On February 1, the OFCCP mailed Corporate Scheduling Announcement Letters to 1,000 lucky federal contractors and subcontractors.
A CSAL is a “courtesy” notice from the Office of Federal Contract Compliance Programs that one or more of a contractor’s establishments have been placed on the audit list for the fiscal year and may undergo a compliance review during the next scheduling cycle. These notices are sent to each particular establishment, not the contractor’s headquarters, so you should advise your local folks to “be on the look out.”
Although the CSAL puts a contractor on notice that a compliance review may be forthcoming, a compliance review will not begin until the contractor receives the actual Scheduling Letter. Once a Scheduling Letter is received, the contractor has 30 days to submit its affirmative action plans and other required data. The OFCCP says that it will begin mailing this round of Scheduling Letters on March 19.
For those of you wondering whether you made it onto this year’s list, you are in the clear if you had a compliance review close within the last five years. (Good news! This grace period used to be only two years.)
Additionally, no more than 10 establishments of a single contractor are placed on the scheduling list, and no more than four establishments of a single contractor will be audited by a particular OFCCP district office.
You can't necessarily relax if you haven't received a CSAL. The OFCCP can and will audit facilities in other circumstances, such as in response to an individual complaint.
If you receive a CSAL, we recommend that you immediately begin reviewing and finalizing your affirmative action plans and other required data so that you will be prepared once you receive the Scheduling Letter and the 30-day clock starts ticking. As those of you who have been through a compliance review know, this 30-day time period goes by quickly, and the extra notice provided by the CSAL can be very helpful in preparing for the audit.
If you have any questions about the audit process or how to prepare for a compliance review, you can always contact Constangy’s Affirmative Action/OFCCP Compliance Practice Group, and we can help prepare you for the process.
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