Posted by Katie Johnson, PHR, SHRM-CP, HR Consultant on August 25 2015
Katie Johnson, PHR, SHRM-CP, HR Consultant


Often when we think about action-oriented programs, we think of recruiting – posting jobs on diversity sites, participating in career fairs, and forming relationships with organizations that provide diverse candidates, just to name a few. An important but sometimes overlooked piece of action- oriented programs is training. Training can take many shapes and can include training offered in-house by the company, or training provided by an external vendor. Training could also be programs offered to employees or development programs created to attract new talent. Not only is training important for employees to stay up to date on important topics, it can also be used strategically to address problem areas identified in your AAP development. 

Training should also be used to ensure that those accountable for employment related processes understand their responsibilities. Often, through the development of AAP narratives and data analyses, contractors closely review their data and through research into initial flags identified in the analysis, may identify specific procedures or inconsistent application of procedures causing the issue.

The issue may be with recordkeeping, a lack of data, or employees not being aware of a policy or requirement that ultimately impact 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 recruiters are using the same disposition reasons for different situations.

Whatever the data issue is, once it is uncovered, you can use training as an opportunity to get everybody on the same page and make sure they are all aware of the correct processes. 

Training can also be used to educate employees on compliance-related issues. 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 may take the opportunity to train employees on what the self-id responses are used for and that they will not impact employment opportunities. Using training can help increase participation by employees and help alleviate any concerns with completing the forms. 

Providing training opportunities for employee development is also action oriented. An area of focus with AAPs is promotions. You may find there is talent within the organization that could be developed to promote internal movement. Creating development programs for employees is a great way to help current employees gain the skills and knowledge needed to progress in their careers and can help employers tap into existing talent.

Training/development programs could also be used to recruit new talent. Some organizations, through partnerships with local outreach organizations use training, apprenticeship, or internship programs to recruit external candidates and help them develop skills for various roles within the organization. 

It is important for companies to not only train employees for skills to perform their current jobs, but also to strategically use training as an opportunity to develop action-oriented programs in their AAPs. In addition to providing training opportunities to employees, contractors should also be sure to highlight training and development programs in their AAP narratives. This can be a great way to show OFCCP your commitment to affirmative action and to show that you have taken steps towards increasing your compliance and addressing any problem areas. 

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Katie Johnson, PHR, SHRM-CP, HR Consultant
Katie Johnson, PHR, SHRM-CP, HR Consultant
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.

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