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At a time when executive orders and other rapid changes affecting the nonprofit sector are being announced at a dizzying pace, it can feel nearly impossible for human resources leaders to keep pace with adapting their employment policies and enacting workforce retention strategies.

Be bold and proactive. Take steps now to set your nonprofit up for success, avoiding actions that may be impulsive or an overreaction to unnerving headlines as you navigate through myriad uncertainties. Being proactive in your workplace planning and reviews will help your organization thrive through any challenges presented by the Trump administration’s changing expectations.

Here are four actions that HR departments would be wise to prioritize in the face of potential changes affecting their operations:

1. Review your organizational strategic plan concurrently with your staffing plan.

This is the time to review job descriptions and your organization’s employment policies. These include, most notably, DEI, work authorizations and gender-related anti-discrimination policies. If you need to make changes in the future, you need goals and strategies in place now to help you move forward. Concurrently, review your organization’s strategic plan for alignment with employment policies as well as your talent plan.

This may mean adjusting the timetable for your standard policy review process. It’s important to recognize the urgency of re-evaluating the principles and wording describing your employment policies, so you are prepared to make shifts if needed. But most critically, avoid making changes in haste or in a knee-jerk fashion.

2. Reevaluate DEI programs.

Don’t assume your organization needs to abandon its commitment to diversity, equity and inclusion principles in hiring, promotions and other workplace practices. While it’s important to monitor announcements from the executive branch and legal developments related to DEI, these should not automatically mean your organization has to change its DEI priorities. These decisions need to be evaluated on a case-by-case basis.

With the Trump administration’s stated commitment to equal employment opportunity, driven by its desire to “restore merit-based opportunity,” organizations should continue to examine their employment practices through a nondiscrimination lens. The administration is motivated by a concern not to give diverse applicants an unfair advantage in hiring or promotions.

Federal contractors must include terms in their contracts or grant awards requiring them to comply with all applicable federal anti-discrimination laws and certify they do not operate any potentially “illegal” DEI programs, recognizing that there is no consensus on what constitutes an illegal practice.

When considering changes to the DEI language on your website or in other shared materials, it’s important to keep in mind your organization’s specific concerns, mission and the needs of the communities you serve. It may make sense to consider verbiage changes that align with Title VII and Equal Employment Opportunity rather than removing the language altogether.

There is no one-size-fits-all solution in addressing your DEI policies. But remember that the language choices you make don’t need to undermine your organization’s commitment to equity and inclusion.

3. Prepare for future compliance audits.

The Trump administration’s executive orders imposing significant reforms to the immigration system have important implications for employment. Now is the time to conduct internal audits in preparation for the likelihood of increased audits of your I-9 document verification practices.

A new I-9 form with some language updates was issued on April 3, 2025, so employers should begin using it in the verification process going forward.

While federal law requires HR staff to ensure that all new hires complete forms within three days of their start date to document their eligibility to work in the U.S., some organizations can be lax in their compliance with this requirement. This is the time to tighten those practices and increase your training on your due diligence requirements, so your organization is prepared.

Employers should conduct an internal audit and address any I-9 compliance issues immediately. If you come across an issue for any employee that can’t be easily resolved during your internal audit, you should engage with legal counsel to mitigate the concern.

4. Be ready for potential federal investigations.

Be sure all employment decisions are based on objective, job-related criteria to avoid potential legal challenges. In your recruitment processes, it is important to use a standardized list of questions to evaluate candidates. In addition, using a rating tool to consider candidates objectively can help avoid using subjective impressions in the hiring decision.

The same objectivity is necessary in the design and implementation of performance reviews. Evaluate your review process to ferret out areas that could lend themselves to bias. Use objective measures or key performance indicators (KPIs) to rate or otherwise evaluate employees.

And lastly, keep detailed records of hiring, promotions, and DEI program participation to demonstrate compliance with existing labor laws.

Stay vigilant

Proactive preparation is the surest approach to managing regulatory changes in an uncertain environment. Remaining vigilant and adaptable is the best way to be ready in the event of a federal investigation and to instill confidence in your workforce and the communities your organization serves so that all parties feel protected to the maximum extent possible.

Avoid making precipitous changes to your employment practices when no one can be sure how many of the current administration’s orders will result in changes to federal law or requirements.

How Wipfli can help

Navigating workplace challenges in these uncertain times is putting many nonprofits on edge about their responsibilities and requirements. Wipfli specialists are available to help HR teams, and their overall organizations stay up to date on changing expectations and how best to adapt. We provide tailored strategies in the face of shifting regulations and executive orders to position your organization for success in a volatile environment. Contact us to learn more about our services for nonprofits.