Appendix VIII: Comments &om the 

 Department of Energy 



Education Amendments of 1972. 



Second, in S^tember 2000, the Director, OCRD, issued a memorandum to all 

 EEO/Diversity Managers regarding the need for conducting civil rights compliance 

 reviews. The memorandinn sets forth the Departments' civil rights responsibilities and 

 the requirements that OCRD conduct field reviews of the field ofiice's responsibilities 

 and efforts to ensure compliance with Federal law by recipients of financial assistance. 



Third, in September 2000, the Office of Civil Rights and Diversity also published and 

 disseminated a handbook entitled, Conducting Compliance Reviews of Federally Assisted 

 Programs. This handbook was disseminated to all Diversity Managers having 

 enforcement responsibilities under Title DC and other civil rights statutes. In addition, on 

 October 23 and 24, 2002, OCRD sponsored civil rights training for its Diversity 

 Managers. The Department of Justice, Coordination and Review Section, conducted the 

 training. Twelve (12) of the 16 field EEO/Diversity Managers received the training, as 

 well as some headquarters and procurement staff. The training dealt primarily with Title 

 VI, however, DOE's Title DC and Title VI complaint processing regulations are the same. 



Fourth, since July 2000, OCRD has conducted civil rights compliance reviews at ten (10) 

 of the Department's 16 field offices. The aim of the reviews has been to assess the 

 adequacy and effectiveness of each field offices' civil rights compliance program, 

 including its system of enforcement and oversight of recipients of Federal financial 

 assistance, including Title DC OCRD has dedicated one staff person as a reviewer of the 

 field office Title DC program of enforcement The reviewer evaluates the program of pre- 

 award and post-award compliance, notification and outreach programs, and the field 

 offices' complaint processing program. While the field offices have not conducted Title 

 DC field compliance reviews, OCRD has reminded each field office reviewed of its 

 obligation to conduct such compliance reviews of its grantees. Field office managers, 

 procurement and EEO/Diversity managers have consistently, however, stated that they 

 lack the staiTing and office resources to conduct civil rights compliance reviews of their 

 grantees. 



Fifth, in fiscal year 2002, the Department awarded 1724 grants and cooperative 

 agreements. The Department conducted 732 pre-award reviews, of which 48 were desk 

 audits. DOE's pre-award process consists of obtaining a DOE FORM 1600 5, Assurance 

 of Compliance, executed and dated by the authorized official, and in many cases, a 

 questionnaiie is completed by the recipient. The pre-award review is an important part of 

 the compliance process, in that it assures tiiat the recipients are meeting the requirements 

 of DOE's regulations governing nondiscrimination at the time the award is made. 



In addition, the Department headquarters procurement office includes in its grant 

 packages a Title DC brochure developed by the Office of Civil Rights and Diversity 

 entitled, Nondiscrimination on the Basis of Sex in Federally Assisted Programs. A 

 poster is also made available to recipients entitled, £91^/ Opportunity: It 's the Law! 



Page 43 GAO-04-639 Gender Issues 



