Report Contents
What OIG Reviewed
In 2024, at the request of the then-Under Secretary for Management, the Office of Inspector General (OIG) initiated an evaluation to determine whether the Office of Civil Rights (S/OCR) has policies and procedures to avoid conflicts of interest in both equal employment opportunity (EEO) and AntiHarassment Program (AHP) cases and how these policies are communicated to employees.
What OIG Found
The Equal Employment Opportunity Commission requires that federal agencies adopt procedures to avoid conflicts of interest within EEO offices, such as when an employee of an EEO office initiates a complaint or is the subject of one.
OIG found that while the EEO and AHP programs within S/OCR are separate and distinct programs, it is important to mitigate conflicts of interest in both, yet S/OCR does not have consistent processes for doing so. OIG also found that S/OCR policies on conflict cases were outdated. The lack of consistency and current procedures has resulted in considerable confusion among Department of State (Department) officials as to how conflicts of interest are handled in S/OCR.
OIG also found that S/OCR has not developed and issued clear information for Department employees on how conflicts of interest are handled. Finally, OIG identified best practices for handling conflict cases, such as the involvement of ethics attorneys and conflict case managers, but found that S/OCR has only partially adopted such best practices. These practices are important to ensure the fairness and consistency of complaints.
What OIG Recommends
OIG made three recommendations to S/OCR to adopt consistent and current conflict of interest procedures for both EEO and AHP cases, to adopt a standard practice to consult with the Office of Legal Adviser when EEO or AHP complaints involve a current or former S/OCR employee to ascertain whether there is a conflict of interest and seek guidance on proper handling, and to include current information on conflict case procedures on its intranet page. S/OCR concurred with all of the recommendations.
Report Terms
Report Recommendations
The Office of Civil Rights should adopt consistent and current conflict of interest procedures for both equal employment opportunity and anti-harassment program complaints that include use of a conflict case manager.
The Office of Civil Rights should adopt a standard practice to consult with the Office of the Legal Adviser in any case involving a complaint involving a current or former Office of Civil Rights employee to ascertain whether there is a conflict of interest and to seek guidance as to proper handling of the complaint.
The Office of Civil Rights should update its intranet page to include current and comprehensive information on conflict case procedures.