The Office of Federal Contract Compliance Programs (OFCCP) announced that it mailed 1,000 Corporate Scheduling Announcement Letters (CSALs) on February 1, 2018. CSALs are courtesy notifications from the OFCCP to an establishment that it has been selected to undergo a compliance evaluation during the next scheduling cycle. The OFCCP District Offices plan to begin mailing scheduling letters for actual compliance reviews (audits) on March 19, 2018.
Generally, CSALs are not sent to the corporate headquarters. Instead, the letters are mailed directly to the selected establishment(s). For example, a letter could be sent to the attention of the company’s Human Resources Department at a distribution center two time zones away from headquarters. Establishment level HR departments should be reminded to alert their mailrooms that letters from US Department of Labor should be processed immediately and to forward any letters received to appropriate personnel (e. g. corporate HR) upon receipt.
More than one establishment of a single contractor may receive a CSAL. The OFCCP has announced the following limits in this cycle’s compliance review scheduling:
- No more than 10 establishments of a single contractor are placed on the scheduling list.
- No more than 4 establishments of a single contractor are placed in a single district office.
- No establishment with a review that closed in the last five years is placed on the scheduling list (note that this is a happy extension of the prior two-year audit suspension).
If you have received a CSAL, use the time to make sure your Affirmative Action Program (AAP) is in good shape, audit your compliance, and reach out to legal counsel for help and with questions. Once you receive your Scheduling Letter, you will have only 30 days to submit your AAP. Contractors who have in the past felt that the 30-day submission deadline was more of suggestion than a firm rule should be wary of late submissions. At the town hall meetings in the fall, OFCCP representatives stated that they would move much more quickly to enforcement with regard to delayed submissions. Upon receipt of a CSAL wise contractors will begin identifying and organizing the information that must be included in the initial submission to OFCCP upon receipt of the scheduling letter and itemized list used by the OFCCP.