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OMB Approves Revised OFCCP Scheduling Letter

Client Alert | 1 min read | 10.03.14

Significant changes are just over the horizon for federal contractors and subcontractors, as OMB has approved the revised Scheduling Letter and Itemized Listing proposed by the Office of Federal Contract Compliance Programs. As further explained in the linked alert, the revised Scheduling Letter will require contractors, at the outset of a compliance review, to submit to OFCCP individualized compensation data, personnel activity data broken out by each racial subgroup (rather than in two groupings, minorities and non-minorities), and additional materials to demonstrate compliance with the new Veterans' Readjustment Assistance Act and section 503 of the Rehabilitation Act regulations that became effective earlier this year.


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Client Alert | 3 min read | 11.21.25

A Sign of What’s to Come? Court Dismisses FCA Retaliation Complaint Based on Alleged Discriminatory Use of Federal Funding

On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future....

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