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FY 2019 Management Challenges

BACKGROUND
In accordance with the Reports Consolidation Act of 2000, the Office of Inspector General (OIG) is reporting what it has determined are the most serious management and performance challenges facing the U.S. Equal Employment Opportunity Commission (EEOC). This annual report provides our views on the most serious management and performance challenges facing EEOC for inclusion in the 2019 Annual Financial Report (AFR).

MANAGEMENT CHALLENGES

EEOC faces evolving obstacles as it continues with its mission to “prevent and remedy unlawful employment discrimination and advance equal opportunity for all in the workplace.” This year, OIG presents three challenges — (1) Mission-Critical Data System Modernization, (2) Data Analytics Capabilities, and (3) Strategic Performance Management. Of these, Mission-Critical Data Modernization is the only challenge not included in our 2018 Management Challenges. Under the leadership of Chair Janet Dhillon, EEOC has the opportunity to address these three challenges in fiscal year (FY) 2020.

In FY 2019, as in FY 2018, EEOC took steps to improve the management of its human capital processes and development of its data analytics program. Because data analytics is early in its development and faced unforeseen obstacles in 2018, it remains a challenge. EEOC’s data modernization is at a critical stage and should result in more useful information, which we believe could assist Agency leadership and management in developing and meeting strategic performance goals.

Mission-Critical Data System Modernization
The Integrated Mission System (IMS) is used by Agency staff to carry out EEOC’s mission and is the system of record for: private and public sector charges filed with the EEOC and 92 state and local Fair Employment Practices Agencies (FEPAs); federal sector complaints, hearings and appeals; and litigation. EEOC has used IMS as its primary mission-critical information system for the past 17 years. The system's age and antiquated technology infrastructure constrain Agency efforts regarding strategic performance and operational management. This dated technology also constrains the development and expansion of other EEOC projects, such as the Public Portal.

EEOC’s Office of Information Technology (OIT) is modernizing IMS with IMS NXG. The goals of IMS NXG are to improve content management and workflow-based activity processing, as well as improve reporting and analytical capabilities. To expedite IMS NXG development, EEOC requested $4,000,000 from the General Services Administration (GSA)-managed Technology Modernization Fund (TMF). TMF was authorized through the Modernizing Government Technology Act of 2017 and is intended to aid Agencies in funding technology modernization projects. With the TMF funds, OIT estimates IMS NXG could be completed during FY 2021. However, without the funds, OIT estimates the project completion could be extended until the end of FY 2024. As of October 16, 2019, the TMF funds had not been awarded to EEOC. According to EEOC, timely completion of IMS NXG will position the Agency to use its mission-critical information to improve strategic decision making.

Data Analytics Capabilities
Data analytics is a process of inspecting, cleaning, transforming, and modeling data to discover useful information to support the decision-making process. The Office of Enterprise Data and Analytics (OEDA) is responsible for managing data analytics. The data analytics program is in the early stages of development at EEOC. The degree of success EEOC achieves in developing a robust data analytics program depends on a strong Agency-wide data analytics culture.
Building a strong data analytics culture is a long process, requiring both buy-in from many Agency senior managers and other personnel. During FY 2019, EEOC continued to build its analytic capabilities by completing several of the recommendations from the OIG’s Evaluation of the EEOC’s Data Analytics Activities, creating the Enterprise Analytics Team, and holding regular meetings of the Data Governance Board.1 The team is led by newly hired data scientists skilled in state-of-the-art modeling approaches and model management techniques. Continuing to build upon these steps in FY 2020 is essential for growing the Agency’s data analytics culture and capabilities.
The continued progress of the data analytics program is challenged due to EEOC’s recent requirement to gather additional data from employers. On April 25, 2019, a federal judge ordered EEOC to collect detailed data on employee compensation and hours worked from covered employers by September 30, 2019. This placed strains on the development of data analytics because OEDA resources, funding, and personnel intended to grow the data analytics program were diverted to comply with the new requirement. Agency leadership should focus efforts to continue building data analytics capabilities in FY 2020 while continuing to meet the demands of the additional data requirement.

Strategic Performance Management
In FY 2019, as well as in FY 2018, the Agency met some of its performance targets (three were met, and nine partially met, based on EEOC’s midyear data as of October 16, 2019). As noted last year, the 2018-2022 Strategic Plan contains three performance measures that assess “activity or milestones” rather than outcomes directly related to accomplishing EEOC’s mission. For example, Performance Measure 3 for Outcome Goal I.A states “each year through 2022, EEOC reports on its efforts to identify and resolve systemic discrimination.”2 This measure concerns EEOC reporting on its activities rather than accomplishments towards fulfilling EEOC’s mission.
EEOC’s 2018-2022 Strategic Plan continues to lack a performance measure of the rate of employment discrimination. As we pointed out last year, the Office of Management and Budget (OMB) agreed, recommending that EEOC develop a baseline to measure and study EEOC’s impact in reducing employment discrimination. Given the mission of the EEOC includes preventing and remedying employment discrimination, EEOC should address this shortcoming in its strategic planning. While we recognize this is not easy, its importance justifies an increased focus by EEOC in FY 2020.

1https://oig.eeoc.gov//reports/audit/2017-002-eoig

2https://www.eeoc.gov/eeoc/plan/strategic_plan_18-22.cfm