CFPB Report: 2015-MO-C-002 March 4, 2015
According to GAO, an agency with a diverse workforce that includes minorities and women in key positions benefits from multidisciplinary knowledge and skills that can help the organization better accomplish its mission and goals and increase innovation.69 An agency that effectively manages its employees provides for equal opportunities, which is essential to attracting, developing, and retaining the most qualified workforce. GAO further states that when an organization's top leaders demonstrate the importance of diversity and inclusion initiatives, a clear message is sent about the organization's commitment to diversity management.
The CFPB has taken steps to enhance its diversity and inclusion practices, including, but not limited to, contracting with third-party consulting firms to review its major human capital processes (e.g., performance management, hiring, promotions, and compensation); elevating OMWI and the OEEO to the Office of the Director; conducting listening sessions with its employees to identify and respond to perceptions of fairness, equality, and inclusion at the CFPB; and creating the Executive Advisory Council, the Diversity Hiring Working Group, and the Diversity and Inclusion Working Group to work on diversity and inclusion issues. The CFPB has also conducted data analysis related to diversity and inclusion, such as its internal analysis of its FY 2013 performance ratings and its identification, monitoring, and reporting of significant trends in complaint processing activity as part of its annual MD-715 reporting.
We identified four areas in which additional actions could be taken to enhance the effectiveness of the CFPB's diversity and inclusion efforts.
Training--By not requiring employees to attend training on performance management and diversity and inclusion, the CFPB risks supervisors and senior managers implementing related policies and managing employees in an inconsistent manner. In addition, an increased awareness and understanding of diversity among staff, supervisors, and senior managers can improve communication, employee productivity, and organizational performance.
Data Quality and Monitoring Trends--Data quality issues exist in the CFPB's tracking spreadsheets for both EEO complaints and negotiated grievances. As a result, the CFPB may be relying on inaccurate data to identify and analyze trends and may have an increased risk of reporting incorrect information. Further, we found that when trend data were available for performance management, the CFPB missed opportunities to analyze certain data for potential diversity and inclusion issues.
Supervisors' and Senior Managers' Accountability for Diversity and Inclusion--A diversity and inclusion strategic plan has been developed, but not implemented, that includes diversity and inclusion best practices such as leadership and accountability. Further, supervisors' and senior managers' performance assessments do not specifically require them to take steps in support of the CFPB's diversity and inclusion initiatives. Additionally, supervisors are not consistently implementing the CFPB's performance management policies, such as the requirement to provide counseling for employees at risk of falling below the acceptable level of performance. Tying supervisors' and senior managers' performance ratings to their diversity and inclusion efforts should help ensure that all employees, including minorities and women, have equal opportunities for advancement.
Succession Planning--A formal succession planning process could help the CFPB ensure that it will have a sufficient and diverse pool of candidates for its executive positions and mission-critical positions. Specifically, succession planning can help the CFPB diversify its executive workforce by forecasting senior leadership needs; identifying and developing candidates for future leadership positions; and selecting individuals from among a diverse pool of qualified candidates.
It is important to note that while our report focuses on specific CFPB diversity and inclusion initiatives and human resources-related activities, initiatives and activities that are beyond the scope of our review also contribute to enhancing diversity and inclusion principles. Additionally, for the purposes of our review, we focused on diversity in gender, race/ethnicity, and age, which are only three individual attributes that contribute to the diversity of an organization's workforce. In considering the factors that impact diversity and inclusion, the CFPB should continue to incorporate GAO's nine leading diversity management practices.
