Racial and Gender Diversity in State DOTs and Transit Agencies (2007)

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26 Conclusions • Not all SDOTs and transit agencies file EEO-4 reports and FHWA-1392 forms to record their progress in achieving EEO goals. • SDOTs and transit agencies report their EEO information in inconsistent formats, making analysis difficult. • Not all SDOTs and transit agencies conduct comprehen- sive availability analyses. A large number of agencies do not report availability information. Some agencies that do report availability information provide the information only in the aggregate, which precludes agencies from determining which racial/ethnic groups and occupational categories are underutilized and from developing narrowly tailored and legally defensible hiring goals. • The employment tracking systems used by SDOTs and transit agencies are insufficient to instill confidence in the EEO data produced by the agencies. • Agencies are given little incentive to submit EEO data. Recommendations The research team proposes five key recommendations based on the four elements of the conceptual framework (compliance, consistency, comprehensiveness, and confi- dence) and on a fifth element, consequences, which surfaced as a result of the analysis. Make It Easier for Agencies to Be Compliant A process should be developed to enable SDOTs and tran- sit agencies to submit their EEO-4 and FHWA-1392 data electronically. This would allow for more efficient data col- lection and would improve the data analysis. SDOTs and transit agencies should ensure employment information is regularly and accurately recorded. Provide Standardized Training and Facilitate the Sharing of Information and Best Practices Among Agencies SDOT and transit agency staff responsible for EEO report- ing should be properly trained on how to develop and main- tain an effective EEO program. Staff should be accorded time away from their regular duties to attend training sessions. In The Workforce Challenge, the authors recommend that training be a key priority for all transportation agencies and that training be viewed as an investment. They note that suc- cessful organizations spend at least four times as much as do transportation agencies on training, and they suggest that transportation agencies consider an “investment goal of 2 percent of salaries for training,” which is “equivalent to about 40 hours of training annually for each employee” (3). SDOTs and transit agencies also need opportunities for sharing their best practices regarding the development and monitoring of diversity goals (for a discussion of best prac- tices, see Appendix E). One means that SDOTs currently have for sharing best practices is through postings on the Trans- portation Workforce Development website (www.nhi.fhwa. dot.gov/transworkforce/innovative.asp). For example, one current posting in the Innovative Practices for State DOT Workforce Management section of the site describes how the New Hampshire DOT “used an ACCESS software database to create a tracking system that analyzes various stages of its internal hiring and selection process” (www.nhi.fhwa.dot. gov/transworkforce/IP_NH.PDF). The NHDOT staff found that the database they developed helps them save valuable time when filling a job vacancy. It allows them to track an application’s progress through the system and to identify where improvements could make the process more efficient. As a result of the benchmarking process, NHDOT learned that the impediments were “the time lost in manually C H A P T E R 4 Conclusions and Recommendations

27 transferring paperwork through messenger and mail systems” and “the time between when the Bureau posted vacancy an- nouncements and coordinated candidate reviews.” NHDOT now has a baseline from which to measure its progress. The re- sult has been a 50% reduction in the time needed to process job vacancies. Communicate the Key Elements of an Effective Affirmative Action Plan SDOTs and transit agencies should incorporate an avail- ability analysis in their affirmative action plan. It is important that agencies have a comprehensive affirmative action plan that includes both a utilization analysis and an availability analysis, as well as a report on areas of underutilization, an analysis of applicant flow, the establishment of short- and long-range hiring goals, and strategies for achieving those goals. The information in the plan should be disaggregated (i.e., provided for each racial/ethnic group, cross-referenced by gender), and each racial/ethnic group should be analyzed separately. The utilization analysis will identify racial/gender groups that are underutilized and allow agencies to establish targeted goals. The availability rate should be calculated using Census data, as well as data reflecting actual applicant flow; the latter will provide a more narrowly tailored applicant pool. To Promote Greater Accuracy, Agencies Should Improve Internal Monitoring and Tracking Systems Funds should be made available to allow SDOTs and tran- sit agencies to improve their internal reporting, monitoring, and tracking systems. It is no secret that successful agencies monitor results. “Companies must consider more than the numerical mix of various demographic groups in the work- force. As a rule, whatever gets measured in corporations gets done, so defining metrics and tracking progress are critical to keeping management attention focused on the issue” (19). In Canada, internal monitoring is a characteristic of govern- ment agencies that have been successful in their diversity efforts: Departments and agencies with strong leadership and “own- ership” of Embracing Change, are generally more successful . . . . These organizations typically adopt measures such as active in- ternal monitoring and discussion of progress at executive tables . . . focussed strategies to move visible minorities into executive ranks, investment in recruitment and development programs, and support for visible minority networks. (20) SDOTs and transit agencies should monitor and track applicants, hires, and promotions by race and gender so they can prepare detailed reports that will allow them to identify occupations where there is an underutilization of women and minorities and to establish narrowly tailored goals. Make Diversity an Agency Priority by Holding Everyone Accountable for Achieving Diversity Goals SDOTs and transit agencies should hold everyone, staff and leadership alike, accountable for achieving diversity and af- firmative action goals. Traditionally, it has been one office, whether it be personnel/human resources or affirmative action, that has been responsible for developing, coordinating, and re- viewing diversity and affirmative action policies and initiatives, as well as for collecting, reporting, and monitoring diversity and affirmative action goals. That is no longer sufficient; there needs to be commitment from everyone in the organization. According to FTA, affirmative action programs are to be managed by an executive who reports directly to the agency’s CEO, as evidence of the importance of the program to the agency. The importance of an EEO program is indicated by the indi- vidual the agency has named to manage the program and the authority this individual possesses. An executive should be ap- pointed as Manager/Director of EEO who reports and is di- rectly responsible to the agency’s chief executive officer. Since managing the EEO program requires a major commitment of time and resources, the Manager/Director of EEO should be given top management support and assigned a staff commen- surate with the importance of this program. (15) Diversity and affirmative action efforts should cross racial, gender, ethnic, and occupational lines. In the article, “Creat- ing Status of Women Reports: Institutional Housekeeping as ‘Women’s Work,’” the authors discuss how committees that collect, analyze, and interpret data associated with recruiting, retaining, and promoting female students and faculty have traditionally been staffed by female members of the faculty (21). The authors argue that institutions also need to take responsibility for improving the status of women. Academia is not alone in recognizing the need for institu- tional responsibility; the transit industry has also acknowl- edged that it is imperative that the entire organization take responsibility for diversity and affirmative action goals. As stated in FTA’s guidelines: Although the agency’s EEO program manager has primary re- sponsibility for implementing agency’s EEO plan, carrying out EEO and affirmative action is an integral function of all officials, managers and supervisors. Management—from the supervisor of the smallest unit to the chairman of the board or chief executive officer—bears the responsibility of ensuring that the agency’s EEO policies and programs, as outlined in its EEO program, are carried out. (15)

28 Suggestions for Further Research Benchmarking can take several forms. A U.S. Depart- ment of Defense report (www.defenselink.mil/comptroller/ icenter/learn/bestpracconcept.pdf) discusses four forms of benchmarking: • Internal benchmarking, which studies the practices and performance within the organization itself. • External benchmarking, determines the performance of others, preferably world-class organizations. • Quantitative benchmarking, which allows organizations to measure progress toward goals and to set improvement ob- jectives in terms of specific performance measures or metrics. • Process benchmarking, which examines how top- performing companies accomplish a specific process. These studies are undertaken through research, surveys, interviews, and site visits. As part of this project, the research team began identifying internal and external benchmarks. For internal benchmarking, Virginia DOT was identified as an organization that exhibited best practices. The agency met the conceptual framework in that it • Was compliant; • Reported its employment counts by categories that were consistent with the EEO-4 categories; • Provided a comprehensive affirmative action report in that it not only completed an EEO-4 form but also conducted a utilization and availability analysis, as well as an analysis of the application flow; and • Could be confident in the data it produced because it has instituted an applicant tracking system and because the DOT commissioner has effectively communicated both the importance of having a diverse workforce and his in- tent to hold everyone within the organization accountable for results. In Best Practices of Private Sector Employees (www.eeoc. gov/abouteeoc/task_reports/prac2.html), EEOC defined a best practice as one that • Complies with the law; • Promotes equal employment opportunity and addresses one or more barriers that adversely affect equal employ- ment opportunity; • Manifests management, commitment, and accountability; • Ensures management and employee communication; • Produces noteworthy results; and • Does not cause or result in unfairness. The research team has identified the Department of Inte- rior as an external benchmark, because it seems to have a good process for tracking progress toward achieving diversity goals and for holding people accountable for results. The perform- ance measures included in the Department of Interior’s strate- gic plan can be used as a guide for developing quantitative benchmarks. The disproportionality analysis could be expanded to look at internal and external factors that affect whether there is a disproportionality between an agency’s utilization and avail- ability of women and minorities. Regression analysis could be used to determine what percentage of the disproportionality might possibly be attributed to internal and external variables. Possible internal factors to be analyzed could include • Total number of agency employees, • Percentage of staff working in the EEO division, • Total agency budget, • Percentage of agency budget allocated to the EEO program, • Percentage of agency budget coming from federal funds, • Percentage of agency budget coming from local funds, • Type of agency (public, private, public with private con- tractors), • Agency leadership (commission, board, etc.), • Number of EEO complaints, • Number of open positions, • Number of applicants, • Number of new hires, and • Number of promotions. Possible external factors to be analyzed could include • Total population in service area, • Percentage of minorities (disaggregated by racial/ethnic classification), • Percentage of women, • Poverty rate, • Unemployment rate, • Percentage of population with a high school diploma (dis- aggregated by racial/ethnic classification), • Percentage of population with a college degree (disaggre- gated by racial/ethnic classification), • Home ownership rate, • Density, • Whether affirmative action ban has been proposed or passed by state legislature, and • Political affiliation of government official (governor, mayor, county administrator). A process benchmark would provide insight into the prac- tices of successful agencies. The web survey developed for this project could be expanded to serve as one means of investi- gating best practices that could lead to the development of process benchmarks.