All New 2007 OPM Report!

2007 Edition:  U.S. Office of Personnel Management Report
(6) Definitions and Computations

(Web Posted 7/23/07 -- Adversity.Net 2007)

All New 2007 OPM Report!

(6) Data Coverage and Definitions
(From page 46 of OPM's FEORP FY 2006 report)

What does 'underrepresentation' really mean? (1) What Does "Underrepresentation" REALLY Mean?
OPM Def of Civilian Labor Force (CLF) (2) OPM Definition of Civilian Labor Force (CLF)
OPM Def of Relevant Civilian Labor Force (RCLF) (3) OPM Definition of Relevant Civilian Labor Force (RCLF)
Computations and Math (4) Computations: How Adversity.Net Arrived at It's Numbers
Commentary (5) Adversity.Net Commentary

(1) Definition of Underrepresentation: Top

          "Underrepresentation, as defined in 5 CFR, Section 720.202, means a situation in which the number of women or members of a minority group within a category of civil service employment constitutes a lower percentage of the total number of employees within the employment category than the percentage that women or the minority group constitutes within the civilian labor force of the United States."

-- FEORP FY 2006 at page 46

Discussion and Illustration:

          According to the feds' statistics, 12.8% of the Relevant Civilian Labor Force (RCLF) is comprised of Hispanics.  This number allegedly represents the proportion of Hispanics in the general population who are qualified for the federal jobs under analysis.

Underrep_2006-2007.jpg (32757 bytes)
Chart from page 9 of the FY 2006 OPM report.
The red notations were added by our editors.
          The feds' employment data show that only 7.6% of federal jobs (Federal Workforce, or FW) for which the Hispanics are qualified are actually filled by Hispanics.

          Under the law this means Hispanics are "underrepresented" in the Federal Workforce by -5.2% (12.8% RCLF - 7.6% FW = -5.2%).  This, in turn, triggers an "affirmative action plan" by the feds to increase their employment of Hispanics by at least 5.2% over current federal levels.  (As the preponderance of the data show, there is actually no upper limit on federal hiring of preferred minorities.)

          Very reasonable, right?   Wrong!  This is only a reasonable and just policy if you buy into the notion that every race, skin color, and gender is entitled to proportional representation in all employment opportunities.

          But where does it say that in the U.S. Constitution or in the Bill of Rights?  One must reasonably ask are we a country that promises equal opportunity based upon effort and ability regardless of skin color, or are we a country that promises equal results based on skin color?

          Furthermore, there are some insurmountable problems with the way in which the feds compute the underrepresentation of of "Hispanics".

          First, the Civilian data used by OPM to compute "underrepresentation" includes non-citizens and unemployed individuals, whereas the Federal Workforce (FW) data, by their own definition, includes only employed individuals who are predominantly U.S. citizens.  This chart illustrates the non-comparability of the two sets of data used by OPM:

  Included in the
Included in the
Relevant Civilian Labor
U.S. Citizens: YES YES
Non-U.S. Citizens: NO YES!
Employed: YES YES
Unemployed: NO YES!
Resulting Proportion of Hispanics: 7.6% 12.8%

          The inclusion of non-citizen Hispanics, unemployed Hispanics, and undocumented (illegal) immigrants greatly inflates the RCLF which in turn greatly overstates the alleged "underrepresentation" of Hispanics in the fed workforce.

          The U.S. Government Accountability Office (GAO) issued a report last year in which they strongly urged the feds to take citizenship into account when computing the representation of Hispanics.   According to GAO, both OPM and the U.S. EEOC rejected this suggestion.  This is evident in the current FEORP FY2006 data which Adversity.Net has analyzed.

          Furthermore, the GAO report showed that the likelihood of Hispanics being employed by the federal government is actually higher than for non-Hispanics when the population data are adjusted for citizenship and education!

          GAO's report to Congress in substantial part stated the following:

          The EEOC and the U.S. Office of Personnel Management should discontinue their practice of counting non-citizen Hispanics in the Civilian Labor Force (CLF).  After all, as GAO helpfully points out in their report, the federal government does not hire non-citizens except in extremely rare instances.

          Furthermore, GAO reports that when U.S. citizenship and level of education are taken into account, Hispanics are 24% MORE likely to be federal employees than non-Hispanics!

          According to GAO's report, both the EEOC and OPM were unenthusiastic about these recommendations.  In fact, as our analysis of the OPM's FY 2006 hiring data clearly show, OPM has completely ignored the GAO's recommendations.  Read all about the GAO Report.

GAO Report
August 2006

GAO Aug. 2006: Do NOT Count Non-U.S. Citizens!
See the August 2006  GAO report which strongly recommends that the feds STOP counting non-citizen Hispanics in calculating racial quotas.
See our

(2) Definition of Civilian Labor Force (CLF): Prev

          "The Civilian Labor Force (CLF) percentages for each minority group presented in this report are derived from the Bureau of Labor Statistics' Annual Current Population Survey (CPS). The CPS data cover non-institutionalized individuals 16 years of age or older, employed or unemployed, U.S. citizens and non-U.S. citizens."

-- FEORP FY 2006 at page 46

(3) Definition of Relevant Civilian Labor Force (RCLF): Previous

          "The Relevant Civilian Labor Force (RCLF) is the Civilian Labor Force (CLF) data that are directly comparable (or relevant) to the occupational population being considered in the FW. For example, we would compare Black engineers employed in the Federal workforce with Black engineers reported in the RCLF. In this report, the RCLF varies from agency to agency because of the differing occupational mix within each agency."

-- FEORP FY 2006 at page 46

(4) Adversity.Net's Computations

How We Calculated Over and Under Hiring of Minorities Using OPM's Data


          The percentages in Columns A and B of all of our tables have been computed by OPM and we have duplicated these numbers exactly from OPM's official FY 2006 report.  Columns C and D were computed by Adversity.Net based upon the OPM data in Cols A and B of our tables.

Column A:  OPM data shows 8.6% as the proportion of blacks available in the civilian population for the specific jobs and agency in question (EEOC in this example).  This constitutes a de facto "affirmative action target" (quota) for EEOC.

Column B:  OPM data shows that 43.1% of EEOC's workforce are blacks.

Column C:  This is an intermediate number used in Adversity.Net's calculations and is simply the difference between (A) the "racial target"; and (B) the actual employment of that race by the agency.  In the case of blacks at the EEOC the difference between (A) and (B) is +34.5%

Computation of Column C:
          Col B - Col A = Col C (difference between target "A" and actual employment "B")

Column D:  Using a simple computation, Adversity.Net used OPM's data to show that the percentage of blacks in GSA's workforce is 401.2% higher than the proportion of blacks in the civilian population.  The simple computation is as follows:

Computation of Column D:
( Col C / Col A ) X 100 = Col D (rate of over or under hiring, expressed as a % of the racial 'target' or 'goal' stated in Column A)

In this example, Col. C = 34.5 and Col. A = 8.6.  Using these numbers:

(34.5 / 8.6) X 100 = 401.2% more blacks work at EEOC than their proportion in the relevant civilian labor force.

          Adversity.Net defines this as "over hiring" of the designated minority group.  OPM, however, does not define "over hiring" or even "overrepresentation".

2007 OPM Annual Report to Congress (FY 2006 Hiring Data)
EXAMPLE: Tabulation of Minority Hiring at the U.S. EEOC
Site Index
% in Relevant Civilian Labor Force (RCLF)
(affirmative action target)
% in Federal Workforce (FW)
(actual % employed by EEOC)
Difference between target (col A) and actual (col B)
Rate of OVER (under) hiring selected minority groups by EEOC
Blacks 8.6 43.1 +34.5 +401.2%
Interpretation:  EEOC employed 401.2% more blacks than their proportion in the civilian labor force
Hispanics 6.5 13.0 +6.5 +100.0%
Interpretation:  EEOC employed 100.0% more Hispanics than their proportion in the civilian labor force
Asian Pacific Islanders 4.8 3.7 -1.1 -22.9%
Interpretation:  EEOC employed 22.9% fewer Asian Pacific Islanders than their proportion in the civilian labor force
Native American 0.9 0.7 -0.2 -22.2%
Interpretation:  EEOC employed 22.2% fewer Native Americans than their proportion in the civilian labor force
Women 67.5 66.9 -0.6 -0,9%
Interpretation:  EEOC employed 0.9% fewer Women (of all races) than their proportion in the civilian labor force
  Note 1 Note 1 Note 2 Note 3
Note 1 -- Source: OPM "Annual Report to Congress; Federal Equal Opportunity Recruitment Program FY 2006" (October 1, 2005 - September 30, 2006).  Current link to original OPM report:

Note 2 -- Our computation:  Col (B) - Col (A) = Col (C)

Note 3 -- Our computation:   [Col (C) / Col (A)] X 100 = Col (D)

(5) Adversity.Net Commentary Previous
Index - Bottom

          The Code of Federal Regulations (5 CFR 720.202) cited by OPM defines underrepresentation in such a way that white males and other, non-preferred groups cannot, by definition, be "underrepresented" in federal employment and presumably therefore cannot claim racial discrimination by their federal employers when they are denied a job or promotion due to their non-preferred status.

          Significantly, in the approximately 50 pages of fine print comprising the OPM report there is not one, single graphic or table illustrating the the proportion of white males employed by the feds.

          Equally pointedly, OPM also does not define a concept of overrepresentation whereby hiring too many members of preferred racial groups would be discouraged if not illegal.  This is quite evident in OPM's FY2006 report:  The GPO employs 503% more blacks than their proportion in the available civilian population.  HUD employs 363% more blacks than their quota, while the Dept. of Education employs 329% more blacks than their quota.

          In fact, the FY2006 OPM report -- just as the previous 6 years of data we have analyzed -- continue to clearly illustrate that overrepresentation of selected, preferred races (overhiring) by the federal government is the rule and not the exception.  Further, the practice is obviously strongly encouraged especially as regards the hiring of blacks.

Tim Fay, Editor

Top of Page

More FY 2006 Charts and Excerpts:

FY 2006 OPM Report           FY 2006 OPM Report           FY 2006 OPM Report
OPM FY2006 Minority Hiring


Asian - Pacific Islanders
Native Americans
(6) Definitions, Math
END: (6) OPM Definitions and Computations FY 2006