Manchester City's Sterling
called for more black managers in football while speaking about racism in the aftermath of the death of American George Floyd.
He compared the jobs given to Lampard and Rangers boss Steven Gerrard with those of Sol Campbell and Ashley Cole.
Lampard said the 25-year-old's comparison was "very casual".
"I think in the actual case of managers, I think he got it, from my point of view, slightly wrong," said Lampard.
"Those opportunities have to be equal for everybody, I think we all agree on that.
"But within that then there are the details of how hard you worked.
"I certainly worked from the start of my career to try to get this opportunity, and there's a million things along the way that knock you, set you back, that you fight against."
Campbell, 45, is manager of Southend having spent nine months at Macclesfield, where he helped the club avoid relegation from League Two.
Cole, 39, works for Chelsea's academy and coached at Derby during Lampard's only other managerial stint since retiring as a player.
Liverpool legend Gerrard, 40, coached at the club's academy before his first role as a manager with Rangers.
"The FA do a lot of good work, I've just finished my pro licence, it was very diverse, it was very open," added Lampard. "That needs to be encouraged, if there's anything we can do to ensure everyone gets an equal opportunity in the paths towards management then it needs to be done. And the numbers suggest that needs to be done.
"But with Raheem, the individual comparison, when you don't have the detail of each person's pathway, I felt that wasn't quite right.
"And again I'll level that out slightly, because I want to say that Raheem Sterling as a player and as a person and what he's stood up for over the last two years, I think has been fantastic."