“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…
Read More
“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…
Read More
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…
Read More
For much of 2025 and early 2026, federal contractors have watched the Office of Federal Contract Compliance Programs (OFCCP) become unusually quiet. Compliance reviews stopped. Enforcement activity nearly disappeared. The contractor portal was shut down, and the agency’s future was publicly questioned. That is why the most recent appropriations news is significant: OFCCP has now…
Read More
Executive Summary Between anti-DEI messaging from federal leadership and continued Title VII enforcement actions penalizing race and sex discrimination, private employers and federal contractors face a complicated compliance environment heading into 2026. While rhetoric suggests heightened scrutiny of “illegal DEI,” the legal reality is that Title VII has not changed: employment decisions may not be…
Read More
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