Development and Approval of Mandatory Training

231 FW 6
FWM Number
Originating Office
Division of Training (NCTC)

6.1 What is the purpose of this chapter? This chapter establishes procedures for approving mandatory training developed or generated within the U.S. Fish and Wildlife Service. Mandatory training is training that:

A. Is mandated by law, regulation, policy, or other directive,

B. Managers track to ensure completion, and

C. Requires a specific set of employees or all employees to complete the training by a specific date and time or within a specific time period.

6.2 What is the objective of this chapter? Our objective is to ensure that we design and develop new mandatory training and redesign existing training in a way that minimizes the impact on employee time while still accomplishing the required training objectives.

6.3 What is the scope of this chapter? Table 6-1 shows what mandatory training this chapter covers.

Table 6-1: Scope of This Chapter

A. This chapter covers mandatory training that…

B. This chapter does NOT apply to mandatory training that…

(1) Impacts employees from multiple programs or multiple Regions.

(2) Is:

     (a) New,

     (b) Redesigns existing training when the redesign increases the time employees must spend in training or the number of employees who must attend, or

     (c)  Expands the scope of training directed by the Department or another outside controlling agency (e.g., the Office of Management and Budget) beyond the scope required by the Department or agency.

(1) The Department or another outside controlling agency (e.g., the Office of Management and Budget) requires,

(2) The Regional Directors require for employees in their Regions,

(3) The Assistant Directors require for employees in their programs in Headquarters,

(4) Service policy already requires before the date this chapter takes effect, (unless it is redesigned as per (2)(b) in column A), or

(5) A law (e.g., the Occupational Safety and Health Act (OSHA)) requires.

6.4 What are the authorities for this chapter?

A. Executive Order 11348 (as amended by Executive Order 12107), Providing for the Further Training of Government Employees.

B. Executive Order 13111, Using Technology to Improve Training Opportunities for Federal Government Employees.

C. Department of the Interior Human Resources Management Handbook (August 1995).

6.5 Who is responsible for approving mandatory training in the Service?

A. The Director may choose to require specific training at any time.

B. The Chief of Training, National Conservation Training Center:

(1) Manages this policy and the mandatory training approval process, and

(2) Organizes and serves as a voting member on the Mandatory Training Approval Team.

C. The Service Deputies Group:

(1) Is comprised of a Deputy to each Directorate member or their designated representative where no Deputy exists. The Chief of Training, National Conservation Training Center, and the Chief, Division of Human Capital are non-voting members of the Deputies group.

(2) Oversees the implementation of this policy.

(3) Provides two Deputies (including at least one Deputy Regional Director) as voting members for the Mandatory Training Approval Team.

(4) Nominates and provides one Refuge Manager or other Project Leader in the grade of GS-14 or higher as a voting member of the Mandatory Training Approval Team. (The Deputy Regional Director serving on the Team nominates this person.)

D. The Chief, Division of Policy and Directives Management or a designee:

(1) Serves as a voting member on the Mandatory Training Approval Team, and

(2) Ensures there are appropriate authorities to justify mandatory training requirements.

6.6 What is the Mandatory Training Approval Team (MTAT)? The MTAT is:

A. Comprised of:

(1) Two Deputies who the Deputies Group elects toserve a term of 2 years. One of the two Deputies must be a Deputy Regional Director.

(2) One Refuge Manager or other Project Leader in the grade of GS-14 or higher who the Deputy Regional Director serving on the Team nominates. This person serves a term of 2 years.

(3) The Chief of Training, National Conservation Training Center, and

(4) The Chief, Division of Policy and Directives Management or their designee.

B. Responsible for reviewing and approving:

(1) All new mandatory training requirements, and

(2) Training that has been redesigned if the redesign results in an increase in size, length, frequency, scope, or other variable that increases the impact on employee time.

6.7 How do employees developing or revising mandatory training get approval from the MTAT? The MTAT must approve proposed mandatory training before it can be required. To get approval:

A. Offices/employees who want to impose a mandatory training requirement on Service employees must send a description of the proposed training and a justification for the requirement, which addresses all of the elements outlined in section 6.8, to their respective Deputy Regional Director, Deputy Assistant Director or the equivalent for review. If the Deputy (or equivalent) concurs with the request for mandatory training, they will send the request to the Chief of Training, National Conservation Training Center.

B. The Chief of Training compiles mandatory training requests for the MTAT to review and approve.

C. The MTAT generally should meet three times annually, or as required to review the proposed mandatory training. These meetings may be teleconferences (or use other electronic means), or they may be scheduled in conjunction with the recurring Deputies Group meetings.

D. The primary point of contact (POC) for the proposal of the new or redesigned mandatory training must either:

(1) Brief the MTAT on the proposed training via teleconference, or

(2) Provide background and justification documentation to the MTAT at least 2 weeks in advance of the meeting where the MTAT will review, discuss, and approve/decline to approve the proposal.

E. After completing their review, the MTAT will provide feedback to the POC for the mandatory training. The MTAT may:

(1) Approve the training as proposed,

(2) Approve the training with required changes, or

(3) Decline to approve the training.

6.8 What does the MTAT consider when approving or disapproving a proposed mandatory training requirement?

A. The MTAT considers:

(1) The authorities that the training developer cites to justify the proposed mandatory training, including policy and regulatory or other legal authorities.

(2) The usefulness, practicality, and necessity of requiring the proposed mandatory training.

B. The MTAT members ask (so training developers should also ask and be prepared to discuss):

(1) If the authorities cited do not clearly direct mandatory training, why should the training be mandatory for Service employees?

(2) What are the primary objectives or goals of the training? What should an employee know or be able to do as a result of completing this training?

(3) Is the scope of the training, including length of time to complete the training and audience, reasonable and appropriate given the stated objectives?

(4) Were other alternatives considered that would lessen the impact on employee time? Would these alternatives also meet or exceed the stated objectives of the training? (Alternatives may include, but are not limited to, instructional memoranda, handbooks, desk guides, job aids, non-mandatory training, etc.)

(5) What are the recurring requirements for the training (e.g., annual, biannual), if any? Are these requirements necessary and justified?

(6) If a recurring mandatory training requirement is justified, is the scope and length of the recurring training justified? Will employees re-take the entire training or will alternatives be offered that reduce the impact of the recurring training? (Alternatives may include, but are not limited to, options to “test out” of the recurring training (i.e., “go to test” option), training reviews, reading memorandums or other documents, etc.).

(7) How long will the mandatory training requirement last? Is there a set length of time that the training will be required or will it be in effect until rescinded? If in effect until rescinded, how frequently will the continued authority and requirement be reviewed and by whom?

(8) Can we deliver the training through a more cost- or time-efficient means?

(9) If the training is to be delivered online over the Internet, does it take into account connectivity and bandwidth, especially for remote field locations?

(10) If the training is not the direct responsibility of the office proposing the training, did the responsible office:

     (a) Review the proposed training,

     (b) Agree it is necessary,

     (c) Recommend it with or without changes, and

     (d) Identify the changes it believes is necessary?

6.9 What should employees do if they discover an urgent need to get approval for a mandatory training requirement?  Contact the Chief of Training, National Conservation Training Center. If justified, the Chief of Training may request an ad hoc meeting of the MTAT. Employees must fully justify requests for urgent approvals.  The MTAT will not routinely grant them.

6.10 What happens after the MTAT approves the mandatory training requirement?

A. NCTC staff post the new or redesigned training requirement in the Service Mandatory Training List found on the NCTC Web site. The training POC or that person’s organization may then publish the mandatory training requirement, including posting and maintaining the requirement in DOI Learn.

B. Training POCs and their organizations must continue to monitor the training to ensure its necessity and effectiveness, including its impact on employee time and cost to deliver the training.

Amended by Decision Memorandum, “Approval of Revisions to ~350 Directives to Remove Gender-Specific Pronouns,” 6/22/2022