Commission on Human Rights and Opportunities Recommendations

Legislative Program Review and Investigations Committee

Committee Approved Recommendations
December 16, 1999

Commission on Human Rights and Opportunities

The appointment of CHRO commissioners shall be subject to the advice and consent of either house of the General Assembly.
CHRO should re-evaluate its guidance documentation for investigators and maintain well-trained staff at the intake and MAR stage to ensure each case receives full and consistent assessment among all regions. MAR activities should be closely monitored to detect unintentional over- or under-screening of complaints and identify any problems in regional application of standards. The agency must also ensure commission members are kept informed of MAR activities on a periodic basis as prescribed by C.G.S §46a-83(b).
CHRO should separate the mediation and investigations components, and establish clear and consistent policies on mediation activities. The commission should incorporate these policies into the agency’s training curriculum.
CHRO should make sure respondents are informed when complainants are represented by counsel when the respondent is notified of the complaint.
The Chief Human Rights Referee must establish uniform operating policies, procedures, and guidelines clearly defining the role and function of the Public Hearing Office. Adoption or any changes to the policies and procedures shall be duly communicated to the full Commission on Human Rights and Opportunities. It shall be the responsibility of the Chief Human Rights Referee to ensure all human rights referees are adequately trained in the uniform implementation of the policies and procedures.
CHRO shall institute a follow-up evaluation form for parties involved in the complaint process to provide feedback on their experience with the agency's handling of discrimination complaints. The process should offer the parties to the complaint a confidential forum to submit observations, suggestions, concerns, and comments directly to central office management. The information should be reviewed and summarized on a periodic basis and results shared with the regions and the commissioners.
Committee staff supports the discontinuation of evaluating staff performance on numerical standards. CHRO should establish performance standards reflecting the quality of the work and/or the difficulty of case as well as the effective management of caseloads such as regular and timely activity.
CHRO shall conduct a formal evaluation of the current training curriculum and an assessment of training needs of the agency. Based on the evaluation, CHRO should develop and institute a comprehensive training and professional development program. This program should be designed to provide extensive training in civil rights law, investigative techniques, mediation, analytical methods, communication skills, and other necessary areas. It should be tailored to fit the needs of enforcement staff at each level of the process including, but not limited to, intake, merit assessment review, and investigation. Training should also be provided to staff involved in the public hearing process including, but not limited to, commission counsel and human rights referees. In addition, CHRO should conduct ongoing assessment of training needs of the agency's enforcement staff. The assessment results should be monitored and used to adjust the training curriculum and to identify areas for staff improvement whenever necessary.
CHRO should review both its Investi-GATOR manual and the Field Operations Interpretive Guidelines for ease of use by investigators in the regional offices, and ensure they represent current agency practice.
CHRO must re-examine its coding system. Specific codes should be developed with input from system users. Written definitions for each code should be provided to agency staff and training given to implement a uniform coding system to facilitate tracking of complaint trends and outcomes.

Clear accountability should be assigned for assuring consistent, uniform, and accurate data recording.

CHRO shall establish a uniform, automated management information system for the regions that captures essential enforcement case information and results in the production of valid, reliable data. The system, at a minimum, should include, but not be limited to, the following:

critical case processing milestones, such as MAR dismissal and retention dates, cause determination dates, and reconsideration and closed dates;
case information, such as attempts at mediation and whether parties have legal counsel;
case outcomes information, such as type of resolutions;
the ability to generate standard management reports on the timeliness and performance of individual personnel as well as regions in completing investigations; and
the ability to generate customized reports when necessary.

CHRO shall develop a set of performance measures to be used in evaluating the agency’s overall performance as well as all key components and phases of the process. At a minimum those standards shall address:

specific time frames for complaint handling, public hearings and outcomes; and
the components of settlements, such as job reinstatement, back pay, and other remedies.

CHRO should continue to assess its technological resources and equipment needs for its enforcement operations and develop a plan for addressing those needs as determined. The plan should aim to enhance accurate information sharing between field operations, the legal services unit, and the public hearing office.
CHRO should proceed with its plan to request additional staff resources.

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