Federal contractors looking for the “DEI issue” in FAR 52.222-90 may be looking in the wrong place. Yes, the clause is about what Executive Order 14398 calls “racially discriminatory DEI activities.” But that’s only the starting point. The new clause also reaches subcontract flowdowns, records access, reporting obligations, bilateral modifications, suspension and debarment, and False Claims Act (FCA) risk. This isn’t just an HR issue, and it isn’t just a DEI issue. It is a contract-administration issue, a supply-chain issue, and an invoice issue all at once.
Continue Reading Everything Everywhere All at Once: The Contractor DEI Clause Hits HR, Supply Chains, Invoices, and SubcontractsEverything Everywhere All at Once: The Contractor DEI Clause Hits HR, Supply Chains, Invoices, and Subcontracts
