OFCCP releases another CSAL

The importance of certifying compliance becomes evident.

The Office of Federal Contract Compliance Programs issued a new Corporate Scheduling Announcement List, identifying the contractors that will be slated for a compliance review in the future. The courtesy CSALs posted by the agency benefit contractors by providing notice that a Scheduling Letter is forthcoming. When a contractor receives a Scheduling Letter, it has only 30 days to submit its affirmative action plans and supporting information. That means time is getting the heads up – and taking advantage of it -- is essential.

According to the methodology released by the OFCCP, this CSAL includes contractors that did not certify compliance in the OFCCP’s Contractor Portal by December 1, 2022. The list includes 500 contractor locations.

Contractors should be mindful that the OFCCP has proposed significant changes to its Scheduling Letter & Itemized Listing – the documents that outline the information and data that must be submitted to the agency during a compliance review. The deadline to comment on this proposal ends today, and the OFCCP is likely to need several months to review the comments before providing its final version to the Office of Management and Budget for approval.

Contractors on this CSAL will not receive their Scheduling Letters before any changes to the Scheduling Letter & Itemized Listing go into effect. If any of the OFCCP’s proposed changes are adopted, the new version will undoubtedly be more burdensome than the current requirements.

For an in-depth discussion on the proposed changes to the Scheduling Letter & Itemized Listing, please join me and colleagues from the National Industry Liaison Group’s Advisory Council for a webinar on January 26.

Our Affirmative Action Alert blog focuses on the latest news and topics affecting federal contractors and subcontractors and their compliance with affirmative action and other employment-related laws and regulations.  With breaking news, quick updates, and headlines on the Office of Federal Contract Compliance Programs and affirmative action issues, this blog is a great resource for in-house counsel, HR managers, and other compliance professionals.  Our blog is a companion to Constangy’s Affirmative Action newsletters, which address significant legislative, regulatory, and administrative proposals and changes.  Subscribe to both to stay current on these important topics!

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