DCI Consulting – On January 28, 2026, the General Services Administration (GSA) proposed changes to SAM registration requirements that would add a DEI certification for federal financial assistance recipients, including universities and organizations receiving federal grants or loans. The proposed certification implements Executive Order 14173 and DOJ guidance by requiring entities to certify they do not operate programs promoting illegal diversity, equity, and inclusion (DEI) that violate federal anti-discrimination laws, with false certifications carrying potential liability under the False Claims Act. While the current proposal targets the Financial Assistance Reps & Certs section of SAM.gov registration, federal contractors who also receive financial assistance may be affected, and a similar DEI certification requirement for federal contractors specifically is expected in the near future.
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Recipients of Federal Financial Assistance Can Look to the New DEI Clause to Prepare for Potential Increased Scrutiny of Their Own Awards • Back to Basics: Novation Agreements (and Name Changes) • Unrelated Relators: DOJ Launches FOCUS Initiative as Data-Driven FCA Filings Surge • EEOC Submits Proposal to Rescind Federal EEO Reporting and Recordkeeping Rules • The Multifaceted Nature of Government Contracts Practice
DEI-Related Changes to SAM Certification Proposed
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