The Office of Federal Contract Compliance Programs (OFCCP) mailed a set of corporate scheduling announcement letters (CSALs) on March 27. A CSAL is an advance warning to a federal contractor that its establishment may be “audited” in an upcoming compliance review. In past years, the OFCCP mailed CSALs to both corporate headquarters and specific establishments the OFCCP may audit. This year, the CSALs were not mailed to corporate headquarters, but were only mailed directly to the location that is potentially subject to the compliance review. The letters were sent to the attention of the “Human Resources Director.” If you are a federal contractor, consider alerting company locations to watch for the notices. Company locations identified in the CSAL may or may not be audited in the coming year depending on the workload of OFCCP offices.
If a company is selected for a compliance review, the OFCCP will send an additional Scheduling Letter to those specific locations selected for review, notifying them of the 30-day period they have to submit their affirmative action plan (AAP) to the OFCCP.
If your corporation or parent company received a CSAL, this is a good opportunity to:
• Ensure that compliant AAPs are in place for the specified locations,
• Review any potential issues that are likely to cause problems during an OFCCP review, particularly adverse impact in hiring and compensation disparities, and
• Take affirmative steps to remedy any identified deficiencies.