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…
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Part 3: Best Practices for Federal Contractors and Private Employers

Organizations seeking to reduce Title VII, Executive Order, and FCA risk should consider adopting a prevention-based compliance strategy. Conduct Periodic Workforce Diagnostic Reviews At least annually, evaluate: Applicant flow data Hiring outcomes Promotions Terminations Compensation decisions Performance ratings The objective is to identify potential indicators requiring further review. Validate Job-Related Decision Criteria Ensure hiring, promotion,…
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Part 2: Workforce Diagnostic Analytics, The Missing Risk Management Tool

The most important lesson from recent DOJ investigations is not that discrimination exists. The most important lesson is that the government is increasingly using data, statistical evidence, and outcome analyses to identify potential violations. Federal contractors should be doing the same. What Are Workforce Diagnostic Analytics? Workforce diagnostic analytics are statistical and compliance analyses designed…
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Breaking News: EEOC Reaffirms the Importance of Applicant Demographic Data Collection for Title VII Compliance

EEOC’s Uniform Guidelines Survive: Why Employers Should Continue Collecting Applicant Demographic Data In a development that may surprise many employers, the federal government has quietly reaffirmed one of the most important—and often misunderstood—compliance frameworks in employment law. On June 24, 2026, the White House Office of Information and Regulatory Affairs (OIRA) approved, without change, the…
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Part I: What Recent DOJ Investigations Reveal About Compliance Risks for Federal Contractors

Recent actions by the U.S. Department of Justice (DOJ) should serve as a wake-up call for federal contractors and employers nationwide. In June 2026, the DOJ launched an investigation into alleged race discrimination at the City University of New York (CUNY) involving its Black Male Initiative program. The Department is examining whether educational opportunities and…
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