Equal opportunity and workforce programs | On-the-job training program
Good faith effort
When on-the-job training goals aren't met
The primary objective of MnDOT’s On-the-job Training (OJT) program is to assist with the development of a skilled and diverse highway construction workforce. Specifically, it enhances the career prospects of traditionally underrepresented individuals by improving access to journey-level positions.
Federal regulations require contractors that fail to meet applicable OJT goals to demonstrate that a good faith effort (GFE) was made to recruit and hire minorities, women, and/or disadvantaged people.
Good faith effort
If a contractor does not meet the OJT goal for a project – trainee and/or hours goal – it must provide MnDOT Office of Civil Rights (OCR) with a written explanation of the GFE made to reach the goal.
There is no template or formula for contractors to follow when drafting the GFE explanation. However, MnDOT OCR's list of questions, which is neither all-inclusive nor intended to serve as a checklist, can aid in this process.
Questions to consider
- Did you analyze your current workforce for eligible OJT trainees?
- Did you contact your subcontractors for eligible OJT trainees?
- Did you include the OJT goal in your subcontract agreements?
- Did you contact the union halls for eligible OJT trainees?
- Did you contact employees to gain referrals of other minorities, women, and/or disadvantaged person applicants?
- Did you develop in-house employment referral incentives to recruit minorities, women, and/or disadvantaged person applicants?
- Did you provide training opportunities to minorities, women, and/or disadvantaged persons for career advancement?
- Did you review and follow up on previously received applications from minorities, women, and/or disadvantaged persons when hiring opportunities arose?
- Which community organizations and other channels did you contact to solicit minorities, women, and/or disadvantaged persons to fill training positions?
- Did you interview minorities, women, and/or disadvantaged persons (even if it did not result in hirings)?
- Did you contact MnDOT Office of Civil Rights to locate other resources for eligible OJT trainees?
The written explanation must include all supporting documentation such as emails, contact numbers, timelines, dates, and any other relevant information. Missing or incomplete information is not considered.
Review by Office of Civil Rights
GFE met
MnDOT OCR will review the written explanation and supporting documentation to determine whether the contractor made a GFE to recruit and hire for the project. If it is determined the contractor did demonstrate a GFE, MnDOT OCR will clear the OJT requirement for the project.
GFE not met
If MnDOT OCR determines a GFE was not made after reviewing the written explanation and supporting documentation, the contractor is considered to be noncompliant.
MnDOT expects that a noncompliant contractor will make all reasonable and necessary efforts to reach OJT goals for any future projects.