                             Plan




                             and its need to collect the baseline data for those appropriate measures
                             against which future performance will be tracked.

                             In response to these problems, the plan states that OSHA will review a
                             number of different data and information sources as part of the
                             development of its annual performance plans. These annual efforts will be
                             coordinated with OSHA’s data initiative that will be fully implemented by
                             fiscal year 1998. The plan also states that resources will be devoted in the
                             early years of the plan to identifying appropriate performance measures
                             and collecting the baseline data necessary for their use. Although it is not
                             explicit, this wording suggests that OSHA will begin to track interim
                             measures of progress prior to fiscal year 2002. Such actions can facilitate
                             the assessment of progress toward the strategic plan’s goals during the
                             early years of the plan and are consistent with the Results Act.


External Factors Could       OSHA’s strategic plan presents a comprehensive discussion of the factors
Influence Achievement of     that could influence the achievement of its strategic goals and the way it
Goals                        measures the impact of its efforts. As OSHA notes, agency performance in
                             improving worker safety and health can be significantly affected by
                             general economic conditions, such as layoffs; workforce demographics,
                             such as employing non-English-speaking workers; changes in the
                             economy’s job mix, for example, a shift from manufacturing to
                             service-based employment; and governmental budget decisions (for
                             example, the fiscal year 1996 shutdown). Even its data collection efforts
                             are constrained by external requirements like the Paperwork Reduction
                             Act and difficulties associated with the use of data from the Bureau of
                             Labor Statistics. Finally, OSHA notes that a key component of its strategic
                             plan is the inclusion of partner, stakeholder, and customer needs and
                             requirements, although, in some cases, conflict between these parties may
                             make inclusion or consensus difficult.

                             The strategic plan does not convey the degree to which achievement of
                             OSHA’s goals would be affected by these external factors and the degree to
                             which these factors may limit OSHA’s ability to commit itself to making
                             significant progress toward its goals. In some instances, these outside
                             factors may seriously impede or even overcome OSHA’s good faith efforts
                             to implement its strategy or may render OSHA’s performance measures
                             unsuitable.


Role of Evaluation Not       OSHA’s strategic plan neither describes program evaluations that were used
Included in Strategic Plan   in preparing the strategic plan nor refers to future program evaluations


                             Page 27                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
                          Enclosure II
                          Observations on OSHA’s Draft Strategic
                          Plan




                          that go beyond analysis of measured performance, assessment of the
                          external environment, and the needs of its stakeholders. In our view,
                          evaluations could play a particularly helpful role for OSHA in gauging its
                          performance and achieving its goals, given the often limited availability of
                          data for performance measures and the presence of serious external
                          factors that could confound agency program and measurement efforts. For
                          example, evaluations can be used to directly measure agency performance
                          and to develop improved outcome performance indicators, particularly
                          given that many of the agency’s specified performance measures would
                          not be in place until fiscal year 2002.


                          OSHA administers the Occupational Safety and Health Act of 1970 (29
Statutory                 U.S.C. 651). The purposes delineated in this act are generally reflected in
Responsibilities          the goals in OSHA’s plan, which are as follows:

                      •   “Assure safe and healthful working conditions for all workers, as
                          evidenced by fewer hazards, reduced exposures, and fewer injuries,
                          illnesses, and fatalities
                      •   “Change workplace culture to increase employer and worker awareness
                          of, commitment to, and involvement in safety and health
                      •   “Secure public confidence through excellence in the development and
                          delivery of OSHA’s programs and services.”

                          The first goal reflects purposes declared in the 1970 act. Although the act
                          does not explicitly require Labor to reduce hazards, exposures, injuries,
                          illnesses, or fatalities, such a goal is consistent with the overall purpose of
                          the act. The second goal also reflects purposes declared in the act, and it is
                          driven by the act, but it does not reflect a specific mandate. The third goal
                          does not appear to be based on specific provisions of law.


                          OSHA’s  strategic plan identifies, as a key component, the inclusion and
Crosscutting Issues       consideration of its partner, stakeholder, and customer needs and
                          requirements. Although OSHA has met with some key stakeholders while
                          developing its draft plan (including Office of Management and Budget
                          (OMB) and congressional staff), the plan does not indicate the input OSHA
                          has received from these groups. For example, while OSHA has met with
                          representatives from among the 25 state-operated health and safety
                          programs, the plan does not indicate the input OSHA solicited and received
                          on its strategic goals or on any other part of the plan. The strategic plan
                          states that the 25 state-operated OSHA programs are “integral partners in



                          Page 28                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
                   Enclosure II
                   Observations on OSHA’s Draft Strategic
                   Plan




                   OSHA’s  mission of assuring the safety and health of the Nation’s workers.”
                   OSHA’s  plan also states that the objectives, strategic measures, and
                   strategic tools chosen to guide OSHA’s achievement of the three strategic
                   goals may not reflect the focus and emphasis for each state program.
                   However, the plan reports that the goals are reflective of broad generic
                   aspirations for the nationwide occupational safety and health effort, and
                   as such establish the parameters against which the status of the 25 states
                   will be measured. Greater consultation with the state-operated health and
                   safety programs during the development of the strategic plan, rather than
                   in a later, “subsidiary process” might lead to superior strategic goals for
                   OSHA and possibly more inclusive national standards that would facilitate
                   program effectiveness in both the federal- and state-operated OSHA
                   programs.

                   The plan also acknowledges the importance of coordinating with agencies
                   that may have related missions and authorities. The plan notes that OSHA
                   has in place a number of memorandums of understanding with federal
                   agencies that administer other laws that affect work place conditions. For
                   example, the Department of Transportation has legal authority for rail, air,
                   and water safety and regulates many conditions that affect workers in
                   those industries. The plan also states that as the administration of these
                   laws changes, OSHA will continue to modify its memorandums of
                   understanding to minimize administrative overlap.


                   As we have identified in past reports,8 and as OSHA has acknowledged, a
Major Management   major management issue it faces in conducting its mission is the
Challenges         development of data and information management systems that can
                   facilitate the measurement and tracking of OSHA’s performance. The
                   strategic plan acknowledges the central importance of this issue, including
                   as one of its strategic measures the full implementation of the information
                   systems necessary to collect OSHA data and the capacity to analyze its
                   performance measures.

                   OSHA continues to face a major challenge in developing the data sources
                   and measures necessary to track progress toward its performance goals.
                   As the plan points out, OSHA depends on data from a number of other
                   agencies that must accommodate information needs beyond those of OSHA.
                   Many external factors may also impede OSHA from collecting the necessary
                   data, and from developing meaningful measures themselves, including

                   8
                    See Occupational Safety and Health: Changes Needed in the Combined Federal-State Approach,
                   (GAO/HEHS-94-10, Feb. 28, 1994) and Occupational Safety and Health: Assuring Accuracy in Employer
                   Injury and Illness Records (GAO/HRD-89-23, Dec. 30, 1989).



                   Page 29                                GAO/HEHS-97-188R Labor Components’ Strategic Plans
Enclosure II
Observations on OSHA’s Draft Strategic
Plan




external constraints on its information collection efforts, such as
legislative and budgetary developments. In many of these cases, the
careful use of evaluation can assist OSHA’s efforts, but it may not be
sufficient for it to make progress toward its goals.




Page 30                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
Enclosure III

ESA’s Statutory Responsibilities


                Four offices within the Employment Standards Administration (ESA) carry
                out the following laws: the Fair Labor Standards Act (29 U.S.C. 201) and
                the Contract Work Hours and Safety Standards Act (29 U.S.C. 327), carried
                out by the Wage and Hour Division (WHD); acts such as the Davis-Bacon
                Act (40 U.S.C. 276a) and the Service Contract Act (41 U.S.C. 351), which
                establish wage and other labor standards for government contracts, also
                carried out by WHD; the Federal Employee’s Compensation Act (FECA) (5
                U.S.C. 8101), the Longshore and Harbor Workers’ Compensation Act (33
                U.S.C. 901), and the Black Lung Benefits Act (30 U.S.C. 901), which are
                carried out by the Office of Workers’ Compensation Programs; and the
                Labor-Management Reporting and Disclosure Act (29 U.S.C. 400) and
                related laws, which are carried out by the Office of Labor Management
                Standards (OLMS). In addition, the Office of Federal Contract Compliance
                Programs (OFCCP) enforces statutory and nonstatutory nondiscrimination
                and affirmative action requirements for federal contractors.

                WHD’s goals are not based on specific statutory requirements, but are
                desirable performance goals. These goals are to (1) “increase compliance
                with the laws and regulations administered and enforced by WHD”,
                (2) “increase customer satisfaction with the services provided by WHD”,
                and (3) “achieve a high performance workplace which anticipates and is
                responsive to the needs of our customers and all our employees.”

                The goals of the Office of Workers’ Compensation Programs are to
                (1) ensure that “[u]nder the FECA, employees return to work following a
                work injury at the earliest appropriate moment”; (2) ensure that “[t]he
                FECA program, employing agencies, and Federal unions work as partners to
                improve the delivery of Federal employees’ compensation benefits”;
                (3) “[a]pply tools and technology to expand FECA program capabilities and
                enhance program effectiveness”; (4) “[c]ontinue to organize and support
                national union/management reengineering teams as vehicles for broad
                based participation in decisions”; (5) “[p]romote a more efficient Black
                Lung benefit delivery system”; (6) “[p]rovide a secure, effective, efficient
                and prompt compensation and service delivery system for the Longshore
                Program”; (7) “[e]nhance adjudicatory efficiency and quality”; (8) ensure
                that “[i]njured FECA workers are served by a fair, swift, and people-oriented
                compensation system”; (9) “create a leaner Black Lung organization that
                delivers improved program services and eases stakeholder burdens by
                reinventing and reengineering”; (10) “[i]nsure fair, swift, cost-effective and
                people-oriented services for Black Lung customers”; (11) “[r]educe the
                burden of reporting for Longshore’s customers”; (12) “[e]nhance public
                awareness and voluntary compliance with the provisions of the Longshore



                Page 31                        GAO/HEHS-97-188R Labor Components’ Strategic Plans
Enclosure III
ESA’s Statutory Responsibilities




Act”; (13) “[m]aintain the fiscal integrity of the FECA system and deliver
cost-effective services”; and (14) “[e]xercise fiscal responsibility in Black
Lung while accomplishing the mission.”

The first goal is not a specific statutory requirement but is consistent with
FECA, which allows Labor to require an injured employee to submit to a
physical examination as often as necessary (5 U.S.C. 8123). Goals 2, 3, 4, 7,
8, and 13 are not linked to specific statutory requirements but are
consistent with the Secretary’s authority to administer the FECA program (5
U.S.C. 8145). Goals 5, 9, 10, and 14 deal with the Black Lung Program, and
are not based on a specific statutory requirement. Goals 6, 7, 11, and 12 all
relate to the Longshore and Harbor Workers’ Compensation Program. (As
noted, goal seven also relates to FECA.) Although none of the goals is
required by law, each is consistent with the Longshore Act.

OLMS’ goals are to (1) “[p]rotect union financial integrity by enforcing
safeguards established under LMRDA [Labor-Management Reporting and
Disclosure Act] and related laws”; (2) “[r]esolve member complaints
concerning union officer elections, union trusteeships, and other matters
pertaining to safeguards for union democracy under the LMRDA and related
laws and supervise remedial union officer elections as required by law”;
(3) “[e]nsure that reports required of unions and others are available for
public disclosure in accordance with the requirements of the LMRDA and
related laws”; and (4) “[e]nsure protections for transit employees and the
timely release of Federal transit grant funds by expeditiously certifying
statutory employee protection arrangements.”

All four of OLMS’ goals reflect statutory requirements. The first three reflect
Labor’s responsibility to carry out LMRDA. More specifically, the first goal
reflects Labor’s statutory responsibility to issue necessary rules and
regulations to “prevent the circumvention or evasion” by labor
organizations of LMRDA’s reporting requirements, which include the
submission of annual financial condition reports. Fines may be assessed
against those who violate the reporting requirements. (29 U.S.C. 431(b),
438, 439.) See 29 U.S.C. 464, 482, for the statutory requirement relating to
the second goal and 29 U.S.C. 435 for the statutory requirement relating to
the third goal. The fourth goal, which involves coordination between the
Secretaries of Labor and Transportation, reflects a statutory requirement
that appears in a transportation statute. (49 U.S.C. 5323(a)(1)(D), 5333.)

OFCCP’sgoals are to (1) ensure compliance by federal contractors with
equal employment opportunity and affirmative action requirements;



Page 32                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
           Enclosure III
           ESA’s Statutory Responsibilities




           (2) secure voluntary compliance by federal contractors with equal
           employment opportunity requirements; and (3) produce high-quality
           compliance reviews, complaint investigations, and compliance assistance.
           The first two goals reflect both statutory and nonstatutory requirements
           that apply to federal contractors. The statutory requirements come from
           statutes that explicitly impose requirements on federal contractors and
           Labor—for example, section 503 of the Rehabilitation Act of 1973 (29
           U.S.C. 793), which explicitly requires federal contractors to take
           affirmative action to employ and advance in employment qualified
           handicapped individuals and directs Labor to take necessary enforcement
           action. The nonstatutory requirements come from Executive Order 11246,
           as amended, which explicitly imposes upon federal contractors
           nondiscrimination and affirmative action requirements based on race,
           color, religion, sex, or national origin and directs Labor to enforce the
           requirements. The third goal is not based on a specific statutory
           requirement, but is a general management goal.




(205348)   Page 33                            GAO/HEHS-97-188R Labor Components’ Strategic Plans
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