On September 11, 2020, the Office of Federal Contractor Compliance Programs (OFCCP) released its Corporate Scheduling Announcement List (CSAL) online for public access. The CSAL identifies contractors who will be receiving an audit scheduling letter.
This CSAL includes 200 construction contractors and 2,200 supply and service contractors. The supply and service list includes multiples different types of reviews. A full copy of the lists can be found here.
Historically, contractors receiving a CSAL received a scheduling letter formally initiating the audit after about 45 days. The advance notice provided by the CSAL can be a valuable opportunity for contractors to prepare for an upcoming audit, collect the data and documents the contractor will be required to submit to OFCCP within a relatively short period after receipt of the scheduling letter, and identify any potential compliance vulnerabilities that may need to be addressed during the audit process. As we raised in an earlier blog post here, OFCCP plans to review and evaluate any reductions in force during the time period under audit so contractors should in particular be prepared to defend selection decisions in any layoffs.
Contractors named in the CSAL should consider consulting with experienced counsel to assist in preparing for the forthcoming audit scheduling letter.