The OFCCP announced on their website that a new round of Corporate Scheduling Announcement Letters (CSAL) will be released in the near future. Additionally, the text of the new letter was also released. As many readers know, there were rumors circulating around the contractor community that the OFCCP would be discontinuing the "audit heads-up" letter. This rumor turned out to be just that; for at least this federal fiscal year, contractors can continue to expect the CSAL letter and use it to determine which establishments are most likely to get selected for a compliance review.
One of the biggest changes in the new CSAL letter is that there is no longer a limit on the number of new compliance evaluations OFCCP can conduct in a fiscal year. Under the prior administration, a rule was established that a contractor could only be scheduled for a maximum of 25 new compliance evaluations in a given fiscal year. The new CSAL letter states: "Finally, there will be no limit on the number of new compliance evaluations of your company's facilities that OFCCP will conduct during a fiscal year."
This appears to be the first major policy change under Patricia Shiu, OFCCP's new Director. It could end up being a very busy year for some contractors that have a large number of establishments that are potentially subject to a compliance evaluation. It will be important for contractors to keep track of the number of audits initiated in a fiscal year to understand how this policy change will affect enforcement.
Contractors should notify their executive offices that this scheduling letter is coming in the near future and to send to it HR/Compliance as soon as it is received.
