What Agencies Can Actually Ask For: Books, Records & Accounts

“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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The Three Certification Layers Every Federal Contractor Must Know

“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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FEDERAL CONTRACTOR COMPLIANCE ALERT: $25 Million Accenture Settlement – Civil Rights Noncompliance Can Become False Claims Act Exposure

Federal contractors should take notice. On September 14, 2026, the U.S. Department of Justice announced that Accenture Federal Services, Accenture plc, and Accenture LLP agreed to pay $25 million to resolve allegations that they violated the False Claims Act (FCA) by failing to comply with nondiscrimination requirements in federal contracts while allegedly discriminating in employment…
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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 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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