National Council of EEOC Locals, No. 216


Gabrielle Martin, President

c/o Denver District EEOC Office

303 East 17th Avenue, Suite 510

Denver, Colorado    80203


                                                   September 9, 2004


Chair Cari Dominguez

Vice Chair Naomi Churchill Earp

Commissioner Leslie E. Silverman

Commissioner Stuart J. Ishimaru

Equal Employment Opportunity Commission

1801 L Street, N.W., 10th Floor

Washington, D.C.  20507


Re:     National Council of EEOC Locals, No. 216, Requests A Public Vote

On the Establishment of a National Call Center


Dear Chair Dominguez, Vice Chair Earp, Commissioners Silverman and Ishimaru: 


In a June 28, 2004, E-mail distributed to all EEOC staff, Chair Dominguez stated, “[w]e hope that before the end of the fiscal year a recommendation for award of a contract [for a national call center] will be ready for submission to the Commission.”  The fiscal year ends in three weeks.  The National Council urges the Commissioners to conduct this vote in a public Commission meeting, which allows for sufficient notice to interested parties who would want to attend and prepare testimony.


According to the Chair’s testimony at the March 25, 2004 Congressional Oversight Hearing, “the commissioners voted to explore the concept”of a call center.  That vote was made by way of a secret notation vote.  A final vote, conducted in the sunshine, should weigh the cost-benefit analysis of approving a privatized call center.   Thus far, the Commission has never made public the facts and figures to back its claims that an in-house call center is cost prohibitive.    The vote should also consider “a carefully monitored and studied pilot program in two or three volunteer offices,” as recommend by EEOC’s Regional Attorneys, rather than the riskier and more costly approach of going nationwide from the outset.    In addition, a public hearing should also include testimony and caller surveys from Federal agencies, which have experimented with a call center.  For instance, the use of a National Call Center for the Bureau of Citizenship and Immigration Services suggests that customer service and satisfaction has decreased with increased usage of a national call center staffed by contract employees.


As all of you are aware, there is grave concern among bargaining unit employees, managers, stakeholder groups, and members of Congress about the wisdom of establishing a nationwide privatized contact center.   The fact that there is such widespread concern is reason enough for any vote to be conducted in an open and public session of the Commission.  


As the Union which represents EEOC’s employees, we have a special stake in the outcome of the Commission’s call center vote.  Employees in EEOC’s fifty-one offices are stretched dangerously thin.  This is the case because 300 employees have been lost and not replaced during a three-year hiring freeze.   Money spent on a call center is money diverted away from replenishing our own EEOC staff.  Not only have EEOC jobs already been lost, but the National Academy of Public Administration recommended that EEOC move “toward having fewer field locations and a National Call Center.”  Fewer field locations means future EEOC job loss.   For these reasons, among others, the Union opposes the creation of a privatized call center.  


A vote that will impact the public should be conducted in public.   Privatizing EEOC’s initial communications with the public is a drastic change in the delivery of customer service.  When Congress established the EEOC through Title VII of the Civil Rights Act of 1964, it contemplated that Commission employees, not telemarketers, would enforce the law and provide advice and guidance to the public.   The public will experience diminished customer service when they are forced to deal with amateurs, who rely on 6 days of training and a script, rather than experienced EEOC staff.  Moreover, EEOC’s intention to lift its order prohibiting recording of conversation of the public, in order to monitor contact center calls, will be a deterrent for victims of discrimination calling to discuss sensitive claims, such as sexual harassment. 


The Commission’s decision to set the call center in motion carries significant risk.  While a pilot is typically tested on a small-scale, the Commission’s call center “pilot” will be nationwide from the start.   A vote authorizing such a major change in the agency’s operation, will greatly impact the public and Commission employees.  Such a decision should not be authorized behind a procedural veil of secrecy.   The public should have an opportunity to testify, observe, and hold accountable the EEOC Commissioners, who will be voting on their future. 


A public Commission vote on the call center is necessary.  However, any vote between now and September 30, hardly allows for meaningful public participation.  





Gabrielle Martin

President, National Council of EEOC Locals, No. 216 AFGE/AFL-CIO