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Report to Congressional Committees: 

February 2004: 

OFFICE OF COMPLIANCE: 

Status of Management Control Efforts to Improve Effectiveness: 

GAO-04-400: 

GAO Highlights: 

Highlights of GAO-04-400, a report to the Subcommittee on Legislative 
Branch, Committee on Appropriations, U.S. Senate and Subcommittee on 
Legislative, Committee on Appropriations, U.S. House of 
Representatives

Why GAO Did This Study: 

The Consolidated Appropriations Resolution of 2003 Conference Report 
mandated that GAO review the Office of Compliance (OOC), an 
independent legislative branch agency created by the Congressional 
Accountability Act of 1995 (CAA). OOC, a 15-person office with about 
$2 million in expenditures during fiscal year 2003, administers and 
enforces various CAA provisions related to fair employment and 
occupational safety and health among certain legislative branch 
agencies. OOC’s current Executive Director has been in place since 
April 2001 and its General Counsel joined the Office in June 2003. The 
mandate directed GAO to assess OOC’s overall effectiveness and 
efficiency and to make recommendations, as appropriate. 

What GAO Found: 

OOC is in the early stages of a concerted and vitally needed effort to 
improve and strengthen management control across the Office and to 
carry out its mission more effectively and efficiently while 
safeguarding its institutional independence. OOC’s success in 
completing this important effort depends upon making significant 
progress on a number of key management control areas: 

Sharpen focus on results. OOC’s current strategic planning initiative 
is beginning to address the more fundamental question of the Office’s 
effectiveness rather than the Office’s traditional focus on activities 
and outputs, such as the number of cases processed and inspections 
conducted. OOC’s planning initiative can also provide a vehicle for 
engaging and consulting with key congressional and other stakeholders 
on OOC’s purposes, how those purposes will be achieved, how progress 
will be assessed, and for sustaining feedback on what progress is 
being made and what additional improvement opportunities exist. The 
planning initiative is still very much a work in progress and 
continued efforts are needed in a number of key areas including 
developing results-oriented performance measures. 

Ensuring an effective program structure. As OOC shifts its focus from 
outputs and activities to results, it must put in place a more 
effective program structure that includes new ways of doing business. 
OOC has taken a number of actions to administer the CAA, such as 
managing a dispute resolution process and conducting investigations 
and inspections to ensure compliance with safety and health standards. 
However, OOC is not fully in compliance with the CAA’s requirement 
concerning biennial safety and health inspections of legislative 
branch agency facilities. OOC also needs to expand on recent efforts 
to develop programs that are based on collaboration with legislative 
branch agencies.

Building effective communication emphasizing outreach and 
coordination. OOC’s congressional and other stakeholders whom we 
interviewed said that OOC recently has used a more collaborative 
approach rather than the “gotcha” approach of the past. On the other 
hand, several agency officials said that current interactions with OOC 
could be improved. To facilitate more effective communication, OOC 
should establish congressional and agency protocols to document 
agreements between the Congress, legislative branch agencies, and OOC 
on what can be expected as OOC carries out its work. 

Creating and sustaining an enhanced management control environment. 
Since its creation, OOC has operated without having any formal 
performance management system for its Executive Director and General 
Counsel. OOC should establish an enhanced management control 
environment and strengthen accountability by requiring performance 
agreements between the Board and both the Executive Director and 
General Counsel, as well as expanding and improving on OOC’s 
performance management system for all staff. Another important 
challenge concerns the lack of institutional continuity that may occur 
due to statutory term limits on OOC’s leadership positions. To prevent 
the loss of critical organizational knowledge, the Congress should 
consider changing the term limits contained in the CAA. 

What GAO Recommends: 

GAO makes several recommendations to strengthen OOC’s strategic 
planning process, facilitate communication between OOC and its 
congressional and legislative branch stakeholders, and build an 
enhanced control management environment within OOC. This report also 
contains matters for congressional consideration regarding statutory 
changes to the CAA to help maintain institutional continuity for OOC.

In a joint response, OOC’s Board of Directors, Executive Director, and 
General Counsel all generally agreed with our recommendations and 
stated that OOC is making progress toward their adoption and 
implementation. 

www.gao.gov/cgi-bin/getrpt?GAO-04-400.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact J. Christopher Mihm 
at (202) 512-6806 or mihmj@gao.gov.

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

OOC Has Effort Under Way to Sharpen Focus on Results: 

Ensuring an Effective Program Structure: 

Building Effective Communication Emphasizing Outreach and 
Coordination: 

Creating and Sustaining an Enhanced Management Control Environment 
Essential for Effective Operations: 

Agency Comments: 

Appendixes: 

Appendix I: Objective, Scope, and Methodology: 

Appendix II: Comments from the Office of Compliance: 

Table: 

Table 1: The 12 Civil Rights, Workplace, and Labor Laws Included under 
the CAA: 

Figures: 

Figure 1: Organizational Structure of the Office of Compliancea: 

Figure 2: Expenditures for Fiscal Years 1997-2003 Covering OOC 
Functions under the Responsibility of the Board of Directors, 
Executive Director, and General Counsel: 

Figure 3: Dispute Resolution Cases, by Stage, Reported by OOC for 1996-
2003: 

Figure 4: Health and Safety Cases Reported by OOC for 1997-2003: 

Figure 5: Unfair Labor Practice Charges Filed Reported by OOC for 1997-
2003: 

Abbreviations: 

ADA: Americans with Disabilities Act: 

AOC: Office of the Architect of the Capitol: 

CAA: Congressional Accountability Act: 

EEOC: U.S. Equal Employment Opportunity Commission: 

GPO: Government Printing Office: 

GPRA: Government Performance and Results Act: 

LOC: Library of Congress: 

OOC: Office of Compliance: 

OSHA: Occupational Safety and Health Administration: 

IT: information technology: 

USCP: United States Capitol Police: 

Letter February 3, 2004: 

The Honorable Ben Nighthorse Campbell: 
Chairman: 
The Honorable Richard Durbin: 
Ranking Minority Member: 
Subcommittee on Legislative Branch: 
Committee on Appropriations: 
United States Senate: 

The Honorable Jack Kingston: 
Chairman: 
The Honorable James P. Moran: 
Ranking Minority Member: 
Subcommittee on Legislative: 
Committee on Appropriations: 
House of Representatives: 

Congress established the Office of Compliance (OOC) in 1995 as an 
independent office within the legislative branch to administer and 
enforce various provisions of the Congressional Accountability Act 
(CAA) related to fair employment and occupational safety and health. As 
mandated by the Consolidated Appropriations Resolution of 2003 
Conference Report,[Footnote 1] we examined OOC's effectiveness and 
efficiency in fulfilling its responsibilities and role as set out in 
the CAA. Our specific objective was to assess key management controls 
in place at OOC and identify what improvements, if any, could be made 
to strengthen OOC's effectiveness and efficiency.

Management controls, also known as internal controls, are a major part 
of managing an organization.[Footnote 2] They comprise the plans, 
methods, and procedures used to meet missions, goals, and objectives 
and, in doing so, support performance-based management. Effective 
management control also helps in managing change to cope with shifting 
environments and evolving demands and priorities. As programs change 
and as agencies strive to improve operational processes and implement 
new technological developments, management must continually assess and 
evaluate its management control to assure that activities being used 
are effective and updated when necessary.

To meet our objective, we analyzed applicable laws, legislative 
history, rules, and regulations; obtained and analyzed written 
documentation of guidance, policies, procedures, and performance of 
OOC; met with OOC's Board of Directors; conducted interviews with OOC 
executives, managers, and staff; met with key congressional 
stakeholders and officials in other legislative branch agencies and 
offices; and performed selected reliability and validity tests of OOC's 
dispute resolution process database. We also drew on key management 
practices and guidance identified in previously issued GAO reports, 
where appropriate.

In addition, to assist OOC in its management control improvement 
efforts, we provided OOC with briefings, reports, and examples of best 
practices in the areas we reviewed. For example, at OOC's request, GAO 
officials provided briefings on our approach to strategic planning and 
provided copies of GAO strategic planning documents. We plan to 
continue working with OOC's leadership and to meet with them regularly 
to discuss the progress of their management reform initiatives. We 
performed our work in Washington, D.C., from January 2003 through 
January 2004 in accordance with generally accepted government auditing 
standards. See appendix I for additional information on our scope and 
methodology.

Results in Brief: 

OOC's Board of Directors, senior leadership, and employees are in the 
early stages of a concerted and vitally needed effort to improve and 
strengthen management control across the Office. This effort will need 
to address a fundamental question--how effective are OOC's efforts in 
contributing to achieving mission results such as fostering a safer and 
healthier workplace that is free from discrimination and other forms of 
conflict? OOC will also need to address concerns of congressional and 
other stakeholders about whether the Office's scarce resources are 
being targeted efficiently. OOC's ability to answer these critical 
issues will depend on, among other things, its ability to make 
significant progress in the following four key management control 
areas: 

Sharpen focus on results: OOC has begun to more fully define the 
fundamental results, or outcomes, that it seeks to achieve. 
Traditionally, OOC's operations and reporting have emphasized 
activities or outputs, focusing on measures such as the number of 
mediation requests received, the number of health and safety 
inspections conducted, or the time taken for particular phases of a 
process. While these types of measures provide important information on 
the efficiency of its operations, OOC's current strategic planning 
initiative will begin to address the more fundamental question of OOC's 
effectiveness in achieving actual mission results. As part of this 
process, OOC has defined its mission as working to "advance safety, 
health, and workplace rights for employees and employers of the 
Legislative Branch as mandated by the Congressional Accountability 
Act." Towards that end, OOC has identified three strategic objectives 
or goals: (1) effectively enforce and administer the CAA, (2) educate, 
collaborate, and facilitate its regulated community, and (3) maintain 
an efficient and accountable workplace.

OOC's strategic planning initiative is an important and positive 
development that is still very much a work in progress. OOC's planning 
effort can provide a vehicle for engaging and consulting with key 
congressional and other stakeholders on the fundamental purposes of 
OOC, how those purposes will be achieved, how progress will be 
assessed, and what progress is being made and improvement opportunities 
exist. Congressional and other stakeholders also need to be engaged as 
OOC develops results-oriented performance measures. By doing so, OOC 
will help to improve its performance, assure its accountability, and 
provide for more useful and transparent annual reports. Building on the 
planning effort, OOC is in its early stages of developing work plans to 
ensure its daily operations, programs, and activities are aligned with 
the goals and priorities in its plan. The strategic use of information 
technology (IT) provides a key and continuing opportunity to improve 
OOC's efficiency and effectiveness.

We make several recommendations to OOC to help it continue and advance 
its efforts to become more results-oriented. Specifically, we recommend 
that OOC's strategic plan includes performance measures that link 
directly with annual work plans, integrates IT planning and 
implementation, and is developed with extensive collaboration and input 
from key congressional and agency stakeholders. In addition, we 
recommend that OOC use its completed strategic plan as the basis for 
future budget and staff requests, as well as a basis for developing and 
implementing new program initiatives and assessing the contributions of 
those initiatives to achieving results. We further recommend that OOC's 
strategic plan provide the foundation for developing an augmented and 
more results-oriented annual report that provides data on the degree to 
which key goals are being achieved, in addition to meeting existing 
statutory reporting requirements, as is currently the case.

Ensuring an effective program structure: As OOC shifts its focus from 
outputs and activities to the results of those outputs and activities, 
it must put in place a program structure that meets its statutory 
responsibilities, contributes to real improvements in the working 
environment and workplaces of legislative branch employees, and 
safeguards OOC's independence. The CAA contains a series of specific 
requirements for OOC to meet as it carries out its responsibility to 
administer and enforce the CAA. Toward this end, OOC has taken a number 
of actions, including administering a dispute resolution process; 
conducting investigations and inspections to ensure compliance with 
safety, health, and disability access standards; investigating and 
managing matters concerning labor-management relations; and educating 
both employees and employing offices about their rights and 
responsibilities under the CAA.

Leading organizations have found that as they shift their orientation 
to results, new, different, and more effective ways of doing business 
will emerge. OOC is beginning to experience such changes. For example, 
in light of the increasing demands for health and safety inspections, 
and the very small number of OOC staff available to conduct those 
inspections, OOC's General Counsel and his staff have begun to explore 
possible approaches to leverage OOC's limited resources through 
constructive engagement with legislative branch agencies covered under 
the CAA. As an example of this constructive approach, OOC will sponsor 
the first-ever Organizational Health and Safety Program Conference for 
legislative agencies in February 2004.

We make a number of recommendations to help OOC accelerate this needed 
shift in orientation and instill a more effective program structure. 
Specifically, we identify several ways OOC can strengthen its 
effectiveness using data including improving how the Office measures 
its activities and performance. These include the possible use of 
benchmarks to facilitate comparison and analysis; developing additional 
measures to provide a more complete picture of its workload; using 
information on the number and type of complaints it receives to better 
target education and information distribution efforts; and increasing 
its capacity to use occupational safety and health data to facilitate 
risk-based decision making. We also recommend that OOC explore 
additional ways to better disseminate information including 
establishing a clearinghouse for sharing best practice information on 
topics covered by the CAA; reaching out to relevant congressional 
groups, forums, and networks to ensure they are aware of OOC's programs 
and activities; and working with the Congress to determine the 
feasibility of using feedback surveys and focus groups to provide 
information on awareness among legislative branch employees and 
employers concerning their programs and activities. Finally, we 
recommend that OOC work with the Congress to develop a strategy to 
ensure that all facilities under OOC's jurisdiction and located in the 
Washington, D.C. area--including the Senate and House page dormitories, 
and the National Library Service for the Blind and Physically 
Handicapped of the Library of Congress--receive occupational safety and 
health inspections at least biennially, as required by the CAA. These 
facilities were not included in the last biennial inspection conducted 
in 2002. OOC officials told us that the decision not to inspect these 
facilities was largely due to resource constraints.

Building effective communication emphasizing outreach and 
coordination: OOC needs to develop a communications strategy to seek 
mutual understanding among OOC's key congressional stakeholders and 
agencies covered by the CAA concerning its mission and role as well as 
build trust among its stakeholders and clients. Developing an effective 
communications strategy could also assist OOC in becoming more 
collaborative and partnerial. Our interviews with OOC's congressional 
stakeholders found that OOC's efforts to consult with the Congress have 
been uneven and could benefit from having a set of congressional 
protocols, which would document agreements between the Congress and OOC 
on what congressional stakeholders can expect as the Office carries out 
its work. Likewise, OOC could make progress in achieving its mission by 
developing protocols for interacting with legislative branch agencies 
covered by the CAA. Some congressional staff members and agency 
officials said that OOC had recently shown a new attitude and approach 
in its work that is characterized by greater collaboration and 
cooperation rather than a "gotcha" approach that they said often 
characterized OOC's past efforts. On the other hand, several agency 
officials said that interactions with OOC could still be improved. They 
said, for example, that OOC failed to always follow its own rules and 
procedures when conducting investigations of health and safety 
complaints.

We recommend that OOC develop both congressional and agency protocols 
to facilitate open and effective communications with stakeholders, 
clients, and other recipients of the Office's services and activities. 
The purpose of such protocols is to help create a basic understanding 
of OOC's goals, functions, and procedures, what OOC will communicate to 
whom, when, and how, and not to compromise the independence the 
Congress gave OOC to enforce the CAA. In both cases, OOC should 
carefully pilot the protocols before they are fully implemented so that 
OOC, the Congress, and legislative agencies can gain experiences in 
their application and that appropriate adjustments can be made. We also 
recommend that OOC review and revise its case-handling policies and 
procedures and ensure that they are effectively communicated with 
appropriate legislative agency officials.

Creating and sustaining an enhanced management control environment: OOC 
also faces challenges in creating an enhanced control environment, 
which forms the foundation for an organization's ability to put into 
place the management controls necessary for effective and efficient 
operations. A key factor that could affect OOC's management control is 
the lack of institutional continuity due to the term limits of OOC's 
Board and senior leadership positions and the impending turnover of 
these individuals. Specifically, because the CAA permits incumbents in 
these positions to serve only a single, nonrenewable 5-year term, the 
Chair and two members of the five-member Board will conclude their 
service in September 2004, and the two remaining members will leave 8 
months later in May 2005. Similarly, the terms of all of OOC's senior 
executives, except the General Counsel, will expire within 6 months of 
each other in 2006. Taken together, eight out of nine of OOC's top 
officials will have left the organization by September 2006.

Adding to this challenge is the fact that OOC has operated without any 
formal performance management system for its Executive Director and 
General Counsel since its creation in 1995, although as of 2003 these 
officials prepare annual self-assessments. OOC's Board can strengthen 
accountability for specific goals and help align daily operations with 
the organization's programmatic goals by going the further step of 
requiring performance agreements for the Executive Director and General 
Counsel. In addition, while OOC established a performance management 
system for most of its staff in 2002, some individuals continue to work 
without any formal system to set goals, establish individual 
expectations, provide feedback, and evaluate their performance. OOC's 
need to establish a modern, effective, and credible performance 
management system with appropriate safeguards for all its employees 
represents an additional human capital challenge for OOC.

To address these concerns, we identify two matters for congressional 
consideration and make several recommendations to OOC. To help prevent 
the loss of critical organizational knowledge due to the impending loss 
of most of OOC's leaders, the Congress should consider amending the CAA 
to allow Board members to be reappointed by the Congress to an 
additional term. In addition, the Congress should consider allowing 
OOC's Executive Director, General Counsel, and two Deputy Executive 
Directors to be reappointed to serve additional terms in either the 
same or a different position, if warranted and desired. This would 
enable, for the first time, the possibility of succession planning 
among these officials. However, any such reappointments should be 
contingent on the ability to clearly assess the performance of these 
officials and their achievement of OOC's goals. Towards this end, we 
recommend that OOC's Board require performance agreements for the 
Executive Director and General Counsel. The Executive Director and 
General Counsel, in turn, should actively engage their staff to build 
on and expand OOC's recent efforts in this area in order to develop a 
more robust and effective approach to individual performance management 
for all OOC employees.

OOC's Board of Directors, Executive Director, and General Counsel, in a 
joint response, all generally agreed with our recommendations and 
stated that OOC is making progress toward their adoption and 
implementation. Their written response is reprinted in appendix II.

Background: 

Enacted on January 23, 1995, the CAA as amended, applies 12 federal 
civil rights, workplace, and labor laws to legislative branch employees 
who were previously exempted from such coverage.[Footnote 3]

Table 1: The 12 Civil Rights, Workplace, and Labor Laws Included under 
the CAA: 

CAA-covered federal law: 1. Title VII of the Civil Rights Act of 1964, 
as amended; Summary of provisions: Prohibits discrimination in hiring, 
promotion, and treatment of employees based on race, sex, color, 
religion, or national origin.

CAA-covered federal law: 2. The Age Discrimination in Employment Act of 
1967, as amended; Summary of provisions: Prohibits discrimination in 
hiring, promotion, and treatment of employees based on age.

CAA-covered federal law: 3. The Rehabilitation Act of 1973; Summary of 
provisions: A precursor to the Americans with Disabilities Act; 
prohibits discrimination against qualified individuals with 
disabilities with regard to federal employment.

CAA-covered federal law: 4. The Family and Medical Leave Act of 1993; 
Summary of provisions: Provides that employees may use unpaid leave for 
certain family and medical needs.

CAA-covered federal law: 5. The Fair Labor Standards Act of 1938, as 
amended; Summary of provisions: Provides for fair compensation for 
employees for work performed.

CAA-covered federal law: 6. The Employee Polygraph Protection Act of 
1988; Summary of provisions: Prohibits most private employers from 
requiring employees and prospective employees to take a polygraph 
examination.

CAA-covered federal law: 7. The Worker Adjustment and Retraining 
Notification Act; Summary of provisions: Requires employers to provide 
advance notice of plant closings and mass layoffs.

CAA-covered federal law: 8. Chapter 43 of title 38 of the U.S. Code 
(relating to veterans' employment and reemployment); Summary of 
provisions: Provides reemployment rights for employees who serve in the 
uniformed services.

CAA-covered federal law: 9. The Americans with Disabilities Act of 
1990; Summary of provisions: Prohibits discrimination in hiring, 
promotions, and treatment of employees on the basis of disability; 
requires full and equal access to public accommodations for the 
disabled.

CAA-covered federal law: 10. The Occupational Safety and Health Act of 
1970; Summary of provisions: Requires employers to provide a workplace 
that complies with occupational safety and health standards.

CAA-covered federal law: 11. Chapter 71 of title 5 U.S.C. (relating to 
federal labor-management relations); Summary of provisions: Protects 
the rights and obligations of employers and employees in labor-
management relations.

CAA-covered federal law: 12. Veterans' Employment Opportunities Act of 
1998; Summary of provisions: Provides hiring preferences for veterans.

Source: GAO presentation based on the CAA and laws referenced above.

[End of table]

By passing the CAA, the Congress extended to approximately 30,000 
employees of the legislative branch certain fair employment and 
occupational safety safeguards. The CAA applies to current employees, 
applicants for employment, and former employees of the following 
organizations: 

* Senate,

* House of Representatives,

* Capitol Guide Service,

* Capitol Police,

* Congressional Budget Office,

* Office of the Attending Physician,

* Office of the Architect of the Capitol, and: 

* Office of Compliance.

The CAA did not include GAO, the Library of Congress (LOC), and the 
Government Printing Office (GPO) in many of its provisions because the 
employees at these organizations already enjoyed the protections of 
many of the civil rights laws extended to legislative branch staff by 
the CAA prior to its enactment. For example, GAO, LOC, and GPO 
employees were already protected against discrimination based on race, 
color, religion, sex, and national origin (42 U.S.C. § 2000e-16); 
discrimination based on age (29 U.S.C. § 633a); and discrimination 
based on disability (42 U.S.C. § 12209). In addition, GAO, LOC, and GPO 
employees already enjoyed the protections provided by the Fair Labor 
Standards Act (29 U.S.C. § 203) and by the Federal Service Labor-
Management Relations Act (5 U.S.C. § 7103 for GPO and LOC employees; 31 
U.S.C. § 732(e) for GAO employees). Furthermore, all three 
organizations have individualized processes for resolving employee 
disputes. For example, GAO uses an independent entity, the Personnel 
Appeals Board, to adjudicate employment disputes involving GAO 
employees.

The CAA does extend the protections of the Employee Polygraph 
Protection Act, the Worker Adjustment and Retraining Notification Act, 
the Uniform Services Employment and Reemployment Rights Act, the Family 
and Medical Leave Act, the public access provisions of the Americans 
with Disabilities Act (ADA), and the Occupational Safety and Health Act 
to GAO and LOC employees.

OOC's duties are divided among a Board of Directors, an Executive 
Director, and a General Counsel, as shown in figure 1.

Figure 1: Organizational Structure of the Office of ComplianceA: 

[See PDF for image]

[A] OOC's Executive Director, General Counsel, Deputy Executive 
Director for the Senate, and Deputy Executive Director for the House 
are statutory positions mandated by the CAA. The post of Deputy General 
Counsel as well as other OOC and General Counsel staff positions are 
not specifically required by the CAA.

[B] THE CAA LIMITS THE GENERAL COUNSEL'S HIRING AUTHORITY TO ATTORNEYS 
WITH THE GENERAL COUNSEL'S OFFICE. According to OOC's General Counsel, 
although the Executive Director is responsible for hiring occupational 
safety and health and ADA specialists who work with the General 
Counsel, it has been the practice at OOC that the Executive Director 
approves the General Counsel's hiring recommendations.

[End of figure]

The five-member Board of Directors has the duty of administering 
appeals for the CAA's dispute resolution process. Employees or 
employers covered by the CAA who are dissatisfied with the final 
decision resulting from a dispute resolution process hearing may 
request that the Board review the decision. From 1996 through 2003, the 
Board has heard 20 appeal cases. The Board is also responsible for 
appeals of decisions by hearing officers with respect to complaints 
filed by the General Counsel regarding occupational safety and health 
issues, disability access concerns, and labor-management relations 
violations.

The CAA also assigns the Board the duties of developing and issuing 
regulations to implement the rights and protections of employees for 9 
of the 12 laws included in the CAA. The Board has issued regulations, 
which were approved by the Congress, for the Family and Medical Leave 
Act, federal labor-management relations provisions found in Chapter 71 
of title 5 U.S. Code, the Fair Labor Standards Act, and Worker 
Adjustment and Re-Training Act. The CAA also provides that OOC may 
apply existing regulations promulgated by executive branch agencies for 
regulations not issued by the Board, except for regulations regarding 
labor-management relations. Before the Board's adopted regulations can 
become effective, they must first be placed in the Congressional Record 
for a comment period and must subsequently be approved by the Congress. 
The Board has delegated much of the work to complete these duties to 
OOC's Executive Director.

The Executive Director has overall responsibility for managing OOC's 
education and dispute resolution processes as well as directing OOC's 
staffing and budgeting functions. Reporting directly to the Executive 
Director are two deputies, to whom the Executive Director has delegated 
specific functional roles in addition to those identified in the CAA: 
the Deputy Executive Director for the House is responsible for managing 
OOC's education and information distribution functions, and the Deputy 
Executive Director for the Senate is responsible for administering 
OOC's dispute resolution process.

The OOC General Counsel's duties include investigation and enforcement 
of the Occupational Safety and Health Act and ADA requirements and 
managing labor-management relations unfair labor practice case 
processing and court litigation. Assisting the General Counsel is an 
attorney and an inspector detailed from the Department of Labor to 
investigate and enforce occupational safety and health standards with 
the assistance of part-time contractors on a limited basis.

In summary, OOC's organizational structure has a leadership hierarchy 
with different top leadership functions shared among the Board of 
Directors, Executive Director, and General Counsel. This organizational 
structure of shared functions is largely due to statutory requirements 
that OOC carry out a variety of different roles--including 
adjudication, education, and enforcement--as it applies the 12 
workplace laws covered by the CAA. In order to provide for a degree of 
needed independence between these different functions, the CAA 
established an organizational structure that, among other things, gave 
the Board the responsibility for hearing appeals of the dispute 
resolution process for cases that are initially within the province of 
the Executive Director or General Counsel.

While the CAA gives the Board of Directors the authority to appoint and 
remove OOC's four senior executives--the Executive Director, General 
Counsel, and two Deputy Executive Directors--the Board does not play an 
active role in the daily operational management of OOC. Instead, OOC's 
part-time Board focuses on its adjudicatory and policy functions 
including hearing appeals and issuing regulations. Although the CAA 
designates OOC's Executive Director as the organization's chief 
operating officer, the law provides the General Counsel with 
independent authority to investigate and enforce matters concerning 
occupational safety and health, disability access, and labor-management 
relations. In practice, this has resulted in a division of OOC by 
function, with the Executive Director responsible for hiring and 
managing staff to carry out the education and dispute resolution 
process functions and the General Counsel responsible for hiring 
attorneys and managing staff in his operational areas.

OOC is staffed by 15 employees, including 4 in statutorily appointed 
positions. As figure 2 shows, OOC's annual expenditures have ranged 
from a high of $2.15 million in fiscal year 1997 to a low of $1.80 
million in fiscal year 2001. Fiscal year 2003 expenditures were $2.02 
million. In general, these expenditures are allocated between the 
duties performed by the Executive Director, General Counsel, and Board 
of Directors. Over the past 7 fiscal years, functions that are the 
responsibility of the Executive Director have accounted for most of 
OOC's expenditures.

Figure 2: Expenditures for Fiscal Years 1997-2003 Covering OOC 
Functions under the Responsibility of the Board of Directors, Executive 
Director, and General Counsel: 

[See PDF for image]

[A] Executive Director: OOC's chief operating officer is responsible 
for all OOC functions except those specifically delegated to the 
General Counsel. These include OOC's education function and the 
administrative dispute resolution process as well as directing 
staffing and budget functions. The expenditures reported under this 
category also include officewide overhead costs such as information 
technology, utilities, and supplies.

[B] Office of General Counsel: Reports and manages compliance with 
occupational safety and health standards and disability access 
requirements, manages labor-management relations unfair labor practice 
case processing, court litigation, and obtains staff resources. The 
expenditures reported under the General Counsel do not reflect the 
salary of OOC's occupational safety and health inspector on long-term 
detail from the Department of Labor.

[C] Board of Directors: Hears appeals of the dispute resolution 
process, issues regulations and reports, and selects four statutory 
appointees to OOC management positions.

[End of figure]

OOC Has Effort Under Way to Sharpen Focus on Results: 

Since August 2003, the OOC Board, its senior leadership team, and OOC's 
employees have been exerting a concerted effort--consistent with our 
suggestions--to more fully define the fundamental results, or outcomes, 
that OOC seeks to achieve. OOC's operations and reporting have 
traditionally been activity or output focused (e.g., number of requests 
for mediation received, time within phases of the process, and number 
of occupational safety and health inspections conducted). Such 
information is important to managing OOC and to ensuring that its 
scarce resources are efficiently targeted. However, the current Board 
and OOC leadership have undertaken OOC's first strategic planning 
initiative in recognition that despite the real value from output 
information, such data do not address the more fundamental question of 
the effectiveness of OOC's efforts. That is, OOC's current planning 
effort is intended to help OOC and its congressional and other 
stakeholders ensure that OOC's activities and outputs are optimizing 
the Office's contribution to results, such as a safer and healthier 
workplace and one free from discrimination and other forms of conflict. 
Our discussions with OOC stakeholders across the Congress and 
legislative branch agencies confirmed the need for and importance of 
the current planning effort.

Effective management control requires that an organization establish 
its organizational objectives in the form of a set of defined mission, 
goals, and objectives. Furthermore, we found that leading organizations 
consistently strive to ensure that their day-to-day activities support 
their organizational missions and move them closer to accomplishing 
their strategic goals.[Footnote 4] Thus, OOC is not alone among 
organizations in seeking to answer critical questions about its overall 
effectiveness. Our assessments over the last decade of executive 
agencies' implementation of the Government Performance and Results Act 
(GPRA) have consistently found that executive agencies have struggled 
with shifting the focus of their management and accountability from 
outputs to results. At OOC's invitation, we have met with OOC's 
leadership to share our wealth of information and perspective on 
executive agencies' efforts under GPRA, as well as our own experiences 
in strategic planning, performance planning, and accountability 
reporting at GAO. While maintaining our respective institutional 
independence, we are prepared to offer OOC continuing support as its 
planning efforts proceed.

OOC's planning initiative is important to ensuring that OOC's programs, 
activities, and limited resources are contributing to results that are 
making improvements in the work and work environments of legislative 
branch employees. OOC's efforts to achieve this goal are complicated by 
the inevitable tension that arises between organizations charged with 
the duty to implement and enforce regulations and the agencies subject 
to those regulations. Under the current draft of its strategic plan, 
OOC defines its mission as working to "advance safety, health, and 
workplace rights for employees and employers of the Legislative Branch 
as mandated by the Congressional Accountability Act." OOC is developing 
strategic objectives (goals) in three areas: effectively enforce and 
administer the CAA; educate, collaborate, and facilitate the regulated 
community; and maintain an efficient and accountable workplace (within 
OOC). More specifically: 

* Effectively enforce and administer the CAA: Regulatory enforcement 
and administration focuses on operation of dispute resolution 
procedures and investigation and prosecution of alleged violations.

* Educate, collaborate, and facilitate for our regulated community: The 
Office will encourage and facilitate positive change in the employment 
cultures within the regulated community to stimulate compliance with 
the entire CAA; and effectively communicate with the Congress regarding 
the status quo and potential enhancement of the CAA.

* Maintain an efficient and accountable workplace: Efficiency involves 
not only careful and wise use of appropriated funds, but also continued 
utilization of resources in a way that allows for timely and 
expeditious completion of office activities and functions in order to 
better serve our regulated community.

OOC's effort to develop a results-oriented strategic plan is an 
important and positive development that is still very much a work in 
progress--as the Board and OOC's senior leadership clearly appreciate. 
Perhaps most important is OOC's recognition that its planning effort 
provides a vehicle for engaging and consulting with key congressional 
and other stakeholders on the fundamental purposes of OOC (strategic 
goals), how those purposes will be achieved (programs and strategies), 
how progress will be assessed (performance measures), and what progress 
is being made and improvement opportunities exist (accountability 
reporting). More specifically, as OOC's draft plan and our discussions 
with the Board and OOC's leadership have confirmed, OOC is committed to 
an approach that meets its statutory responsibility by adopting a more 
cooperative and collegial approach with legislative branch offices and 
agencies, while at the same time maintaining its enforcement capability 
and safeguarding its institutional independence. The planning effort 
underway provides the opportunity to reach agreement with key 
congressional and other stakeholders on the direction--and potential 
limits--of this new commitment.

OOC has held a series of discussions with selected congressional 
stakeholders and plans additional outreach with them and other 
stakeholders as the planning effort moves forward. In fact, as we have 
found by looking at leading results-oriented organizations, the 
production of the actual strategic planning document is one of the 
least important parts of the planning process. Leading results-oriented 
organizations understand that strategic planning is not a static or 
occasional event, but rather a dynamic and inclusive process. By 
working with and actively engaging key congressional and other 
stakeholders in its planning effort, OOC can better justify to 
stakeholders its current budget and staff resources allocation and 
program efforts then, as appropriate, OOC can build a business case for 
additional resources and new initiatives that OOC leadership may 
believe are necessary for an agreed-upon mission and set of strategic 
goals.

In short, if done well, strategic planning is continuous and provides 
the basis for everything that the organization does each day. Moving 
forward, OOC plans to align key programs and strategies with each of 
these objectives. In that regard, OOC managers have begun drafting 
several work plans intended to link OOC's programs and activities to 
the strategic objectives contained in the draft plan. Similar to the 
strategic plan, these work plans are still in draft and therefore do 
not yet provide a clear linkage between OOC's strategic objectives and 
the day-to-day operations of these functions.

OOC's strategic planning also needs to include the development of 
results-oriented performance measures. OOC is committed to this effort 
and has "place-markers" in its draft plan for these measures. OOC could 
benefit from considering the experiences of leading organization in 
results-oriented performance measurement. Results-oriented 
organizations we have studied, which were successful in measuring their 
performance, developed measures that were: 

* tied to program goals and demonstrated the degree to which the 
desired results were achieved,

* limited to the vital few that were considered essential to producing 
data for decision making,

* responsive to multiple priorities, and: 

* responsibility-linked to establish accountability for 
results.[Footnote 5]

Similar to decisions about strategic goals, determining the appropriate 
set of performance measures should also be based on input from key 
stakeholders to determine what is important to them to determine OOC's 
progress and assess its performance. Put most directly, agreed-upon 
performance measures are the key to providing the Congress with the 
data it needs to answer a key question that the current fiscal 
environment is demanding of all agencies across the federal government: 
"What are we getting for our investment in this agency, and is it worth 
it?": 

OOC Is Beginning to Integrate Information Technology Planning into its 
Strategic Plan: 

OOC officials said that they are committed to making better use of IT 
in the future, and to ensuring that doing so is accomplished in a 
prudent and systematic fashion. For example, OOC's draft strategic plan 
cites "fully leveraging IT to complement and expand office activities" 
as one strategy under its "maintain an efficient and accountable 
workplace" goal.

OOC has begun to take some action, but much remains to be accomplished. 
For example, it established an Information Technology Task Force in May 
2003, and consistent with our suggestions to OOC leadership, the task 
force has been charged with developing parallel IT strategies: one 
addressing near-term, stay-in-business IT needs and the other 
addressing long-term IT modernization needs. Thus far, the task force 
has met numerous times and has been guided in this initiative by a 
private consultant. It has also, for example, reviewed the current IT 
environment and has surveyed OOC staff about IT needs and preferences.

With respect to near-term needs, OOC is taking steps to address 
immediate shortfalls in its ability to produce the information it needs 
to manage current operations and workloads. For example, OOC is 
investing a few weeks of staff time to create a new Access database to 
provide a temporary solution to meet certain case-tracking information 
needs. In our view, such relatively small, low-risk investments that 
provide immediate mission value are appropriate near-term steps.

However, before pursuing strategic, modernized system solutions, it is 
important that OOC first position itself for successfully doing so by 
establishing certain basic IT management capabilities. These 
capabilities include, among other things, developing a picture or 
description, based on OOC's strategic plan, of what it wants its future 
IT environment to look like, putting in place and following defined and 
disciplined processes for allocating limited resources across competing 
IT investment options, employing explicit and rigorous IT system 
acquisition management processes, and ensuring that needed IT human 
capital knowledge and skill needs and shortfalls are identified and 
systematically addressed. According to OOC officials, each of these 
areas will be addressed. If they are not, the risk of being unable to 
effectively leverage technology in achieving strategic mission goals 
and outcomes will be increased.

OOC's current use of IT is limited. For example, OOC's automated 
dispute resolution case tracking system does not have the capability to 
notify system users when a case closes or should be closed. OOC's 
system manager said they must periodically review some cases manually 
and update the system for closed cases. OOC officials told us that they 
had experienced some data quality problems during early implementation 
stages of the dispute resolution case tracking system, but had tested 
the system in March 2003 to determine if corrective actions were 
effective. According to OOC officials, the data accuracy test 
demonstrated that the information was now reliable, although they said 
the test was performed informally and they had no documentation on the 
methodology and the test results. We performed our own independent test 
of data quality for this system as part of this review and found that 
the data were sufficiently reliable for the purposes of this report. 
(See app. I for additional information on our reliability and validity 
reviews of OOC's database.): 

OOC also recognizes the need to make better use of IT when enforcing 
the Occupational Safety and Health Act-related provisions of the CAA. 
For example, OOC's Office of the General Counsel is considering the 
purchase of specialized IT software that would centralize and automate 
a variety of tasks concerning the occupational safety and health-
related cases it handles, including assessing risk, monitoring case 
status, and tracking agency abatement efforts. In November 2003, after 
meeting with us to discuss best practices in IT acquisition and 
planning, OOC's General Counsel established a group to develop specific 
selection criteria to assess potential IT case management software. As 
part of this process, the group and an outside IT consultant gathered 
information from both legislative and executive branch agencies 
including the Architect of the Capitol (AOC), LOC, and the Occupational 
Safety and Health Administration (OSHA) concerning their practices and 
experiences with similar IT applications. OOC expects to complete this 
evaluation process by the end of March 2004.

In regards to the accounting and budgeting system used by OOC, a 2003 
audit by an independent accounting firm of LOC's financial statements 
found that the system was reliable. LOC administers the accounting and 
budgeting system and the accounting firm's findings were addressed to 
LOC. Although the auditors reported the system was, overall, reliable, 
they also reported that there were two IT-related deficiencies that 
could adversely affect the user's ability to meet its financial 
management objectives. The deficiencies were that (1) security 
practices over IT systems need to be improved and (2) LOC needs to 
establish a comprehensive disaster recovery program to maintain service 
continuity, minimize the risk of unplanned interruptions, and recover 
critical operations should interruptions occur. The audit recommended 
that the LOC address these deficiencies as a high priority. LOC 
officials acknowledged the need to address these deficiencies and have 
taken some preliminary actions including drafting an officewide policy 
on IT security practices and acquiring an off-site facility for their 
disaster recovery program.

Strategic Planning Provides Opportunity for More Useful Annual Reports: 

As required by section 301(h) of the CAA, OOC issues an annual report 
that contains "statistics on the use of the Office by covered 
employees, including the number and type of contacts made with the 
Office, on the reason for such contacts, on the number of covered 
employees who initiated proceedings with the Office under this Act and 
the result of such proceedings, and on the number of covered employees 
who filed a complaint, the basis for the complaint, and the action 
taken on the complaint.": 

Based on our reviews of the reports issued thus far, OOC is meeting 
this annual report requirement. However, the information is almost 
entirely output based, providing little sense of OOC's broader impact. 
Most of OOC's congressional stakeholders with whom we spoke were not 
familiar with OOC's annual reports and those congressional stakeholders 
who had seen the report said that it was difficult to understand and 
could be more user-friendly. For example, one congressional stakeholder 
said that it was difficult to make decisions about OOC using the 
information contained in the annual report.

As an outgrowth of its strategic planning effort to identify, measure, 
and manage toward results, OOC can enhance its annual report and 
incorporate elements that would make it a more useful and relied-upon 
accountability report. New, results-oriented information, showing the 
extent to which goals were met and suggesting improvement 
opportunities--including those that may suggest the need for 
congressional concurrence or actions--could be reported along with the 
activity and workload statistics required in section 301(h) of the CAA.

Recommended Next Steps: 

Building on the strategic planning efforts underway, we recommend that 
the Board of Directors, Executive Director, and General Counsel of OOC 
ensure that the planning effort: 

* Is developed with extensive collaboration and input from key 
congressional and agency stakeholders to ensure that there is a 
reasonable and appropriate degree of agreement concerning OOC's overall 
direction and that its programs are effectively coordinated with other 
efforts. To be most effective, this stakeholder and agency input should 
be part of an ongoing dialogue to ensure goals, objectives, and 
strategies are adjusted as warranted.

* Includes performance measures that are linked to the strategic plan 
and resulting annual work plans.

* Becomes the basis for OOC's budget and staff requests and developing 
and implementing program efforts and for assessing the contributions of 
those efforts to results.

* Makes information technology planning and implementation an integral 
component of the process.

* Is used as a basis for an augmented and more results-oriented annual 
report that provides data on the degree to which key goals are being 
achieved, in addition to meeting important statutory reporting 
requirements.

Ensuring an Effective Program Structure: 

Our work looking at leading organizations has often found that as 
organizations shift their orientation from outputs and activities to 
the results that those outputs and activities are intended to achieve, 
new, different, and more effective ways of doing business will 
emerge.[Footnote 6] OOC is in the midst of just such a shift in its 
orientation as was discussed earlier in this report. This shift entails 
putting in place a program structure at OOC that meets its statutory 
responsibilities, contributes to improvement in the working environment 
and workplaces of legislative branch employees, and safeguards OOC's 
independence.

OOC's Functions and Workload: 

The CAA contains a series of specific requirements for OOC to meet as 
it carries out its responsibility to administer and enforce the CAA. 
Towards this end, OOC has taken a number of actions including 
establishing and administering a dispute resolution process for 
employees who allege violations of civil rights, labor, and employment 
laws covered by the CAA; conducting investigations and periodic 
inspections of legislative branch facilities to ensure compliance with 
safety, health, and disability access standards; adopting substantive 
regulations, many of which have been approved by the Congress, to apply 
covered laws to the legislative branch; educating both employees and 
employing offices about their rights and responsibilities under the 
law; and regularly reporting to the Congress on its activities in a 
variety of required reports and studies.

Dispute Resolution: 

Dispute resolution is the largest of the functions performed by OOC, 
available to any legislative branch employee in an agency covered under 
the CAA's dispute resolution provisions who alleges violations of 
certain sections of the CAA. OOC's dispute resolution process consists 
of a series of statutorily prescribed steps beginning with counseling 
and mediation. If these actions fail to resolve the dispute, the 
employee may choose to either file a formal complaint with OOC and 
proceed with an administrative hearing before an independent hearing 
officer, or file suit in federal court. Both employees and covered 
legislative agencies that are dissatisfied with the decisions of their 
administrative hearings may appeal to OOC's Board of Directors.

Figure 3: Dispute Resolution Cases, by Stage, Reported by OOC for 1996-
2003: 

[See PDF for image]

[A] Data for 1996 covers January 23-December 31.

[B] Data for 2003 covers January 1-December 9.

Note: The number of cases closed in a given year may not equal the 
total number of cases identified in each of the other categories for 
that year because of other factors including cases carried over from 
previous years.

[End of figure]

OOC told us that the large jumps in the number of cases in the dispute 
resolution system in 1999, 2000, and 2001, were the result of two 
single-issue large group requests involving employees from AOC and the 
United States Capitol Police (USCP) as they worked their way through 
the process. For example, 274 (or almost 70 percent) of the 395 
requests for counseling reported in 2001 pertained to a single USCP 
large group case. Similarly, 272 of the cases that were closed that 
same year and were reported as resulting in civil actions being filed 
with the district court were also associated with this same single-
issue group request. In fact, OOC cites the absence of such group cases 
in its annual report to the Congress on the use of the Office when 
describing the significant decrease in total requests for counseling 
received in 2002.

These cases illustrate that OOC's approach to reporting case activity 
does not provide a complete picture of OOC's workload since it reports 
each individual included as part of the large group as an individual 
request regardless of whether the individual personally requested or 
even participated in services such as counseling or mediation. OOC 
could not provide us with a specific number of the individuals included 
in these group requests who actually received counseling or mediation 
services in 1999 or 2001. According to OOC, dispute resolution data is 
presented in this manner because the CAA specifically requires the 
Office to report on the total number of individuals requesting 
counseling or mediation. While this information is needed to meet 
existing statutory reporting requirements, other data, such as the 
actual number of counseling and mediation sessions held, could provide 
a helpful complement to the data which OOC currently reports, as well 
as a more useful indicator of its actual workload.

In addition to rethinking how it might supplement the way it currently 
reports on single-issue large group requests, OOC should consider other 
potential improvements on how it measures its activities and workload. 
Such improvements can play an important role in helping organizations 
both obtain a fuller understanding of the process and implications of 
its activities as well as provide stakeholders with more transparent 
and complete information. OOC is exploring options in this area and we 
have offered our assistance in this regard. One possibility would be 
for OOC to benchmark its data against that reported by other federal 
agencies, when comparable measures exist, or against OOC's own past 
performance when such measures do not. For example, following the 
practice of the U.S. Equal Employment Opportunity Commission (EEOC), 
OOC might consider using such benchmarks to set both long-and short-
term performance targets.

Occupational Safety and Health, Disability Access, and Labor-Management 
Relations: 

The CAA assigns OOC's General Counsel with a number of independent 
investigative and enforcement functions related to ensuring 
occupational health and safety, disability access, and labor-management 
relations.

Occupational safety and health. Enforcement of occupational safety and 
health standards accounts for the majority of the time spent by the 
General Counsel and his staff, and roughly 30 percent of OOC's overall 
workload. The CAA requires the General Counsel to perform this work in 
two basic ways: (1) by conducting inspections and investigations of 
potential hazards in response to requests by any covered employee or 
employing office and (2) by performing periodic inspections of the 
facilities of all entities covered by the act.

Figure 4: Health and Safety Cases Reported by OOC for 1997-2003: 

[See PDF for image]

[A] Data for 2003 covers January 1-December 9.

[End of figure]

Any covered legislative branch employee can file a complaint requesting 
the General Counsel inspect and investigate a possible health and 
safety hazard. As shown in figure 4, the annual workload of requested 
inspections has risen dramatically since 2000, from 14 in 2000 to 39 in 
2003 (as of December 9, 2003). The General Counsel's resources, 
however, have not kept pace with this growth. The General Counsel's 
financial expenditures increased by less than 5 percent from fiscal 
year 2000 to fiscal year 2003. In addition, during this same period the 
number of full-time staff assigned to conduct the actual workplace 
health and safety investigations remained steady at a single 
individual, an OSHA workplace safety specialist assigned to OOC from 
the Department of Labor on long-term detail, with the assistance of 
part-time contractors on a limited basis.

OOC also enforces health and safety regulations by conducting periodic 
inspections of the facilities of all covered entities at least once 
each Congress, as required by the CAA. These inspections are scheduled 
ahead of time with legislative agencies and resemble the "walk around" 
inspections conducted by OSHA. In contrast to most other CAA 
requirements, OOC is not fully in compliance with the CAA requirement 
that it "conduct periodic inspections of all facilities" of the 
agencies covered by the provision.[Footnote 7] Although OOC conducted 
periodic inspections at the majority of facilities in the Washington, 
D.C. area including large structures such as all Senate and House 
office buildings and the U.S. Capitol building, OOC did not include 10 
out of 46 facilities subject to its jurisdiction in its last biennial 
inspection in 2002. For example, according to documents provided by 
OOC, the Office did not perform safety and health inspections at the 
Senate or House page dormitories, or at LOC's National Library Service 
for the Blind and Physically Handicapped. OOC officials told us that 
the decision not to inspect these facilities was largely due to 
resource constraints.

Disability access. The CAA requires the General Counsel to both conduct 
investigations of charges alleging discrimination in public services 
and accommodations on the basis of disability, and to inspect covered 
facilities in the legislative branch at least once each Congress for 
compliance with the public services and accommodations provisions in 
the ADA. From 1997 through December 9, 2003, five charges of 
discrimination have been filed with the General Counsel. According to 
OOC documents, its biennial inspections have included all public areas 
where constituents, individuals on official business, and visitors have 
access--approximately 8 million square feet of space.

Labor-management relations. Under the CAA, OOC's General Counsel is 
responsible for investigating charges of unfair labor practices and for 
filing and prosecuting complaints in administrative hearings and before 
the Board of Directors as appropriate. Since 2001, the number of 
charges filed with the General Counsel has remained fairly constant, 
varying between 18 and 19 per year, as shown in figure 5. In 2000, OOC 
experienced a sharp spike in charges filed with the number jumping to 
38 in that year. OOC was unable to provide a definitive reason for this 
increase, but told us that it was probably related to the large group 
cases going through OOC's dispute resolution process as these cases 
raised issues that could relate to charges of unfair labor practices. 
Despite the relatively stable number of new unfair labor practice 
charges received by OOC since 2001, the backlog of cases still pending 
at the end of the year has almost doubled, increasing from 6 in 2001 to 
11 in 2003 (as of December 9, 2003).

Figure 5: Unfair Labor Practice Charges Filed Reported by OOC for 1997-
2003: 

[See PDF for image]

[A] Data for 2003 covers January 1-December 9.

[End of figure]

OOC's Executive Director is responsible for a variety of other 
functions relating to labor-management relations including supervising 
union elections and resolving issues involving such matters as good 
faith bargaining. OOC has supervised 14 union elections since 1997, 12 
of these in 2000 or earlier.

Another duty of the General Counsel under the CAA is to represent OOC 
in any judicial proceeding under the act, including cases before the 
U.S. Court of Appeals for the Federal Circuit.[Footnote 8] In past 
years, the number of such cases has been low, with no cases filed in 
1997, 2001, and 2002 and one case each filed in 1998, 1999, and 2000. 
However, in 2003 the number of federal circuit review cases involving 
OOC and requiring attention from the General Counsel and his staff 
unexpectedly increased to six. OOC's General Counsel told us that this 
situation has been exacerbated by the loss of two attorneys during 
2003, reducing his previous staffing level of four full-time OOC 
attorneys to only two, including the General Counsel, by December 2003. 
According to the General Counsel, his office is currently recruiting 
for a staff attorney and he expects to have that individual hired by 
spring of 2004.

Education and Information Distribution: 

OOC has a broad mandate under the CAA to provide education and 
information to the Congress, employing offices, and legislative branch 
employees about their rights, protections, and responsibilities under 
the act. To this end, OOC uses a variety of approaches including 
distributing written material such as home mailings, fliers, bulletins, 
fact sheets, and reports; conducting briefings with new staff at 
agency-sponsored orientation sessions; holding seminars at the offices 
of stakeholders and legislative agencies; maintaining a Web site and 
information number; and responding to direct inquires. More recently, 
OOC's education efforts have made increased use of technology including 
a redesign of its Web site to make it more user friendly and increased 
use of resources such as electronic news bulletins and online tools 
such as its interactive template for creating an emergency action plan.

Despite such potentially promising initiatives, OOC's current approach 
to tracking and reporting on its education efforts--its Education 
Program Year End Report--remains firmly focused on counting products 
and activities rather than focusing on results. Other approaches such 
as conducting feedback surveys and focus groups could provide OOC with 
valuable mechanisms to increase its understanding of the actual level 
of awareness specific target populations have of its programs and 
activities. OOC can then use this knowledge to assess its effectiveness 
in actually communicating its message rather than simply its diligence 
in distributing documents.

Developing appropriate performance measures has the potential to help 
OOC realize several significant benefits such as improving its ability 
to understand and track its process toward achieving goals, giving 
managers crucial information on which to base their organizational and 
management decisions, and creating powerful incentives to influence 
organizational and individual behavior. Of course, the benefits of such 
improvements will need to be balanced against real-world 
considerations, such as the cost and effort involved in gathering and 
analyzing performance data, and the burden such data collection may 
present for stakeholders and covered employees.

Opportunities to Strengthen OOC's Effectiveness by Ensuring Programs 
Are Aligned with Results: 

We have previously reported that as agencies develop information 
systems and capacities for analysis and evaluation, they discover that 
having a better understanding of the facts and the relationship between 
their activities and desired outcomes provides them with a solid 
foundation for focusing their efforts and improving their 
performance.[Footnote 9] Facing an increasing workload and scarce 
resources, OOC's leadership has begun the process of asking these 
questions in an effort to find more effective ways in which to do their 
work.

OOC's senior leadership has expressed a willingness to explore 
opportunities to develop the technical and analytical capacity needed 
to more effectively work toward results. For example, over the last 
several years OOC has used a variety of methods for tracking and 
recording summary information on its occupational safety and health 
related caseload in order to manage its work in this area. These 
systems were generally basic in design and ranged from several 
incompatibly designed databases to using simple tables in a word 
processor to keep track of cases.

None of these approaches provided the General Counsel and his staff 
with an easy way to systematically examine the approximately 50 open 
requests for health and safety investigations, or the hundreds of 
inspections and investigations conducted by OOC in the past, to look 
for patterns and identify possible common or underlying causes of 
potential workplace hazards. Toward this end, OOC is exploring the 
possibility of acquiring a specialized regulatory case-tracking 
database application that would enable the General Counsel and his 
staff to take a more strategic and risk-based approach towards their 
work, including such decisions as assigning cases, determining the 
appropriate amount of follow-up required, and informing the selection 
of particular facilities for its biennial inspections. Until OOC 
decides on whether, and which, permanent case-tracking software system 
it may adopt, staff in the General Counsel's office have been 
developing a new Microsoft Access database intended to offer a short-
term solution to OOC's need to more effectively track basic information 
related to its occupational safety and health related caseload, such as 
case type, key dates, principal parties involved, and actions planned 
and accomplished. According to the General Counsel, this system should 
be operational in January 2004.

Ensuring that an organization is focusing on the right activities to 
effectively achieve its goals is always an important part of good 
management control. However, focusing on the right activities is 
especially important in times of economic scarcity, when the benefit of 
having programs that deliver a maximum impact towards achieving results 
is particularly critical. For example, in light of increasing demands 
for safety and health inspections, and the very small number of OOC 
staff available to conduct those inspections, OOC's General Counsel and 
his staff have begun to explore possible approaches to leverage OOC's 
limited resources through constructive engagement with legislative 
agencies. This approach seeks to obtain agency compliance with 
occupational safety and health requirements by motivating them to do so 
out of a sense of common purpose and mutual benefit rather than forcing 
them with the threat of punitive citations.

Toward this end, in February 2004 OOC will sponsor its first-ever 
Organizational Health and Safety Program Conference. The conference 
will bring together congressional and agency staff involved in health 
and safety issues from throughout the legislative branch in order to 
learn about recent thinking and practice in workplace health and safety 
and to discuss issues of mutual concern. The conference will include 
presentations by outside safety experts from a variety of organizations 
from the legislative branch and elsewhere. Tentatively scheduled 
presenters include representatives from AOC, organized labor, OSHA, and 
the National Safety Council.

The recent experiences of AOC provide another example of the potential 
benefits of sharing lessons learned concerning health and safety 
practices. AOC is undertaking a major effort to augment and make more 
strategic its approach to worker safety and health.[Footnote 10] This 
effort obviously has important implications for AOC and its employees. 
Equally important, by sharing AOC's experiences and leveraging its 
efforts in such areas as incident reporting and follow-up and risk 
mitigation, AOC's efforts can potentially have great value across 
legislative branch agencies. Building on this idea, OOC should explore 
the possibility of playing a more active role as a central repository 
for good practices developed by agencies throughout the legislative 
branch on topics covered under the CAA.

OOC's recent experience with USCP to offer fire safety training for its 
officers provides a lesson in the importance of carefully targeting 
such initiatives to the intended audience. The impact of OOC's 
initiative may be somewhat limited until OOC develops a deeper 
understanding of what would make this type of supplemental training 
useful in the view of USCP's management and officers. Specifically, a 
senior USCP official who was directly aware of this effort informed us 
that although the training contained some good material, it was not 
sufficiently tailored to USCP to be very useful.

The value of thinking about outcomes and the relationship between 
activities and outcomes can also help OOC make determinations about 
whether it is providing the right mix of services and activities to 
achieve its overall goals. For example, until recently OOC's education 
efforts have been largely focused on activities such as sending mass 
mailings of written material to the homes of legislative branch 
employees, distributing fliers and bulletins to legislative agencies 
for subsequent distribution, and conducting general information 
sessions for new employees. Moreover, OOC's education efforts would 
benefit from better analysis of the types of complaints that have been 
made. As noted above, OOC tracks the number of cases it handles and how 
they proceed through established processes. It does not, however, 
currently gather data on the nature of complaints. While protecting the 
confidentiality of OOC's case files must continue to be of primary 
concern, OOC could also seek ways to examine if common issues are being 
raised. Such information could prove very valuable in targeting OOC's 
education efforts.

In addition, OOC's current leadership team recognizes the importance of 
looking for new ways to get information about the CAA and OOC out to 
employees. They are also experimenting with new approaches such as 
posting e-bulletins and other ways to use the Internet creatively. On 
the basis of our work, ample opportunities exist for continued progress 
in this area. For example, in our conversations with congressional 
stakeholders, representatives from the Senate Administrative Office 
Managers-Chief Clerks Steering Committee told us that they would 
welcome additional contact with OOC. These Senate office managers and 
Chief Clerks are senior staff responsible for working with Members to 
ensure the efficient and effective operation of each member's personal 
office. As such, office managers are key clients of OOC. Office 
managers meet periodically to discuss issues of mutual interest and 
concern--an ideal opportunity for OOC outreach. However, 
representatives from the Senate Administrative Office Managers Group 
told us that they had not had contact with OOC for several years. OOC 
should consider whether there are similar groups that it might reach 
out to as part of its effort to establish consistent and ongoing 
relationships with its clients.

Recommended Next Steps: 

We recommend that OOC's Executive Director and General Counsel: 

* identify potential improvements to how the Office measures its 
activities and performance, including the possibility of using 
benchmark data from federal agencies with similar functions for 
purposes of comparison and analysis;

* provide a more complete picture of OOC's workload by improving how it 
tracks and reports on single-issue large group requests for counseling 
and mediation;

* work with the Congress to develop a strategy to ensure that all 
facilities under OOC's jurisdiction and located in the Capitol Hill 
complex and the surrounding Washington, D.C. area--including the Senate 
and House page dormitories, and LOC's National Library Service for the 
Blind and Physically Handicapped--are covered as part of the biennial 
safety inspections required by the CAA;

* establish a clearinghouse for sharing best practice information on 
topics covered by the CAA;

* work with the Congress to determine the feasibility of using such 
mechanisms as feedback surveys and focus groups to provide valuable 
information on the actual level of awareness among target populations 
concerning OOC's programs and activities;

* outreach to other groups and forums such as the Senate Administrative 
Managers-Chief Clerks Steering Committee;

* use data on the number and type of complaints received by OOC to 
better target education and information distribution efforts; and: 

* develop capacity to use safety and health data to facilitate risk-
based decision making.

Building Effective Communication Emphasizing Outreach and 
Coordination: 

Effective communication and coordination with both stakeholders and 
clients is essential for organizations to operate effectively, manage 
risks, and achieve results. We have previously identified the ability 
of federal agencies to engage in relevant, reliable, and timely 
communication relating to internal and external events as fundamental 
for effective management control.[Footnote 11] At OOC, an effective 
communications strategy could provide a powerful tool to seek mutual 
understanding among OOC, key stakeholders, and legislative agencies 
concerning its mission and role, convey OOC's recent initiatives and 
improvement efforts, obtain information about the external environment 
that may affect the Office's ability to achieve its mission, as well as 
build up trust among the stakeholders and clients that is necessary for 
the Office to realize its goal of becoming more collaborative and 
partnerial.

OOC has recently undertaken a number of important initiatives to 
improve communications and coordination. Consistent with, and building 
upon those initiatives, we identified two specific areas where OOC can 
continue to make improvements in the way in which it communicates with 
other entities and organizations including: 

* ensuring clear, regular, and timely consultation with congressional 
stakeholders; and: 

* communicating and coordinating with agencies openly and effectively.

Ensuring Clear, Regular, and Timely Consultation with Congressional 
Stakeholders: 

A key component of an effective communications strategy is 
communicating with, and obtaining information from, external 
stakeholders.[Footnote 12] OOC's leaders recognize the importance of 
communicating with stakeholders and have taken steps to expand their 
efforts in this area. However, our interviews with a wide range of 
congressional stakeholders, including majority and minority staff in 
both the Senate and the House, indicate that OOC's efforts to 
effectively consult with the Congress have been uneven and additional 
efforts are needed.

On the one hand, some congressional staff--but by no means all--told us 
that they believed OOC has made efforts to develop more transparent and 
collegial working relationships with congressional stakeholders. For 
example, a congressional staff member cited the efforts of OOC's 
General Counsel to reach out to congressional staff shortly after he 
joined the Office in May 2003. Another staff member cited an example 
where OOC worked constructively with his office to resolve a potential 
fire safety problem involving the placement of furniture. This staff 
member appreciated OOC's willingness to discuss the issue with his 
office and work to find a satisfactory solution that would both comply 
with safety requirements and take into account the need of his office 
to continue to conduct business and the physical limitations of the 
space involved.

On the other hand, a number of staff, including some who acknowledged 
and appreciated OOC's recent efforts, said that they remained unclear 
about the office's role and services, how it makes decisions, and 
related matters. Moreover, several congressional staff members told us 
that they have not seen much outreach from OOC, or that the outreach 
they did experience was inconsistent and could be more effective. For 
example, one individual told us that he only received information from 
OOC when it was interested in proposing a legislative change that would 
require the cooperation of the Congress. Another concern cited by 
several staff was the perception that OOC did not make an effort to 
ensure that they were informed "at the front end" concerning 
significant activities and initiatives. Thus, the concern is not so 
much the existence of OOC's operating procedures. Rather, the concern 
is communication as those procedures are being applied and OOC 
undertakes its daily operations.

Effective communications strategies take into account how to most 
effectively communicate the message given their intended audience. For 
example, in September 2003 OOC initiated a formal rulemaking process to 
amend parts of its operating procedures. As required by the CAA, OOC's 
Board of Directors submitted an announcement for inclusion in the 
Congressional Record announcing proposed changes in OOC's procedural 
rules and inviting comment. A key staff member said that it would have 
been more helpful--and could have avoided, or at least limited, 
subsequent concerns with the process used to issue the draft rules--if 
OOC had more fully reached out to key committees and Members before the 
draft proposal was announced publicly. Another staff member told us 
that, at a minimum, it would have been helpful if OOC followed the 
notice by contacting them directly to ensure that they were aware of 
the proposed rules and the subsequent 30-day comment period, explaining 
that such announcements are easy to miss if one is not looking for 
them. Although OOC's initial posting met its legal obligations, the 
Office decided to place another notice and extend the comment period.

To encourage additional feedback from stakeholders and other interested 
parties, OOC's Board decided to hold a public hearing on the proposed 
changes even though the CAA does not require it. According to OOC, the 
decision to hold the hearing was consistent with feedback OOC had 
received several years earlier from some congressional stakeholders. 
However, instead of creating an opportunity for stakeholders to provide 
additional feedback, the Board had to cancel the session because only 
one person had agreed to speak at the hearing. Congressional staff told 
us that the Congress' lack of participation in the hearing was not an 
indication of a lack of interest in the issues to be discussed, but was 
due to concerns about the nature and structure of the forum. OOC had 
not informed congressional staff of its intention to seek additional 
comment in this way. Moreover, one congressional stakeholder said that 
OOC's approach to solicit additional comments through a public hearing 
was inappropriate.

Communication protocols provide a potentially valuable tool that 
organizations can use to avoid such surprises and help foster clearer 
understanding with stakeholders. For example, after working closely 
with the Congress and after a trial phase, GAO implemented 
congressional protocols in November 2000.[Footnote 13] From our 
experiences in developing the protocols, we have identified key lessons 
and success factors--that developing protocols is a time-consuming 
process which involves (1) personal commitment and direction from the 
agency head, (2) senior management participation and buy-in, and (3) 
continuous outreach to and feedback from external stakeholders. Despite 
the time and the effort, however, our experience using protocols as a 
transparent, documented, and consistent way to set priorities has been 
very positive for us as well as our congressional clients. Similarly, 
for OOC such protocols could help foster an understanding of its goals, 
functions, and procedures with its congressional stakeholders.

Communicating and Coordinating with Agencies Openly and Effectively: 

Open and effective coordination with legislative agencies and other 
stakeholders including employee groups is another critical component of 
an effective communications strategy at OOC. We have previously 
reported that organizations can develop and refine their operations and 
better achieve results by establishing channels that facilitate open 
and effective communication with clients and other recipients of their 
services and activities.[Footnote 14]

Several officials at legislative branch agencies covered by the CAA 
told us that at points over the more than 8 years since OOC's has been 
in operation, communications and interactions among the Office and 
their agencies have not been good. These agency officials told us that 
some of OOC's past actions had created distrust and had fostered the 
belief among some staff that OOC was more interested in making them 
look bad (by using a "gotcha" approach) rather than working with 
agencies to comply with the CAA and create a better workplace. In 
contrast, the union groups we met with generally characterized their 
interactions with OOC as positive throughout this period.

OOC's Board and leadership are aware of the concerns expressed by some 
legislative agencies and have taken steps to address them. As a result, 
officials we interviewed at these agencies generally agreed that over 
the last year or two, OOC has taken steps to improve the working 
relationships with their respective offices. These officials cited 
efforts by OOC's senior executives to reach out to them through a 
series of meetings held by the Executive Director and General Counsel 
as evidence of a new, more constructive attitude towards legislative 
agencies. For example, in the area of occupational safety and health 
enforcement, an AOC official told us that OOC's General Counsel had 
initiated several meetings with AOC to discuss possible initiatives to 
improve health and safety on Capitol Hill. Included in these 
discussions was AOC's recent decision to adopt an internal IT 
application to assist the agency in tracking and monitoring potential 
safety and health problems before complaints are made to OOC. According 
to both the AOC official and OOC's General Counsel, the two 
organizations have had preliminary discussions on the possibility of 
sharing such health and safety data, although they have yet to come to 
an agreement on whether or how to do so.

Despite some advances, our interviews with agency officials identified 
several areas where OOC needs to make improvements in how it 
communicates and coordinates with agencies covered by the CAA. Among 
the continuing problems officials mentioned were (1) OOC's failure to 
always follow its own rules and procedures when conducting 
investigations of health and safety complaints and (2) the lack of 
timely and consistent follow-up on the status and disposition of 
investigations conducted by the Office and clear communication with 
agency officials.

For example, several agency officials told us that OOC was not always 
consistent in the manner in which it conducts investigations of 
occupational safety and health-related complaints, occasionally 
failing to follow its own processes and procedures. The CAA gives OOC's 
General Counsel considerable authority to inspect and investigate 
places of employment under the jurisdiction of employing agencies 
covered by the CAA and does not require him to provide advance notice 
before starting an investigation or visiting buildings or 
facilities.[Footnote 15] However, to foster a constructive working 
relationship with the agencies they regulate, OOC's General Counsel and 
a staff member told us that it has been a long-standing policy of OOC 
to immediately notify the agency involved when the Office receives a 
safety and health-related complaint. In addition, except in cases of 
emergency or when any delay might pose a danger, it is also OOC's 
policy to give agencies the option of attending an opening conference 
before proceeding with the investigation. However, officials at two 
agencies told us that there have been cases, including some within the 
past year, where OOC has failed to follow its policy on agency 
notification. They said these instances have contributed to 
misunderstandings, confusion, and, in at least one case, the perception 
among senior agency officials "that a 'gotcha' mentality still exists 
at OOC." While OOC and the agency involved in this last case do not 
agree concerning the facts and significance of OOC's actions that led 
to this comment on the part of the agency, the situation provides an 
illustration of the differences that exist in perceptions between OOC 
and some agency officials.

In addition, agency officials told us that often OOC would not follow 
up with agency officials on the status and disposition of 
investigations in a timely or consistent manner. For example, agency 
officials told us of cases where, after meeting with OOC staff to 
discuss the findings of a particular investigation and responding with 
a plan to address the issues, they did not hear back from OOC for 
months, or in several instances, for a year or more. The agency 
official we spoke with explained that this absence of closure 
complicated efforts to resolve the current status of cases.

Our review of OOC's procedure manual for handling safety and health-
related complaints found that it did not provide a clear, complete, and 
up-to-date source of OOC's policies and procedures on how the Office 
responds to such complaints. In addition, the manual did not provide 
clear time frames on when OOC would communicate to agencies during this 
process. For example, the manual has not been updated since 1997 and 
does not contain any specific language on the Office's policy of 
providing agencies with opening conferences as described to us by OOC's 
General Counsel and his staff. In response to follow-up requests, OOC 
staff did provide us with a separate one-page document, dated May 1999, 
which described topics discussed at an opening conference. However, 
this document also did not clearly set forth OOC's policy on agency 
notification, and it was not clear how it was used and how widely it 
had been distributed. OOC's General Counsel has recently acknowledged 
the need to revise and update these procedures, but he told us that 
because of other needs he has not given this a high priority.

To establish channels that facilitate open and effective communication, 
organizations need to clearly set out procedures--such as communication 
protocols--that they will consistently follow when doing their work. 
For example, building on the foundation of the congressional protocols 
we developed in 2000, GAO launched the pilot phase of our agency 
protocols in 2002 that contain clearly defined and transparent policies 
and practices on how we carry out our work at federal 
agencies.[Footnote 16] These protocols identify what agencies can 
expect from GAO and what GAO expects of agencies. Toward this end, our 
protocols present information on the framework of GAO's engagement and 
audit activities--including communication between GAO and agencies, 
interactions during the course of GAO's work, and follow-up on GAO's 
recommendations--and contain a description of the specific actions and 
activities we will take at each stage as well as specific time frames 
when appropriate. In this way the protocols are intended to help ensure 
the consistency, fairness, and effectiveness of interactions between 
GAO and the agencies with which it works. Rather than being just a 
paperwork exercise, the development of agency protocols that clearly 
and accurately communicate OOC's current policies and procedures can be 
an important tool to assist OOC's management achieve its commitment to 
communicate more openly and effectively with legislative agencies. In 
addition, protocols can have a significant impact on OOC's ability to 
work constructively and fairly with the agencies it regulates, and to 
accomplish its overall mission goals.

Recommended Next Steps: 

Both OOC's Board of Directors and its senior executives recognize the 
importance of communicating with stakeholders and have begun to make 
efforts in this area. Consistent with that commitment, we recommend 
that OOC take the following steps: 

* Develop congressional protocols, in close consultation with 
congressional stakeholders, that would document agreements between the 
Congress and OOC on what congressional stakeholders can expect as the 
Office carries out its work. Protocols help to ensure that OOC deals 
with its congressional stakeholders using clearly defined, consistently 
applied, and transparent policies and procedures. They can also help 
OOC reach agreement on the best mix of products and services to achieve 
its mission. It is important to note that consulting with stakeholders 
is not the same as seeking their acceptance or approval on matters 
where that would not be appropriate. The purpose of such protocols is 
to help create a basic understanding of OOC's goals, functions, and 
procedures; and what OOC will communicate to whom, when, and how, 
without compromising the independence the Congress gave OOC to enforce 
the CAA.

* Develop agency protocols, in cooperation with legislative agencies, 
that would clarify and clearly communicate the procedures OOC will 
follow when interacting with agencies while carrying out its work.

In both cases OOC should carefully pilot the protocols before they are 
fully implemented so that OOC, the Congress, and legislative agencies 
can gain valuable experiences in their application and that appropriate 
adjustments can be made.

We also recommend that the Executive Director and the General Counsel 
review and revise OOC's case handling policies and procedures, such as 
OOC's procedure manual for handling safety and health-related 
complaints, and ensure that they are effectively communicated to 
appropriate legislative agency officials.

Creating and Sustaining an Enhanced Management Control Environment 
Essential for Effective Operations: 

The creation of an enhanced control environment forms the foundation 
for an organization's ability to put in place the management controls 
necessary for effective and efficient operations. Well-managed 
organizations establish and maintain an environment that sets a 
positive and supportive attitude toward internal control and 
conscientious management. In our previous work, we have identified 
several key factors that affect an organization's ability to create 
such an environment including its organizational and leadership 
structure and its ability to effectively manage and develop its human 
capital.[Footnote 17] OOC faces challenges in both of these areas, 
which it needs to successfully overcome in order to exercise effective 
management control.

Performance Agreements Offer a Potential Tool to Increase 
Accountability of Top Leaders and Focus on Organizational Goals: 

We have previously reported that federal agencies have used 
performance agreements between senior political and career executives 
as a tool to define accountability for specific goals, monitor 
progress, and contribute to performance evaluations.[Footnote 18] 
Congress has also recognized the role that performance agreements can 
play in holding organizations and executives accountable for results. 
For example, in 1998, the Congress chartered the Office of Student 
Financial Assistance as a performance- based organization and required 
the agency to implement performance agreements. In addition to 
providing OOC's Board with a mechanism to increase accountability, 
performance agreements would also provide the platform for ongoing 
dialogue to help ensure that the goals and priorities contained in 
OOC's strategic plan are carried out by its top executives and help 
ensure the proper alignment among daily operations and activities and 
the broader results OOC strives to achieve. 

Since it was created in 1995, OOC has operated without having any 
formal performance management system for its Executive Director and 
General Counsel. Starting in 2003, OOC's Board of Directors required 
these officials to prepare an annual self-assessment that they submit 
to the Board for review. The Executive Director and General Counsel 
prepare narratives assessing themselves in five performance categories: 
operational management, external relations, ethics, strategic 
planning, and Board relations. These narratives then form the basis for 
a subsequent informal review session with the Board. The development of 
these self-assessments is an important first step in improving the 
performance and assuring the accountability of OOC and its executive 
team.

OOC's current efforts to develop a strategic plan provide an ideal 
opportunity for the Office to build on this first step. Once OOC has 
reached agreement with its stakeholders and has completed its strategic 
plan, it can take the next step and develop results-oriented 
performance agreements with its senior executives that are directly 
linked to organizational goals embodied in its strategic plan--the 
absence of which is a major limitation of the current effort. We have 
reported on a number of benefits of performance agreements that may 
have direct importance to achieving improved performance at OOC. 
Performance agreements have: 

* Strengthened alignment of results-oriented goals with daily 
operations. Performance agreements define accountability for specific 
goals and help to align daily operations with agencies' results-
oriented, programmatic goals.

* Fostered collaboration across organizational boundaries. Performance 
agreements encourage executives to work across traditional 
organizational boundaries or "silos" by focusing on the achievement of 
results-oriented goals.

* Enhanced opportunities to discuss and routinely use performance 
information to make program improvements. Performance agreements 
facilitate communication about organizational performance, and provide 
opportunities to pinpoint improved performance.

* Provided a results-oriented basis for individual accountability. 
Performance agreements provide results-oriented performance 
information to serve as the basis for executive performance 
evaluations.

* Maintained continuity of program goals during leadership transitions. 
Performance agreements help to maintain a consistent focus on a set of 
broad programmatic priorities during changes in leadership.[Footnote 
19]

In addition to assuring accountability and alignment of operations to 
results, performance agreements could help OOC ensure it maintains a 
common and consistent vision and approach to the implementation of the 
CAA. In the past, a lack of such a common vision on how OOC should 
approach the enforcement of workplace health and safety requirements or 
interact with stakeholders resulted in clashes between the Executive 
Director and the previous General Counsel. Specifically, a number of 
congressional and legislative agency officials we interviewed had the 
perception that a previous General Counsel's emphasis on a strict 
"gotcha" approach toward enforcement led to a combative and adversarial 
relationship with legislative agencies and other stakeholders that was 
at odds with the more collaborative approach supported by OOC's 
Executive Director.

OOC's current Board, Executive Director, and General Counsel told us 
that they share a common commitment to pursuing a collaborative and 
constructive approach towards enforcing the CAA. OOC's recent effort to 
develop a strategic plan is a reflection of the common vision of the 
organization's mission, goals, and operational approach shared by OOC's 
current leaders. In addition, they appear to enjoy good working 
relationships among themselves. However, the standards of effective 
management control and OOC's own past experience demonstrate the need 
for the office to take appropriate steps to address the OOC's 
organizational structure and presents a challenge to effective 
management control.

Effective Human Capital Management Is Also a Key Factor in Management 
Control: 

Effective human capital management is an important factor contributing 
to management control as well as an organization's ability to achieve 
results. We have identified two human capital challenges currently 
facing OOC: (1) the need to ensure leadership continuity and preserve 
critical organizational knowledge in the face of the impending loss of 
a large number of leaders over the next 2 years and (2) the need to 
establish a modern, effective, and credible performance management 
system with appropriate safeguards for all OOC employees.

Leadership Continuity Is Key to Management Control: 

Sustained focus and direction from top leadership is a key component of 
effective management. Management control requires that organizations 
consider the effect upon their operations if a large number of 
employees--including executives and other leaders--are expected to 
leave and then establish criteria for a retention or mitigation 
strategy.

OOC currently faces a considerable loss of knowledge and leadership 
capacity due to impending turnover of its Board of Directors. This 
expected loss is the result of CAA provisions that limit current Board 
members to a single 5-year term. For example, within the next year-and-
a-half all five members of the current Board will reach the end of 
their terms. When the Congress crafted the CAA, it included a provision 
to provide for staggered terms for OOC's Board. However, delays in the 
appointment of successors to the original group of board members 
resulted in the appointment of several new members at the same time. 
Specifically, the Chair and two members of the five-member Board were 
appointed in October 1999 and are scheduled to complete their terms in 
September 2004. The terms of the two remaining Board members will end 
eight months later in May 2005.

The situation is only slightly better for OOC's four appointed 
executives. Similar to the Board, the CAA restricts OOC's four 
appointed executives to nonrenewable 5-year terms of service. In 
addition, this restriction also prevents the possibility of having a 
deputy executive director serve in the role of executive director, 
making the potential of succession planning among this group of 
executives impossible. The terms of all but the General Counsel will 
expire within 6 months of each other in 2006. If one considers both 
OOC's Board and its senior executives together, eight out of nine of 
the organization's top officials will have left by September 2006. The 
loss of such a large proportion of OOC's senior leadership within a 
relatively short period will likely result in a loss of leadership 
continuity, institutional knowledge, and expertise that has the 
potential of adversely impacting OOC's performance at least in the 
short term.

Other federal agencies with functions similar to OOC do not restrict 
their board members from serving subsequent terms. For example, there 
are no statutory restrictions on the five board members of the EEOC and 
the three board members of the Federal Labor Relations Authority from 
serving addition terms. In addition, the statute governing the National 
Labor Relations Board permits the five board members to be reappointed.

Need for Modern, Effective, and Credible Approach to Performance 
Management: 

We have previously reported that performance management systems can 
create a "line of sight" showing how team, unit, and individual 
performance can contribute to overall organizational results.[Footnote 
20] An explicit alignment of daily activities with broader results is 
one of the defining features of effective performance management 
systems in high-performing organizations. Organizations naturally need 
to develop performance management systems that reflect their specific 
structures and priorities. Given OOC's small size and specific 
situation, it is important that it considers these and other key 
practices in the context of its own needs, capabilities, and 
circumstances.

In September 2002, OOC rolled out its first formal performance 
management system to staff who report to the Executive Director. OOC 
assesses employees on eight performance dimensions: (1) job knowledge 
and technical skills, (2) overall quality of work, (3) employee and 
professional relationships, (4) planning and organization, (5) work 
habits, (6) judgment, (7) initiative and creativity, and (8) 
development. Supervisors are to meet with their staff twice a year to 
provide ratings and feedback on the previous 6-month assessment period. 
They also are to hold an interim meeting halfway through each 
assessment period. For these eight performance dimensions, supervisors 
give each employee two separate ratings--the first describes the 
employee's overall achievement in the performance dimension, and the 
second represents the progress of the employee toward achieving 
specific goals established at the start of the evaluation cycle.

On one hand, OOC's decision to establish a formal performance 
management system covering at least some of its employees represents a 
good first step and its performance management system exhibits some 
positive characteristics. For example, OOC's requirement that 
supervisors and employees meet at least four times a year to discuss 
the employees' recent performance and individual goals provides regular 
opportunities for staff to discuss and act on feedback. On the other 
hand, there are areas where the system can be improved as OOC's efforts 
in this area move forward. For example, OOC's current performance 
management system assesses staff against the eight performance 
dimensions identified above without providing specific standards or 
detailed descriptions of the behaviors associated with varying levels 
of performance. For instance, for the performance dimension "overall 
quality of work," the only descriptive standard provided is 
"consistently produces competent work." OOC should explore the 
usefulness of including descriptions of competencies--those specific 
skills or supporting behaviors that employees are expected to 
demonstrate as they carry out their work--in its performance management 
system to provide a basis for making judgements about an individual's 
performance and contribution to OOC's results.

In addition, OOC's current performance management system does not apply 
to the General Counsel or any OOC attorneys who report to him. These 
employees continue to work without any formal performance management 
system in place. Moving forward, the involvement of employees will be 
crucial to the success of any efforts by OOC to create a new 
performance management system or reform and expand its existing 
one.[Footnote 21] Given OOC's small size, the cost in time and effort 
to obtain such feedback likely could be minimal.

Matters for Congressional Consideration: 

Congress should consider making legislative changes to the CAA to help 
ensure that OOC maintains institutional continuity into the future. 
Specifically, the Congress should consider amending the CAA to allow: 

* Board members to be reappointed to an additional term, and: 

* the Executive Director, General Counsel, and the two Deputy Executive 
Directors to be reappointed to serve subsequent terms in either the 
same or a different position, if warranted and the Congress so desires. 
Any reappointments should be contingent on an individual's demonstrated 
performance and achievement of goals as documented in executive 
performance agreements for OOC's Executive Director and General 
Counsel, as recommended below, or another performance management system 
in the case of OOC's two Deputy Executive Directors.

Recommended Next Steps: 

We recommend that OOC's Board: 

* Require performance agreements between the Board of Directors and 
OOC's Executive Director and General Counsel to help translate the 
Office's strategic goals into day-to-day operations and to hold these 
executives accountable for achieving program results.

We recommend that OOC's Executive Director and General Counsel: 

* Establish a modern, effective, and credible performance management 
system with appropriate safeguards for all OOC employees. OOC should 
build on the first step of establishing a basic performance management 
system for employees reporting to the Executive Director by ensuring 
that all employees, including those who report to the General Counsel, 
participate in an individual performance management system. In 
addition, OOC should look for ways to develop a more robust and 
effective approach to individual performance management by considering 
key practices employed by leading organizations.

* Actively involve all OOC's employees in this process, whether it 
entails the revision and expansion of its existing performance 
management system or the creation of an entirely new initiative.

Agency Comments: 

On January 22, 2004, we provided a draft of this report to OOC's Board 
of Directors, Executive Director, and General Counsel for their review 
and comment. We received written comments prepared jointly by the Board 
of Directors, Executive Director, and General Counsel on January 26, 
2004. In their joint response, OOC generally agreed with the contents 
of this report, noting that the Office has begun to adopt many of our 
recommendations as part of its strategic planning process and current 
programmatic initiatives. Furthermore, the Board of Directors strongly 
supports our statement that the Congress should consider amending the 
CAA to allow OOC's Board members to serve an additional term and to 
allow the Executive Director, General Counsel, and the two Deputy 
Executive Directors to be reappointed to serve additional terms in 
either the same or a different position, if warranted and desired. As 
mentioned in their response and as acknowledged in our report, we have 
provided information and assistance to OOC regarding their management 
control improvement efforts and we plan to continue working with OOC's 
leadership and meet with them regularly to discuss their progress. 
Their written response is reprinted in appendix II. In addition, OOC's 
Executive Director and General Counsel provided minor technical 
clarifications, and we made those changes where appropriate.

We will provide copies of this report to other interested congressional 
committees, and the Office of Compliance. In addition, we will make 
copies available to others upon request. The report will be available 
at no charge on the GAO Web site at [Hyperlink, http: //www.gao.gov.].

If you have any questions about this report, please contact me or 
Steven Lozano on (202) 512-6806 or on [Hyperlink, mihmj@gao.gov] 
and [Hyperlink, lozanos@gao.gov]. Major contributors to this report 
were Jeff Dawson, Peter J. Del Toro, Jeffery Bass, Bruce Goddard, and 
Jeff McDermott.

J. Christopher Mihm: 
Managing Director, Strategic Issues: 

Signed by J. Christopher Mihm: 

[End of section]

Appendixes: 

Appendix I: Objective, Scope, and Methodology: 

To meet our objective of assessing key management controls in place at 
the Office of Compliance (OOC) and identify what improvements, if any, 
could be taken to strengthen OOC's effectiveness and efficiency, we 
followed a multipronged approach. First, we analyzed applicable laws, 
legislative history, rules, and regulations; and obtained and analyzed 
written documentation of guidance, policies, procedures, and 
performance of OOC.

Second, to understand the complex operating environment and long-
standing challenges facing the agency, we conducted a series of 
interviews with agency officials, key stakeholders, and officials from 
agencies covered by the Congressional Accountability Act (CAA). To 
obtain OOC's perspectives on its operations and the challenges it 
faces, we interviewed OOC's Board of Directors as well as each of its 
top executives--the Executive Director, General Counsel, Deputy 
Executive Director for the Senate, and Deputy Executive Director for 
the House. We also met with all of OOC's managers including the Deputy 
General Counsel, Director of Counseling, and Budget and Administrative 
Officer.

To understand how key stakeholders perceive the OOC, we conducted 19 
interviews with selected majority and minority congressional staff from 
both the Senate and House. Among those we interviewed were staff from 
Senate and House leadership offices, Senate and House Subcommittees on 
Legislative Branch Appropriations, Committee on Governmental Affairs, 
Committee on House Administration, Office of the Senate Employment 
Counsel, Senate Sergeant-At-Arms, Senate Administrative Managers 
Group, Office of the Clerk of the House, Office of the House Employment 
Counsel, Office of the Chief Administrative Officer of the House, House 
Inspector General, as well as personal staff of several senators and 
representatives.

We also spoke with cognizant officials from agencies covered by the CAA 
to obtain their views of the performance of the Office. These included 
the Architect of the Capitol, the Congressional Budget Office, the 
United States Capitol Police, the Office of the Attending Physician, 
the Library of Congress, and GAO. To obtain the perspectives of 
organized labor and employee groups we spoke with two of the largest 
unions representing employees in legislative agencies--the Association 
of Federal, State, County, and Municipal Employees, and the Fraternal 
Order of Police.

In addition, we conducted selected reliability and validity reviews of 
OOC's dispute resolution process database. For these reviews, we 
questioned OOC staff about their internal controls for their dispute 
resolution database. We then drew a random sample of 5 cases out of a 
total field of 44 cases reported as closed in the database for 2002 and 
compared the electronic data to source documents. We also examined 
whether OOC was processing cases within statutorily defined thresholds 
for key process phases. The OOC's responses to our questions and the 
results of this comparison led us to conclude that the data were 
sufficiently reliable for the purposes of our report.

We also drew on key management practices and guidance identified in 
previously-issued GAO reports, where appropriate. As part of a process 
of constructive engagement, we provided OOC with briefings, reports, 
and examples of best practices in the areas we reviewed. For example, 
at the OOC's request, GAO officials provided briefings on our approach 
to strategic planning and we provided copies of our strategic planning 
documents.

On January 22, 2004, we provided a draft of this report to OOC's Board 
of Directors, Executive Director, and General Counsel for their review 
and comment. We received written comments prepared jointly by the Board 
of Directors, Executive Director, and General Counsel on January 26, 
2004. Their written response is reprinted in appendix II. OOC also 
provided technical comments that we have incorporated where 
appropriate. We performed our work in Washington, D.C., from January 
2003 through January 2004 in accordance with generally accepted 
government auditing standards.

[End of section]

Appendix II: Comments from the Office of Compliance: 

Office of Compliance:

Advancing safety, health, and workplace rights in the legislative 
branch:

Board of Directors:

Susan S. Robfogel: 
Chair:
Barbara L. Camens: 
Alan V. Friedman: 
Roberta L. Holzwarth: 
Barbara Childs Wallace: 

January 26, 2004:

J. Christopher Mihm 
Director:

Strategic Issues:

United States General Accounting Office: 
441 G Street NW:
Washington, D.C. 20548:

Dear Mr. Mihm:

The Board of Directors and Executive Appointees of the Office of 
Compliance are pleased to submit these comments to be appended to the 
GAO Report: Office of Compliance: Status of Management Control Efforts 
to Improve Effectiveness (GAO-04-400). The Board and management of the 
Office are united in our response to the GAO Report, as we are united 
in our ongoing efforts further to improve the effectiveness and 
efficiency of this agency in administering the dispute resolution, 
education, and regulatory programs mandated by the Congressional 
Accountability Act of 1995. As the Report is being issued, this agency 
continues to make progress toward adoption and implementation of the 
recommendations of GAO.

Our Mission:

"The Office of Compliance works to advance safety, health, and work 
place rights for employees and employers of the Legislative Branch as 
mandated by the Congressional Accountability Act of 1995."

Our Response to the GAO Report:

The Office of Compliance has embraced the GAO constructive engagement 
as a primary resource in our ongoing effort to develop a comprehensive 
focus for the future of this agency. We have benefitted from GAO's 
advice and counsel regarding our strategic planning process, our IT 
master plan, and establishment of more effective human capital 
management.

Because of the open and collegial interchange which has characterized 
our partnership with GAO, many of the observations and recommendations 
in the Report are already reflected in ongoing 
programmatic initiatives, and in our Three Year Strategic Plan, which 
is in the final stages of development. The Office has also recently 
submitted a comprehensive zero base budget estimate for FY2005, 
consistent with the major objectives in our draft Strategic Plan, which 
reflects the Office's needs as we move into implementation of the 
recommendations by GAO.

The Board of Directors strongly supports the GAO recommendation that 
Board Members and the executive staff appointed by the Board be 
eligible for reappointment. Currently, the entire Board and management 
staff must be replaced every five years. GAO has recommended to 
Congress that the governance structure of the Office of Compliance be 
changed to permit both Board Members and executive staff appointed by 
the Board to serve more than one term in office. The Board of Directors 
is particularly hopeful that the Congress will give the Board 
flexibility to reappoint members of the executive staff who have proven 
their value to the agency. To that end, the Board of Directors intends 
to establish performance agreements with the Executive Director and 
General Counsel as soon as the Office's three year Strategic Plan is 
finalized in the coming weeks. Similarly, the Executive Director and 
General Counsel are in the process of enhancing our existing staff 
performance appraisal system, and linking performance appraisal 
directly with objectives under the Strategic Plan.

GAO is encouraging the Office to continue to clarify its interaction 
with all stakeholders, as well as to build on other initiatives which 
the Office has begun over the past several years. The unique role 
played by this Office requires that the agency's leadership effectively 
engage simultaneously with stakeholders as a regulated community, as 
peer agencies of Congress, and as oversight/appropriation authorities. 
In a small organization occupying such a singular position in the 
Legislative Branch, a position which requires a careful balance of 
collegiality and independence, institutional stability and success is 
directly related to our ability to develop and maintain the trust of 
the regulated community in the experience of our leadership. Board 
particularly urges the Congress to authorize the Board's option to 
reappoint of the executive staff, who are leading the day-to-day 
efforts to improve the effectiveness of the Office of Compliance.

As recommended by GAO, the Office will continue to strive to maximize 
efficiencies, and to regularly engage in reevaluation of the direction 
and effectiveness of our programs in education, dispute resolution, and 
enforcement. Our ability to implement the goals and objectives which 
have resulted from the comprehensive review of our enterprise will 
require the enhancement of the Office's capacity and capability in 
several critical areas. We respectfully request that the appropriations 
subcommittees review our zero base budget estimate for FY 2005 with 
reference to recommendations included in this Report.

The Office of Compliance looks forward to a continuing engagement with 
GAO after this Report has been submitted to the appropriations 
subcommittees. We hope that GAO will continue to provide the Office 
with constructive support in areas of expertise which a small agency 
must access externally.

The Office also solicits input from stakeholders in the Legislative 
Branch regarding the observations and recommendations made by GAO. We 
intend to engage in informal discussions with interested entities and 
individuals about the Report, and about what this Office is doing to 
better protect and serve the Capitol Hill community.

The Office of Compliance strives to make a positive permanent impact on 
the quality of work life in Congress and its instrumentalities, and on 
the health and safety of the entire Capitol Hill community. We welcome 
the recommendations of GAO as a major contribution to our effort to 
improve our ability to carry out Congress's mandate to implement the 
Congressional Accountability Act of 1995.

Sincerely,

Signed by: 
 
William W. Thompson II: 
Executive Director:

Peter A. Eveleth, Esq.: 
General Counsel

Alma R. Candelaria:
Deputy Executive Director, House

Paul Coran: 
Deputy Executive Director, Senate:

Susan S. Robfogel: 
Chair: 

Alan Friedman: 

Barbara Childs-Wallace: 

Barbara Camens: 

Robert Holzwarth: 

(450171): 

FOOTNOTES

[1] H. Rpt. 108-10, Feb. 13, 2003. 

[2] U.S. General Accounting Office, Standards for Internal Control in 
the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 
1999).

[3] Pub. L. No. 104-1, 2 U.S.C. §§ 1301-1438. 

[4] U.S. General Accounting Office, Executive Guide: Effectively 
Implementing the Government Performance and Results Act, GAO/GGD-96-118 
(Washington, D.C.: June 1996) and GAO/AIMD-00-21.3.1.

[5] GAO/GGD-96-118.

[6] GAO/GGD-96-118.

[7] This includes all facilities of the House of Representatives, the 
Senate, the Capitol Guide Service, the Capitol Police, the 
Congressional Budget Office, the Office of the Architect of the 
Capitol, the Office of the Attending Physician, the Office of 
Compliance, the Library of Congress, and the General Accounting Office. 
See 2 U.S.C. § 1341(e)(1).

[8] See 2 U.S.C. § 1382(c)(3). 

[9] GAO/GGD-96-118.

[10] U.S. General Accounting Office, Architect of the Capitol: Status 
Report on Implementation of Management Review Recommendations, GAO-04-
299 (Washington, D.C.: Jan. 30, 2004). 

[11] GAO/AIMD-00-21.3.1.

[12] GAO/AIMD-00-21.3.1.

[13] U.S. General Accounting Office, GAO's Congressional Protocols, 
GAO-01-145G (Washington, D.C.: November 2000). 

[14] U.S. General Accounting Office, Internal Control Management and 
Evaluation Tool, GAO-01-1008G (Washington, D.C.: August 2001). 

[15] See 2 U.S.C § 1341(c)(1).

[16] U.S. General Accounting Office, GAO's Agency Protocols, GAO-03-
232SP (Washington, D.C.: December 2002). 

[17] GAO/AIMD-00-21.3.1.

[18] U.S. General Accounting Office, Managing for Results: Emerging 
Benefits From Selected Agencies' Use of Performance Agreements, GAO-01-
115 (Washington, D.C.: Oct. 30, 2000).

[19] GAO-01-115. 

[20] U.S. General Accounting Office, Results-Oriented Cultures: 
Creating a Clear Linkage between Individual Performance and 
Organizational Success, GAO-03-488 (Washington, D.C.: Mar. 14, 2003); 
Results-Oriented Cultures: Insights for U.S. Agencies from Other 
Countries' Performance Management Initiatives, GAO-02-862 (Washington, 
D.C.: Aug. 2, 2002); and GAO-01-115.

[21] U.S. General Accounting Office, A Model of Strategic Human Capital 
Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002) and GAO-02-
862.

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