Mind your mailbox!
The Office of Federal Contract Compliance Programs mailed 750 new Corporate Scheduling Announcement Letters on September 7. The CSALs notify contractors that one or more of their establishments will be scheduled for a compliance evaluation and provide at least 45 days’ notice before receipt of the Scheduling Letter and Itemized Listing. After receipt of the Scheduling Letter, a contractor has 30 days to submit its affirmative action plans and the required supporting information.
The OFCCP also puts contractors on notice that requests for extension will not be granted unless specific requirements are met:
OFCCP will provide a 30–day extension for supporting data related to the EO 11246, VEVRAA and Section 503 AAPs, provided that: 1) the contractor requests the extension prior to the initial 30–day due date for the AAPs and 2) the contractor timely submits the basic EO 11246, Section 503 and VEVRAA AAPs within the initial 30–day period after receiving the Scheduling Letter and Itemized Listing. . . . OFCCP generally will not allow extensions for submission of the basic EO 11246, Section 503 and VEVRAA AAPs, which contractors are required to maintain and update annually, nor allow extensions of supporting data if requested after the submission date for the AAPs has passed. OFCCP, however, reserves discretion to grant such extensions in extraordinary circumstances.
The OFCCP does not explain what comprises “the basic” AAPs or what it considers “supporting data.” The agency does state that failure to submit AAPs after any approved extensions will result in an immediate Show Cause Notice.
According to the OFCCP’s announcement, the CSAL mailing list encompasses 445 regular establishments, 69 corporate management compliance evaluations, and 66 functional AAP establishments. Universities were excluded from the list “due to currently available compliance workload.”
Contractors should take advantage of the advance notice provided by the CSAL and ensure all identified establishments have “audit-ready” AAPs.
PartnerCara co-chairs Constangy’s practice groups relating to EEO/Contractor Compliance, Reporting & Analytics, and DEI Compliance. She advises employers on proactive strategies to help avoid litigation and has defended employers ...
From developments in pay equity and changing requirements in data reporting, to DEI risk mitigation, Title VII compliance, and shifts in enforcement of Section 503 & VEVRAA, the EEO Compliance Dispatch blog is designed to keep employers informed and ahead of the curve.
Whether you’re a federal contractor navigating audits, an HR professional tackling pay transparency, or in-house counsel tracking state and local reporting requirements, our updates, legal analysis, and compliance strategies are tailored to help you manage risk and support a more inclusive workplace.
