Statement of Nicholas M. Inzeo, Director, Office of Field Programs U.S. Equal Employment Opportunity Commission

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

I worked with the Chair, Lea Guarraia, the Chief Operating Officer, and Jim Lee, the Deputy General Counsel, in preparing this repositioning proposal for your consideration. I also want to acknowledge the enormous help of Ralph Soto of my office, who served on the Vice Chair’s Repositioning Taskforce and made himself available to me and other agency managers as a key resource in preparing this proposal. Ralph and Cynthia Pierre, the Director of Field Management Programs, are here today to assist in answering any questions that may arise.

One of the most important reasons to be here today is to obtain a decision of the Commission on the Chair’s repositioning proposal. As an agency, we have taken a long time thinking about and considering repositioning. During that time speculation and rumor, much of it unfounded, created considerable concern among employees and stakeholders. Agency managers expressed to me their desire to have a decision made. By making a decision those concerns can be placed behind us and we can focus on our mission of eliminating employment discrimination.

As soon as it became apparent to EEOC employees and managers that repositioning efforts were to begin, we heard the question, “What is the business case for repositioning?” To me, the business case for repositioning is the enforcement of this nation’s laws banning employment discrimination.

We have to ensure that we use as many resources as we can muster to enforce the law. The President has asked each agency to prepare a repositioning plan to be more customer-centered. OMB Bulletin 01-07 has defined this requirement to mean “deploying resources to direct service delivery positions” and “using workforce planning to flatten the Federal hierarchy.” As the Chair so clearly articulated at a recent meeting with State and Local Fair Employment Practices Agencies directors, when EEOC received a supplemental appropriation in 2002, Congress and OMB required additional financial reporting and a repositioning plan from EEOC. The Office of Management and Budget, and the Congress, assess agencies and approve budgets based on how well each agency has performed. During the current fiscal year we saw the lists of government programs that were cut or eliminated and government agencies that had to absorb significant cuts because their programs and structures were not customer-centered and results-oriented. EEOC cannot afford to be on that list of agencies.

An EEOC that is customer-centered must be structured around where the workload is located. This proposal looks to EEOC workload as the major criterion in deciding where EEOC offices should be located and what size they should be. Our largest offices should be where our largest workloads are. In order to make sure that everyone is served, from San Juan, Puerto Rico, to Honolulu, Hawaii, we must ensure that the size of each office and the size of our staff in each office are appropriate for the workload.

Reuben Daniels, Jr., who served as Acting Director of Field Programs, appeared before the Commission at a meeting in September 2003 to urge the Commission to reduce the span of control of headquarters’ program offices and expand the span of control of District Directors. As many as 25 offices reported directly to the Office of Field Programs. That span of control was too large and did not allow for effective communication nor for consistent operation. This proposal balances the span of control by reducing to 16 the number of offices reporting directly to Field Programs. The District Directors and Regional Attorneys in the 15 EEOC District Offices will have expanded workloads and expanded geographic responsibilities. This proposal ensures that the budget that OMB and Congress approve for EEOC will be well and wisely spent.

Perhaps most importantly, this proposal also provides additional resources for enforcing the law. By flattening the management and administrative ranks, we should be able to redeploy up to 80 staff to front-line positions with responsibility for investigations, mediations, outreach and litigation. In announcing this proposal to EEOC field managers in May, the Chair indicated that the next phase of repositioning will be to look at the headquarters structure. The Chair articulated her goal to reduce the headquarters operation by 20% and to redeploy those resources to front-line positions. Both the redeployment of field management and administrative staff and the redeployment of headquarters staff will enable us to provide better service to those individuals who come to EEOC.

The Chair has made it clear that the repositioning plan must also be employee friendly. First, no EEOC office will be closed. In fact, we will add two “Local” offices in Las Vegas, Nevada, and Mobile, Alabama. Second, under this proposal no EEOC employee will lose a job, be forced out through a “RIF” or reduction in force, or will be forced to relocate geographically.

As Lea indicated, we met with numerous stakeholder groups, briefed Congressional staff, and received numerous comments about this proposal. As a result, some refinements were made to the plan. Let me emphasize one change. Two weeks ago we met with the State and Local Fair Employment Practices Agencies (FEPA’s) in Atlanta, Georgia, at our annual meeting with them. Some FEPA representative had a concern with the proposal because it called for the jurisdiction of some states to be “split” between different district offices. Having had the opportunity to discuss those concerns with the Chair, the Commissioners and other Commission officials, we have modified the proposal so that both contract administration and the substantial weight review process would be performed by one district office. Our relationship with the FEPA’s will not create any additional “split” states.

As I indicated earlier, I believe that enforcement of the law is the clearest commitment that a Chair, and the entire Commission, can make. By protecting EEOC’s workforce, and utilizing our staff more efficiently, this proposal will help us protect the Nation’s workforce.

This page was last modified on November 14, 2005.