OFCCP gives contractors the gift of time by issuing Corporate Scheduling Announcement Letters (CSAL), typically twice a year, 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 the OFCCP. It does not initiate an audit but instead provides additional time for preparation.
Although previously mailed, OFCCP will not be mailing letters for this next release, but instead will only post the CSAL list on its website, specifically the FOIA Library. As a result, the “L” in CSAL will now refer to “List” rather than “Letter.” This change aligns with the agency’s new approach to transparency while cutting costs associated with mailing CSAL letters. Currently, one of OFCCP’s FAQ still states that CSALs will be mailed to the local HR director, so we recommend contractors communicate with local offices, in addition to monitoring the agency’s website, to determine if they have been selected.
It is estimated that OFCCP will conduct 3,500 audits in 2019, 500 of which will be focused reviews and 500 will be compliance checks. The remaining 2,500 audits will be a combination of typical compliance reviews and complaint investigations. Less common in recent years, compliance checks are scheduled using an abbreviated letter with the objective to determine whether a contractor maintained certain records as required by the regulations at 41 CFR 60-1.12, 41 CFR 60-300.80, and 41 CFR 60-741.80. Contractors interested in learning more about the types of compliance evaluations can reference the Federal contractor Compliance Manual used by the agency.
OFCCP’s latest email update indicated the next list will be posted in mid-to-late March. DCI will continue to monitor the next CSAL release and will provide updates as they become available.
By Yesenia Avila, Consultant, and Amanda Bowman, Associate Principal Consultant at DCI Consulting Group