The U.S. Office of Personnel Management’s (OPM) mission is to ensure the Federal Government has an effective civilian workforce. To help accomplish the mission, it is important to collect accurate, comprehensive training information and make it available to decision-makers and others who have a vested interest in the training activities of the Federal government.

On May 17, 2006, OPM issued Final Regulations  requiring agencies to report accurate data and completed training events to OPM. To properly execute a Human Capital Strategic Plan, agencies must manage and collect training information in support of their mission objectives and strategic goals. In addition, all training must be properly evaluated to determine whether or not it provides meaningful contributions to agency results.

If you have any questions regarding training policy or executive development, you can contact the Training, Learning and Development Group by sending an email to HRDLeadership@opm.gov.

There are 27 mandatory data elements that agencies must report to OPM. Agencies should refer to OPM's Guide for Collection and Management of Training Information and Chapter 4 of OPM’s Guide to Human Resources Reporting for detailed guidance on collecting and electronically reporting the mandatory training data elements to OPM. Each training record should include all of the mandatory data elements. These data elements are included on the Standard Form (SF-182), Authorization, Agreement and Certification of Training.

The mandatory data elements must be reported to OPM under the following conditions:

• For each completed training event for each individual in the agency, including all
  subcomponents/bureaus;
• On a regular basis (at least monthly);
• For all types of training (e.g., traditional classroom, blended, etc.); and
• All records must include cost data even if the cost is $0.

Overhead costs must be reported by the end of the fiscal year. Overhead or development costs
consist of any indirect cost not associated with course delivery (e.g. utilities, salary, building
space). For those agencies unable to provide these costs at this time, OPM, at a minimum,
requires the following overhead costs of all agencies:

• Learning Management System (LMS)
• Online libraries (e-Learning packages)
• Employee licenses
• Commercial-off-the-shelf (COTS) products
• Course development costs unless captured by individual training records, which is the
  preferred method.

Responsibility for maintaining and storing training records is delegated to the agencies. Agencies develop their own internal policies for this purpose, but typically agencies keep records of approved training in their training files or learning management systems. Employees may want to keep their own record of any significant training, whether sponsored by their agency or taken on their own.

OPM’s Guide to Personnel Recordkeeping contains general policies on the creation, maintenance and disposition of human resources management records. As specified in 5 CFR 410.601, agencies must establish a schedule of records to be maintained in accordance with regulations promulgated by the National Archives and Records Administration (NARA) and the General Services Administration (GSA).

This guidance is intended to assist agency managers and providers of Federally sponsored diversity training, including human resource managers, human resource development specialists, organizational development specialists, special emphasis program managers, EEO managers, teachers, and instructors, with the design, delivery, and evaluation of diversity training.

Introduction and Basic Guidelines for Diversity Training

General Principles

The purpose of Government training for Federal employees is to assist in achieving an agency's mission and performance goals by improving employee and organizational performance. Agency officials are responsible for ensuring that their organizations' training needs are identified, programs are established to meet those needs, lines of authority are clearly identified, and all training programs contribute to the overall efficiency and effectiveness of the Federal service.

Diversity training, like other Federally sponsored training, should adhere to certain principles. It should:

• Have clearly stated goals and learning objectives that relate to the mission and needs of the organization;
• Use appropriate training approaches, methods and materials;
• Provide advance information to employees on course content and instruction methods, attendance policy, and alternatives for learning;
• Be provided in a supportive and non-coercive environment;
• Be conducted only by experienced and fully qualified instructors; and
• Be monitored and regularly evaluated.

The Principles for Implementing Diversity Training section of these guidelines discusses these points in more detail.

Goals of Diversity Training

The goals of diversity training are to help Federal employees understand:

• The legal and statutory requirements for Equal Employment Opportunity and Affirmative Action which support diversity in the Federal government and in private industry;
• That diversity is the similarities, as well as the differences, among and between individuals at all levels of the organization, and in society at large; and
• How diversity contributes to a richness in the organization by having a variety of views, approaches, and actions to use in strategic planning, tactical planning, problem solving, and decision-making.

Diversity training usually focuses on:

• Interpersonal skills Federal employees need to provide services to, work with, and manage persons and groups with similarities and differences;
• Behavior Federal employees are expected to exhibit in all workplace contacts -- behavior that respects each individual, preserves human dignity, honors personal privacy, and values individual differences as well as common characteristics; and
• The work environment and its relationship to effectiveness and efficiencies in organizational performance.

Management's goals for diversity training may include:

• Increasing employee awareness of equal employment opportunity laws;
• Increasing employee understanding of how diverse perspectives can improve organizational performance;
• Preventing illegal discrimination or harassment in the workplace;
• Improving workplace relations;
• Building more effective work teams;
• Improving organizational problem-solving; and
• Improving service to customers.

Agency goals for diversity training may be achieved through a specific course on diversity, such as "Managing Diversity," or by including diversity content in other agency training programs, such as "Introduction to Supervision," "Building Effective Work Teams," or "Customer Service Training."

Internal Review and Control

Agencies should review diversity training programs in advance of delivery. This review should include:

• Review by at least one level of management above the person who prepares or selects the materials;
• If training is developed or conducted by contractor, review of the training materials by a competent, knowledgeable training specialist with delegated approval authority;
• Review of the training material by an EEO official; and
• Consultation with the appropriate employee partnership mechanism.

In addition, agencies should use feedback mechanisms to monitor the quality and effectiveness of diversity training and the reactions of participants and instructors. The organizational need that the diversity training is intended to meet should be addressed in the design of the training evaluation.

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Principles for Implementing Diversity Training

Establish Clearly Stated Goals and Learning Objectives that Relate to the Mission and Needs of the Organization.

Clearly stated goals and learning objectives are strongly recommended for all Federally sponsored training, including diversity training.

• Do a thorough needs analysis and link diversity training to needed improvements in organizational and/or individual performance.
• From identified performance improvement needs, identify goals for the training.
• Ensure training program design is consistent with top management direction and guidance.
• Specify learning objectives in behavioral terms.
• Obtain employee and management support for the training goals and objectives.

Use Appropriate Training Approaches, Methods and Materials.

Training approaches, methods, and materials, to be effective, should consider the organization's culture, the intended audience for the training, and the nature of the diversity issues that the organization wishes to address. The specific approaches, methods, and materials should be thoroughly planned.

• Use best practices of others as benchmarks for diversity training.
• Document, or have vendors document, all methodologies employed and how they support desired training outcomes.
• Diversity training may use a variety of methodologies including reading, lecture, discussion, case study, role play, structured experience, or multimedia presentations.
• Training should not be accomplished using T-groups, encounter groups, and sensitivity groups as a methodology.
• Make sure planned discussions of individual experiences will be voluntary and limited to work-related issues. If an employee needs to discuss personal issues or conflicts, he or she should seek assistance from the agency Employee Assistance Program.
• Consider having the course content and exercises reviewed by an experienced training official who is technically knowledgeable and skilled in identifying psychological issues that may arise during the training.
• Address any risk concerns identified by persons in lines of authority and accountability prior to conducting training.
• Pilot the diversity training first to human resource and diversity specialists and use participant feedback to modify the course.
• Consider using "Train the Trainer" programs to facilitate consistency in agency training program delivery.

Provide Employees Advance Information About the Training.

Consistent with an agency's authority to assign work, employees may be assigned to training on a voluntary or mandatory basis. In either case, agencies should provide advance information to employees on course content and instructional methods, attendance policy, and alternative training opportunities.

Although diversity training is not required by statute or regulation, an agency may require employees to attend diversity training for the good of the service. Should an agency choose to make diversity training mandatory, the following procedures are recommended.

• Have top management notify effected employees that the training is mandatory.
• Tell employees the purpose of the training, what the specific course is about, and how it will be taught.
• Have a policy for handling employee requests to be excused for "workplace accommodation" reasons (religious, medical, physical, etc.).
• Have available, and tell, excused employees about alternative opportunities for learning the required material.

Conduct Training in a Supportive, Non-Coercive Environment.

The training environment should be such that all attendees, including those who share information about work experiences, are confident that no harm will come to them and that there will be no threat to their careers.

• Provide training in a supportive and non-coercive environment where participants may feel safe discussing workplace experiences and practicing appropriate interpersonal skills and expected behaviors.
• Obtain consensus on the "ground rules" for class interaction early in the training activity, including agreement on what is permissible to discuss in class (and what is not).
• Assure that training is done with proper regard for participant's privacy and constitutional rights.
• Avoid using training methods that will induce unnecessary psychological stress. (Some training programs might, of necessity, have the potential for inducing psychological stress and yet be in the Government's best interest. A course simulating stresses present in the employees' work environment would be an example.)
• Allow sufficient time for processing each learning exercise and continually monitor participant reaction. Take appropriate measures to address issues if they arise.
• Determine if managers and line supervisors should attend training with the people they supervise. If employees attend training with their supervisors, both should be advised of any agency policy regarding disclosure of work-related diversity issues.

Use Only Experienced, Fully Qualified, Instructors.

Instructors should have subject matter expertise, with demonstrated knowledge and understanding of diversity. They should also have demonstrated interpersonal skills and skills in managing group dynamics.

• Verify each instructor's expertise and experience with other professionals and management officials.
• Conduct a pre-briefing with all instructors, including substitute or subcontract instructors, to cover expected standards of service and delivery from every instructor. The briefing may cover course expectations, anticipated participant reactions, and the dynamics of the current workforce culture (employment factors, outside influences, current and projected changes to on-board strength, dynamics of the changing Federal workplace, "reasonable accommodation" issues, designation of key officials, etc.).

Monitor the Training Activity.

Monitor training delivery to assure proper classroom management and desired management results for the diversity training.

• Allow for immediate participant feedback in or outside of the classroom.
• Inform participants where to direct complaints about the training program, including anonymous feedback.
• Respond quickly and appropriately to any complaint about the diversity training program.

Evaluate the Training.

Agencies should evaluate the level of training success in terms of the extent to which it meets established goals and learning objectives. Specific areas of assessment include, employee satisfaction, increased employee understanding of workforce diversity issues, demonstrated interpersonal skills and appropriate workplace behaviors or improved organizational performance.

• Use written end-of-course evaluations to assess participant reaction, vendor and instructor performance and the effectiveness of any participatory learning techniques.
• Revise training methods and materials, as warranted, in response to feedback from participants and instructors.
• Consider using other evaluation methods to measure attainment of learning outcomes, transfer of learning, and the extent to which the training contributed to improved individual and/or organizational performance.

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