The Office of Federal Contract Compliance Programs (OFCCP) has begun sending Corporate Scheduling Announcement Letters (CSALs) to federal contractors, giving them a “heads-up” warning of a possible compliance review or audit by OFCCP. Although OFCCP claimed this summer that it would post future notifications online, these recent letters were sent to contractors by mail.
The recent letters sent to establishments by OFCCP’s national office are addressed to “Human Resources Director.” If one of your locations receives this type of notification from OFCCP (example provided here), please note that it is not an official scheduling notice for an OFCCP audit, but only a “heads-up” that an audit will likely be conducted during OFCCP’s next scheduling cycle.
Whether an audit will actually be scheduled by OFCCP after receipt of a CSAL letter is uncertain and depends on the current workload of the OFCCP district or area office involved, as well as other factors. Nonetheless, receipt of a CSAL letter should serve as an extra incentive to contractors to ensure that their affirmative action programs are current and defensible.
Leigh M. Nason is a shareholder in the Columbia office of Ogletree Deakins, and she chairs the firm’s Affirmative Action and OFCCP Compliance Practice Group.
