By Amanda Bowman and Benjamin Kerner
The Office of Federal Contract Compliance Programs (OFCCP) released its first Corporate Scheduling Announcement List (CSAL) for federal fiscal year 2023 today, January 20, 2023. The list includes Supply and Service contractors only.
The CSAL is a courtesy notification for the contractor community regarding audits that will be scheduled. The list does not initiate an audit. As in past years, OFCCP has also provided the public with a copy of the methodology used to develop the current scheduling list.
The January 2023 CSAL includes 500 establishment or functional affirmative action plans (FAAP) in various industry segments throughout the United States. This is an increase from the 2022 list, which included 400 plans (see our previous DCI blog in this regard). For the 500 entities scheduled in the 2023 list, the breakdown for review type is as follows: 452 establishment reviews, 24 FAAP review, and 24 Corporate Management Compliance Evaluations (CMCE). OFCCP’s methodology statement says that no parent company should have more than four reviews on the CSAL.
OFCCP has confirmed the list includes both prime and subcontractors. OFCCP historically has had a difficult time identifying subcontractors through their typical scheduling process and methodology. Subcontractors, if they meet the regulatory thresholds, are required to comply with OFCCP requirements just like the prime contractor.
The OFCCP methodology document indicates that “Contractor and subcontractors that certified in the OFCCP Contractor Portal as of December 1, 2022, were removed from the pool.” However, based on DCI’s cursory review, the CSAL does include contractors that certified in 2022. DCI will be reviewing the published list and methodology in more detail.
What is a CSAL? OFCCP gives federal contractors notification of pending compliance evaluations by issuing a Corporate Scheduling Announcement List (CSAL) in advance of sending out scheduling letters. A CSAL is a “courtesy” notice to an establishment that it has been selected to undergo an audit by OFCCP. It does not initiate an audit, but instead provides additional time for preparation.
Additional updates and insight will be provided as DCI learns more information. If you are a DCI client, your consultant will be in touch if you are listed on the CSAL.