What Are Your Training Obligations As a Federal Contractor?

Pulling all the necessary data points, policies, and other information together to create your affirmative action plans is a significant task. But while you’d be forgiven for sitting back and congratulating yourself on a job well done once your plans are drawn up, the ongoing execution of your program will leave little room for complacency! In this article, we look at the next logical step after plan completion: training your employees on affirmative action.

What Training Should a Federal Contractor Provide?

So, your affirmative action plans are complete—what’s next? You’ll have employees at every level of your organization who’ll prove critical for engaging with the plan and taking steps toward your organizational goals. To ensure you get the best results—and to meet your obligations as a federal contractor—it’s critical that your employees are educated on the aims and proper execution of affirmative action, ethics, and key workforce compliance topics.

"The OFCCP requires all federal contractors to show their good faith compliance with its affirmative action program requirements. Without training you’re taking a big risk: employees may be unaware of what they need to do, or may be resistant to the goals of affirmative action without an opportunity to learn what it involves and what it requires."

If your organization is a federal contractor with contracts over the thresholds detailed below, you should provide the following affirmative action compliance training:

Training on Your Affirmative Action Program and Discrimination Prevention

The OFCCP requires all federal contractors to show their good faith compliance with its affirmative action program requirements. In order to achieve this, organizations will need to educate HR personnel, managers, and senior leaders on the relevant details of their affirmative action program.

Executive Order 11246 (as amended), along with its implementing regulations, are administered by the OFCCP, and cover federal contractors or subcontractors with over $10,000 in federal contracts. Organizations subject to the order must refrain from discriminatory practices and engage in affirmative action to ensure that applicants and employees receive equal employment opportunity regardless of race, color, religion, sex, and/or national origin.

Without training you’re taking a big risk: employees may be unaware of what they need to do, or may be resistant to the goals of affirmative action without an opportunity to learn what it involves and what it requires.

MORE ON YOUR AFFIRMATIVE ACTION REQUIREMENTS | ‘Affirmative Action Scope: When Is an AAP Required, Who Should Be Included, and How?

How Can Affirmity Help?

Affirmity offers the following eLearning courses to help you fulfill these obligations:

  • Affirmative Action Compliance for HR/Managers/Senior Leaders: Covering information on the basics of affirmative action to fine-detail explorations of how to set placement goals, refine recruitment strategies, and address disparities.
  • Recruiter Compliance for Federal Contractors: This three-part interactive eLearning course introduces a recruiter’s affirmative action responsibilities and a range of related subjects.
  • Preventing Discrimination and Harassment: Establish the expected behaviors for building a respectful workplace with this course, which introduces employees to key concepts related to all forms of workplace harassment, retaliation, discrimination, bystander intervention, diversity, inclusion, and civility.

Click here to explore the full catalog.

ADA and Disability Discrimination Training

Employers with federal contracts or subcontracts exceeding $10,000 should also be aware of their obligations under Section 503 of the Rehabilitation Act of 1973, (as amended, 29 U.S.C. 793). Section 503 requires these organizations to take affirmative action and refrain from discriminating in employment with respect to individuals with disabilities.

Furthermore, the Federal Contract Compliance Manual states that “Contractors are required to train their personnel involved in recruitment, screening, selection, promotion, disciplinary and related processes about the company’s EEO obligations and, if appropriate, about the contractor’s affirmative action commitments under Section 503”, and it includes documentation providing proof of training to ensure implementation as part of its desk audit process.

How Can Affirmity Help?

Affirmity offers the following disability-specific eLearning courses:

  • Understanding the Americans With Disabilities Act (ADA): Supply employees with an overview of the ADA, an explanation of their rights, and an understanding of how the ADA applies in their workplace.
  • Recruiter Compliance for Federal Contractors: In addition to affirmative action more generally, this three-part course covers recruiter responsibilities under Section 503.

Click here to explore the full catalog.

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"Federal contractors and subcontractors must also provide training material required by the Federal Acquisition Regulations (FAR). Part 3 and Part 52 of FAR both mention the requirement to have a “compliance program and internal control system” to communicate and enforce the contractor’s written code of business ethics and conduct."

Code of Conduct and Business Compliance Training

Federal contractors and subcontractors must also provide training material required by the Federal Acquisition Regulations (FAR). Part 3 and Part 52 of FAR both mention the requirement to have a “compliance program and internal control system” to communicate and enforce the contractor’s written code of business ethics and conduct. Therefore, your organization should:

  1. Have a written code of business ethics and provide a copy of the code to all employees.
  2. Establish an ethics and compliance program (i.e. a formal training program) and internal control system of reporting mechanisms, audits, and disciplinary procedures that enables the timely discovery and correction of improper conduct.

How Can Affirmity Help?

Affirmity offers the following eLearning module that will satisfy the formal training program requirement:

  • Code of Conduct—Federal Acquisition Regulation (FAR): Covering all material required by FAR, this course is divided into brief episodes and covers a variety of ethically challenging situations employees may encounter.

Click here to explore the full catalog.

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"All federal contractors and grantees are subject to the Drug-Free Workplace Act of 1988, which makes providing a drug-free workplace a condition of receiving a contract or grant from a Federal agency. This includes a requirement to establish an on-going drug-free awareness program."

Drug and Alcohol Awareness Training

All federal contractors and grantees are subject to the Drug-Free Workplace Act of 1988, which makes providing a drug-free workplace a condition of receiving a contract or grant from a Federal agency.

This includes a requirement to establish: “an on-going drug-free awareness program to inform employees about (1) the dangers of drug abuse in the workplace, (2) the grantee’s drug-free workplace policy, (3) any available drug counseling, rehabilitation, and employee assistance programs, and (4) the penalties for drug-abuse violations occurring in the workplace.”

How Can Affirmity Help?

Affirmity offers the following training module covering the responsibilities listed above:

  • Drugs and Alcohol in the Workplace: This 20-minute course provides a definition of substance misuse and the potential consequences in your workplace. It also provides information about identifying the signs that someone may have a substance misuse issue, and a list of self-help sources.

Click here to explore the full catalog.

Ready to learn more about Affirmity’s training, services, and software for federal contractors? Connect with our team today.

About the Author

Kim Hendon headshotKim Hendon oversees account management and sales for Affirmity as Vice President of Sales. Having served with the company for more than 20 years, Ms. Hendon has in-depth knowledge and broad experience in all areas of compliance and diversity. Ms. Hendon assists clients with planning and development of affirmative action programs, diversity initiatives, and diversity training. She holds a Bachelor of Arts in Speech Communication and a Master’s in Business Administration.

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