OFCCP Releases 750 CSAL Letters – What You Need to Know

On September 7, 2018, OFCCP announced the release of 750 Corporate Scheduling Announcement Letters (CSALs).

Here’s what you need to know:

• Contractors receiving a CSAL should theoretically have, at least, 45 days advance notice prior to receiving a scheduling letter and, therefore, at least 75 days from receipt of the CSAL to ensure their plan is in place.
• Establishments that received a CSAL or concluded a review or progress reporting within the last five years should NOT have received a letter.
• No more than four establishments were targeted for any given contractor at a single district office.
• Universities were not targeted this round.
• This list does not include focused reviews, which will first be captured in the FY2019 scheduling lists.

Within the CSAL announcement, OFCCP linked FAQs to their new policy on requesting extensions, which states that a 30-day extension will be granted for support data related to EO 11246, Section 503, and VEVRAA AAPs, if:

1. The contractor requests the extension prior to the 30-day due date (based on 30 days from receipt date of scheduling letter)
2. The contractor submits the basic EO 11246, Section 503, and VEVRAA AAPs, verifying a baseline level of compliance per Directive 2018-07.

From DCI’s perspective, this could be seen as a victory for contractors who may need additional time to finalize their transactional applicants, promotions, and terminations data. However, given OFCCP’s emphasis on transparency and ensuring contractors are reaching a proactive, annual baseline level of compliance, one may also predict that the agency will become stricter with deadlines, especially for requests for additional information (RFIs). DCI will remain alert as to exactly how this plays out in practice.

By Jeff Henderson, MPS, SHRM-SCP, Consultant at DCI Consulting Group