The Office of Federal Contract Compliance Programs (OFCCP) has announced that it will discontinue the process of mailing Corporate Scheduling Announcement Letters (CSALs)—meaning the notice that a specific establishment of a federal contractor or subcontractor is expected to be audited by OFCCP in the near future. OFCCP will now instead solely post online the names and locations of federal contractors and subcontractors that would otherwise have received CSALs.
Contractors should also note that:
- OFCCP has indicated that it expects to post the next batch of CSALs on the OFCCP FOIA Library page in mid- to late-March. Contractors are encouraged to check for inclusion on this list and, particularly if listed, immediately take action to be well-positioned when it receives the Scheduling Letter.
- OFCCP has significantly tightened the lag between CSALs and Scheduling Letters. When OFCCP released CSALs in September 2018, it only provided for a 45-day period before it indicated it would send out Scheduling Letters. Once a contractor receives the Scheduling Letter, it has only 30 days to respond to OFCCP with a significant volume of information, including its affirmative action plans.
Cooley attorneys are happy to assist contractors in better understanding their OFCCP obligations or in undergoing an audit.