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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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 – Federal Contractors: Prepare for the Next Wave of Audits

EO 14398 and FAR 52.222-90 Signal a Major Shift in Federal Enforcement The federal contractor compliance landscape is undergoing one of its most significant transformations in decades. For years, contractors largely associated compliance oversight with affirmative action plans, OFCCP desk audits, and technical reporting obligations. Today, however, the federal government appears to be expanding its…
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