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Report to the Ranking Minority Member, Committee on Homeland Security 
and Governmental Affairs, U.S. Senate: 

January 2005: 

Diversity Management: 

Expert-Identified Leading Practices and Agency Examples: 

GAO-05-90: 

GAO Highlights: 

Highlights of GAO-05-90, a report to the Ranking Minority Member, 
Committee on Homeland Security and Governmental Affairs, U.S. Senate: 

Why GAO Did This Study: 

A high-performance organization relies on a dynamic workforce with the 
requisite talents, multidisciplinary knowledge, and up-to-date skills 
to ensure that it is equipped to accomplish its mission and achieve its 
goals. Such organizations typically (1) foster a work environment in 
which people are enabled and motivated to contribute to mission 
accomplishment and (2) provide both accountability and fairness for all 
employees. To accomplish these objectives, high-performance 
organizations are inclusive, drawing on the strengths of employees at 
all levels and of all backgrounds—an approach consistent with diversity 
management. For purposes of our review, diversity management is defined 
as a process intended to create and maintain a positive work 
environment where the similarities and differences of individuals are 
valued, so that all can reach their potential and maximize their 
contributions to an organization’s strategic goals and objectives.

As part of a request that GAO report on the federal government’s 
performance in managing its diverse workforce, GAO was asked to 
identify (1) leading diversity management practices and 
(2) examples of the identified practices in the federal government.

This report contains no recommendations.

What GAO Found: 

Of the experts in the field of diversity management we spoke with or 
whose publications we reviewed to identify leading diversity management 
practices, a majority cited the following nine practices as leading.

* Top leadership commitment—a vision of diversity demonstrated and 
communicated throughout an organization by top-level management.
* Diversity as part of an organization’s strategic plan—a diversity 
strategy and plan that are developed and aligned with the 
organization’s strategic plan.
* Diversity linked to performance—the understanding that a more diverse 
and inclusive work environment can yield greater productivity and help 
improve individual and organizational performance.
* Measurement—a set of quantitative and qualitative measures of the 
impact of various aspects of an overall diversity program. 
* Accountability—the means to ensure that leaders are responsible for 
diversity by linking their performance assessment and compensation to 
the progress of diversity initiatives.
* Succession planning—an ongoing, strategic process for identifying and 
developing a diverse pool of talent for an organization’s potential 
future leaders.
* Recruitment—the process of attracting a supply of qualified, diverse 
applicants for employment.
* Employee involvement—the contribution of employees in driving 
diversity throughout an organization. 
* Diversity training—organizational efforts to inform and educate 
management and staff about diversity.

Experts and the literature generally agree that a combination of the 
identified practices should be considered when an organization is 
developing and implementing diversity management. We selected 10 
agencies with the highest summary rankings from a 1999 governmentwide 
survey of federal agencies’ diversity management programs to review for 
examples of the implementation of the identified practices. The 
implementation of the leading practices by these agencies may provide 
insights to other agencies as they undertake or attempt to strengthen 
or improve their own diversity management initiatives. 

We provided a draft of this report to the Equal Employment Opportunity 
Commission and the U.S. Office of Personnel Management for review and 
comment. In their comments, agency officials generally agreed with the 
findings of the draft report.

www.gao.gov/cgi-bin/getrpt?GAO-05-90.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact George H. Stalcup on 
(202) 512-9490 or at stalcupg@gao.gov.

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

Experts Identified Nine Diversity Management Practices as Leading: 

Agencies Provided Examples of Their Implementation of the Cited 
Practices: 

Agency Comments: 

Appendixes: 

Appendix I: Objectives, Scope, and Methodology: 

Objective 1: Identifying Leading Practices: 

Objective 2: Identifying Examples of Leading Diversity Management 
Practices in the Federal Government: 

Appendix II: Summary of Selected Antidiscrimination Laws: 

Appendix III: Recognized Experts: 

Appendix IV: Comments from the Equal Employment Opportunity Commission: 

Appendix V: Comments from the Office of Personnel Management: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Acknowledgments: 

Figures: 

Figure 1: Leading Diversity Management Practices Identified by a 
Majority of Experts: 

Figure 2: Agency Examples of Top Leadership Commitment: 

Figure 3: Agency Examples of Diversity as Part of the Strategic Plan: 

Figure 4: Agency Example of Diversity Linked to Performance: 

Figure 5: Agency Examples of Measurement: 

Figure 6: Agency Example of Accountability: 

Figure 7: Agency Examples of Succession Planning: 

Figure 8: Agency Examples of Recruitment: 

Figure 9: Agency Examples of Advisory Boards: 

Figure 10: Agency Examples of Mentoring: 

Figure 11: Agency Examples of Community Outreach: 

Figure 12: Agency Examples of Diversity Training: 

Abbreviations: 

ADA: Americans with Disabilities Act: 

BOP: Federal Bureau of Prisons: 

CEO: Chief Executive Officer: 

DAB: Diversity Advisory Board: 

EAS: Executive Administrative Service: 

EEO: equal employment opportunity: 

EEOC: U.S. Equal Employment Opportunity Commission: 

FAA: Federal Aviation Administration: 

FDA: Food and Drug Administration: 

NIH: National Institutes of Health: 

NIST: National Institute of Standards and Technology: 

NOAA: National Oceanic and Atmospheric Administration: 

NPR: National Partnership for Reinventing Government: 

NOBCCHE: National Organization of Black Chemists and Black Chemical 
Engineers: 

OEODM: Office of Equal Opportunity and Diversity Management: 

OPM: U.S. Office of Personnel Management: 

PCES: Postal Career Executive Service: 

SEA: Science and Engineering Alliance: 

SES: Senior Executive Service: 

SFA: Survey Feedback Action: 

VA: Department of Veterans Affairs: 

VHA: Veterans Health Administration: 

Letter January 14, 2005: 

The Honorable Joseph I. Lieberman: 
Ranking Minority Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Dear Senator Lieberman: 

A high-performance organization relies on a dynamic workforce with the 
requisite talents, multidisciplinary knowledge, and up-to-date skills 
to ensure that it is equipped to accomplish its mission and achieve its 
goals. Such organizations typically foster a work environment in which 
people are enabled and motivated to contribute to continuous learning 
and improvement as well as mission accomplishment. Such organizations 
also provide both accountability and fairness for all employees. In 
addition, the approach that a high-performance organization takes 
toward its workforce is inclusive and draws on the strengths of 
employees at all levels and of all backgrounds. This approach is 
consistent with that of diversity management. For purposes of our 
review, diversity management is a process intended to create and 
maintain a positive work environment where the similarities and 
differences of individuals are valued, so that all can reach their 
potential and maximize their contributions to an organization's 
strategic goals and objectives.

This report responds, in part, to your request that we report on the 
federal government's performance in managing its diverse workforce. Our 
objectives were to identify (1) leading diversity management practices 
and (2) examples of how federal agencies implement the identified 
practices in the federal government. To identify leading diversity 
management practices, we first reviewed literature on diversity 
management. We then met with various federal officials and experts in 
the field of diversity management.[Footnote 1] We identified as leading 
those diversity management practices that a majority of experts cited 
in interviews or publications as leading practices, best practices, or 
components of a successful diversity initiative. We recognize that 
other experts may have identified other practices and are not 
suggesting that this list is exhaustive. We did not evaluate the 
effectiveness of the cited practices, although many of these practices 
are consistent with practices identified in prior GAO reports on human 
capital management.[Footnote 2]

To identify agency examples of leading practices in the federal 
government, we reviewed diversity management literature and met with 
officials from the National Academy of Public Administration and others 
who directed us to agencies that may have implemented some of the 
expert-identified practices. Through our literature search, we located 
a 2001 paper[Footnote 3] that ranked federal agencies' diversity 
management programs based on results from a 1999 governmentwide survey, 
which was administered to 160 agencies and subagencies that represented 
more than 80 percent of the federal civilian workforce.[Footnote 4] We 
used this paper for selecting federal agencies because (1) it employed 
a systematic methodological approach for gauging agencies' diversity 
management programs and (2) we found no other research subsequent to 
the paper that assessed agencies' diversity management programs using a 
systematic methodological approach that covered a large number of 
agencies and subagencies. Using the rankings in that paper, we selected 
the 10 agencies with the highest summary rankings to examine in more 
detail.[Footnote 5] These agencies--in the ranked order cited in the 
paper, starting with the highest--were the U.S. Coast Guard, National 
Institute of Standards and Technology (NIST), the Department of 
Veterans Affairs (VA),[Footnote 6] Federal Bureau of Prisons (BOP), 
U.S. Postal Service, National Oceanic and Atmospheric Administration 
(NOAA), Veterans Health Administration (VHA), Food and Drug 
Administration (FDA), Federal Aviation Administration (FAA), and 
National Institutes of Health (NIH). Officials from these 10 agencies 
also provided documents that illustrated their agencies' diversity 
management efforts, including the expert-identified practices. The 
agency examples of diversity management practices in this report do not 
represent all the potential ways that an agency could implement 
diversity management initiatives or address the specific diversity 
management practice being discussed. We did not evaluate the 
effectiveness of each agency's implementation of the practices, and the 
fact that an agency is profiled to illustrate the implementation of a 
particular diversity management practice is not meant to imply agency 
success or lack of success in the implementation of other diversity 
management practices or diversity management overall.

We did our work in Washington, D.C., between July 2003 and October 
2004, in accordance with generally accepted government auditing 
standards. Details of our scope and methodology are in appendix I.

Results in Brief: 

Of the experts in the field of diversity management we spoke with or 
whose publications we reviewed to identify leading diversity management 
practices, a majority cited the nine practices in figure 1 as leading.

Figure 1: Leading Diversity Management Practices Identified by a 
Majority of Experts: 

* Top leadership commitment--a vision of diversity demonstrated and 
communicated throughout an organization by top-level management; 

* Diversity as part of an organization's strategic plan--a diversity 
strategy and plan that are developed and aligned with the 
organization's strategic plan; 

* Diversity linked to performance-- the understanding that a more 
diverse and inclusive work environment can yield greater productivity 
and help improve individual and organizational performance.[Note A]; 

* Measurement--a set of quantitative and qualitative measures of the 
impact of various aspects of an overall diversity program; 

* Accountability--the means to ensure that leaders are responsible for 
diversity by linking their performance assessment and compensation to 
the progress of diversity initiatives; 

* Succession planning--an ongoing, strategic process for identifying 
and developing a diverse pool of talent for an organization's potential 
future leaders; 

* Recruitment--the process of attracting a supply of qualified, diverse 
applicants for employment; 

* Employee involvement--the contribution of employees in driving 
diversity throughout an organization; 

* Diversity training--organizational efforts to inform and educate 
management and staff about diversity. 

Source: GAO analysis.

NOTE: 

[A] This practice is often referred to as an organization's business 
case for diversity.

[End of figure]

Each of the 10 agencies selected for our review had its own way of 
implementing the identified practices, which could reflect each 
agency's organizational structure, culture, and priorities. Examples of 
agencies' implementation of these leading practices cited in the report 
may provide insights to other agencies as they undertake or attempt to 
strengthen or improve their own diversity management initiatives.

We provided a draft of this report to the Equal Employment Opportunity 
Commission (EEOC) and the U.S. Office of Personnel Management (OPM) for 
review and comment. In their comments, agency officials generally 
agreed with the findings of the draft report. We also provided drafts 
of the relevant sections of this report to cognizant officials from the 
10 agencies we reviewed. We made technical clarifications based on 
these comments where appropriate.

Background: 

During the 1980s and 1990s, the composition of the U.S. workforce, as 
documented in demographic statistics, became increasingly diverse. In 
1987, a landmark report entitled Workforce 2000,[Footnote 7] written by 
researchers with the Hudson Institute for the Department of 
Labor,[Footnote 8] described the increasing diversity of the American 
workforce by the year 2000. Among the demographic changes the report 
projected was a rise in the average age of the workforce and an 
increase in the number of women and minorities entering the workforce. 
Against this backdrop of expectations for an increasingly diverse 
workforce, by the 1990s, an industry of consultants had developed, 
offering books, videos, and training to sensitize workplaces "to the 
different perspectives and needs of a more diverse workforce."[Footnote 
9] Dr. R. Roosevelt Thomas, Jr. is generally credited with originating 
the term "managing diversity" in 1990.[Footnote 10]

The concept of managing diversity includes everyone and therefore 
serves as a complement to equal employment opportunity (EEO). EEO 
focuses on those groups protected by law from employment 
discrimination. By law, employment actions are to be free from 
prohibited discrimination on such bases as race, color, religion, 
gender, national origin, age, or disability.[Footnote 11] For purposes 
of this review, workforce diversity refers to ways in which people in a 
workforce are similar and different from one another. In addition to 
the characteristics protected by law, other similarities and 
differences commonly cited by the literature include but are not 
limited to background, education, language skills, personality, sexual 
orientation, and work role.[Footnote 12] OPM includes workforce 
diversity as a critical success factor for one of the six elements of 
human capital leadership--results-oriented performance culture--in its 
Human Capital Assessment and Accountability Framework.[Footnote 13] OPM 
uses the critical success factors in this framework when scoring a 
federal agency's implementation of Strategic Human Capital under the 
President's Management Agenda.[Footnote 14] Among other things, OPM 
examines whether an agency maintains an environment characterized by 
inclusiveness of individual differences and is responsive to the 
diverse needs of employees as a critical success factor.

Experts Identified Nine Diversity Management Practices as Leading: 

Of the experts in the field of diversity management we spoke with or 
whose publications we reviewed, the majority cited nine practices as 
leading. These practices are (1) commitment to diversity as 
demonstrated and communicated by an organization's top leadership; (2) 
the inclusion of diversity management in an organization's strategic 
plan; (3) diversity linked to performance, making the case that a more 
diverse and inclusive work environment could help improve productivity 
and individual and organizational performance; (4) measurement of the 
impact of various aspects of a diversity program; (5) management 
accountability for the progress of diversity initiatives; (6) 
succession planning; (7) recruitment; (8) employee involvement in an 
organization's diversity management; and (9) training for management 
and staff about diversity management. Experts and the literature 
generally agree that some combination of these identified practices 
should be considered when an organization is developing and 
implementing diversity management.

Agencies Provided Examples of Their Implementation of the Cited 
Practices: 

We met with officials from the 10 agencies selected for our 
review,[Footnote 15] and these officials provided examples of diversity 
management practices that their respective agencies had implemented and 
considered to be leading practices. We judgmentally chose from the 
examples agencies provided to illustrate the implementation of the nine 
practices that a majority of experts cited as leading. The following 
sections of this report further describe the nine practices as well as 
provide examples of how the selected agencies have implemented them.

Top Leadership Commitment: 

As we testified in 1999, perhaps the single most important element of 
successful management improvement initiatives is the demonstrated 
commitment of top leaders to change.[Footnote 16] Similarly, top 
management commitment is a fundamental element in the implementation of 
diversity management initiatives. According to the literature, leaders 
and managers within organizations are primarily responsible for the 
success of diversity management because they must provide the 
visibility and commit the time and necessary resources. A leader 
committed to diversity management communicates the organization's 
support for diversity in newsletters, policy statements, speeches, 
meetings, and Web sites. Communication of this commitment from senior 
management throughout the organization sends a clear message to others 
in the organization about the seriousness and business relevance of 
diversity management.

Figure 2: Agency Examples of Top Leadership Commitment: 

The Director of NIH has taken several steps to show his commitment to 
diversity management. For example, 3 months after his arrival at NIH in 
2002, the Director signed the NIH policy on EEO and diversity 
management, which states that NIH "must offer opportunities for all 
persons to develop to their full potential in the pursuit and support 
of science with diversity management integrated into all facets of the 
NIH." One NIH official said that the Director leads by example, having 
made several appointments from diverse groups to leadership positions 
in the Office of the Director and in the institutes and centers during 
his tenure thus far. The NIH Director, the official said, frequently 
discusses the importance of diversity in public meetings and to NIH 
employees and has created a more unified culture that moves beyond the 
feeling that at NIH, "there are science people and then the rest of you 
all." Another NIH official said that at "town hall" style meetings and 
other public speaking opportunities,[Note A] the Director discusses 
diversity management, noting, for example, that the Director had 
stressed the importance of diversity management at a meeting with 
Presidential Management Fellows.[Note B] The NIH Director has also 
written an article on diversity for NIH's newsletter. In October 2003, 
NIH's Director was recognized for his commitment to diversity 
management, receiving a Chief Executive Officer (CEO) Leadership Award 
from Diversity Best Practices in recognition of NIH's efforts to ensure 
a diverse workforce.[Note C] Of the 10 CEOs to be honored, NIH's was 
the only award recipient representing a federal agency.

The U.S. Coast Guard has focused on the management of diversity since 
March 1993, when its Headquarters Human Resources Coordinating Council 
chartered a "Managing Diversity as a Process" study. Since 1994, Coast 
Guard Commandants have included diversity as one of the Coast Guard's 
major priorities through the Commandants' Directions, which establish 
the vision and priorities of the Coast Guard. The first of the then-
Commandant's eight goals in the 1994 Direction was to provide 
leadership and a working environment that enabled all to reach their 
full potential. The current Commandant reinforces the importance of a 
capable and diverse workforce in his Direction as well as public 
speeches. For example, in a 2002 speech at the Coast Guard Academy, he 
stated that the future of the Coast Guard demands a multitude of 
technical skills and capabilities that require people with broadly 
diverse talents and backgrounds. In its diversity policy statement, the 
Coast Guard further states that "diversity in the workforce contributes 
measurably to creative thinking and innovation so critical to 
excellence." A Coast Guard official said that the Coast Guard has been 
integrating diversity in all processes and has been working hard to 
"connect the dots." The U.S. Coast Guard is another federal agency that 
has been recognized for having implemented diversity management 
initiatives in an exemplary manner.[Note D].

Sources: NIH and U.S. Coast Guard.

NOTES: 

[A] The official said that the town hall style meetings were large 
affairs that were broadcast on NIH's Webcast and available to the 
entire organization.

[B] The Presidential Management Fellows Program is a governmentwide 
program administered by OPM. The program has two components: 
Presidential Management Fellows, whose nomination process is conducted 
by colleges and universities, and Senior Presidential Management 
Fellows, who may apply directly if they have the requisite 
qualifications. OPM conducts the selection process for finalists, and 
individual agencies make the ultimate hiring decisions for the fellows' 
2-year appointment.

[C] Diversity Best Practices is a member-based service for companies 
and government entities to exchange best practices around diversity 
issues and build management and resources. Diversity Best Practices' 
CEO Leadership Awards recognize business leaders across the country who 
have proven themselves and their organizations as champions for 
creating inclusive, respectful, and diverse organizational cultures.

[D] In the October 2000 report, Best Practices in Achieving Workforce 
Diversity, the Coast Guard was the only federal agency included among 
organizations that implemented diversity management practices in an 
exemplary manner. See U.S. Department of Commerce and the National 
Partnership for Reinventing Government, Best Practices in Achieving 
Workforce Diversity (Washington, D.C.: 2000), p. 3.

[End of figure]

Diversity as Part of the Strategic Plan: 

Because successful change management initiatives in large public and 
private sector organizations suggest that it can often take 5 to 7 
years to substantially complete such initiatives, it is important to 
institutionalize them by integrating the initiatives into agencies' 
strategic planning efforts. As we have said, sustaining top leadership 
commitment to improvement is particularly challenging in the federal 
government because of the turnover of senior agency political 
officials.[Footnote 17] In 2003, we reported that governmentwide, the 
average tenure of political appointees for 1990 through 2001 was just 
under 3 years.[Footnote 18] Integrating diversity management into an 
organization's strategic plan fosters a culture change that supports 
and values differences. One recognized expert we talked with also 
pointed out that an organization must link diversity to its overall 
strategic plan to ensure that diversity initiatives are not viewed as 
an "extra," which could make them vulnerable to cuts, for example, when 
funds are tight.

Figure 3: Agency Examples of Diversity as Part of the Strategic Plan: 

VA includes diversity management as an "enabling goal" in its 2003 to 
2008 strategic plan. The plan explains that the enabling goal differs 
from a strategic goal as it represents crosscutting activities that 
enable all organizational units to carry out VA's mission. The enabling 
goal is to "deliver world-class service to veterans and their families 
by applying sound business principles that result in effective 
management of people, communications, technology, and governance." The 
first objective under this enabling goal is "to recruit, develop, and 
retain a competent, committed, and diverse workforce that provides a 
high quality service to veterans and their families." VA states that it 
has strategies and processes in place to assist the achievement of the 
enabling goal, specifically that VA "will recruit, support, and retain 
a knowledgeable, diverse, engaged, and continuously learning 
workforce."

FDA has a separate diversity management strategic plan that has the 
vision, mission, goals, objectives, strategies, and measures for 
addressing FDA's human capital goal. In its August 2003 strategic 
action plan, FDA states that one goal is to have "more effective 
regulation through a stronger workforce." The first objective under 
that goal is to "ensure a high quality, diverse and motivated 
workforce." According to the executive summary of FDA's multiyear 
Office of Equal Employment Opportunity and Diversity Management 
strategic action plan, a prerequisite for achieving FDA's strategic 
objective is supporting the principles of equity and diversity in the 
workforce, which the office states that it endeavors to lead.[Note A] 
The office has three strategic goals for addressing this objective: (1) 
eradicate discrimination in the workplace by enforcing federal EEO 
laws, regulations, and policies; (2) promote inclusion and diversity in 
all levels of the workforce; and (3) empower individuals so that they 
may participate and contribute to their fullest potential to FDA's 
mission.

Sources: VA and FDA.

NOTE: 

[A] The plan is intended to be a multiyear living blueprint for 
promoting and integrating diversity management strategies into FDA's 
operations.

[End of figure]

Diversity Linked to Performance: 

By focusing on diversity management and looking for more ways to be 
truly inclusive, leading organizations have recognized that diversity 
can contribute to the achievement of improved individual and 
organizational performance. According to the literature reviewed, 
diversity management makes good business sense that enhances 
productivity and innovation. For example, promoting diversity might 
help an organization expand services to meet the needs of a more 
diverse customer base. The literature also stated that fostering a 
diverse and inclusive workplace could help organizations reduce costs 
by reducing turnover, increasing employee retention across demographic 
groups, and improving morale.

Figure 4: Agency Example of Diversity Linked to Performance: 

In its Office of Diversity Development's 2003 strategic plan, the U.S. 
Postal Service states that its policy is to value and manage the 
diversity of its employees, customers, and suppliers. In the plan, the 
Postal Service lays out its business case for diversity and states that 
to leverage diversity and work toward inclusion, it must provide 
developmental opportunities to all employees equitably, recruit for 
needed skills, use its talent base to its advantage, and address 
potential loss of leadership.[Note A] The Postal Service also states 
that to reach out to diverse, multidimensional, and emerging markets, 
it must identify and understand the needs of customers and design and 
implement a comprehensive strategy that demonstrates a value for all 
customer markets. As an example of extending services to emerging 
markets, the Postal Service translated customer mailing guides and 
instructions for many post office documents into Chinese and Spanish.
[Note A] The instructions were done as four-color pictures of each 
document and contained a description of the service provided and how it 
was used. The Office of Diversity Development identified the post 
offices with the highest concentration of Spanish and Chinese non-
English speaking customers. After a 24-month controlled pilot test at 
25 post offices to measure the effectiveness of these tools and 
evaluate sales at the sites that received them compared with sales at 
those sites with the national average, the results indicated a growth 
of over $14.8 million in net new walk-in retail revenue. According to a 
Postal Service official, the pilot test results created a business case 
to widen the program. The official said that the program was deployed 
in fiscal year 2002, and now new post offices have access to Internet 
printouts of the translated instructions.

Source: U.S. Postal Service.

NOTES:
 
[A] This business case includes (1) achieving an inclusive organization 
as a critical business issue and (2) understanding customers' diversity 
enables the Postal Service to provide solutions that help customers 
meet their needs.

[B] These documents included instructions for completing a postal money 
order; receipts for registered mail, a signature confirmation, a return 
for merchandise, a domestic return, certified mail, and insured mail; 
and customs declarations.

[End of figure]

Measurement: 

Quantitative and qualitative performance measures "help organizations 
translate their diversity aspirations into tangible 
practice."[Footnote 19] For example, an organization can track data on 
its workforce to evaluate the effectiveness of the organization's 
diversity management efforts and the progress it is making in those 
efforts. Organizations also can track the return they receive on 
investments in such areas as diversity training and recruitment to 
evaluate the progress they are making in those efforts.[Footnote 20] In 
addition to analyzing quantitative workforce data, organizations can 
use qualitative data derived from interviews, focus groups, and surveys 
for identifying employee perceptions--including available opportunities 
and work environment/culture--among various segments of their 
workforces. For example, organizations can ask employees a series of 
general organizational questions in such areas as climate, 
organizational commitment, promotions, job satisfaction, supervision, 
and performance evaluations.[Footnote 21] Over time, trends in 
responses are the types of qualitative information that can help 
organizations assess how their diversity initiatives are progressing in 
achieving organizational goals and objectives. Finally, in a 2001 
report on human capital and workforce diversity,[Footnote 22] the 
National Academy of Public Administration stated that good performance 
measurements shared some common traits regardless of the environment in 
which they were used, including being based on reliable and accurate 
data that are consistent and compatible with existing business systems 
and processes. VA, for example, provides data on its workforce, 
including data on those in the leadership pipeline (i.e., employees in 
grades 13, 14, and 15), to all managers through their personal 
computers.

Figure 5: Agency Examples of Measurement: 

NOAA relies on one of its organizational assessment tools--the Survey 
Feedback Action (SFA) process--to survey all NOAA employees via an 
online questionnaire,[Note A] hold facilitated feedback sessions at the 
workgroup level (i.e., an employee's immediate group of people--the 
lowest level of contact) to provide survey results, and plan actions to 
address issues raised in the feedback sessions. In 1998, NOAA conducted 
its first NOAA-wide baseline survey and continued with a successive 
survey in 2002. The SFA process is designed to measure the perception 
of employees on NOAA's organizational culture in a standard survey, 
covering a range of dimensions on the quality of an employee's work 
life.[Note B] In addition to the survey component, the SFA process 
provides survey results to employees and their workgroup members during 
facilitated feedback and action planning meetings.[Note C] Survey 
feedback was provided at all organizational levels. According to a NOAA 
official, to measure its progress in its diversity strategy, NOAA uses 
such measures as use of sick leave, complaints, grievances, accessions, 
and attrition. According to information on NOAA's Web site, feedback 
action meetings, which are facilitated by trained NOAA in-house 
facilitators, are to provide a forum for workgroup members to interpret 
the survey results, determine how to work better together, identify 
successes and areas that need improvement, and develop a process for 
action planning. According to a NOAA official, the "heart" of the 
diversity component of SFA is in the facilitated meetings, which serve 
as an experiential learning laboratory of NOAA's diversity premises: 
inclusion; supportive systems, policies, and practices; and supportive 
behaviors at the personal, interpersonal, and group levels.[Note D] The 
Director of the Office of Diversity said that if a workgroup cannot 
resolve an issue in a feedback meeting, the issue is elevated to the 
next management level to see if it can be resolved there. In addition, 
the Director said that a contractor implemented "Action Tracker," a 
system that gives managers the flexibility to input actions taken to 
resolve issues, and that approximately 6,133 actions have been taken as 
a result of workgroups, reflecting intervention "from the bottom up and 
the top down."

NIST uses a survey conducted under its Diversity Assessment Program to 
assess culture and morale. According to a NIST official, the Diversity 
Advisory Board (DAB) recognized that NIST had only anecdotal evidence 
of how staff felt and needed a more systematic approach in assessing 
culture. Another official said that questions for the first survey in 
1998 contained a variety of categories, including career progression, 
overall satisfaction, and open-ended questions. Although the initial 
survey focused only on the culture of the agency, the then Deputy 
Director wanted to add questions that would gauge morale as well, to 
determine how people actually felt about working at NIST. As a result, 
components on culture and morale were combined in the next two surveys, 
which included some diversity management questions.[Note E] Each 
operating unit received feedback at the division level in a briefing 
from the contractor who administered the survey, and operating unit 
managers were asked to put action plans in place to address concerns 
raised by survey results.[Note F] According to a NIST official, survey 
results were used to help develop diversity goals and objectives for 
the diversity strategic plan.

Sources: NOAA and NIST.

NOTES: 

[A] The survey is also made available via the telephone or hardcopy for 
those who do not have access to the Internet.

[B] The survey includes questions about NOAA's reward and recognition 
processes, team work, communication, training and career development, 
fairness and treatment of employees, supervision, customer focus, work 
environment, employee involvement, innovation, EEO, overall 
satisfaction, additional experiences, leadership, communication, and 
organizational measures.

[C] According to a NOAA official, these meetings are integral to SFA 
because employees are provided an opportunity and equal voice to 
interpret survey results, identify successes and areas that need 
improvement, and resolve issues of concern in their work environment 
through the development of focused action plans.

[D] NOAA's in-house facilitators are educated in managing diversity, 
understanding differences, and experiential learning and serve as 
neutral third parties assisting workgroups, identifying issues, 
ensuring inclusion of all voices, and achieving agreement during the 
feedback and action planning meetings.

[E] A NIST official said that the survey had two specific indexes: 
diversity and employee satisfaction, which were in the NIST balanced 
scorecard.

[F] A NIST organizational chart shows 12 operating units, and an 
organizational listing shows those operating units to be composed of 
divisions.

[End of figure]

Accountability: 

We have previously pointed to the importance of holding managers 
accountable for contributing to the achievement of an organization's 
strategic goals through performance management and rewards 
systems.[Footnote 23] According to diversity management 
literature,[Footnote 24] accountability is also a key element for 
organizations to ensure the success of a diversity management effort by 
providing a means for ensuring that managers at all levels are made 
responsible for diversity in their organizations and evaluated on their 
progress toward achieving their diversity goals and their ability to 
manage a diverse group of employees. An organization may make managers' 
performance ratings and compensation dependent, in part, on their 
success in achieving diversity-related goals. For federal senior 
executives, such accountability is consistent with section 4313 of 
title 5, which provides performance appraisal criteria for those in the 
Senior Executive Service (SES), including the achievement of EEO 
requirements. This accountability also is consistent with EEOC's recent 
instructions to federal agencies for implementing EEO Management 
Directive 715.[Footnote 25] The instructions describe the requirement 
that agencies inform managers and supervisors that success and a 
positive evaluation will include an assessment of how that manager 
contributes to the agency's EEO program by emphasizing to managers and 
supervisors that equality of opportunity is essential to attracting, 
developing, and retaining the most qualified workforce, with such a 
workforce being essential to ensuring the agency's achievement of its 
strategic mission.

Recognizing that an agency's people are vital assets and people achieve 
organizational goals and results, OPM's regulations on SES performance 
management call for appraisal of executives using measures that balance 
organizational results with employee perspectives.[Footnote 26] In 
2002, we reported that senior executives can foster fairness and 
diversity by protecting the rights of all employees, providing a fair 
dispute resolution system, and working to prevent discrimination 
through equality of employment and opportunity.[Footnote 27] We found 
examples of senior executive performance expectations included (1) 
taking steps to implement EEO requirements; (2) requiring all 
subordinate managers and supervisors to receive diversity awareness and 
EEO training; and (3) establishing a zero tolerance standard for 
discrimination, harassment, and hostile work environments.

Figure 6: Agency Example of Accountability: 

According to an NIH official, NIH managers take diversity seriously, 
holding people accountable for managing diversity in their 
organizations.[Note A] According to NIH's SES Performance Guidance for 
2003, each SES executive was to submit narrative descriptions of 
accomplishments for the year, including a narrative for a critical 
element that promotes EEO and workforce diversity programs. To address 
their contribution toward this element, executives were to write 
narratives describing actions the executives had taken including to: 

* comply with relevant EEO laws, regulations, and NIH policies; 
* ensure the equitable development and recognition of staff at all 
levels; 
* implement and manage a diverse workforce; 
* support EEO and diversity management programs by allocating adequate 
staff and fiscal resources; and; 
* describe the procedures implemented for monitoring a 
subordinate manager's EEO and diversity management programs; 

NIH SES annual performance ratings and bonus nominations are reviewed 
by the NIH Performance Review Board and approved by the NIH Director. 
The Performance Review Board membership includes the NIH Deputy 
Directors and representatives of the Institute Directors and Institute 
Scientific Directors. The Director of the Office of Equal Opportunity 
and Diversity Management (OEODM) serves as an advisor to the board. If 
there are serious proven EEO violations, under the requirements of the 
critical element that promotes EEO and workforce diversity programs, 
the Director of OEODM can advise the Performance Review Board on the 
appropriateness of a bonus. One NIH official explained that if an SES 
official had a proven record of noncompliance with this critical 
element, the OEODM Director could advise the board against that 
official getting a bonus; this happened in one instance, and the bonus 
did not go through.

Source: NIH.

NOTE: 

[A] NIH also holds managers accountable for their EEO responsibilities.

[End of figure]

Succession Planning: 

Succession planning is a comprehensive, ongoing strategic process that 
provides for forecasting an organization's senior leadership needs; 
identifying and developing candidates who have the potential to be 
future leaders; and selecting individuals from among a diverse pool of 
qualified candidates to meet executive resource needs. Succession 
planning and management can help an organization become what it needs 
to be, rather than simply recreate the existing organization. Leading 
organizations go beyond a "replacement" approach that focuses on 
identifying particular individuals as possible successors for specific 
top-ranking positions and engage in broad, integrated succession 
planning and management efforts that focus on strengthening both 
current and future capacity. They anticipate the need for leaders and 
other key employees with the necessary competencies to successfully 
meet the complex challenges of the 21ST century.

Succession planning also is tied to the federal government's 
opportunity to change the diversity of the executive corps through new 
appointments. As we testified in October 2003,[Footnote 28] the federal 
government faces large losses in its SES, primarily through retirement 
but also because of other normal attrition. The SES generally 
represents the most experienced and senior segment of the federal 
workforce. The expected loss of more than half of current career SES 
members through fiscal year 2007, as well as significant attrition in 
the GS-15 and GS-14 workforce--the key source for SES appointments--has 
important implications for federal agencies and underscores the need 
for effective succession planning. This presents the government with 
substantial challenges for ensuring an able management cadre and also 
presents opportunities to affect the composition of the SES. In 
September 2003,[Footnote 29] we reported that agencies in other 
countries use succession planning and management to achieve a more 
diverse workforce, maintain their leadership capacity, and increase the 
retention of high-potential staff. Our work has shown that federal 
agencies will need to enhance their efforts to improve workforce 
diversity as the SES turns over.

Figure 7: Agency Examples of Succession Planning: 

The U.S. Postal Service has a formal succession planning process in 
which its Office of Diversity Development plays a key role. According 
to a Postal Service official, this succession planning program is 
unique because it includes self-nomination, self-assessment, and a 
leadership assessment survey administered by Gallup. According to the 
guidelines on Corporate Succession Planning, the Postal Service's goal 
is to have a pool of qualified Executive Administrative Service (EAS) 
and Postal Career Executive Service (PCES) employees ready to fill 
current and executive and officer positions. Each year, after the 
Office of Diversity Development announces the dates of the succession 
planning cycle, all EAS employees at level 22 and above,[Note A] as 
well as current executives, can nominate themselves for executive 
positions by completing an online succession planning application on 
the Postal Service Diversity Development Intranet site.[Note B] The 
nominee's executive manager then informs the succession planning 
committee of whether he or she supports the nominee. The area and 
headquarters succession planning committees review application 
packages, discuss nominees, and make selections on the basis of the 
extent to which nominees meet experience requirements, leadership 
potential, and eight corporate competencies.[Note C] The Postal Service 
considers the development of potential successor employees for 
executive leadership roles as a stage in the succession planning 
process. In fiscal year 2002, the Postal Service completed a Web-based 
individual development plan system, which is found on the Diversity 
Development Intranet site. Individuals who already are in management 
positions must use the Web-based individual development plan system to 
identify their skills, training, areas of expertise, and areas of 
development focus. The Postal Service states that it tracks this 
information to ensure that all potential candidates for higher level or 
more specialized jobs are following a plan that includes the training 
and work experiences necessary to enable these individuals to fill 
vacant positions and lead the organization into the future.

In January 2003, VA provided guidance to all of its components on 
succession planning in the form of a directive on workforce and 
succession planning.[Note D] The directive requires that all VA 
administrations, staff offices, and boards with 100 employees or more 
produce workforce and succession plans aligned with overall VA 
strategic planning, budget, and legislative processes. In addition, the 
directive states that the workforce and succession planning process is 
intended to align VA's workforce with the critical needs of VA's 
mission. As part of this alignment, the directive requires various 
assessments, including the current and projected workforce in terms of 
workforce diversity. In VA's 2003 Strategic Human Capital Management 
Plan, VA's three administrations--the Veterans Health Administration 
(VHA), Veterans Benefits Administration, and the National Cemetery 
Administration--as well as VA's Central Office summarize their 
workforce and succession plans.[Note E] In analyzing their workforces, 
VHA and several organizations in VA's Central Office forecast their 
needs for potential future leaders. VHA states that although its 
overall workforce is fairly diverse, women and minorities are not well 
represented in leadership positions and the pipeline to leadership 
positions. In addition, in the workforce and succession plan summary of 
VA's Central Office, the Office of the Assistant Secretary for 
Management proposes developing a process for identifying high-
performing nonsupervisory employees and providing those employees with 
a formal mentoring program, experiential leadership opportunities, and 
exposure to all facets of the organization's operations. Similarly the 
Board of Veterans' Appeals states that it is developing a plan to 
cultivate professional staff to step into more responsible roles and 
provide the backbone of the board's leadership cadre. In addition, VA 
addresses candidate developmental opportunities for individuals who 
demonstrate outstanding executive potential through another 
directive.[Note F] This directive states that VA would provide 
appropriate developmental opportunities for VA executives and 
individuals competitively selected as candidates for executive 
positions within VA. Such opportunities are to reflect VA's commitment 
to promote EEO and to build a diverse executive corps that reflects the 
diversity of the labor force.

Sources: U.S. Postal Service and VA.

NOTES: 

[A] EAS employees at level 22 compare roughly to other federal 
employees who are paid under the fiscal year 2004 general schedule at 
grade 11, step 6 to grade 14, step 3.

[B] A nominating executive or officer also can identify nominees and 
request that they complete and submit applications.

[C] The eight corporate competencies are strategic thinking, problem 
solving, communication policy/program information, listening, 
leadership and team building, interpersonal sensitivity, initiative, 
and change agent.

[D] VA Directive 5002 issued on January 15, 2003.

[E] VA's Central Office workforce and succession plan includes the 
following organizations with 100 or more employees: Assistant Secretary 
for Management, Assistant Secretary for Human Resources and 
Administration, Assistant Secretary for Information and Technology, 
Office of General Counsel, and the Board of Veterans' Appeals.

[F] VA Directive 5027 and its related Handbook 5027 were issued on 
April 15, 2002.

[End of figure]

Recruitment: 

Recruitment, a key process by which federal agencies attract a supply 
of qualified, diverse applicants for employment, is the first step 
toward establishing a diverse workforce. To ensure that organizations 
are reaching out to diverse pools of talent, they can widen the 
selection of schools from which they recruit to include, for example, 
historically Black colleges and universities, Hispanic-serving 
institutions, women's colleges, and schools with international 
programs. In addition, the literature discusses the importance of 
organizations building formal relationships with such schools to ensure 
the cultivation of talent for future talent pools. The literature 
states that organizations also may want to consider partnering with 
multicultural professional organizations and speaking at their 
conferences to communicate their commitment to diversity to external 
audiences and strengthen and maintain relationships. Although the focus 
of recruitment efforts in the diversity management literature is with 
colleges and universities, given the number of federal employees, 
including those in the SES, who are eligible for retirement in the next 
few years, there will be a need for the federal government to also 
recruit midcareer employees, which we are defining as employees who are 
generally 40 and over and have 10 or more years of work experience.


Figure 8: Agency Examples of Recruitment: 

FAA recently revised some of its recruitment strategies. In June 2002, 
FAA issued a 5-year Corporate Recruitment Plan that contains the 
findings and recommendations of a cross-organizational recruitment task 
force.[Note A] One of the plan's recommendations, which FAA implemented, 
was to develop a recruitment tool kit for use by managers, supervisors, 
and those with recruitment responsibilities. The recruitment tool kit 
includes various recruitment sources for minorities and diverse 
populations by state, including lists of Hispanic-serving institutions, 
historically Black colleges and universities, colleges and universities 
with a significant population of Asian Americans and Pacific Islanders, 
and professional minority organizations. FAA also has internship 
opportunities, which are designed to recruit a diverse group of future 
candidates for FAA. Its Minority-Serving Institutions Internship 
Program is designed to provide professional knowledge and experience at 
FAA or firms in the private sector for minority students and students 
with disabilities who are enrolled in a college or university, major in 
relevant fields and related disciplines, and have a minimum of a 3.0 
grade point average. The program allows students to earn academic 
credit for their participation in an internship during the fall or 
spring semesters or over the summer.[Note B] In addition, FAA launched 
an interactive Web site to facilitate recruitment and outreach efforts 
for managers and supervisors.[Note C] By accessing the Web site, 
managers and supervisors may view, manage, and post jobs as well as 
access the resume database and search resumes, view a specific resume, 
and identify resume search agents based on selected areas of expertise 
or key words and phrases.

A NIST official said that when NIST hosts recruitment or other 
programs, it makes use of relationships the agency has with colleges, 
universities, and other groups to inform students about internship or 
employment opportunities. One group that helps arrange such recruitment 
efforts is the National Organization of Black Chemists and Black 
Chemical Engineers (NOBCCHE).[Note D] The NIST official said that NIST 
had been active in NOBCCHE's leadership for years and that two NIST 
employees are on its executive board. Another NIST official said that 
NOBCCHE has helped with NIST summer intern recruitment efforts. For 
example, if NIST had a few summer internships for the chemical science 
area, NIST officials would contact NOBCCHE scientists who would inform 
college and university students who were members of NOBCCHE. The 
official also said that the Science and Engineering Alliance (SEA) is 
another organization in which NIST also has been active in the 
leadership. According to information on its Web site, SEA is a 
consortium that serves four state-supported historically Black colleges 
and universities[Note E] and the Department of Energy's Lawrence 
Livermore National Laboratory to help ensure an adequate supply of top-
quality minority scientists, while meeting the research and development 
needs of the public and private sectors. The NIST official explained 
that SEA and NIST are involved in the scientist exchange program, which 
serves as a vehicle for an exchange of students, faculty, and staff 
members between the SEA institutions and NIST. He said that this 
exchange helps supply the NIST pipeline with students and interns.

Sources: FAA and NIST.

NOTES: 

[A] The plan recommended that FAA establish a corporate council for 
recruitment and retention; produce recruitment and retention plans; 
develop a recruitment tool kit for use by managers, supervisors, and 
those with recruitment responsibilities; establish a recruitment 
Intranet site; develop a formal mechanism for the lines of business to 
share recruitment and retention information and initiatives; and 
establish a corporate-level system to track, monitor, and measure 
ongoing progress.

[B] The program provides interns with a weekly stipend and the cost of 
travel to and from their internship locations.

[C] FAA contracted with a Web-based recruitment source that provides 
FAA with multicultural recruitment advertising and exposure in 
promoting FAA employment opportunities nationwide.

[D] According to information on the NOBCCHE Web site, the organization 
has held national meetings since 1974 and provides an opportunity for 
black chemists and chemical engineers to discuss issues of significance 
to their careers, present technical papers, and formulate priorities 
and topics for future meetings.

[E] The four schools are Alabama A&M University, Jackson State 
University, Prairie View A&M University, and Southern University and 
A&M College.

[End of figure]

Employee Involvement: 

According to the literature, involving employees in diversity 
management helps them contribute to driving diversity throughout an 
organization. Employees may become involved in their organizations' 
diversity management efforts by forming employee diversity task forces, 
councils, boards, and networks (also called advisory, advocacy, 
support, affinity, or resource groups) to identify issues, recommend 
actions, and help develop initiatives. Organizations also can establish 
advisory groups that include representatives from many specific groups. 
In addition, mentoring programs are a popular method for organizations 
to develop and retain newer employees and require the involvement of 
more senior or experienced employees. The diversity management 
literature also describes employees reaching out in their communities.

Forming Advisory Groups to Facilitate Change: 

Most of the 10 agencies had some type of diversity advisory board.

Figure 9: Agency Examples of Advisory Boards: 

NIST's Diversity Advisory Board (DAB) was established in 1993 but 
received its current name in 1998 under a rechartering. The DAB 
provides a visible forum for independent advice and assistance to NIST 
and the management of NIST's 12 operating units on diversity-related 
plans, policies, and programs.[Note A] In addition to the DAB,[Note B] 
NIST has an advisory council--the People Council--that is chaired by a 
senior manager and that focuses on people.[Note C] A NIST official 
explained that the DAB and People Council both contributed to the 
diversity strategic plan, with the DAB starting the draft plan in 2001 
and turning it over to the People Council for completion. In 2003, 
senior NIST management adopted the diversity strategic plan, which has 
four objectives: increased awareness of diversity values and 
sensitivities by NIST senior management, managers, and staff; retention 
of existing diversity and work-life enhancement; active promotion of 
outreach and creation of a visible network of connections or routes to 
NIST; and recruitment and workforce planning for enhanced diversity.
[Note D]

More recently, according to an FDA official, FDA founded its Diversity 
Council in August 2004. The Diversity Council's charter states that the 
council was designed to serve as an advisory body to the Commissioner 
of FDA, the FDA Management Council, and the; Director of the Office of 
Equal Employment Opportunity and Diversity Management. Among its 
purposes, the Diversity Council is to foster effective diversity 
management practices in FDA, promote workforce diversity initiatives, 
and integrate the principles of diversity management in FDA. According 
to its charter, the Diversity Council, which meets monthly, has 18 
voting members, 2--an appointed management employee and an appointed 
nonmanagement employee--from each FDA Center and the Office of the; 
Commissioner, from the headquarters Office of Regulatory Affairs, and 
from the field offices of the Office of Regulatory Affairs; and 5 
nonvoting members, including 1 union representative, FDA's Human 
Resources Liaison, and 3 representatives from FDA's Office of Equal 
Employment Opportunity and Diversity Management.

VHA established the Under Secretary of Health's Diversity Advisory 
Committee in 1993. In 1995, the committee was renamed the Under 
Secretary of Health's Diversity Advisory Board. According to a VHA 
official, VHA recently selected new leadership to take the board "to 
the next level."

Sources: NIST, VHA, and FDA.

NOTES: 

[A] According to NIST officials, the DAB consists of a representative 
from the Diversity Program Office, each operating unit, employee 
organizations, administrative staff, group leaders, and ex-officio 
members.

[B] NIST states that the DAB has two main roles: (1) to advise the NIST 
Director on diversity issues, plans, and policies and (2) to advise the 
operating unit management on strategic planning for diversity, 
addressing recruitment outreach, retention, staff development, and 
organizational culture.

[C] According to a NIST official, the People Council was formed in 
January 2002 and consists of two operating unit directors, one deputy 
director, one division chief, one group leader, and one or two members 
at the bench level.

[D] According to a NIST official, the agency's 5-year diversity 
strategic plan is worked into the overall agency strategic plan through 
the People Council.

[End of figure]

Providing Mentoring Opportunities for Developing and Retaining Staff: 

According to one expert, mentoring programs became popular in the mid-
1980s as part of organizations' efforts to improve the promotion and 
retention of women and minorities. However, as mentoring success 
stories continued, organizations increasingly realized that mentoring 
relationships could benefit all employees, not just those from the 
protected groups. Mentoring can help new employees adjust to an 
organization's culture. It also can help identify and develop high-
potential employees, improve employee productivity and performance, and 
promote retention and diversity.

Figure 10: Agency Examples of Mentoring: 

NIH encourages mentoring through various programs, such as the NIH 
Management Intern Program,[Note A] the Presidential Management Fellows 
Program,[Note B] the Emerging Leaders Program,[Note C] and the 
Management Cadre Program.[Note D] An NIH official explained that having 
the right mentor for new or young employees in the science areas is 
critical, especially for retaining minorities, and that the mentoring 
program is consciously trying to foster relationships. The official 
added that NIH also tries to get employees to have more than one 
mentor, because a scientist, for example, might not be very helpful at 
helping a young person develop networking skills. In addition, the NIH 
Administrative Training Committee has a Mentoring Subcommittee that 
promotes the availability of high-quality mentoring resources to 
support the NIH Management Intern Program, the Presidential Management 
Fellows Program, and the Emerging Leaders Program. For example, each 
fellow in the Presidential Management Fellows Program is assigned a 
mentor for the duration of the fellowship to provide advice on 
rotational assignments, training opportunities, and future career 
options. In addition, for the Emerging Leaders Program, mentors are 
assigned to provide career development advice and support, and training 
in Department of Health and Human Services core competencies and 
values. According to information on the NIH Web site, for the NIH 
Management Cadre Program, a mentor is assigned at the beginning of the 
program and, among other things, assists with preparing the individual 
development plan for the mentee. NIH states that the program represents 
an important component of NIH's efforts to develop a diverse group of 
well-qualified candidates for management positions.

According to information on its Web site, the Coast Guard has had a 
mentoring program since 1990, and a Coast Guard official said that 
people must go through training to become mentors. The Coast Guard has 
a guide titled, Establishing a Local Mentoring Program, which is 
intended to be a resource for commands to establish and manage a 
mentoring program, providing a tool for managing local programs and a 
curriculum for training program coordinators and participants. The 
Coast Guard Web site provides additional information and guidance on 
mentoring, such as how to be an effective mentor and mentee and 
frequently asked questions about mentoring, such as the difference 
between formal and "natural" mentoring. The Web site explains that 
natural mentoring occurs when people select people who are similar to 
them and form a mentoring relationship. Sometimes natural mentoring may 
not occur, so the Coast Guard established the formal mentoring program. 
A Coast Guard official said that there is a computer process for 
matching mentors and mentees and that the Coast Guard wants people to 
mentor individuals who are different from them.

Sources: NIH and U.S. Coast Guard.

NOTES: 

[A] The NIH Management Internship Program is a 2-year program that 
offers highly motivated NIH employees (GS-5 or above) an opportunity to 
explore different administrative fields and change careers.

[B] The Presidential Management Fellows Program is a governmentwide 
program administered by OPM. The program has two components: 
Presidential Management Fellows, whose nomination process is conducted 
by colleges and universities, and Senior Presidential Management 
Fellows, who may apply directly if they have the requisite 
qualifications. OPM conducts the selection process for finalists, and 
individual agencies make the ultimate hiring decisions for the fellows' 
2-year appointment.

[C] The Emerging Leaders Program is a 2-year program within the 
Department of Health and Human Services, that allows participants to 
explore scientific, public health, social science, information 
technology, and administrative career paths.

[D] The Management Cadre Program is designed to develop a diverse group 
of well-qualified candidates for future leadership positions by 
training successful and highly motivated NIH employees currently in GS/
GM grades 12 to 14.

[End of figure]

Encouraging Employees to Reach Out to the Community: 

Several sources described organizations' encouraging employees to 
volunteer in their communities to help make the communities aware of 
what the organization does.[Footnote 30] In addition, in its recent 
instructions to federal agencies for implementing EEO Management 
Directive 715, EEOC suggests that agencies allocate mission personnel 
to participate in, among other things, community outreach programs with 
private employers, public schools, and universities.

Figure 11: Agency Examples of Community Outreach: 

According to NIST's Diversity Tool Kit for Managers,[Note A] the 
community outreach programs at NIST support diversity initiatives by 
educating the community about the agency and the functions it performs. 
According to a NIST official, staff actively reach out to local 
schools, including through mentoring and tutoring programs that help 
students with their class work, raise their awareness of scientific 
careers, and increase community involvement. Other outreach programs 
identified in the tool kit include (1) the National Hispanic Youth 
Initiative, which prepares, motivates, and encourages high school 
Hispanic youth to pursue a career in the areas of scientific and 
biomedical research; (2) the Student Volunteer Program, which provides 
high school and college students a learning experience and exposure to 
career opportunities by volunteering at NIST in such areas as physical 
science, mathematics, engineering, computer science, and 
administration; (3) the Student Career Experience Program, which 
provides high school, undergraduate, and graduate students work 
experience at NIST that is directly related to their educational and 
career goals; (4) the Resource Education Awareness Partnership, which 
includes researchers and other professionals at NIST who volunteer 
their time by giving science presentations to public school students; 
and (5) the Metropolitan Consortium for Mathematics, Science, and 
Engineering,[Note B] which strives to increase the awareness of 
students from underrepresented groups in career opportunities and 
challenges in the fields of mathematics, science, and engineering.

FAA has a number of outreach programs that support diversity 
initiatives through educating the community. According to information 
on the FAA Web site, the programs include the aviation education 
counselors, the "Air Bear" program, the Aviation Career Education 
camps, and the Space Day program. The aviation education counselors are 
trained volunteers who have an interest in sharing their knowledge with 
the community and give speeches and presentations as requested, 
depending on the availability of counselors in the region where a 
request is made. FAA states that the Air Bear program is a national 
program designed for children in kindergarten through third grade that 
can stimulate an early interest in math and science, introduce exciting 
career choices for boys and girls, eliminate fears children often have 
about flying, and promote aviation safety.[Note C] The Aviation Career 
Education camp program is a 1-week summer aviation education program 
that exposes middle and high school students to a range of aviation 
career experiences, with an emphasis on opportunities for women and 
minorities.[Note D] FAA also is a partner of the Space Day program, 
which is an educational initiative that takes place on the first 
Thursday of May worldwide and is designed to promote math, science, 
technology, and engineering education.[Note E]

Sources: NIST and FAA.

NOTES: 

[A] The Diversity Tool Kit for Managers provides managers with 
supporting guidance and information toward managing and measuring 
different aspects of a diversity management program, including 
mentoring, community outreach, and recruitment and retention.

[B] The Metropolitan Consortium for Mathematics, Science, and 
Engineering is a nonprofit organization dedicated to providing a link 
between the Washington, D.C. public schools and technology-orientated 
resources in the region.

[C] The Air Bear program involves the Air Bear mascot visiting schools 
for a demonstration and is sponsored by FAA, the National Association 
of State Aviation Officials, and the Ninety-Nines--an international 
organization of women pilots.

[D] The program is cosponsored by FAA and other organizations and 
reaches approximately 1,500 to 2,000 students per year.

[E] The Space Day program is international, has more than 75 sponsors, 
and has participants numbering in the hundreds of thousands of teachers 
and millions of students in 21 countries.

[End of figure]

Diversity Training: 

According to the literature, diversity training can help an 
organization's management and staff increase their awareness and 
understanding of diversity as well as help them develop concrete skills 
to assist them in communicating and increasing productivity. Such 
training can provide employees with an awareness of their differences-
-including cultural, work style, and personal presentation--and an 
understanding of how diverse perspectives can improve organizational 
performance. It also should teach employees about the importance of the 
organization's diversity goals and the skills required to work 
effectively in a diverse workforce.[Footnote 31] In addition, to 
increase employee effectiveness in a diverse environment, one source 
stated that training should include teambuilding, communication styles, 
decision making, and conflict resolution.[Footnote 32] This is 
consistent with EEOC's recent instructions to federal agencies for 
implementing EEO Management Directive 715, which requires that agencies 
develop supervisors and managers who have effective managerial, 
communication, and interpersonal skills to supervise most effectively 
in a workplace with diverse employees. Finally, as we recently reported 
on training in the federal government,[Footnote 33] agencies should 
attempt to assess the effectiveness of their training efforts. Such an 
assessment can help decision makers in managing scarce resources and 
help agencies improve results.

Figure 12: Agency Examples of Diversity Training: 

NIH has interactive training modules on EEO and diversity management 
available online to individuals inside and outside of NIH. Upon 
completion of the three modules, participants receive certificates of 
completion in the prevention of sexual harassment, disability 
awareness, and diversity management. The first module provides 
information and situational examples to help NIH managers, supervisors, 
and employees recognize sexual harassment and eliminate it from the 
workplace. The second module is meant to provide an awareness of issues 
concerning persons with disabilities, including legislation related to 
disability, reasonable accommodation, and attitudinal barriers. The 
third module focuses on approaches to diversity management, NIH's 
diversity management efforts, and how participants can avoid cultural 
collisions.

According to a BOP official, BOP holds two sets of diversity training 
for trainers per year. These trained diversity specialists ensure that 
all BOP staff receive refresher diversity training annually at their 
respective facilities. Wardens choose the diversity specialists at each 
facility based on their maturity and whether they have worked for BOP 
for at least 1 year. The specialists are trained in-house and hold 
collateral duty positions. The official said that the diversity 
training emphasizes that not all differences are related to race and 
gender and that often problems seen as racial in nature are actually 
based on personality differences. BOP follows up its training sessions 
with surveys to find out how well the training worked, and participants 
are to evaluate the training and how it will affect them when they 
return to their facilities.

NOAA's Director of the Office of Diversity said that NOAA does not rely 
heavily on traditional diversity training classes. Instead, she said 
that NOAA relies on David A. Kolb's model of experiential training, 
which she explained is how adults learn better.[Note A] For example, 
NOAA's Office of Diversity partnered with the Howard University School 
of Continuing Education to develop Developing a Multi-Lingual Ear, a 
course that helps NOAA employees develop and use listening skills and 
techniques essential for communicating more effectively with colleagues 
and customers whose native language is not English.[Note B] One Office 
of Diversity staff member said that the office at one time had many 
different course offerings. To be more cost-effective, the staff member 
said that the Office of Diversity decided to have a large training 
event, which is how it started the diversity education conferences. Now 
at the conference--NOAA's Diversity Summit--several hundred NOAA 
employees from all occupations, regions, line offices, and staff 
offices have the opportunity to learn and network and take a variety of 
week-long courses, including a diversity change agent course,[Note C] 
which is required for all NOAA diversity consultants; group process 
consultation; and the Myers-Briggs Type Indicator Qualifying Workshop.
[Note D] NOAA also provides various tools for employees to identify 
skills, thinking styles, personality types, and where they are on 
various diversity dimensions.[Note E]

Sources: NIH, BOP, NOAA.

NOTES: 

[A] The Diversity Director stated that Kolb's model asserts that 
learning should really be approached as a continuous spiral and that 
the learning cycle can begin at any one of four points: (1) a person 
carrying out a particular action and then seeing the effect of the 
action in this situation, (2) understanding these effects in the 
particular instance so that if the same action was taken in the same 
circumstance it would be possible to anticipate what would follow from 
the action, (3) understanding the general principle under which a 
particular instance falls, and (4) applying experiential learning 
through a new circumstance within the range of generalization.

[B] According to information on NOAA's Web site, the Office of 
Diversity contacts course participants before the class to identify the 
types of accents or languages they encounter in the workplace. Course 
participants can listen to audiotapes of different dialects by country 
of origin, so that they can train their ears to better understand 
English spoken by a foreign tongue. The Director said that part of the 
course is for participants to attune themselves to hear that some 
languages are tonal and that certain words have special emphasis.

[C] In 1998, NOAA's change agent course received the Trainer's 
Conference Distinguished Service Award for content and design, which 
includes systems diagnosis, conflict resolution, cross-cultural 
communications, and understanding and managing change. The objective of 
the course is to provide participants with the skills, knowledge, 
tools, and techniques to effectively become agents for change in 
diversity management.

[D] Participants who successfully complete the Myers-Briggs Type 
Indicator Qualifying Workshop are qualified to administer the Myers-
Briggs Type Indicator--a measurable psychological instrument that is 
used to help people understand how their personality differs from that 
of others and deal with the differences in a constructive way.

[E] These tools include the Thomas Kilman Conflict Model, FIRO-B, and 
the Disc--dimensions of behavior--among others that act as 
communication vehicles for workgroups.

[End of figure]

Agency Comments: 

On November 10, 2004, we provided a draft of this report to EEOC and 
OPM for review and comment. In written comments, the Director of EEOC's 
Office of Federal Operations generally agreed with the findings of the 
draft report and stated that expanding agency knowledge of the 
available tools to achieve diversity is critical to the government's 
success in maintaining a workplace that is inclusive and responsive to 
the needs of an increasingly diverse workforce (see app. IV). The 
Director stated that federal agencies can learn from the experiences 
and successes of others and that this report would assist in that 
effort. He added that future studies of diversity management practices 
are warranted and could explore the effectiveness of these practices, 
particularly measurement. We agree. We have an engagement under way 
that reviews measurement practices for EEO and diversity management in 
selected federal agencies. We also have begun work that is to provide 
examples from the private sector of the leading diversity management 
practices identified in this report. In written comments, the Director 
of OPM generally agreed with the findings of the draft report, noting 
that the agencies identified merit recognition for their efforts in 
diversity management (see app. V). The Director of OPM also noted that 
the area of diversity is an important element in the President's 
Management Agenda. In addition, the Director of OPM provided technical 
comments, which we incorporated.

We also provided drafts of the relevant sections of this report to 
cognizant officials from the 10 agencies we reviewed. We made technical 
clarifications based on these comments where appropriate.

As arranged with your office, unless you publicly announce its contents 
earlier we plan no further distribution of this report until 7 days 
from the date of this letter. At that time, we will send copies of this 
report to other interested congressional parties, the Director of OPM, 
and the Chair of EEOC. We also will make copies available to others 
upon request. In addition, the report is available on GAO's home page 
at [Hyperlink, http://www.gao.gov].

If you or your staff have questions about this report, please contact 
me on (202) 512-9490 or Belva Martin, Assistant Director, on (202) 512-
4285. Key contributors to this report are listed in appendix VI.

Sincerely yours,

Signed by: 

George H. Stalcup: 
Director, Strategic Issues: 

[End of section]

Appendixes: 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to identify (1) leading diversity management 
practices and (2) examples of those practices in federal agencies.

Objective 1: Identifying Leading Practices: 

To identify leading diversity management practices, we first reviewed 
literature on diversity management. This review included academic 
literature on diversity management, books and articles written by 
consultants and practitioners, and reports produced by government 
agencies and research organizations.

We then met with various federal officials and experts in diversity 
management. This included officials from the central leadership 
agencies--the Equal Employment Opportunity Commission (EEOC), Merit 
Systems Protection Board, U.S. Office of Personnel Management (OPM), 
and the U.S. Office of Special Counsel. At the National Academy of 
Public Administration (NAPA), we met with one former official--a former 
Director of the Center for Human Resource Management--and two current 
officials--the Director and Deputy Director of the Center for Human 
Resources Management. These officials were helpful in suggesting 
experts to contact in the field of diversity management.

On the basis of our literature review and our discussions with federal 
and NAPA officials, we established criteria for and identified a list 
of recognized experts. These criteria included: 

* the expert's recognition in the professional or academic community,

* depth of experience in diversity management, and: 

* relevance of his or her published work or research to diversity 
management.

We defined recognition as an acknowledgment of expertise from officials 
of such organizations as NAPA, the Society for Human Resource 
Management, and the Private Sector Council. We defined experience as 
having practical or academic experience in diversity management for at 
least 7 years. After the experts were selected, we gathered their views 
on leading practices using questions from a data collection instrument. 
We reviewed their responses and counted the number of times an expert 
or a publication by an expert cited a diversity management practice. We 
identified as leading those practices that a majority of experts cited 
in interviews or publications as leading practices, best practices, or 
components of a successful diversity initiative.

Our characterization of diversity management practices is 
methodologically dependent on the experts contacted and sources 
reviewed. We recognize that had we interviewed other experts or 
reviewed other sources that other practices may have been identified as 
leading. We also recognize that diversity management practices are 
dynamic in nature and other practices that were not cited by a majority 
of our sources may, over time, achieve greater acknowledgment. In 
addition, we did not evaluate the effectiveness of the cited practices, 
although many of these practices are consistent with practices 
identified in prior GAO reports on human capital management.[Footnote 
34]

Objective 2: Identifying Examples of Leading Diversity Management 
Practices in the Federal Government: 

To identify agency examples of leading practices in the federal 
government, we reviewed diversity management literature and met with 
officials from NAPA and others who directed us to agencies that may 
have implemented some of the expert-identified practices. Through our 
literature search, we located a 2001 paper by Dr. J. Edward Kellough of 
the University of Georgia and Dr. Katherine Naff of San Francisco State 
University.[Footnote 35] This paper ranked federal agencies' diversity 
management programs based on results from a 1999 governmentwide 
survey,[Footnote 36] which was administered to 160 agencies and 
subagencies.[Footnote 37] We used this paper for selecting federal 
agencies because it employed a systematic methodological approach for 
gauging agencies' diversity management programs. Through our literature 
search, we found no other research subsequent to the paper that 
assessed agencies' diversity management programs using a systematic 
methodological approach that covered a large number of agencies and 
subagencies. Of the organizations responding to the governmentwide 
survey, 138, or 86 percent, returned usable questionnaires. These 
organizations represented more than 80 percent of the federal civilian 
workforce, including components from the 23 largest departments and 
agencies as well as the U.S. Postal Service and most of the smaller 
agencies.

In their paper, Drs. Kellough and Naff identified five separate aspects 
of agencies' diversity management programs that address: 

* characteristics of diversity training efforts,

* internal communications regarding programs,

* accountability for diversity,

* activities reflective of broader resource commitments to the 
programs, and: 

* the scope of programs in terms of the dimensions of diversity 
addressed.

Drs. Kellough and Naff assigned scores by summing agency responses to 
each of the relevant survey items.[Footnote 38] From the Kellough-Naff 
list, we chose the 10 agencies with the highest summary ranking to 
examine in more detail.[Footnote 39] These agencies were the U.S. Coast 
Guard, National Institute of Standards and Technology, the Department 
of Veterans Affairs (headquarters), Federal Bureau of Prisons, U.S. 
Postal Service, National Oceanic and Atmospheric Administration, 
Veterans Health Administration, Food and Drug Administration, Federal 
Aviation Administration, and National Institutes of Health.

We developed a list of topics related to diversity management practices 
to facilitate our discussion with agency officials. The list included 
identification of leading diversity management practices, definition of 
diversity, measures of success, barriers to implementation, and 
examples of leading practices that have been implemented. We provided 
the list to each agency. For some agencies, when we were able to obtain 
information on their diversity management practices before meeting with 
them, we developed more extensive questions. We then conducted 
interviews with officials from these agencies who were responsible for 
diversity management and equal employment opportunity (EEO). During 
these interviews, we covered the material on the list, and agency 
officials described what they considered to be the agencies' leading 
diversity management practices. Agency officials also provided 
documents that illustrated their agencies' diversity management 
efforts, including the expert-identified practices.

The agency examples of diversity management practices in this report do 
not represent all the potential ways that an agency can implement 
diversity management initiatives or address the specific diversity 
management practice being discussed. Because our review objectives did 
not include evaluating the effectiveness of agencies' implementation of 
diversity management practices, we did not evaluate the effectiveness 
of the agency examples. Further, the fact that an agency is profiled to 
illustrate the implementation of a particular diversity management 
practice is not meant to imply agency success or lack of success in the 
implementation of other diversity management practices or diversity 
management overall.

We did our work in Washington, D.C., between July 2003 and October 
2004, in accordance with generally accepted government auditing 
standards.

[End of section]

Appendix II: Summary of Selected Antidiscrimination Laws: 

Over the past 40 years, Congress has enacted a number of laws 
prohibiting employment discrimination with the intent of ensuring equal 
opportunity in employment, both in the public and private 
sectors.[Footnote 40] Among these enactments is Title VII of the Civil 
Rights Act of 1964,[Footnote 41] amended in 1972 to include the federal 
sector, which makes it illegal for employers to discriminate against 
their employees or job applicants on the basis of race, color, 
religion, sex, or national origin.[Footnote 42] The 1972 amendment also 
requires federal agencies to maintain an affirmative program of equal 
employment opportunity.[Footnote 43]

Section 501 of the Rehabilitation Act of 1973, as amended, prohibits 
discrimination against qualified individuals with disabilities who work 
or apply to work in the federal government and requires federal 
agencies to prepare affirmative action plans.[Footnote 44] Title I of 
the Americans with Disabilities Act (ADA) of 1990 prohibits employment 
discrimination against qualified individuals with disabilities in the 
private sector and in state and local governments.[Footnote 45] In 
1992, the Rehabilitation Act was amended to adopt the ADA standards in 
determining whether a federal employer engaged in prohibited 
discrimination.[Footnote 46]

The Age Discrimination in Employment Act of 1967, amended in 1974 to 
include the federal sector, prohibits employment discrimination against 
individuals who are 40 years of age or older.[Footnote 47]

The Equal Pay Act of 1963 protects men and women who perform 
substantially equal work in the same establishment from sex-based wage 
discrimination.[Footnote 48]

[End of section]

Appendix III: Recognized Experts: 

Susan Black: 
Vice President, Catalyst, Canada: 

Todd Campbell: 
Diversity Initiative Manager, 
Society for Human Resource Management: 

Taylor H. Cox, Jr.* 
CEO, Taylor Cox Associates: 

John P. Fernandez* 
President, 
Advanced Research Management Consultants: 

Edie Fraser: 
President, 
Diversity Best Practices: 

Lee Gardenswartz & Anita Rowe* 
Partners, 
Gardenswartz & Rowe: 

Carol A. Hayashida: 
Former Deputy Director, 
Center for Human Resources Management: 
National Academy of Public Administration: 

Robert C. Holland* 
Director, Diversity Analysis Research Team, 
SEI Center for Advanced Studies in Management, 
Wharton School, University of Pennsylvania: 

Karen A. Jehn* 
Faculty Coordinator of the George Harvey Program for Redefining 
Diversity, 
Wharton School, University of Pennsylvania: 

J. Edward Kellough: 
Director, 
Department of Public Administration and Policy, 
University of Georgia: 

Ann M. Morrison* 
Honorary Senior Fellow, 
Center for Creative Leadership: 

Katherine C. Naff: 
Associate Professor, 
Department of Public Administration, 
San Francisco State University: 

Nancy Nelkin: 
Director: 
Audit Services, 
Equal Employment Advisory Council: 

Jeffrey A. Norris: 
President, Equal Employment Advisory Council: 

Al Ressler: 
Former Director, Center for Human Resources Management, 
National Academy of Public Administration: 

Myra Howze Shiplett: 
President, Randolph Morgan Consulting, LLC: 

Pete Smith: 
Former President, Private Sector Council[Footnote 49]

R. Roosevelt Thomas, Jr.: 
President, 
The American Institute for Managing Diversity: 

Mauricio Velasquez* 
President, 
The Diversity Training Group: 

Jo Weiss: 
Former Vice President of Advisory Service and Member Relations, 
Catalyst: 

Trevor Wilson: 
President, TWI, Inc.

We also spoke with officials from and reviewed publications of the U.S. 
Equal Employment Opportunity Commission, the U.S. Office of Personnel 
Management, and the Corporate Leadership Council. For experts with an 
asterisk by their names (*), we reviewed their publications but did not 
interview them.

[End of section]

Appendix IV: Comments from the Equal Employment Opportunity Commission: 

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION: 
Washington, D.C. 20507:

December 16, 2004:

The Honorable David M. Walker: 
Comptroller General of the United States: 
U.S. Government Accountability Office: 
Washington, D.C. 20548:

Dear Mr. Walker:

Thank you for the opportunity to review and comment on the draft 
report, Diversity Management: Expert-Identified Leading Practices and 
Agency Examples (GAO-05-90).

I commend you for identifying leading diversity management practices 
and their use in the federal government. Expanding agency knowledge of 
the available tools to achieve diversity is critical to the 
government's success in maintaining a workplace that is inclusive and 
responsive to the needs of an increasingly diverse workforce.

The agency examples included in the report should demonstrate the 
principles of workforce diversity. Federal agencies can learn from the 
experiences and successes of others. While this report will assist in 
that effort, additional studies are clearly needed to explore this area 
in more depth.

EEOC believes that Management Directive-715 will be an invaluable tool 
to help agencies to improve their workforce diversity and could assist 
in this effort. As you know, EEOC expects to begin receiving federal 
agency MD-715 reports beginning in January, 2005 and EEOC can begin 
providing data that would facilitate GAO's knowledge base in such an 
evaluation. In short, future studies of this area are warranted to 
evaluate whether the identified diversity management practices have 
actually achieved or improved workforce diversity in general or in the 
federal agencies covered.

One of the nine important factors to diversity management GAO cites is 
"measurement." A future study could also examine initiatives to measure 
diversity and how particular measures relate to the cited practices. 
Because GAO reports are widely read throughout the federal government 
and viewed as being highly authoritative, and because there are so few 
reports on diversity in the federal sector, future studies could 
explore in more depth the effectiveness of leading diversity practices.

This report defines diversity as the ways in which people in a 
workforce are similar and different from each other, including race, 
ethnicity, gender, age, background, education, work role and 
personality. A future report might provide a discussion of the means 
through which agencies can determine how the multitude of similarities 
and differences that individuals bring to the workplace are important 
to creating a "high performance organization" with "a positive work 
environment where ... all can reach their potential and maximize their 
contributions to an organization's strategic goals and objectives."

Such a study would be a valuable supplement to this report. Several 
organizations in this area could be consulted in studying the 
relationships among these variables such as Diversity Inc. and the 
National Multicultural Institute. Diversity Inc, for example, 
periodically publishes various lists showing the top companies for 
diversity and which also purport to show a relationship between 
diversity and profitability.

Again, thank you for the opportunity to submit the EEOC's views on your 
draft report.

Sincerely,

Signed by: 

Carlton M. Hadden:

Director, Office of Federal Operations: 

[End of section]

Appendix V: Comments from the Office of Personnel Management: 

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT: 
WASHINGTON, DC 20415-1000:
OFFICE OF THE DIRECTOR:

DEC 23 2004:

U.S. Government Accountability Office: 
Mr. J. Christopher Mihm:
Managing Director, Strategic Issues: 
441 G Street. NW:
Washington, DC 20548:

Dear Mr. Mihm:

Thank you for the opportunity to comment on the Government 
Accountability Office'S s (GAO) draft "Diversity Management: Expert-
Identified Leading Practices and Agency Examples Report." The agencies 
you have identified certainly merit recognition for their efforts in 
diversity management.

In reviewing the report itself, we found one typographical error 
related to the Office of Personnel Management (OPM). On page 5 of the 
report, the last sentence of the paragraph needs a slight revision. The 
last line currently reads as "is responsive to the needs of diverse 
employees as a critical success factor." In fact, it should read as "is 
responsive to the diverse needs of employees as a critical success 
factor." We apologize for the confusion. This error exists on the web 
page and we intend to address it at the next opportunity to update 
President's Management Agenda (PMA) materials.

In addition, a footnote that appears at both pages 7 (note 18) and 21 
(note 60) is not completely accurate in its description of the 
Presidential Management Fellows Program. A more accurate description 
would be as follows:

"The Presidential Management Fellows Program is a governmentwide 
program administered by OPM. The Program has two components: 
Presidential Management Fellows (PMFs) and Senior Presidential 
Management Fellows (SPMFs). Colleges and universities conduct the 
nomination process for PMFs, while individuals with the requisite 
qualifications may apply directly to be an SPMF. OPM conducts the 
selection process for finalists. Individual agencies make the ultimate 
hiring decisions for the Fellows' 2-year appointments."

We observe that the report contains a strong emphasis on the notion of 
individual accountability for the "progress" of diversity initiatives. 
(See, e.g., "Highlights" page and pages 4 and 6.) While we believe that 
the initiatives GAO describes touch upon a broad range of initiatives 
rather than focusing upon achieving particular numbers or percentages 
with respect to particular groups, it would be advisable to caution 
that whatever efforts an agency undertakes must be consistent with the 
Constitution, applicable law, and binding judicial precedent and that 
agencies have a continuing obligation to honor the merit principles in 
effecting personnel decisions.

Finally, it is also important to note that President George W. Bush's 
Management Agenda has had a dramatic impact on the governmentwide 
commitment to building a Federal workforce that is drawn from the rich 
diversity of this Nation. An important element of the PMA is in the 
area of diversity. It is no accident that organizations' efforts on 
diversity-related matters are tracked as a part of the performance 
culture standard of the Human Capital Assessment and Accountability 
Framework. This framework includes six standards that represent the 
Strategic Management of Human Capital element of the PMA.

Every Federal agency is measured by its actions in the Human Capital 
initiative, a major component of which is workforce diversity. As a 
part of the quarterly scoring process, agencies are assessed on 
performance indicators including their strategies with respect to 
diversity-related efforts. Agencies cannot achieve or maintain a 
"green" score without demonstrating they have strategies to attempt to 
improve and/or maintain diversity within their workforce. As never 
before, agencies governmentwide are focusing on the diverse needs of 
their employees. This is a direct result of the efforts of President 
Bush and the requirements of his management agenda to achieve success.

We are hopeful that you will find this information useful in revising 
your draft report. Once again, we thank you for the opportunity to 
comment on the draft report.

Sincerely,

Signed by: 

Kay Coles James: 
Director: 

[End of section]

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George H. Stalcup, (202) 512-9490: 

Acknowledgments: 

In addition to the individual named above, Karin K. Fangman, Eric 
Gorman, Emily Hampton-Manley, Sharon Hogan, Belva Martin, Kiki 
Theodoropoulos, Michael R. Volpe, and Gregory H. Wilmoth made key 
contributions to this report.

(450242): 

FOOTNOTES

[1] Appendix I discusses the criteria used to identify experts 
recognized in diversity management, and appendix III contains a list of 
the recognized experts. 

[2] See, for example, GAO, A Model of Strategic Human Capital 
Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); GAO, 
Management Reform: Elements of Successful Improvement Initiatives, T-
GGD-00-26 (Washington, D.C.: Oct. 15, 1999); GAO, Senior Executive 
Service: Enhanced Agency Efforts Needed to Improve Diversity as the 
Senior Corps Turns Over, GAO-04-123T (Washington, D.C.: Oct. 15, 2003).

[3] J. Edward Kellough and Katherine C. Naff, "Managing Diversity in 
the Federal Service: An Examination of Agency Programs," paper prepared 
for presentation at the Sixth National Public Management Research 
Conference, October 18-20, 2001, School of Public and Environmental 
Affairs, Indiana University, Bloomington, Indiana. Subsequently, the 
paper was published as an article--J. Edward Kellough and Katherine C. 
Naff, "Responding to a Wake-Up Call: An Examination of Federal Agency 
Diversity Management Programs," Administration & Society, Vol. 36, No. 
1 (2004), pp. 62-90.

[4] The survey was conducted by the National Partnership for 
Reinventing Government's Diversity Task Force. See appendix I for more 
details.

[5] As discussed with the requester's office, because of the recent 
passage of the Department of Defense human capital legislation and 
other legislation giving the Department of Defense the authority to 
carry out a pilot program to improve its equal employment opportunity 
complaint process, we did not include any Department of Defense 
agencies in our review. Under the latter legislation, GAO is to 
evaluate the pilot. Therefore, although the Office of the Secretary of 
the Army was ranked tenth on the Kellough-Naff list, it was not 
included in our review. Also, according to an official from the 
Department of Veterans Affairs, the Veterans Benefits Administration, 
which was ranked fourth on the Kellough-Naff list, was in transition 
and had just started its new diversity effort after "bringing in new 
people." The top 10 agencies selected reflect the omission of these 2 
agencies from their original ranking in the Kellough-Naff list.

[6] The paper identified only VA headquarters.

[7] William B. Johnson and Arnold H. Packer, Workforce 2000: Work and 
Workers for the 21ST Century (Indianapolis, Ind.: Hudson Institute, 
1987).

[8] The Hudson Institute is a private, not-for-profit research 
organization with headquarters in Indianapolis, Indiana.

[9] Richard W. Judy and Carol D'Amico, Workforce 2020: Work and Workers 
in the 21ST Century (Indianapolis, Ind.: Hudson Institute, 1997); 
Katherine C. Naff, To Look Like America: Dismantling Barriers for Women 
and Minorities in Government (Boulder, Colo.: Westview Press, 2001).

[10] "Managing diversity does not mean controlling or containing 
diversity, it means enabling every member of your workforce to perform 
to his or her potential." R. Roosevelt Thomas, Jr., 1990. "From 
Affirmative Action to Affirming Diversity," Harvard Business Review, 
Vol. 68 (1990): pp. 107-117.

[11] Antidiscrimination laws also protect individuals from retaliation 
for filing discrimination complaints and other protected activity. 
Appendix II contains a summary of selected antidiscrimination laws. 

[12] In the federal sector, Executive Order (E.O.) 11478, as amended by 
E.O. 13087, prohibits discrimination in federal employment on the basis 
of sexual orientation. However, the Executive Order does not afford the 
same legal protection as antidiscrimination laws.

[13] OPM states on its Web site that the framework offers guidance so 
that all those involved in transforming human capital management can 
understand what is to be done, how it can be done, and how to gauge 
progress and results.

[14] The President's Management Agenda was launched in August 2001 as a 
strategy for improving the management and performance of the federal 
government and includes five governmentwide initiatives: strategic 
management of human capital, competitive sourcing, improved financial 
performance, expanded electronic government, and budget and performance 
integration. 

[15] For VHA, we met with officials from the department level--VA--and 
followed up with a VHA official.

[16] GAO, T-GGD-00-26.

[17] GAO, T-GGD-00-26. 

[18] GAO, High-Risk Series: Strategic Human Capital Management, GAO-03-
120 (Washington, D.C.: January 2003).

[19] Catalyst, Making Change: Using Metrics to Support Workforce 
Diversity (New York, NY: 2002), p. 4.

[20] For diversity training, organizations can calculate the percentage 
of employees retained as a result of the training by first considering 
components that increase retention (e.g., employee development and 
satisfaction), then estimating the effect of the diversity training on 
those elements. For recruitment, organizations can calculate the cost 
of recruiting channels (e.g., agencies, Internet, newspapers) and 
cross-reference those costs with the volume and quality of candidates 
yielded in order to reallocate funds to the most effective recruiting 
channels. 

[21] Jack E. Edwards, John C. Scott, and Nambury S. Raju, The Human 
Resources Program-Evaluation Handbook (Thousand Oaks, Calif.: Sage 
Publications, 2003), p. 354.

[22] National Academy of Public Administration, Human Capital and 
Workforce Diversity: The Business Case Analysis (Washington, D.C.: 
2001), pp. 7-8.

[23] GAO, Human Capital: A Self-Assessment Checklist for Agency 
Leaders, GAO/OGC-00-14G (Washington, D.C.: September 2000); GAO-02-
373SP.

[24] Best Practices in Achieving Workforce Diversity, p. 12.

[25] EEOC's instructions provide guidance and standards to federal 
agencies for establishing and maintaining effective affirmative 
programs of EEO, provide agencies additional operational instructions 
on how to accomplish the requirements of the management directive, and 
emphasize what federal agencies should do to ensure that personnel 
actions are made free of any discrimination.

[26] 5 C.F.R. Part 430, Subpart C.

[27] GAO, Results-Oriented Cultures: Using Balanced Expectations to 
Manage Senior Executive Performance, GAO-02-966 (Washington, D.C.: 
Sept. 27, 2002). 

[28] GAO-04-123T.

[29] GAO, Human Capital: Insights for U.S. Agencies from Other 
Countries' Succession Planning and Management Initiatives, GAO-03-914 
(Washington, D.C.: Sept. 15, 2003).

[30] Most examples of such outreach efforts concerned companies 
encouraging employee community involvement and volunteerism to raise 
awareness of the companies' presence and keep the companies informed of 
demographics and market changes.

[31] Katherine C. Naff, To Look Like America: Dismantling Barriers for 
Women and Minorities in Government, p. 197.

[32] Sherrie St. Amant and Marilyn Mays, "Ten Tips for Diversity Best 
Practices" (Wellesley, Mass.: Northeast Human Resources Association, 
2002).

[33] GAO, Human Capital: A Guide for Assessing Strategic Training and 
Development Efforts in the Federal Government, GAO-04-546G (Washington, 
D.C.: March 2004).

[34] See, for example, GAO, A Model of Strategic Human Capital 
Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); GAO, 
Management Reform: Elements of Successful Improvement Initiatives, T-
GGD-00-26 (Washington, D.C.: Oct. 15, 1999); and GAO, Senior Executive 
Service: Enhanced Agency Efforts Needed to Improve Diversity as the 
Senior Corps Turns Over, GAO-04-123T (Washington, D.C.: Oct. 15, 2003).

[35] J. Edward Kellough and Katherine C. Naff, "Managing Diversity in 
the Federal Service: An Examination of Agency Programs," paper prepared 
for presentation at the Sixth National Public Management Research 
Conference, October 18-20, 2001, School of Public and Environmental 
Affairs, Indiana University, Bloomington, Indiana. Subsequently, the 
paper was published as an article--J. Edward Kellough and Katherine C. 
Naff, "Responding to a Wake-Up Call: An Examination of Federal Agency 
Diversity Management Programs," Administration & Society, Vol. 36, No. 
1 (2004): pp. 62-90.

[36] This survey was conducted by the National Partnership for 
Reinventing Government's (NPR) Diversity Task Force.

[37] Subagencies are components of larger agencies and departments. For 
example, the National Institutes of Health is a subagency of the 
Department of Health and Human Services.

[38] In the summer of 2001, Drs. Kellough and Naff conducted follow-up 
interviews with a small sample of agencies with diversity programs at 
various levels of development. However, the authors did not verify all 
of the agencies' responses to the NPR survey to determine whether 
agency responses were an accurate portrayal of their diversity 
programs. 

[39] As discussed with the requester's office, because of the recent 
passage of the Department of Defense human capital legislation and 
other legislation giving the Department of Defense the authority to 
carry out a pilot program to improve its equal employment opportunity 
complaint process, we did not include any Department of Defense 
agencies in our review. See sec. 1101 of Title XI of Division A, Pub. 
L. No. 108-136, 117 Stat. 1392, 1621-1633 (Nov. 24, 2003) and sec. 1111 
of Title XI of Division A, Pub. L. No. 106-39, 114 Stat. 1654, 1654A-
312 (Oct. 30, 2000), respectively. Under the latter legislation, GAO is 
to evaluate the pilot. Therefore, although the Office of the Secretary 
of the Army was ranked tenth on the Kellough-Naff list, it was not 
included in our review. Also, according to an official from the 
Department of Veterans Affairs, the Veterans Benefits Administration, 
which was ranked fourth on the Kellough-Naff list, was in transition 
and had just started its new diversity effort after "bringing in new 
people." The top 10 agencies selected reflect the omission of these 2 
agencies from their original ranking in the Kellough-Naff list.

[40] These equal opportunity in employment laws also serve to protect 
individuals from retaliation for filing discrimination complaints and 
other protected activity.

[41] Pub. L. No. 88-352, 78 Stat. 241, 253-266 (July 2, 1964).

[42] See 42 U.S.C. secs. 2000e--20000e-17.

[43] Pub. L. No. 92-261, sec. 11, 86 Stat. 103, 111-112 (Mar. 24, 
1972). See 42 U.S.C. sec. 2000e-16(b).

[44] Pub. L. No. 93-112, 87 Stat. 355, 390-391 (Sept. 26, 1973). See 29 
U.S.C. sec. 791.

[45] Pub. L. No. 101-336, 104 Stat. 327, 330-337 (July 26, 1990). See 
42 U.S.C. secs. 12111-12117.

[46] Pub. L. No. 102-569, sec. 503(b), 106 Stat. 4344, 4424 (Oct. 29, 
1992). See 29 U.S.C. sec. 791(g).

[47] Pub. L. No. 90-202, 81 Stat. 602 (Dec. 15, 1967), amended by Pub. 
L. No. 93-259, sec. 28, 88 Stat. 55, 74-75 (Apr. 8, 1974). See 29 
U.S.C. secs. 621-634.

[48] Pub. L. No. 88-38, 77 Stat. 56 (June 10, 1963). See 29 U.S.C. sec 
206(d).

[49] As of September 1, 2004, the Private Sector Council merged with 
the Partnership for Public Service, a nonpartisan, nonprofit 
organization dedicated to revitalizing government service.

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