“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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“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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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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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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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