Yesterday, I highlighted the Acting Executive Director’s letter defending his agency from stinging criticism by a Connecticut attorney in the Connecticut Law Tribune.   In that post, I indicated that if the CHRO was going to change its image, it needed to get its own house in order.  For employers, this is important because a fully-functioning CHRO can save time and effort in cases before that agency.

First on the agenda should be ensuring that the CHRO meets all legally required deadlines.  Case in point — the CHRO missed a deadline this summer that it is actually responsible for overseeing.

Here’s the background: the CHRO is responsible for overseeing the affirmative action plans of agencies from across the state.  In July 2008, the CHRO submitted its own  affirmative action plan for review at a meeting of various CHRO Commissioners (who sit much like a Board of Directors for a corporation). Amazingly, the CHRO’s staff recommended "disapproval" of the plan because it was filed more than 90 days late and in violation of various laws and regulations.

Let that sink in for a minute:  One CHRO staff member submitted an affirmative action plan to the CHRO Commissioners to vote on while the person reviewing the plan itself recommended rejecting the plan because it was not in compliance with the law. 

More background:  Minutes from the July 2008 meeting of the CHRO reflect a lengthy discussion of the issue and significant criticism by the CHRO commissioners; ultimately, the commission voted to reject the recommendation of the CHRO staff to disapprove the plan and the issue of the plan was put on the agenda to discuss again at the August 2008 commission meeting.

The minutes from the August 2008 Commission meeting discuss the fact that the CHRO’s plan was submitted 127 days late.  At that meeting, Mr. Brothers is quoted as saying that he was "embarrassed" by this.  The minutes reflect that there were disagreements about the plan as well. Ultimately, the Commissioners only "conditionally approved" of the CHRO’s own affirmative action plan.

If this were an isolated incident, you could write this off.  But last year, the CHRO’s AAP was also recommended for "disapproval" by CHRO staff members. According to the minutes of the May 2007 meeting, the CHRO recommended disapproval of the plan based:

on non-compliance with the following: the workforce is not in
parity with the relevant labor market area, the agency has not met all or
substantially all of its hiring, promotion and program goals and the agency has
not demonstrated every good faith effort to achieve its unmet goals. 

If the CHRO is indeed serious about improving its image (as I believe, from Mr. Brothers’ remarks that it is), then events like these must stop.  After all, how can the CHRO claim the moral high ground in enforcing anti-discrimination laws when it has trouble following them too?