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  4. Statement of Leonra Guarraia, Chief Operating Officer U.S. Equal Employment Opportunity Commission

Statement of Leonra Guarraia, Chief Operating Officer U.S. Equal Employment Opportunity Commission

The U.S. Equal Employment Opportunity Commission

Meeting of July 8, 2005, Washington D.C. on Field Repositioning

I am pleased to present phase two of our repositioning plan. Phase one was the launching of our National Contact Center in March on a pilot basis, which from all reports is off to a great start. Phase three, which will be forthcoming, will be the streamlining of our headquarters structure. Today we are presenting phase two - the repositioning of our field operations.

This plan is the culmination of several years of work, study, assessment and input. Our work began with a study of the Commission’s organization by the National Academy of Public Administration (NAPA) in 2002. NAPA issued their report in 2003. Among the recommendations made by NAPA was a structure that would be made up of ten “lead” offices. While we have decided to expand the number of “lead” offices above the number recommended by NAPA, we did follow their recommendations concerning communication and comment. The NAPA report was posted on our external website and we had an e-mail response process. Every employee of the Commission was given the opportunity to comment on the report and its recommendations.

Also in 2003 a day long Commission meeting was held to receive additional input from our employees, managers, the union and other interested stakeholders. In 2004 a repositioning workgroup under the leadership of the Vice-Chair and former Commissioner Paul Miller was convened. This workgroup had representatives from all levels of staff at EEOC, both headquarters and field. All of the Commissioners were briefed on the workgroup’s final report.

Chair Dominguez has visited many, if not most, of our field offices to get the views of our employees on a number of issues, to include repositioning, and as the Chair noted we have kept our stakeholders, OMB and various Congressional committees and subcommittees informed as to our progress. Without question this has been the most open, transparent and inclusive restructuring process in the history of the EEOC.

Through all of this we heard several things from our staff and stakeholders - do not close offices - do not reduce service - do not cut staff -and we listened. Our proposal closes no offices, preserves a job for every EEOC employee, actually expands our presence to areas where we have not previously had offices and will allow us to increase the number of front-line staff while reducing costs. We heard the concerns that were raised and we have addressed every single one. As the Chair began this process she set down a marker and made a pledge to the employees of the EEOC, no offices will close, no jobs will be lost, there will be no RIF and no furlough - and by this plan she has kept those promises.

We are in a situation where we must right- size the Commission to operate effectively and efficiently within the resources that have today. The current Commission structure was created almost 25 years ago when we were an agency of almost 3,800 employees, not the 2,400 that we are today.

This proposal fits the size of each EEOC office to the work it must perform. There will be 15 district office directors and 15 regional attorneys. The Commission is expanding its number of field offices, from one (1) to nine (9), and will also have 15 area offices and 14 local offices, two of which are new offices being established to respond to the growing population of workers in Mobile, Alabama, and Las Vegas, Nevada. This repositioning will give the Commission a total of 53 offices, enabling us to increase our presence and still reduce costs. This plan flattens our overall management structure and results in a more logical alignment of our offices. This plan will allow us to redeploy 70-80 staff to front-line positions, and to fill 20 new positions. This is in addition to the more than 130 positions that have been authorized over the past year, most of which have been assigned to our field offices.

What the Commission is voting on are the necessary changes to EEOC Orders 110 and 120 which define the mission and functions of our offices and their structure and the geographic boundaries of each office. Upon approval we will move to the implementation phase. We realize that there are many details to be addressed and these will be addressed over time as we move to implement. There has been concern that all of this is going to happen in one fell swoop. That is not the case. We will ensure a transitioning phase that is adequate and sufficient for proper implementation. This change will not adversely affect the public’s access to the Commission. They will continue to reach the Commission and be served by our staff - at an even higher level of customer service.

Throughout this effort we have been sensitive to the concerns of our employees and our stakeholders. To be frank, we had a number of proposals before us that were far more drastic than this plan - plans which would have required the closing of offices or the laying-off of employees. We were certainly aware that many agencies have been forced to take that route. However we were determined to find a way to make the necessary adjustments to our structure without doing that - and we believe we have been successful on many fronts - by relieving grade compression, opening up new opportunities for promotion and management, expanding our presence for our constituents and creating a right-sized organization that results in operational consistency through a stronger, leaner management team.

Since this proposal was announced in May we have reached out to interested parties about the plan, received their input, addressed their concerns and answered their questions. We have held numerous briefings for our Commissioners, Congressional members and staff, stakeholder groups and our own office directors so they in turn could advise our employees. We have posted a wealth of information on the Commission’s internal and public websites, to include answers to questions generated by interested groups and the transcript of a public forum that was held June 23rd. We also provided e-mailboxes for the receipt of comments from both the public and EEOC employees. We received approximately 137 comments, in total, including 83 from members of the public and organizations, including the union. Fifty-five comments were received from EEOC employees. All of the input we have received has been carefully assessed. Some changes to the original proposal have been made as a result of that input.

  • EEOC Order 110 has been further edited to 1) clarify the role of our regional attorneys and legal units and 2) provide that any of the program functions performed in the field may be performed in field, area or local offices depending on workload needs.
  • The relationship between our district offices and state and local fair employment practice agencies (FEPAs) has been clarified by providing that each FEPA will have a relationship with only one district office for the purposes of administration of its FEPA contract and EEOC file review of its cases.
  • Five counties in California that had been under the Fresno local office, but that are closer to the San Francisco office will be moved to the jurisdiction of the San Francisco office.
  • Four counties in northeast South Carolina will be moved back to the jurisdiction of the Charlotte office.
  • The entire upper peninsula of Michigan will be moved back to the jurisdiction of the Detroit office.
  • Four central Ohio counties around Columbus, Ohio, will be moved back to the jurisdiction of the Cleveland office and three southern Ohio counties will be moved to the jurisdiction of the Cincinnati office.
  • Two of the three Delaware counties and five Pennsylvania counties (including Lancaster and York) will be moved from the jurisdiction of the Philadelphia office to the Baltimore office. Four western Pennsylvania counties will be moved from the Philadelphia office to the Pittsburgh office.

We began this process by commissioning a study by NAPA in 2002. We have kept NAPA advised of our actions since their report issued in 2003. We have just recently received a letter from NAPA. The letter notes that it is clearly necessary that we resize our field staff to our current size and that the proposal appears to be consistent with NAPA’s recommendations and presents a creative way to maintain and even enhance the Commission’s presence while providing for necessary efficiencies. We agree with that assessment and think that this is a good plan, one that will meet the needs of the Commission, its employees and the public we serve as we continue into the 21st century.

This page was last modified on November 14, 2005.