PART 3 – Workforce Diagnostics: Identify Risk Before Someone Else Does

Against this backdrop, relying solely on written nondiscrimination policies may not be enough. An organization can have well-designed policies, experienced HR professionals and established procedures, and still have workforce patterns that management does not know exist. A proactive Workforce Diagnostic Analysis provides an objective, data-driven way to examine what is actually happening across the workforce….
Read More

PART 2 – EEOC Enforcement: The Risk Has Not Gone Away

The revocation of Executive Order 11246 significantly changed the federal contractor compliance landscape, but it did not eliminate employers’ underlying nondiscrimination obligations or enforcement risk. While OFCCP has ceased investigative and enforcement activity under the former EO 11246 program, the EEOC continues to actively enforce Title VII, including cases involving race discrimination in hiring, promotions,…
Read More

PART 1 - EO 14398 & FAR 52.222-90: Nondiscrimination Enters the Federal Procurement Process

PART 1 – EO 14398 & FAR 52.222-90: Nondiscrimination Enters the Federal Procurement Process

The federal contractor nondiscrimination landscape has evolved significantly. Following recent federal procurement changes associated with Executive Orders 14173 and 14398, Addressing DEI Discrimination by Federal Contractors, the FAR Council introduced FAR 52.222-90, Addressing DEI Discrimination by Federal Contractors (APR 2026). The significance for federal contractors is substantial: nondiscrimination requirements are now being incorporated directly into…
Read More

OMB Approves Renewal of Form CC-305: Federal Contractors Must Continue Collecting Voluntary Disability Self-Identification Information

OMB Approves Renewal of Form CC-305: Federal Contractors Must Continue Collecting Voluntary Disability Self-Identification Information

On July 16, 2026, the Office of Management and Budget (OMB) has approved the continued use of Form CC-305 (Voluntary Self-Identification of Disability), reaffirming that covered federal contractors remain subject to the disability self-identification requirements under Section 503 of the Rehabilitation Act. The approved form is available on the U.S. Department of Labor’s website. OFCCP…
Read More

Opinion | Abandoning EEO Data Collection Will Not Eliminate Discrimination, It Will Make It Harder to Detect

Opinion | Abandoning EEO Data Collection Will Not Eliminate Discrimination, It Will Make It Harder to Detect

The Equal Employment Opportunity Commission’s (EEOC) recent proposal to rescind the EEO-1 through EEO-6 reporting requirements marks one of the most significant shifts in federal equal employment policy in decades. The Commission argues that these reports are inconsistent with equal employment law, potentially unconstitutional, unnecessarily burdensome, and no longer needed to enforce anti-discrimination laws. While…
Read More