CSAL letters are being issued as of February 17th

DCI has confirmed with OFCCP that a new round of CSAL letters were officially mailed as of February 17th. The letters were sent directly to establishments and “Frequently Asked Questions” resources have been updated on the Department of Labor’s website regarding the FCSS and CSALs.

Specifically, in referencing OFCCP’s CSAL and FCSS FAQs, we note the following new or revised FAQs:

• Will the corporate headquarters of establishments on the scheduling list receive a CSAL?
  • No. CSALs are mailed to all establishments identified on the scheduling lists developed for a given scheduling cycle. Unlike previous years, OFCCP will not send notice to a corporation’s headquarters. Instead, the CSAL directs the establishment to forward the notice to corporate headquarters, if such is corporate policy.

Unlike previous years, OFCCP will not send notices to a corporation’s headquarters. CSALs will be mailed directly to all establishments on the scheduling lists with the direction that these notices be forwarded on to corporate headquarters. Other FAQs include:

• How many establishments are on the current Scheduling List?
  • There are a total of 800 establishments on this first release of the FY 2017 Scheduling List.
• How many industries are represented on the current Scheduling List?
  • Based on the 2–digit NAICS code, the first release of the FY 2017 Scheduling List covers 29 industries.
• How many companies are represented on the current Scheduling List?
  • 375 distinct companies are represented on the first release of the FY 2017 Scheduling List.
• How many Corporate Management Compliance Evaluations (CMCE) are included in the current Scheduling List?
  • The first release of the FY 2017 Scheduling List includes 30 CMCEs.

It’s important to note that 800 letters were sent, but those letters are only covering 375 companies. This means that some companies will receive multiple letters for multiple establishments. It’s also important to note that organizations may receive a corporate management evaluation letter at their headquarter facility. DCI is trending the 29 industries that are receiving CSALs and will provide updates as we learn more.

One additional point worth mentioning is that OFCCP clarified that a contractor’s establishment may be selected for a review outside of those listed on the CSAL by a Directed Review. The FAQ states that “these compliance evaluations may be scheduled by OFCCP when it receives credible information of an alleged violation of a law or regulations the agency enforces, including those deriving from individual of class complaints filed with the EEOC, or state or local fair employment practices agencies (FEPAs) that allege employment discrimination covered under the laws that OFCCP enforces."

Corporate compliance officials should contact local HR representatives at their company’s facilities to ensure they are aware a letter from OFCCP may be coming in the next few days. Additionally, they should be aware that there may be a CMCE letter coming to their corporate headquarters.

By Rachel Monroe, HR Analyst; David Cohen, President; and Joanna Colosimo, Director of EEO Compliance, at DCI Consulting Group