The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has mailed a second round of FY 2018 “advance notice” letters, officially referred to as corporate scheduling announcement letters (CSALs), to approximately 750 federal contractor establishments, notifying them that they have been flagged for an upcoming compliance evaluation. Under current OFCCP policy, the agency gives targeted establishments 45 days advance notice prior to sending a desk audit scheduling letter, meaning the earliest that OFCCP will begin mailing scheduling letters to those establishments flagged in this second round will be Monday, October 22, 2018.
In conjunction with the CSAL mailing, and in a significant change from past practice, OFCCP has also announced a new formal policy with respect to granting extensions for desk audit submissions beyond the normal 30-day response period. Under the new policy, the agency will routinely provide an additional 30-day extension for the supporting data and information requested by the desk audit scheduling letter, provided that the contractor submits the extension request, and its basic Executive Order 11246, Section 503 and VEVRAA affirmative action programs (AAPs) within the initial 30-day period after receiving the scheduling letter.
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. OFCCP indicates that it began sending out CSALs on September 7, 2018.
Members of the Center for Workplace Compliance (CWC) can read more here.