Posted by Katie Johnson and Heather Fountain on July 31 2023
Katie Johnson and Heather Fountain


Often when we think about action-oriented programs, we think of recruiting - posting jobs on the company careers page, on diversity sites, and with state job banks, participating in career fairs, working with organizations that provide diverse candidates, and much more. Another essential and sometimes overlooked area of action-oriented programs is training. This training can take many shapes, target a variety of audiences for a variety of purposes, and may be offered in-house by the company or outsourced to an external vendor.


Training for compliance

  • Federal contractors must educate their management teams on the results of their affirmative action programs as well as their obligations as federal contractors and decision makers within the organization. Staff that are responsible for employment-related decisions and processes should have guided instruction on an annual basis to understand their responsibilities.
  • Training can also be used to strategically address problem areas identified in the affirmative action plan. Potential problem areas identified during the initial development of an AAP should prompt scrutiny of the data and processes. Research into red flags identified in the analysis may uncover specific procedures or inconsistent application of procedures causing issues. There may be a problem with recordkeeping, a lack of data, or employees not being aware of a policy or requirement that ultimately impacts the contractor’s compliance with AAPs.

    For example, you may find that recruiters are not accurately dispositioning candidates in a way that provides information on where and why the candidates fell out of consideration, or you may find that different recruiters are using the same disposition reason differently or inconsistently.

    Whatever the issue is, once it is uncovered, you can use training as an opportunity to get everybody on the same page and make sure all are aware of the correct processes and procedures. 
  • Training can also be used to educate employees on compliance-related programs. For example, a contractor may realize that they are not meeting their IWD utilization goal, not necessarily because of a lack of employees with disabilities, but because the response rates to the self-id form are low. Contractors could focus their action-oriented programs internally by informing employees about the purpose of the self-ID process, how the self-id responses are used, how employees can benefit from participating, highlighting resources available that support employees with disabilities, and reaffirming that information collected will not impact employment opportunities. This internal approach can help increase participation by employees, alleviate concerns about completing the forms, and inform employees of resources they may not already be aware of which in turn could improve their work performance. 

Training for development

Providing opportunities for employee development is also part of an action-oriented program. Employee development programs can be created and delivered internally or through partnerships with external organizations. These programs may be made available to current employees or externals individuals as a means of attracting new talent.

  • Encouraging employees to participate in development programs is a great way to help staff members gain the skills and knowledge needed to progress in their careers and can benefit employers by tapping into existing talent to fill roles within the organization. Promotions can also be a powerful retention tool for the company.
  • Training and development programs can also be used to recruit new talent from outside of the organization. Some Contractors use training, apprenticeships, or internship programs to recruit external candidates and help them develop the skills necessary for various roles within the organization. 

Contractors should highlight training and development programs in their AAP narratives. These programs show a commitment to affirmative action through action-oriented programs and may be part of your efforts to address identified problem areas.  

Learn more about Berkshire training



Katie Johnson and Heather Fountain
Katie Johnson and Heather Fountain
Katie Johnson, PHR, SHRM-CP is a Senior HR Consultant at Berkshire Associates Inc. With a comprehensive understanding of the inner workings of Office of Federal Contract Compliance Programs (OFCCP), Katie regularly advises her clients in the area of affirmative action and diversity. With over 15 years of experience in government contract compliance, Heather has worked in the areas of construction management, grant management, federal regulation compliance for contracts, finance, and procurement.

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