Part 1: When Civil Rights Compliance Becomes a False Claims Act Risk

How DOJ Is Connecting Civil-Rights Compliance to the False Claims Act Federal contractors are entering a new era of civil-rights enforcement. On August 25, 2026, Deloitte, a Federal Contractor, agreed to pay $21.5 million to resolve Department of Justice allegations that it violated the False Claims Act by certifying compliance with federal-contract nondiscrimination requirements while…
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PART 2 – EEOC Enforcement: The Risk Has Not Gone Away

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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Opinion | Abandoning EEO Data Collection Will Not Eliminate Discrimination, It Will Make It Harder to Detect

The Equal Employment Opportunity Commission’s (EEOC) recent proposal to rescind the EEO-1 through EEO-6 reporting requirements marks one of the most significant shifts in federal equal employment policy in decades. The Commission argues that these reports are inconsistent with equal employment law, potentially unconstitutional, unnecessarily burdensome, and no longer needed to enforce anti-discrimination laws. While…
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Part 3: Best Practices for Federal Contractors and Private Employers

Organizations seeking to reduce Title VII, Executive Order, and FCA risk should consider adopting a prevention-based compliance strategy. Conduct Periodic Workforce Diagnostic Reviews At least annually, evaluate: Applicant flow data Hiring outcomes Promotions Terminations Compensation decisions Performance ratings The objective is to identify potential indicators requiring further review. Validate Job-Related Decision Criteria Ensure hiring, promotion,…
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Breaking News: EEOC Reaffirms the Importance of Applicant Demographic Data Collection for Title VII Compliance

EEOC’s Uniform Guidelines Survive: Why Employers Should Continue Collecting Applicant Demographic Data In a development that may surprise many employers, the federal government has quietly reaffirmed one of the most important—and often misunderstood—compliance frameworks in employment law. On June 24, 2026, the White House Office of Information and Regulatory Affairs (OIRA) approved, without change, the…
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