“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 3 OF 4 Parts 1–2 covered the rules and the three certification layers. This brief: what to actually do about it. Recap: Contractors now certify nondiscrimination through SAM.gov representations, the EO 14173 certification embedded in each contract, and FAR 52.222-90. Here’s what stays in force separately, and…
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“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 2 OF 4 Part 1 covered what changed. This brief: the three layers contractors certify today. Recap: Executive Orders 14173 and 14398 replaced the old EO 11246 affirmative-action framework with a certification-based model, enforceable through the False Claims Act. Here’s how that model actually works, layer by…
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“VERIFY BEFORE YOU CERTIFY” — 3-MINUTE BRIEF, PART 1 OF 4 A quick-read series on how federal contractors certify nondiscrimination today. This brief: what changed, and why. Federal contractors don’t certify nondiscrimination through a single document anymore. As of 2026, compliance runs through three separate layers — and this series breaks down exactly what each…
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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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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….
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Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
Employers contracted with Ohio that meet one of the following criteria:
Employers contracted with Ohio for construction work
What Must Be Submitted?
Who Must Be Included
Employees on payroll over a period of one month.
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Construction employers contracted with Connecticut that meet either of the two criteria:
Construction employers contracted with Connecticut that meet either of the two criteria:
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link
Who Must Submit?
What Must Be Submitted?
Who Must Be Included
Employment Service Delivery System (ESDS) Link