What Agencies Can Actually Ask For: Books, Records & Accounts

“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 4 OF 4 The final brief in this series: what to have audit ready before a request ever arrives. Recap: FAR 52.222-90 requires contractors to furnish “all information and reports, including providing access to books, records, and accounts, as required by the Contracting Officer.” No agency has…
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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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The EEOC’s Title VII Enforcement Transformation: Why Employers Must Reevaluate Their Employment Practices Now

Part I of II: Understanding the New Enforcement landscape and Its Impact on Employers For decades, employers generally viewed Title VII enforcement through the lens of protecting historically underrepresented groups from workplace discrimination. While Title VII itself has not changed, the Equal Employment Opportunity Commission (EEOC) has signaled a significant shift in how it approaches…
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Part 1 – Federal Contractors: Prepare for the Next Wave of Audits

EO 14398 and FAR 52.222-90 Signal a Major Shift in Federal Enforcement The federal contractor compliance landscape is undergoing one of its most significant transformations in decades. For years, contractors largely associated compliance oversight with affirmative action plans, OFCCP desk audits, and technical reporting obligations. Today, however, the federal government appears to be expanding its…
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A Federal Judge Dismissed a DEI Lawsuit Against Starbucks – Here’s What Federal Contractors Should Learn

A recent court decision involving Starbucks offers an important lesson for federal contractors navigating today’s DEI scrutiny: even in a politically charged environment, courts still require specific evidence of actual harm — not assumptions, headlines, or generalized allegations.  In the case, Missouri’s attorney general sued Starbucks, arguing that the company’s diversity, equity, and inclusion (DEI) initiatives unlawfully advantaged…
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