General Audit Trends

In March of this year, OFCCP released their Corporate Scheduling Announcement Letter (CSAL) list, outlining which federal contractors could expect to be audited this year, as well as the type of audit. OFCCP has indicated that Compliance Checks, CMCE reviews, and FAAP reviews were randomly ordered at the beginning of the scheduling list, and were appended to the district offices’ list of unscheduled establishments from the 2018 CSAL. DCI has seen a recent uptick in audit activity, especially in the Midwest region, with scheduling letters sent out in May and June. In line with OFCCP’s indication regarding the 2019 CSAL, DCI has only seen scheduling letters for Compliance Checks, CMCE reviews and FAAP reviews. However, DCI has also seen establishment review scheduling letters come in from the previous CSAL, as OFCCP has stated that it “does not purge unscheduled cases from prior lists before releasing a new scheduling list.”

As a reminder, below is a breakdown of the type of reviews included in the CSAL:

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By Bryce Hansell, Consultant and Dave Sharrer, Senior Consultant at DCI Consulting Group

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