oversight

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

Published by the Government Accountability Office on 1997-07-17.

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

                          United States General Accounting Office

GAO                       Testimony
                          Before the Subcommittee on the Constitution, Committee
                          on the Judiciary, House of Representatives




For Release on Delivery
Expected at 10:00 a.m.
Thursday, July 17, 1997
                          U.S. COMMISSION ON
                          CIVIL RIGHTS

                          Agency Lacks Basic
                          Management Controls
                          Statement of Cornelia M. Blanchette
                          Associate Director
                          Education and Employment Issues
                          Health, Education, and Human Services Division




GAO/T-HEHS-97-177
U.S. Commission on Civil Rights: Agency
Lacks Basic Management Controls

               Mr. Chairman and Members of the Subcommittee:

               We are pleased to be here today to discuss the management of the U.S.
               Commission on Civil Rights.

               Racially motivated church burnings across the country; racial and civil
               unrest in major metropolitan cities such as St. Petersburg, Florida; and the
               national debate over the continuing need for federal affirmative action
               programs and policies are only some of the issues the U.S. Commission on
               Civil Rights is working on today. Established by the Civil Rights Act of
               1957, the Commission had a budget of $8.75 million, 8 part-time
               commissioners, and a staff of 91 in fiscal year 1996. The commissioners
               have two principal responsibilities: (1) investigating claims of voting rights
               violations and (2) studying and disseminating information, often collected
               through specific projects, on the impact of federal civil rights laws and
               policies.

               Last year, amid complaints of mismanagement and in preparation for the
               agency’s reauthorization, your Subcommittee began to look into how the
               Commission carries out its responsibilities and manages its resources. You
               asked us to assist you in this effort by providing information on the
               Commission’s management of projects during fiscal years 1993 through
               1996. The Commission identified 22 projects in this time frame—5 were
               completed, 7 were ongoing, and 10 were deferred. Commission projects
               entail collecting and analyzing information on civil rights issues, such as
               racial and ethnic tensions in American cities and fair housing, in order to
               appraise applicable federal laws and regulations. While our review initially
               addressed the Commission’s management of its projects, problems we
               encountered during our work caused us to be concerned with general
               management at the Commission as well.

               My comments today will summarize the findings discussed in our recent
               report on the management of the Commission, focusing first on general
               management issues and then on the management of the Commission’s
               projects.1 Our report is based on reviews of Commission records;
               interviews with all of the current commissioners, the staff director at the
               time of our review, and other responsible Commission officials; and our
               observations from Commission meetings we attended.




               1
                U.S. Commission on Civil Rights: Agency Lacks Basic Management Controls (GAO/HEHS-97-125,
               July 8, 1997).



               Page 1                                                                    GAO/T-HEHS-97-177
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In summary, we found broad management problems at the Commission on
Civil Rights. The Commission appears to be an agency in disarray, with
limited awareness of how its resources are used. For example, the
Commission could not provide key cost information for individual aspects
of its operations, such as its regional offices; its complaints referral
process; its clearinghouse; public service announcements; and, in one
case, a project. Furthermore, significant agency records documenting
Commission decision-making were reported lost, misplaced, or
nonexistent. The Commission has not established accountability for
resources and does not maintain appropriate documentation of agency
operations. Lack of these basic, well-established management controls
makes the Commission vulnerable to resource losses due to waste or
abuse.

Commission records indicate that projects accounted for only about
10 percent of the agency’s appropriations during fiscal years 1993 through
1996 despite the broad array of civil rights issues addressed. Furthermore,
our work showed that management of the 12 Commission projects
completed or ongoing during this 4-year period appeared weak or
nonexistent. The Commission’s guidance for carrying out projects is
outdated, and the practice described to us for conducting
projects—including specifying anticipated costs, completion dates, and
staffing—was largely ignored. For instance, 7 of the 12 projects had no
specific proposals showing their estimated time frames, costs, staffing, or
completion dates. Specific time frames were not set for most projects, and
when they were, project completion dates exceeded the estimates by at
least 2 years. Overall, projects took a long time to complete, generally 4
years or more. Some projects took so long that Commission staff proposed
holding additional hearings to obtain more current information. Poor
project implementation likely contributed to the lengthy time frames.
Moreover, we found that Commission management did not systematically
monitor projects to ensure quality and timeliness. Finally, Commission
project reports are disseminated to the public through three different
offices, none of which appears to coordinate with the others to prevent
duplication.

We made several recommendations in our report about improving
management at the Commission. Even though the commissioners did not
all agree with our findings, they did agree to implement the
recommendations.




Page 2                                                    GAO/T-HEHS-97-177
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             Lacks Basic Management Controls




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

             The Commission is required to issue reports on the findings of its
             investigations to the Congress and the president, and to recommend
             legislative remedies. The Commission also must submit to the president
             and the Congress at least once annually a report that discusses the
             Commission’s monitoring of federal civil rights enforcement in the United
             States. Because it lacks enforcement powers that would enable it to apply
             remedies in individual cases, the Commission refers specific complaints it
             receives to the appropriate federal, state, or local government agency for
             action.2

             Projects conducted by the Commission to study various civil rights issues
             are largely the responsibility of its Office of the General Counsel (OGC)
             with a staff of 15 and the Office of Civil Rights Evaluation (OCRE) with a
             staff of 12 in fiscal year 1996. The largest component of the Commission is
             the Regional Programs Coordination Unit with 2 staff members in the
             Washington, D.C., office and 25 staff members in six regional offices. The
             regional offices direct the Commission’s work, which is carried out


             2
              Several agencies have enforcement authority for civil rights issues. For example, the Equal
             Employment Opportunity Commission is charged with enforcing specific federal employment
             antidiscrimination statutes, such as title VII of the Civil Rights Act of 1964, the Americans With
             Disabilities Act of 1990, and the Age Discrimination in Employment Act of 1967. Also, the Assistant
             Attorney General for Civil Rights in the Department of Justice is the enforcement authority for civil
             rights issues for the nation.



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                        through 51 advisory committees—one in each state and the District of
                        Columbia—composed of citizens familiar with local and state civil rights
                        issues.


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


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

                        In addition, the Commission’s Administrative Manual was issued in
                        May 1975, but the Commission has paid little attention over the last 10
                        years to maintaining and updating it to accurately reflect agency
                        operations. The purpose of the manual is to translate administrative policy
                        derived from the various legislative and regulatory policies affecting the
                        day-to-day operations of the Commission into procedures that the
                        Commission staff can rely on for guidance in carrying out the agency’s

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



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                         mission. The Commission’s major reorganization in the mid-1980s, coupled
                         with a high turnover of staff in key positions, makes up-to-date operating
                         guidance especially important for maintaining continuity and performing
                         work efficiently and effectively. The directors of the two offices
                         responsible for conducting projects, however—who had been employed at
                         the Commission for 5 and 2-1/2 years, respectively—had only the 1982
                         version of the manual to rely on for official procedures for conducting
                         projects.

                         Commission officials told us that, although it was outdated, the guidance
                         in the manual still reflects the basic Commission policy for conducting
                         projects. We found, though, that projects did not follow all steps outlined
                         in this guidance and could not, for some steps, because the offices no
                         longer existed.

                         Commission officials told us that they were in the process of updating the
                         Commission’s Administrative Manual and had updated 8 of 73
                         administrative instructions; but the administrative instruction for
                         implementing projects is not one of the 8. The staff director4 told us that
                         she had recently convened a task force, made up of the two office
                         directors responsible for conducting projects and the special assistant to
                         the staff director, to revamp the administrative instruction for projects. As
                         of June 16, 1997, Commission officials said that the task force had met at
                         least three times over the past several months and that the Commission
                         expected to have a final version of the administrative instruction to
                         propose to the new staff director when appointed.


Key Commission Records   The Commission reported that key records—which either were the basis
Missing                  for or documented decisions about Commission operations and
                         management of projects—were lost, misplaced, or nonexistent. And
                         minutes of certain Commission meetings were reported to be lost.
                         According to officials, minutes of Commission meetings discussing the
                         initiation of 7 of the 22 projects were lost or misplaced. Additionally, the
                         files for these seven projects were misplaced, misfiled, or not available for
                         review.5 Other key records outlining critical information about projects did
                         not exist, such as project proposals, or were not available, such as the
                         actual start dates for projects. The Commission also did not have a record

                         4
                          The staff director at the time of our review resigned effective December 31, 1996. A new staff director
                         joined the Commission on June 30, 1997.
                         5
                          These projects included six on racial and ethnic tensions in American communities that were
                         completed or ongoing and one completed project on funding federal civil rights enforcement.



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                          showing the total cost of its project on funding federal civil rights
                          enforcement.


Spending Data Not         Commission officials told us that they maintain a central budget and could
Maintained by Office or   not provide the amount or percentage of the budget used by individual
Function                  offices or functions, such as complaint referrals or clearinghouse
                          activities. The only function Commission officials gave us separate
                          financial information on was the projects’ costs. But even for project
                          costs, records were poorly maintained, and it is unclear whether they
                          reflect the true costs for projects. For example, the Commission approved
                          one project’s report for publishing on September 9, 1994, and the report
                          shows an issuance date of September 1994. Yet financial information
                          provided to us showed costs incurred through fiscal year 1996 for this
                          project. A November 1, 1995, letter from the Commission to the House
                          Constitution Subcommittee showed actual costs for the project of
                          $261,529, but data Commission officials provided us showed total project
                          costs of $531,798. At the time of our audit work, the Commission was not
                          able to reconcile these differences.6


Commission’s Management   The Commission’s management controls over its operations are weak and
Controls Are Weak         do not ensure that the Commission can meet its statutory responsibilities7
                          or program objectives. Federal agencies are required under the Federal
                          Managers’ Financial Integrity Act to report annually on internal controls to
                          the president and the Congress, but the Commission did not do such a
                          report for fiscal year 1995. Furthermore, the Commission’s internal
                          controls report for fiscal year 1996 appears to misrepresent information
                          concerning audits of the Commission. The report claims that several
                          administrative activities are randomly audited by the U.S. Department of
                          Agriculture’s Inspector General, when in fact no such audits were done.
                          The only direct connection between the Commission and the Department
                          of Agriculture is that the Commission’s financial transactions are handled
                          through Agriculture’s National Finance Center. Vendors submit invoices
                          directly to the National Finance Center for payment, and the Commission

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



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                      does not verify the accuracy of the invoices submitted. The Agriculture
                      Inspector General is responsible for auditing the automated systems of
                      Agriculture’s National Finance Center. But the Inspector General’s office
                      told us that the Commission has never requested any audits of its
                      transactions. We did not find that any other audits of Commission
                      expenditures had been performed.8

                      Recent reviews of the Commission’s operations by the Office of Personnel
                      Management (OPM) and a civil rights advocacy group have been critical of
                      Commission management. OPM reviewed the Commission’s personnel
                      practices and concluded in a 1996 report that the Commission is “badly in
                      need of managerial attention.”9 The OPM report has resulted in proposed
                      corrective actions that, if fully implemented, should improve the situation.
                      A 1995 report by the Citizens’ Commission on Civil Rights reported that
                      the Commission’s performance has been “disappointing.”10 The report
                      noted that projects take so long to complete that changing conditions may
                      render them out of date by the time the project is completed, reducing the
                      effectiveness of the Commission’s work.


                      Although Commission projects address a broad array of civil rights issues,
Commission Projects   including racial and ethnic tensions in American communities; the
Are Poorly Managed    enforcement of fair housing, fair employment, and equal education
and Take Years to     opportunity laws; and naturalization and citizenship issues, its project
                      spending accounts for a small percentage of the Commission’s budget.
Complete              Furthermore, the Commission’s efforts to manage these projects fall short
                      in areas such as following project management guidance, meeting
                      projected time frames for completing projects, and systematic monitoring
                      of projects. During fiscal years 1993 through 1996, the Commission
                      completed 5 projects, deferred 10 others, and worked on another 7 that
                      were still ongoing at the end of fiscal year l996.



                      8
                       The Commission is not required by statute to have an Inspector General, and its operations have not
                      been audited by an outside accounting firm.
                      9
                      OPM, Office of Merit Systems Oversight and Effectiveness, Report of an Oversight Review: U.S.
                      Commission on Civil Rights-Washington, D.C. (Washington, D.C.: OPM, Nov. 1996).
                      10
                        Citizens’ Commission on Civil Rights, New Challenges: The Civil Rights Record of the Clinton
                      Administration Mid-term: Interim Report on Performance of U.S. Commission on Civil Rights During
                      the Clinton Administration (Washington, D.C.: Citizens’ Commission on Civil Rights, 1995). The
                      Citizens’ Commission on Civil Rights is a private bipartisan group of officials who formerly served in
                      federal government positions with responsibility for equal opportunity. The Citizens’ Commission was
                      established in 1982 to monitor the federal government’s civil rights policies and practices and seek
                      ways to accelerate progress in the area of civil rights.



                      Page 7                                                                          GAO/T-HEHS-97-177
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Project Spending Accounts   Although the Commission appears to spend about 10 percent of its
for Small Percentage of     resources annually on projects, we were unable to verify project spending
Commission Budget           because of the Commission’s poor record-keeping. According to
                            Commission records, costs incurred for ongoing and completed projects
                            during fiscal years 1993 through 1996 ranged from about $33,00011 for a
                            completed project on funding for federal civil rights enforcement to about
                            $764,000 for a project on racial and ethnic tensions in Los Angeles that had
                            been ongoing throughout the 4-year period.


Project Management          The Commission’s Administrative Manual, which governs the process for
Guidance Often Ignored      conducting projects, has not been updated since 1982 and does not
                            accurately reflect the current practices as described to us. Furthermore,
                            our review of the projects showed that the process described was often
                            not followed. According to Commission officials, the process that should
                            be used to develop an idea into a project and ultimately a report includes
                            five stages: (1) initiating an idea as a concept, (2) selecting concepts to
                            develop into proposals for projects, (3) conducting project research,
                            (4) approving final publication of a report, and (5) publishing and
                            disseminating the report.

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


Projects Take Years to      The Commission has no overall standard for assessing a project’s
Complete                    timeliness or for estimating the time needed for specific projects. While an
                            estimate of the time needed to conduct projects is required in proposals,
                            very few projects had estimated time frames for completing projects. For
                            the projects that did specify time frames, the actual time a project took to
                            complete was 2 to 3 years beyond its planned duration. Only two of the

                            11
                             The total cost of this project is not known because Commission officials did not, as they had for
                            other projects, account for staff salaries spent to conduct the project.



                            Page 8                                                                          GAO/T-HEHS-97-177
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five completed projects had anticipated start and finish dates, but both
overran their time frames. Both had anticipated time frames of 1 year, but
one project took 3 years (Federal Title VI Enforcement to Ensure
Nondiscrimination in Federally Assisted Programs, issued June 1996), and
the other took 4 years (The Fair Housing Amendments Act of 1988: The
Enforcement Report, issued Sept. 1994). The Commission attributed
delays in meeting estimated time frames to staff turnover, limited staff
resources, and the need to update factual information.

Although the duration of the projects cannot generally be compared with
an expected or approved length, we found that their actual time frames
spanned several years. During the period of our review, projects took an
average of 4 years to complete from the time they were approved by the
commissioners.12 Four of the five completed projects had data available on
time frames—three of the projects took 4 or more years to complete, and
one was completed in about 2-1/2 years. For one project, the Commission
held a hearing in May 1992 and in the ensuing 3 years incurred additional
costs of about $50,000. In 1995, it issued the hearing transcript,
accompanied by a summary of its contents without any further analysis, as
a final product.13 The Commission’s staff director reported in a
November 1995 letter to the House Judiciary Committee’s Subcommittee
on the Constitution that the Commission originally scheduled publication
of the hearing transcript for fiscal year 1993 but “subsequently, the
decision was made to publish an executive summary in addition to the
transcript, which delayed publication of the document.” Ongoing projects
appeared likely to overrun estimated time frames as well: Six of the seven
ongoing projects were approved nearly 6 years ago.

Problems with the quality of the planning and implementation of certain
projects have apparently contributed to the lengthy time frames. For
example, the Commission’s General Counsel requested additional hearings
on three projects because of poor planning for the initial hearings and the
resulting inadequate data gathering. For the racial and ethnic tensions
projects for New York, Chicago, and Los Angeles, the General Counsel
determined that the information gathered at previous hearings was


12
  Because the Commission did not have information on actual start dates, we determined our cycle
time calculations using the project approval date as the start date and the report issuance date as the
end date.
13
  Commission on Civil Rights, Racial and Ethnic Tensions in American Communities: Poverty,
Inequality, and Discrimination - A National Perspective, executive summary and transcript of hearing
held in Washington, D.C. (Washington, D.C.: U.S. Commission on Civil Rights, May 21-22, 1992).
Commission data provided us showed that the Commission approved the transcript and executive
summary for publication as of March 1995, but the actual document is dated May 1992.



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                           insufficient, outdated, or too weak to support a quality report. The New
                           York project had insufficient testimony and documentation in eight
                           different areas. The Chicago project was criticized by city officials as
                           presenting an unbalanced picture, including unsubstantiated testimony,
                           mischaracterized information, inadequate or nonexistent analyses, and
                           missing certain recent city initiatives. The Los Angeles report contained
                           information that the Commission’s General Counsel viewed as outdated
                           and therefore required further investigation for the Commission’s report to
                           be current.


Projects Not               The Commission does not systematically monitor projects to ensure
Systematically Monitored   quality and timeliness of project results and to help set priorities. The only
                           formal mechanism in place to inform the commissioners about the status
                           of projects is used at the discretion of the staff director, who may report
                           the status orally or in a monthly report to the commissioners.14 We found
                           that the commissioners received only limited updates on some projects in
                           the staff director’s monthly report. The staff director did receive periodic
                           updates about the progress of projects being conducted by OCRE. However,
                           because of frequent staff turnover and misfiled or lost records, we could
                           not determine whether the staff in the General Counsel’s office similarly
                           informed the staff director about project progress.

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

                           14
                            While the Commission holds planning meetings to discuss future projects, these meetings are held
                           annually and therefore do not serve to routinely inform the commissioners about the status of
                           projects.



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                   The Commission uses three different offices to disseminate project
Dissemination of   reports, but a lack of coordination among these offices raises the potential
Project Reports    for duplication. The responsible project office; the Congressional Affairs
                   Unit; and the Office of Management, Administrative Services and
                   Clearinghouse Division, all maintain mailing lists but do not coordinate to
                   prevent duplicative mailings.


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

                   Projects embody a key component of the Commission’s operations, yet the
                   management of projects is haphazard or nonexistent. No overall standard
                   exists for assessing the timeliness of projects or for estimating how long
                   projects should take. And the lack of project documentation, systematic
                   monitoring to detect delays and review priorities, and coordination among
                   offices that disseminate reports seriously hamper the Commission’s ability
                   to produce, issue, and disseminate timely reports. Results from
                   independent reviews of the Commission’s operations, such as the Citizens’
                   Commission on Civil Rights and OPM, substantiate our assessment of the
                   Commission’s management and the need for improvements.

                   In our report, we recommended that the Commission develop and
                   document policies and procedures that (1) assign responsibility for
                   management functions to the staff director and other Commission officials
                   and (2) provide mechanisms for holding them accountable for properly
                   managing the Commission’s day-to-day operations. We specified some
                   actions that such an effort should include.

                   In the Commission’s comments on our draft report, half of the
                   commissioners agreed with our assessment, while the other half
                   challenged the report. All of the commissioners agreed, however, to
                   implement the recommendations. In fact, the Commission Chairperson
                   and the Office of the Staff Director reported that some efforts already




                   Page 11                                                    GAO/T-HEHS-97-177
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           were under way to implement the recommendations. We hope that these
           efforts will significantly improve management of the Commission.


           Mr. Chairman, this concludes my prepared remarks. We would be happy to
           answer any questions you or Members of the Subcommittee may have.




(205346)   Page 12                                               GAO/T-HEHS-97-177
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