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Executive Summary: The Office of Federal Contract Compliance Programs (OFCCP) recently issued a new round of Corporate Scheduling Announcement Letters (CSALs), which notify an establishment that it has been selected to undergo a compliance review during the next scheduling cycle. These letters are not actual audit letters but rather a courtesy notice that a compliance review will likely start in the near future. Contractors who receive such letters should take steps to ensure their affirmative action plans and adverse impact analyses are complete and ready for submission and that compensation systems are reviewed and ready to be defended.
Contractors who receive CSALs should pay special attention to the following issues, which have been the subject of recent OFCCP attention:
The Bottom Line:
The OFCCP has become increasingly aggressive in its examination of contractors' employment practices and compliance with federal affirmative action laws. All contractors should ensure they are in compliance with these laws and any applicable record-keeping requirements.
If you have any questions regarding this Alert or your obligations as a federal contractor please contact the FordHarrison attorney with whom you usually work or Linda Cavanna-Wilk, firstname.lastname@example.org, or Karen Tyner, email@example.com, both of whom are members of FordHarrison's Affirmative Action/Government Contracts practice group.
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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