Part 2: Before You Certify, Verify

A Pragmatic Compliance Framework for Federal Contractors The IBM and Deloitte settlements do not mean that contractors should stop conducting outreach, reviewing workforce data, or working to ensure equal employment opportunity. They demonstrate the importance of distinguishing between two very different activities: Using workforce data to identify and remove possible barriers; and Using protected characteristics…
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OFCCP Is Fully Funded for 2026: Part 2 – What Federal Contractors Should Do Now: Best Practices, Liabilities, and How to Avoid Risk in 2026

Even if OFCCP remains quieter than in past years, federal contractors should not interpret that as a compliance “pause.” In 2026, the smartest strategy is quiet preparation. Contractors should assume: compliance obligations still exist enforcement can resume quickly data and transparency will drive scrutiny complaints and whistleblowers will trigger investigations The Liability Federal Contractors Can…
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What Federal Contractors and Private Employers Should Do Now: Part II

In light of DOJ’s stated priorities, federal contractors and private employers (100 or more employees) should take proactive steps to mitigate FCA exposure tied to discrimination risks. Conduct a Privileged Internal Review Review hiring, promotion, compensation, mentorship, and training programs under attorney-client privilege to assess whether any practices could be interpreted as steering decisions based…
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Understanding the Skilled Labor Crisis: Government Reforms and Global Market Dynamics Every Employer Must Navigate

This two-part article offers a clear and timely look at the forces reshaping today’s labor market. Part I examines the shifting regulatory expectations that are redefining employers’ compliance obligations, while Part II explores the free-market pressures that continue to drive companies toward global and outsourced talent. Together, these insights provide a comprehensive view of how…
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Part II: Practical Compliance Roadmap and Strategic Outlook

To remain compliant and competitive under EO 14173, federal contractors should take immediate steps to realign their policies, data practices, and contracting procedures with the new merit-based framework. The first step is to map your organization’s federal exposure. Identify all contracts, subcontracts, and grants, both prime and sub, with federal agencies, including any flow-down obligations….
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