OFCCP Sends One Thousand Contractors Scheduling Announcement Letters
On February 1, 2018, the Office of Federal Contract Compliance Programs (OFCCP) sent Corporate Scheduling Announcement Letters (CSAL) to 1,000 federal contractors notifying the contractors that the OFCCP might conduct audits of specific contractor’s establishments in 2018. The CSAL is not notification of an audit – it is meant to assist contractors by providing them with advance notice of a possible audit. On March 19, 2018, the OFCCP will send audit letters to the contractors’ establishments that are chosen for an audit.
If one of your establishments receives a CSAL, you should immediately begin to prepare for an audit by ensuring that your affirmative action programs are up to date; the records supporting the affirmative action programs are ready for OFCCP review; and you have conducted an analysis of your applicant and hiring, promotion and termination procedures and data. If you have received a CSAL, Clark Hill can assist you in preparing for the audit.
The OFCCP normally sends contractors a standard audit letter containing a request for documents in 22 categories, including organizational profiles, job groupings and written affirmative action programs. The audit is scheduled for 30 days after the audit letter is sent. The purpose of the CSAL is to:
- Provide the contractor establishment’s internal EEO staff with at least 45–days advance notice to obtain management support for EEO and self–audit efforts;
- Encourage contractors to take advantage of OFCCP 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 it does an evaluation; and
- Help contractors manage/budget the amount of time required for evaluation activity.
The OFCCP sent the CSAL to the specific establishments of the contractor that the OFCCP might target for audits in 2018. Contractors with multiple facilities should ensure that the facility management or human resource managers immediately send the CSAL to the contractor’s headquarters and begin a self-audit to prepare for the OFCCP audit.
The OFCCP begins with a desk audit. If the OFCCP has questions after the desk audit, it will request an in-depth on-site audit. Contractors who provide the necessary documents at the desk audit stage can avoid an on-site audit. By preparing for the audit in advance, the contractor can ensure that it has properly documented its affirmative action program and avoid a time consuming and costly on-site audit.
If you have any questions about CSAL or the requirements of federally mandated affirmative action programs, please contact Thomas P. Brady, (313) 965-8291 or firstname.lastname@example.org; David M. Cessante, (313) 965-8574 or email@example.com; or another member of Clark Hill’s Labor and Employment Practice Group.