DCI has learned that the Office of Federal Contract Compliance Programs (OFCCP) sent out another round of Corporate Scheduling Announcement Letters (CSALs) identifying potential locations for FY2012 compliance evaluations. About 2,000 letters were sent out on or about May 2, 2012. Historically, OFCCP would not send out a CSAL letter to those contractors’ who were scheduled for only one compliance evaluation. However, OFCCP continues to depart from that scheme and, in some circumstances, sent CSALs listing only one establishment. In fact, DCI has learned that if only one federal contractor location was selected for a potential audit, the letter was sent to that specific location, rather than to corporate headquarters. If a federal contractor had 2 or more locations selected for potential audit, the letter was sent to the contractor’s corporate location. Federal contractors at their corporate locations should prepared to communicate with other locations to determine whether CSAL letters were received at non-corporate locations. In addition, for the first time OFCCP is also notifying contractors in advance of they are being scheduled for a corporate management compliance evaluation.
By Joanna Colosimo and Eric Dunleavy, Ph.D., DCI Consulting Group