U.S. Office of Personnel Management
Office of Merit Systems Oversight and Effectiveness






                        TABLE OF CONTENTS
                                 


   I.     Executive Summary. . . . . . . . . . . . . . . . . . .1


  II.     Introduction . . . . . . . . . . . . . . . . . . . . .3


 III.     Findings . . . . . . . . . . . . . . . . . . . . . . .5


 IV.      Conclusion . . . . . . . . . . . . . . . . . . . . . 13



Appendix A:    Interagency Advisory Group Memorandum Regarding
               Guidance on Appropriate Language Restricting Training.A-1


Appendix B:         Agenda Questions . . . . . . . . . . . . .B-1


Appendix C:         OPM FY 1997 Oversight Reports Included in StudyC-1
                  THIS PAGE INTENTIONALLY BLANK                      I.  EXECUTIVE SUMMARY
                                 
This report summarizes the results of a special study of the appropriateness of non-technical training, conducted by the Office of Merit Systems Oversight and Effectiveness in
FY 1997.  The study's principal focus was to assess whether agencies are adhering to legal
appropriateness criteria in conducting non-technical training.  A brief summary of the more
significant study findings follows.

  Agencies reviewed as part of this study were not violating the training appropriateness
  requirements imposed by the Equal Employment Opportunity Commission (EEOC)
  Notice and Public Laws cited in this report, although managers and supervisors were
  generally unaware of the specific regulatory and legal provisions.  Office of Personnel
  Management (OPM) teams provided agencies specific information and guidance while
  on site.

  With one exception, we encountered no instances of clearly inappropriate or offensive
  training, nor did we learn of any employee being denied the opportunity to opt out of
  training he or she may have found to be inappropriate or offensive.  At one installation,
  two employees informed us they had attended classroom training they deemed
  inappropriate; they did not complete the course and did not file a formal objection. 
  These two employees, along with many others, did not realize they could refuse to
  attend non-technical training without fear of reprisal; many of the sites we visited did
  not make this explicitly clear.

  In recent years, Human Immunodeficiency Virus/Acquired Immune Deficiency
  Syndrome (HIV/AIDS) has been one of the more sensitive training topics in most
  agencies.  We found that a small proportion of employees were uncomfortable with
  some aspects of this training, but those employees were offered alternative forms of
  training or told they would not have to attend.  There were no formal written
  complaints concerning HIV/AIDS training.

  In many agencies, written evaluations are not consistently requested of participants in
  training sessions.  The lack of a formal feedback mechanism was not viewed as a
  problem by employees, who indicated they have adequate avenues for voicing
  complaints.  We encouraged agencies to ensure that all employees understand that any
  constructive feedback is welcome. 

  We also discovered that some agencies have responded to the challenge of providing
  training in an era of downsizing by setting up resource centers designed to enable
  employees to gain more control over their careers.  These centers typically provided a
  variety of aids to growth and skill-development, and some even made counselors
  available to assist in career-planning.
                  THIS PAGE INTENTIONALLY BLANK                        II.  INTRODUCTION
                                 
Environment

In Fiscal Year 1997, the U.S. Office of Personnel Management (OPM) conducted a special
study of the appropriateness of non-technical training.  This issue arose because Congress
included language restricting training not related to official duties in the Treasury, Postal
Service and General Government Appropriations Act for Fiscal Year 1996 (Public Law
104-52).  The restrictions covered agencies funded by the Act and the intent was to prohibit
expenditure of Federal funds on training that is offensive to Federal employees and
unnecessary in the execution of an employee's official duties.  This language was made
generally applicable to all agencies in FY 1997 by the Omnibus Consolidated
Appropriations Act, Public Law 104-208 (hereinafter PL 104-28).

Public Laws 104-52 and 104-208 include certain criteria for the appropriateness of non-technical training.  These restrictions include: 

     training course participants should not experience high levels of emotional or
     psychological stress as a result of the training; 

     training courses should not contain methods or content associated with religious or
     quasi-religious belief systems or "new age" belief systems as defined by EEOC Notice
     N-915.022, issued September 2, 1988; 

     training should not be offensive to, or designed to change, participants' personal value
     systems or lifestyles outside the workplace; and

     training course content related to Human Immunodeficiency Virus/Acquired Immune
     Deficiency Syndrome (HIV/AIDS) should be limited to describing the medical
     ramifications of HIV/AIDS as they relate to communicability and affect an employee's
     ability to perform official duties, and workplace rights of HIV-positive employees.

OPM initially issued guidance to the agencies subject to the 1996 Appropriations Act in
March 1996.  Once Public Law 104-208 made the restrictions applicable to all agencies,
OPM provided guidance on the appropriations language restricting training through a
memorandum to members of the Interagency Group and the Human Resource Development
Council, issued November 8, 1996.  Appendix A contains a copy of this guidance.  In
interpreting the law, the guidance included expectations that:

     employees should be notified in advance of the purpose of the training, about the
     content to be expected in the training, and how the content will be taught;

     written end-of-course evaluations should be used to assess participant reaction;

     agency officials should be aware of the appropriateness criteria in order to carefully
     review and be sensitive to training content and methods, and also, through review of
     EEOC Notice N-915.022, know how to handle situations where an employee objects to
     participating in a training program because its content or techniques conflict with the
     employee's religious beliefs.  

This guidance is reflected in the Expected Outcomes used in our study as a framework to
assess whether agencies and installations are adhering to the legal appropriateness criteria. 

Evaluation Plan and Data Sources

Fact-finding was conducted by OPM evaluators through on-site reviews at headquarters and
field offices of various agencies.  These included U.S. Department of Agriculture,
Department of the Army, Department of Commerce, Environmental Protection Agency
(EPA), National Archives and Records Administration (NARA), National Aeronautics and
Space Administration (NASA), Securities and Exchange Commission (SEC), and the
Department of Veterans Affairs (VA).  The fact-finding was conducted in these agencies
because they were scheduled for review in FY 1997 in OPM's established cycle for agency
reviews.  The agencies vary greatly in size, mission, field structure and training needs. 
They represent a broad cross-section of the Federal government's civilian employment.  A
standardized agenda was covered at each agency site reviewed.  Appendix B contains the
key agenda questions covered at each site.  This study draws on the findings related to this
agenda contained in eighty-nine installation and agency reports, listed in Appendix C.

A representative sample of managers, supervisors, and employees were interviewed, either
individually or in groups at each site, and relevant records and data were reviewed.  A total
of 876 managers and supervisors were interviewed.  Of these interviews, 552 were
conducted one-on-one, and 324 supervisors participated in 53 small group interviews. 
Employees were generally interviewed in small groups; we interviewed 933 employees in
114 group sessions.
                                                         III.  FINDINGS

MERIT SYSTEM PRINCIPLES

  All employees...should receive fair and equitable treatment in all aspects of personnel
  management without regard to political affiliation, race, color, religion, national origin,
  sex, marital status, age, or handicapping condition, and with proper regard for their
  privacy and constitutional rights.  Title 5, U.S.C., section 2301(b)(2)
  
  Employees should be provided effective education and training in cases in which such
  education and training would result in better organizational and individual performance. 
  Title 5, U.S.C., section 2301(b)(7)

EXPECTED OUTCOMES

When an installation complies with Merit System Principles in adhering to legal
appropriateness criteria in conducting training for its employees:

  The Training Officer or Coordinator is knowledgeable of the restrictions imposed by
  EEOC Notice N-915.022, and managers and supervisors are aware that training
  objectives and content must be reviewed to ensure appropriateness.

  Training courses do not contain methods or content associated with religious or quasi-religious belief systems or "new age" belief systems as defined by the EEOC notice.

  Participants are notified in advance of the purpose, content and methodology of specific
  training sessions, and are afforded the opportunity to decline training they may find
  offensive.

  Training course participants do not experience high levels of emotional or
  psychological stress as a result of the training.

  Training is not offensive to, or designed to change, participants' personal value systems
  or lifestyles outside the workplace.

  Written post-course evaluations, completed by participants for each training course, are
  monitored for any significant negative feedback, especially comments referring to the
  training as inappropriate or offensive.

  Any training course content related to Human Immunodeficiency Virus/Acquired
  Immune Deficiency Syndrome (HIV/AIDS) is limited to and does not go beyond
  describing:

          1) The medical ramifications of HIV/AIDS as they relate to
             communicability, and as they affect an employee's ability to perform
             official duties

          2) Workplace rights of HIV-positive employees.

  Training assists the organization in accomplishing its mission and coping with
  organizational challenges such as downsizing.

REVIEW RESULTS

Adherence to Legal Requirement

  Most management officials were unaware of the appropriateness criteria for non-technical training contained in EEOC Notice N-915.022 and Public Law 104-208. 
  Nevertheless, our reviews did not identify any training programs that contained
  material related to religious belief or "new age " belief systems.  Many managerial and
  supervisory training programs included a module on organizational values, but we
  encountered no training courses that were designed to change personal value systems.  

  At only one of the sites reviewed did we find an instance of what could be 
  characterized as inappropriate training.  At that installation, two employees told OPM
  that they had attended a training course in which they believed their religious beliefs
  were not respected.  Specifically, the instructor told them to eliminate their religious
  symbolism from a drawing the two employees had made as part of a class assignment;
  later in the course, the instructor played a musical audiotape which the two employees
  felt was symbolic of a different religion.  They objected, but the instructor disagreed
  that the tape had religious connotations.  Although they expected consequences, the two
  employees withdrew from the course and did not complete it.  When apprised of these
  events, local agency management took steps to communicate key provisions of EEOC
  Notice N-915.022 and Public Law 104-208 to all employees.  Management's actions
  assured OPM that the employees would not suffer adverse consequences. 

  Except for this instance, there was neither documentation, nor oral report of complaints
  regarding appropriateness or offensiveness of actual training sessions conducted. 
  Additionally, there were no reports of anyone being denied the opportunity to opt out of
  training to which they objected.  

  Few training officers and coordinators were aware of EEOC Notice N-915.022.
  Nevertheless, all monitored training programs and were sensitive to anything they
  deemed inappropriate.  Despite the pervasive lack of familiarity with the relevant
  guidance, the agencies we reviewed were satisfying the appropriateness criteria in terms
  of outcomes, through the application of sound management principles, good business
  practices, and humane personnel procedures in administering their training programs. 

  We found relatively few locations where efforts had been made to give managers an
  understanding of how to determine whether training was appropriate.  OPM teams
  provided detailed information and guidance for dissemination to local managers and
  supervisors at any installations visited that had not already been provided such
  guidance.

  Forty-two percent of the reports included a corrective action that the installation
  "provide information, guidance, and/or training on implementation of non-technical
  training appropriateness as required by EEOC Notice N-915.022 and Public Law 104-208."  This was the most common corrective action OPM reports imposed. 

  Other less frequently imposed corrective actions appearing in the reports included: 
  provide a point of contact for supervisors to obtain advice on training appropriateness;
  ensure that training course evaluations are completed, screened, and considered; notify
  employees in advance of training course purpose, content, and methodology; and
  inform employees of their right to decline non-technical training they feel may be
  offensive or otherwise inappropriate. 

Adherence to OPM Guidance

  Due to lack of awareness of the laws, EEOC Notice and OPM guidance, at most
  locations training proposed for employees was not being screened to ensure that it
  complied with the law.  However, as mentioned above, training officers and
  coordinators screened for issues they considered inappropriate.  Some managers and
  supervisors routinely reviewed course information when their employees were
  scheduled for training, but most presumed that someone else was reviewing training
  content for the presence of offensive or inappropriate issues.

  Employees typically received advance basic information about the content of training
  sessions for which they were scheduled and generally believed the information was
  sufficient to form an opinion as to the appropriateness of the course.  

  Employees received information about training sessions for which they were eligible or
  were scheduled to attend in widely varying ways.  At some installations, employees
  were given an annual catalog containing course descriptions, target audiences, course
  objectives, training methodologies used, and a schedule of dates.  At other locations,
  employees received an E-mail message with course title and dates shortly before a
  session was scheduled, and little else.  Whatever the approach taken by the agency,
  employees felt they could obtain the training information they desired. 

  For internally-developed training courses, lack of familiarity with the specific
  appropriateness criteria generally precluded application of the screening criteria.  We
  found that much internally-developed training was technical in nature, typically closely
  work-related and non-use of the screening criteria was not an issue.  While the
  screening criteria was also not applied to locally-developed non-technical training, this
  was generally constructed with job-relatedness in mind and did not extend into the areas
  of personal beliefs and value systems.

  Since few agency staff were aware of the specific appropriateness criteria prior to the
  arrival of OPM evaluators, few vendor curricula were screened against appropriateness
  criteria.  However, agency training representatives and managers assured us that
  outside training materials were generally reviewed prior to being used in a class.  When
  this did not happen, it was usually because the vendor's reputation was known and
  trusted, and a specific review was deemed unnecessary. 

  Regarding the expectation that installations should have a post-training feedback
  mechanism which will surface inappropriate courses, instructors or vendors, we found
  that practices ranged from requiring no written feedback, to having employees fill out
  multiple written evaluations, e.g., for the instructor, training office, human resources
  office, supervisor.

  The OPM teams found the process of locating written course evaluations to be a
  challenge.  Many installations do not require them, especially for courses of no more
  than a day in duration.  For other sessions, completed evaluations are handed to the
  instructor at the conclusion of the training session and are apparently disposed of by the
  instructor.  At the other end of the spectrum, a few installations require that an
  evaluation be turned in at the end of the course, and a second evaluation be filled out
  (usually part of the training nomination form) and submitted to the Human Resources
  office.  Some installations also follow up with a phone call to the employee and
  encourage their employees to discuss recently-completed training with their supervisor. 
  OPM teams requested training evaluation forms at every site where they were
  maintained and found no written negative feedback on evaluation forms regarding the
  appropriateness of training. 

  Where written post-course evaluations are collected, they are typically reviewed for
  significant negative comments, including feedback that the training was inappropriate or
  offensive in content or presentation.  In one location, where the training office felt they
  were not adequately staffed to review one hundred percent of the evaluations, sessions
  were randomly selected for review.  We encountered no complaints concerning written
  evaluations or lack thereof; employees felt they had adequate avenues to voice negative
  feedback.  Several installations are in the early stages of implementing training software
  that includes the capability to have an employee enter evaluative comments directly into
  the system.  The ease-of-use and potential advantages this approach offers may increase
  the quantity of feedback in agencies that adopt it.

HIV/AIDS Training

  The EEOC notice clearly advises that HIV/AIDS training not go beyond explaining
  medical ramifications of HIV/AIDS, and describing the workplace rights of HIV-positive employees.  At many locations, we were told that when HIV/AIDS training
  was conducted, several employees expressed discomfort with some aspects of the
  training.  In some cases, certain portions of the HIV/AIDS training program that
  employees found offensive were modified or dropped; in others, employees were
  informed that they would not have to attend and were offered an alternative training
  method, such as a videotape.  We did not come across a single instance of a formal
  written complaint concerning HIV/AIDS training.  We received verbal input from some
  employees who seemed to recall an instance where one or more employees had refused
  to attend HIV/AIDS training, but they were not aware of any disciplinary action that
  had been taken.  

  A number of interviewees were aware of co-workers who had experienced mild levels
  of discomfort while attending HIV/AIDS training, but none would characterize the
  experience as highly stressful.  Employees who anticipated experiencing significant
  stress from this training had previously declined to attend.

  Most HIV/AIDS training was conducted in 1993 and 1994; it has been presented only
  sporadically since then, primarily based on demand.  Agencies have also made this
  topic part of their orientation program for new employees.  We reviewed several
  HIV/AIDS training packages and found that none went beyond covering 
  communicability, impact on an employee's ability to perform official duties, and the
  workplace rights of HIV-positive employees.   HIV/AIDS training programs at the sites
  we visited tended to focus on preventive measures, and avoided moral or value
  judgments.  No employees complained to us that the training was inappropriate or went
  too far, and we encountered no written complaints regarding the training.
Dealing with Employee Objections

  A potential problem for many installations is that a significant number of employees
  indicated they did not know they could refuse to attend a non-technical training course
  (even a "mandatory" one) they might find offensive, without fear of reprisal.  At
  roughly half the sites visited, management did not explicitly communicate to employees
  that the option to decline non-technical training was available.  Nevertheless, based on
  what we heard from employees, supervisors and managers, no one was aware of an
  instance where an employee was forced to attend a non-technical training course he or
  she did not want to attend.  It appears that supervisors and managers have responded to
  employee requests to be excused by giving verbal approval to be absent, or by offering
  an alternative to the classroom session, such as a video.

  When management staff were questioned about how they would deal with an employee
  who objected to attending training that could be offensive, supervisors and managers
  alike indicated that they would not force an employee to attend such training.

Trends in Non-technical Training

  The manner in which non-technical training is delivered varied widely.  While
  instructor-led, small-group classroom training was the dominant (and preferred) 
  method, videotapes and satellite broadcasts were not unusual, especially in field offices. 
  The topics most often covered were EEO, Diversity, HIV/AIDS, Sexual Harassment,
  Violence in the Workplace, and Ethics.  Instructors tended to be drawn from agency
  staff, but outside contractors were often utilized, especially at Headquarters offices. 

  Most training done recently in response to downsizing has been of the technical variety,
  often taking the form of cross-training or re-training to develop or enhance new skills. 
  Most non-technical training in a downsized environment involves team-building, shared
  leadership, change management, workforce planning, or quality improvement, all of
  which are designed to make the workforce more productive and efficient.

  Further, in this era of tight budgets, we found that expenditures on non-technical
  training have been severely trimmed.  In some cases, training has been limited to that
  considered "mandatory."  In fact, some agencies spend their entire discretionary
  training budget strictly on technical training.  There was consensus that the single
  biggest contribution non-technical training makes toward mission accomplishment is in
  fostering teamwork, which is critical in a downsized environment. 

  We also found some successful or innovative approaches, methods or techniques that
  installations developed and implemented to meet the challenge of providing training in 
  the current downsizing environment.  Several installations have set up resource centers
  designed to enable employees to gain more control over their careers.  These centers
  tend to be unique but typically include some form of self-paced computer-based
  learning on a variety of skills and topics, educational videos and audio tapes, reference
  books, tutorials and other self-development materials.  They also house career-planning
  and job-search aids and resources.  In some cases, a counselor is available to discuss
    career planning.                    THIS PAGE INTENTIONALLY BLANK                        IV.  CONCLUSION

Except for the one situation noted in this summary report, we encountered no other
instances of inappropriate or offensive training, nor did we learn of any other employees
being pressured or coerced to attend any training he or she perceived as possibly
inappropriate or offensive.  Although very few managers, supervisors and employees
interviewed professed knowledge of the specific provisions of Public Laws 104-52 and
104-208, and EEOC Notice 915.022, the agencies reviewed are effectively meeting the
underlying intent of the legislation.  Namely, they are ensuring that training is appropriate,
job-related, and has low potential to offend.  While not necessarily a response to legal
requirements, agencies are accomplishing these objectives by routinely reviewing training
course materials, methodologies, and instructors.

At locations where officials were not aware of the provisions of Public Law 104-208, OPM
staff provided copies of EEOC Notice N-915.022 and the Interagency Advisory Group
guidance on implementing the provisions of Public Law 104-208.  Our reports to
installations and agencies included recommendations that all managers, supervisors, and
employees be provided the information about the restrictions on non-technical training, and
to ensure that employees are advised of their options if they feel proposed training is
offensive to, or designed to change, their personal value systems.
                  THIS PAGE INTENTIONALLY BLANK  APPENDIX A
                   INTERAGENCY ADVISORY GROUP
                         United States
                 Office of Personnel Management
                      Washington, DC 20415
  
                        November 8, 1996
  
  MEMORANDUM FOR MEMBERS OF THE INTERAGENCY ADVISORY GROUP
                   AND THE HUMAN RESOURCE DEVELOPMENT
                   COUNCIL
             
  FROM:      KIRKE HARPER
                  ASSISTANT DIRECTOR
                    FOR HUMAN RESOURCE DEVELOPMENT
  
  SUBJECT:        Guidance on Appropriation Language Restricting Training     
  
  
  Section 624 of the Treasury, Postal Service, and General Government Appropriations Act,
  1997, as contained in section 101(f) of the Omnibus Consolidated Appropriations Act, 1997
  (Public Law 104-208), contains language restricting training not related to official duties.  
  
  Similar language appeared last year in the Department of Transportation and Related Agencies
  Appropriations Act of 1996 (Public Law 104-50) and the Treasury, Postal Service, and General
  Government Appropriations Act of 1996 (Public Law 104-52).  This year, Congress has made
  the provisions apply to all appropriated funds for training all Federal employees, civilian and
  military.
  
  In March 1996, the Office of Personnel Management issued guidance to agencies subject to
  these 1996 appropriation acts.  To help clarify any questions that you may have about section
  624, we are updating and reissuing that guidance.  
  
  Please assure that each agency official with the authority to authorize and approve funds for
  training agency employees is made aware of the restrictions in Public Law 104-208.  If you or
  your staff have questions, please contact Judith Lombard at 202-606-2431.
  
  Attachment
  
    Guidance for Implementing Training Restrictions Contained in Public Law 104-208

Background:

   Section 624 of the Treasury, Postal Service, and General Government Appropriation
   Act, 1997, as contained in section 101(f) of the Omnibus Consolidated Appropriations
   Act, 1997 (Public Law 104-208), contains language restricting training not related to
   official duties.  
   
   Section 624 prohibits expenditures of Federal funds on training that is offensive to
   Federal employees and unnecessary in the execution of their official duties.  It is not
   intended to prohibit training that is necessary for Federal workers to effectively
   complete their assigned duties. 

   The following guidance is based on balancing the intent of section 624 with the basic
   authorities contained in training law, chapter 41 of title 5, United States Code.

Guidance Regarding Specific Subsections:

   Sec. 624. "(a) None of the funds made available in this Act, or any other Act, may be
   obligated or expended for any employee training when it is made known to the Federal
   official having authority to obligate or expend such funds that such employee training -"

        Section 624 does not amend title 5, U.S.C., chapter 41, Training, or change the
        legal purpose of training -- to improve individual and organizational performance
        related to an agency's mission.  However, the phrase "this Act, or any other Act"
        refers to all Acts of Congress which appropriate funds to agencies, both civilian or
        military agencies, and to the training of all employees, both those subject to the
        civil service provisions of title 5 of the United States Code and those who are not
        subject to title 5.

   "(1) does not meet identified needs for knowledge, skills, and abilities bearing directly
   upon the performance of official duties;"

        Consistent with current law, this subsection reminds agency officials that there
        should be a relationship between the knowledge, skills, and abilities the training is
        intended to provide and an employee's lawfully assigned duties.  Employees may be
        assigned to training associated with their current duties or anticipated duties related
        to the mission of the agency.  The legal purpose of training continues to be to
        improve individual and organizational performance and to assist in achieving the
        agency's mission and performance goals (5 U.S.C.  4101(4)).  5 CFR 410.203,
        based on Executive Order 11348, provides basic guidance to agencies for
        determining training needs of individuals, occupations, programs, and
        organizations. 

   "(2) contains elements likely to induce high levels of emotional response or
   psychological stress in some participants;"

        We believe the intent of this subsection is to alert officials to carefully review and
        be sensitive to training content and training methods.  Both should be evaluated in
        context with the purpose of the training.  Training should not induce unnecessary
        psychological stress in participants.  Some training programs might, of necessity,
        have the potential for inducing psychological stress and yet be performance related
        and in the Government's interest.  An example would be training simulating stress
        present in the employees' work environment.

   "(3) does not require prior employee notification of the content and methods to be used
   in the training and written end of course evaluations;"

        For all agency-sponsored training, employees should be notified, in advance, of the
        purpose of the training, about the content to be expected in the training, and how
        the content will be taught.

        Written end-of-course evaluations should be used to assess participant reaction to
        the training, vendor and instructor performance, and the effectiveness of any
        participatory learning techniques.

   "(4) contains any methods or content associated with religious or quasi-religious belief
   systems or "new age" belief systems as defined in Equal Employment Opportunity
   Commission Notice N-915.022, dated September 2, 1988;"

        Agency officials should review Equal Employment Opportunity Commission
        (EEOC) Notice N-915.022.  The Notice is available from EEOC and, in electronic
        form, in the Training Forum of the OPM Mainstreet (202-606-4800).  It provides
        guidance in handling situations where an employee objects to participating in a
        training program because its content or the techniques or exercises used conflict
        with the employee's religious beliefs.  In addition, the Notice reminds agency
        officials of their duty under subsection 701(j) of title VII to accommodate
        employees' religious needs.  We believe it is good practice for agencies to have
        procedures for handling employees' requests for religious accommodation regarding
        training.

   "(5) is offensive to, or designed to change, participants' personal values or lifestyle
   outside the workplace; or"

        This subsection reminds agency officials that is inappropriate to use Federally-sponsored training to change employees personal values or to influence their
        lifestyles outside the workplace.  This legislation does not effect training in
        Government ethics and codes of conduct expected of Federal employees.  As noted
        earlier, the primary purpose for training is to improve performance.  Non-technical
        training is appropriate when it addresses:

        1.   Interpersonal skills that Federal employees need to provide services to, work
             with, and manage persons both like and unlike themselves;

        2.   Behavior Federal employees are expected to exhibit, or may encounter, in the
             workplace; and/or

        3.   Workplace health and safety issues, security matters, and other subjects that
             bear directly on individual or organizational performance.

   "(6) includes content related to human immunodeficiency virus/acquired immune
   deficiency syndrome (HIV/AIDS) other than that necessary to make employees more
   aware of the medical ramifications of HIV/AIDS and the workplace rights of HIV
   positive employees."

   In addition to the restriction in section 624, the Ryan White CARE Amendments Act of
   1996 (Public Law 104-146, May 20, 1996), prohibits mandatory HIV or AIDS training
   for Federal employees, except for training necessary to protect the health and safety of
   the Federal employee and the individuals served by the employee.  A Federal employee
   (including a member of the armed forces) may not be required to attend or participate
   in an AIDS or HIV training program if the employee refuses to consent. 

   HIV/AIDS training is permitted to make employees aware of the medical ramifications
   of HIV/AIDS and the workplace rights of HIV positive employees.  Mandatory
   HIV/AIDS training is permissible when it is necessary to protect the health and safety
   of the employee and the individuals served by the employee.

   Agency officials are advised to avoid HIV/AIDS training that goes beyond these stated
   purposes.

   "(b) Nothing in this section shall prohibit, restrict, or otherwise preclude an agency
   from conducting training bearing directly upon the performance of official duties." 

        This legislation does not prohibit any type of training that is necessary for Federal
        workers to effectively complete their legally assigned tasks.  In addition, it is not
        intended to affect any training for displaced workers designed to help them find new
                employment.                           APPENDIX B
                        AGENDA QUESTIONS

1. How does the installation ensure that its non-technical training complies with legal and
   public policy requirements governing training appropriateness?

2. Has information been provided to management staff which can assist them in
   understanding what constitutes training appropriate for organizational performance and
   mission accomplishment?

3. Does the installation screen training requests to ensure that proposed training is in
   compliance with the referenced EEOC notice?

4. For any internally developed training courses, have the appropriateness criteria been
   applied?

5. Does the installation have a post-training feedback mechanism that will surface
   inappropriate courses, instructors or vendors?

6. How are vendors' curricula systematically screened against appropriateness criteria?

7. How does the organization ensure that the non-technical training program is assisting
   the agency in accomplishing its mission?

8. What successful or innovative approaches, methods or techniques has the installation
   developed and implemented to meet the challenge of providing training in an era of
   downsizing? 
                  THIS PAGE INTENTIONALLY BLANK                           APPENDIX C
        OPM FY 1997 OVERSIGHT REPORTS INCLUDED IN STUDY

AGRICULTURE

  U. S. Department of Agriculture, Washington, DC      

  Agricultural Marketing Service

  Agricultural Marketing Service, Washington, DC       
  Agricultural Marketing Service Headquarters, Washington DC          
  Livestock and Seed Division, Greeley, CO             
  Poultry Division, Des Moines, IA                     
  Dairy Division, Glen Ellyn, IL                       
  Cotton Division, Memphis, TN                         

  Agricultural Research Service

  Agricultural Research Service, Washington, DC        

  Animal and Plant Health Inspection Service

  Human Resources Operations, Minneapolis, MN          
  Animal Damage Control, Lakewood, CO                  
  National Wildlife Research Center, Animal Damage Control, Ft. Collins, CO     
  Centers for Epidemiology and Animal Health, Ft Collins, CO          
  National Veterinary Services Laboratories, Ames, IA  
  Field Servicing Office - M&B, Minneapolis, MN        

  Farm Service Agency

  Farm Service Agency, Washington, DC                  
  Farm Service Agency, KCMO/KCCO, Kansas City, MO      
  Farm Service Agency, Columbus, OH                    
  Headquarters, Washington, DC                         

  Food Safety & Inspection Service

  Food Safety and Inspection Service, Washington, DC   

  Forest Service

  Region 5, San Francisco, CA                          
  Sierra National Forest, Clovis, CA                   
  Gifford Pinchot National Forest, Vancouver, WA       
  George Washington and Jefferson National Forest, Roanoke, VA        
  Southern Region, Atlanta, GA                         
  Southern Research Station, Asheville, NC             
  Headquarters, Washington, DC                         

  Natural Resources Conservation Service

  Natural Resources Conservation Service, Little Rock, Arkansas       
  Natural Resources Conservation Service, National Business Center, Fort Worth, TX
  Headquarters, Washington, DC                         

  Rural Housing Service

  Rural Development-Rural Housing Service, Washington, DC             
  Rural Housing Service, Little Rock, AR               
  Rural Housing Service, Columbus, OH                  
  Washington DC Office, Washington, DC                 

ARMY

  Department of the Army, Washington, DC               
  Corps of Engineers Headquarters, Washington, DC      
  Red River Army Depot, Texarkana, TX                  
  Corpus Christi Army Depot, Corpus Christi, TX        
  U.S. Army Garrison, Fort Campbell, KY                
  Garrison, Fort Hood, TX                              
  Garrison, Fort Riley, KS                             
  Southwest Civilian Personnel Operations Center, Fort Riley, KS      
  Evans Army Community Hospital, Fort Carson, CO       
  Army Air Defense Artillery Center and Fort Bliss, El Paso, TX       
  Army Engineer Center and Fort Leonard Wood, Fort Leonard Wood, MO             Garrison, Fort Sam Houston, San Antonio, TX  
  Headquarters, Carlisle Barracks, Carlisle, PA        
  Forces Command, Fort Carson, CO                      
COMMERCE

  Department of Commerce, Washington, DC               
  Office of Personnel Operations, Office of Human Resources Management          
  Mountain Administrative Support Center, Boulder, CO  
  Eastern Administrative Support Center, Norfolk, VA   
  Western Administrative Support Center, NOAA, Seattle, WA            
  Central Administrative Support Center, Kansas City, KS              

  Census
  Census Bureau, Suitland, MD                          
  Data Preparation Division, Jeffersonville, IN        
  Chicago Regional Office, Westchester, IL             


  International Trade Administration

  International Trade Administration, Washington, DC   

  National Institute of Standards and Technology

  National Institute of Standards and Technology, Gaithersburg, MD    

  National Oceanic and Atmospheric Administration

  National Oceanic and Atmospheric Administration      

  Patent and Trademark Office

  Patent and Trademark Office, Washington, DC          

ENVIRONMENTAL PROTECTION AGENCY

  Office of Administration and Resource Management, Cincinnati, OH    
  Regional Office (#10), Seattle, WA                   
  Region 1, Boston, MA                                 
  Region 2, New York, NY                               

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

  Dryden Flight Research Center, Edwards AFB, CA       
  Ames Research Center, Moffett Field, CA              
NATIONAL ARCHIVES AND RECORDS ADMINISTRATION

  Central Plains Region Archives, Kansas City, MO      
  National Personnel Records Center, St. Louis, MO     
  Federal Records Center, Kansas City, MO              

SECURITIES AND EXCHANGE  COMMISSION

  Securities and Exchange Commission, Washington, DC

VETERANS AFFAIRS

  Puget Sound Health Care System, Seattle, WA          
  Domiciliary, White City, OR                          
  Palo Alto Health Care System, Palo Alto, CA          
  Veterans Benefit Administration, Denver Western Area, Lakewood, CO  
  
  Medical Centers
  
  VAMC, Ann Arbor, MI                                  
  VAMC, Poplar Bluff, MO                               
  VAMC, San Francisco, CA                              
  VAMC, Louisville, KY                                 
  VAMC, Columbia, SC                                   
  VAMC, Nashville, TN                                  
  VAMC, Birmingham, AL                                 
  VAMC, St. Louis, MO                                  
  VAMC, Muskogee, OK                                   
  VAMC, West Palm Beach, FL                            

  Regional Offices
  
  VARO, Oakland, CA                                    
  VARO, Atlanta, GA                                    
  VARO, Chicago, IL                                    
  VARO, St. Louis, MO                                  
  VARO, Seattle, WA