Federal Contractors Beware: New Round of OFCCP Audits on the Way
The U.S. Department of Labor’s OFCCP has notified the federal contractor community that it mailed out 1,000 Corporate Scheduling Announcement Letters (CSAL) to covered establishments on February 1, 2018. A CSAL is a preliminary and courtesy warning to a federal contractor that an enforcement audit could be scheduled at any time during the current scheduling cycle – generally coinciding with the Federal fiscal year (October 1, 2017-September 30, 2018). The last round of CSALs were sent to federal contractors at about this same time last year. Some of the letters have been dated January 31, 2018 and signed by newly appointed OFCCP Director Ondray Harris.
Most importantly, OFCCP announced that audit scheduling letters will go out to contractors starting March 19, 2018, and continue as agency investigators can handle new cases.
The letters may be addressed either generally to a contractor’s “human resources director,” or to the chief executive of the organization. Unlike prior years, OFCCP has announced that no contractor with a prior OFCCP compliance review closed within the past five years is on the new scheduling list.
We strongly encourage you to immediately notify your facilities to be on the lookout for a CSAL, which will be sent to individual establishments and not necessarily the corporate headquarters. Facilities should be directed to forward it to the top corporate human resources professional or legal counsel immediately. Once received, contractors have a short 30-day window to provide their current affirmative action plan to OFCCP, and a myriad of other information, documents, and extensive applicants/hires and compensation data.
If you have questions, please not hesitate to contact members of Miller Johnson’s Affirmative Action and Government Contractors Practice Group.