The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has mailed “advance notice” letters, officially referred to as corporate scheduling announcement letters (CSALs), to approximately 1,000 federal contractor establishments, notifying them that they have been flagged for a compliance evaluation during the agency’s current Fiscal Year 2018 scheduling cycle, which began on October 1, 2017, and runs through September 30, 2018.
Consistent with past practice, the CSALs have been sent directly to each of the individual establishments flagged for an audit, rather than to corporate headquarters. In a significant change from past practice, however, this latest version of the CSAL indicates that OFCCP staff will reach out to the establishment to offer technical assistance prior to sending a formal compliance evaluation scheduling letter. OFCCP indicates that it will begin sending out scheduling letters on March 19.
This offer of technical assistance not only indicates that the current leadership at the Labor Department is serious about its announced intent to enhance OFCCP’s compliance assistance efforts, but also gives contractors an additional heads up before a scheduling letter is sent.
OFCCP also has streamlined and updated its CSAL landing page and Frequently Asked Questions (FAQs). According to the updated FAQs, OFCCP will now limit the number of single contractor establishments on the scheduling list to no more than 10. In addition, OFCCP indicates that no more than four establishments of a single contractor are on the scheduling list in a single district office. And in one other change that should be of major interest to employers who are frequent targets of OFCCP audits, establishments with reviews closed in the last five years are not included on the scheduling list.
Members of the Center for Workplace Compliance (CWC) can read more here.