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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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,…
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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…
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Presidential Actions Ending Illegal Discrimination and Restoring Merit-Based Opportunity

By Sandra Hueneman, SR CAAP, President Manchester Consultants On January 21, 2025, President Trump revoked Executive Order 11246, whereby the Office of Federal Contract Compliance Programs within the Department of Labor shall immediately cease: Promoting “diversity” Holding Federal contractors and subcontractors responsible for taking “affirmative action;” and Allowing or encouraging Federal contractors and subcontractors to…
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National Immigrants Day: Embracing Diversity and Supporting Immigrant Employees

  Hello again, my HR friends! October 28th is National Immigrants Day, a day dedicated to celebrating the incredible diversity that immigrants bring to our nation and, just as importantly, our workplaces. It’s a reminder of the invaluable perspectives, skills, and creativity immigrant employees contribute every day. As HR professionals, this day gives us the…
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