“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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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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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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The newly appointed Director of the Office of Federal Contract Compliance Programs (OFCCP) has sent an email, June 27, 2025, inviting federal contractors to voluntarily report how they have wound down their compliance with Executive Order (EO) 11246. The letter asserts that EO 11246 encouraged discriminatory practices such as race- or sex-based quotas and implies…
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Risk & ROI of Continuing Nondiscrimination Practices Post-EO 11246 The Misconception With the revocation of EO 11246 and the introduction of EO 14173, some federal contractors are considering pausing internal nondiscrimination practices built over years. This is a costly mistake. The Reality EO 14173 still prohibits workplace discrimination based on race, gender, and other protected…
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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