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implementation of a reasonably precise and efficient set of priority criteria for the selection of contractors for compliance reviews and investigations; (2) a data system which serves as a basis for determining the efficacy of its regulatory policies and procedures, including the extent to which the affirmative action program goals and timetables requirements and the affected class discrimination policies are producing new and better job opportunities for minorities and women; and (3) research studies from which reasonably adequate estimates can be made of the availability of minorities and women for employment in job groups from which they have been customarily excluded and from which benchmarks for goals and timetables can be established.

Similarly, budgetary and personnel management

supports have not been adequate.

Until recently the

ESA budget system did not permit the full participation of OFCCP in formulating its program needs. Further, the Office has had to compete with other programs within ESA for the limited increases contained in the

organization's annual requests; and, more often than not, allocation decisions apparently have been based primarily on considerations largely unrelated to actual

that Executive Order 11246 has ranked high on

ESA's list of priority programs.

ESA's personnel management services have been even less helpful than its other support activities. Following the departure of Assistant Secretary Fletcher, OFCCP was reorganized to bring its grade structure more in line with other ESA operating units despite the staff/line relationship between the office and the compliance agencies which distinguishes the organization from other Employment Standards programs. The executive level positions were reduced in number from 10 to 6, and the supervisory and senior specialists positions were reduced in number from 16 to 5. One impact of the reorganization was to destroy the corporate/career ladder relationship between OFCCP and the agencies under which the office was able to attract fully experienced, highly capable agency field level compliance review and enforcement specialists for staff vacancies. The result has been a diminution in OFCCP's technical capability. Concurrent with the downgrading of OFCCP and its staff, the compliance agencies were upgrading their programs and compliance personnel to the extent that those to whom the OFCCP staff is charged with the responsibility of providing

levels. The disparity in status and levels of authority and responsibility has not strengthened OFCCP's capability to exercise supervision over the compliance

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Although the Executive Order assigns primary responsibility for enforcing the EEO contractual obligations to the compliance agencies, it also authorizes OFCCP (under delegation from the Secretary of Labor) to conduct compliance and enforcement activities directly with Federal contractors. Because of the peculiar characteristics of the contract construction industry, OFCCP has chosen to exercise this authority rather extensively in that industry by developing and administering areawide compliance and enforcement plans jointly with the compliance agencies. However, its staff resources did not expand at the rate at which such plans developed. In the spring of 1973 and the summer of 1974 investigative staff from other divisions in ESA were temporarily assigned to assist in the conduct of audits of areawide construction industry plans and bid conditions. Since that time no compliance operations support has been forthcoming; and, for lack of sufficient OFCCP staff

construction industry have not been sufficient to permit those plans to realize their potential.

In addition, insufficient staff is available to investigate difficult or unprecedented nonconstruction cases, although significant remedies have been obtained in the past through direct involvement in such matters. Coordination with Other Federal Agencies and with Other Department of Labor Programs

C.

The Director's ability to assure effective coordination and mutual support in equal employment opportunity enforcement has been hampered because of organizational placement in DOL, by the lack of access to the Chairman, general counsel, and other policy and decision making officials of EEOC and the Assistant Attorney General for Civil Rights of the Department of Justice.

Within the Department, the absence of interaction at a peer level with other program officials has, in large part, prevented the necessary coordination between OFCCP, and other Department of Labor programs to achieve data support for affirmative action programs, compliance reviews, target selections, success measurements, and for job training and placement activities. Among those programs are the Bureau of Labor Statistics, Employment and Training Administration, and Office of

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An equally critical problem created by the re

structuring of OFCCP within ESA was the disjoining of OFCCP's field operations from its national office. Under the ESA regional office structure, the field operations of the constituent programs are carried out under the line authority of an ESA regional administrator, who is accountable directly to the Assistant Secretary.

This arrangement places OFCCP's authority over its field operations on much the same tenuous footing as its authority over the compliance agencies and diminishes its capability in much the same manner. Unlike the Fair Labor Standards Act and the Federal Workers' Compensation laws, equal employment laws, policies, and standards are relatively ill-defined, somewhat subjective, and in a constant state of development.

Thus effective performance de

mands that the OFCCP National Office exercise a greater degree of direction, control, and supervision over its field operations than ESA's management system has

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To one degree or another, many of the problems outlined above have been disclosed in the findings of

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