On February 1, 2018, the Office of Federal Contract Compliance Programs (OFCCP) sent 1,000 Corporate Scheduling Announcement Letters (CSALs) to federal contractors informing them that they may be audited for compliance with federal non-discrimination requirements/affirmative action plans.
A CSAL is not a letter scheduling a compliance evaluation, but is a notification that the establishment has been selected to undergo a compliance evaluation during the scheduling cycle. The list of establishments who receive a CSAL is generated from the OFCCP’s Federal Contractor Selection System.
According to the DOL, the CSALs are to:
- Provide the contractor establishment’s internal EEO staff at least 45–days advance notice to obtain management support for EEO and self–audit efforts
- Encourage contractors to take advantage of the OFCCP’s compliance assistance offerings
- Encourage contractors to focus on self–audit efforts that, if problems are adequately analyzed and corrected, saves the OFCCP time/resources when they do an evaluation
- Help contractors manage/budget the amount of time required for evaluation activity.
The OFCCP mails a CSAL to the Human Resources Director (or designated point of contact) of each establishment on the scheduling list issued in a scheduling cycle. To confirm whether an establishment was mailed a CSAL, a company can email a written a written request on company letterhead to the Division of Program Operations at OFCCP-DPO-Scheduling@dol.gov.
According to the DOL website, OFCCP will begin mailing scheduling letters on March 19, 2018.
What to Do Now – Action Items for Federal Contractors
- If your company received a CSAL, now is the time to start preparing for an audit. Do not wait until the audit letter comes.
- Your company should quickly conduct a self-audit to gauge how actual results compare to its affirmative action plan.
- Be sure to notify your facilities to keep their eye out for any CSAL or scheduling letter, and forward them to the appropriate people internally as soon as possible.
For more information, please contact your Baker McKenzie lawyer.