23 January 2023

Starting the Year With a Bang: OFCCP Publishes First CSAL for 2023

Late last week the OFCCP released the first Corporate Scheduling Announcement List (CSAL) for 2023.  The CSAL is advance notice to a federal contractor establishment selected for a Compliance Review (Establishment Review), Corporate Management Compliance Evaluation (CMCE), or Functional Affirmative Action Program (FAAP) Review.

The most recent CSAL includes 500 supply and service contractors selected for review.  The CSAL provides advance notice to contractors that they will be audited.  However, audits do not actually start until the contractor receives a Scheduling Letter.

Previously, Scheduling Letters were not issued until at least 45 days from publishing the CSAL, giving contractors a bit of breathing room.  However, last year OFCCP changed its policies so that Scheduling Letters may be issued immediately.  This means that the clock is ticking for listed contractors.  OFCCP can start initiating audits immediately.

Contractors should review the new CSAL to see if they have been selected for an audit.  Those selected should confirm that they are prepared for OFCCP review.

As a reminder, OFCCP has submitted a revised scheduling letter to the Office of Management and Budget that, if approved, would make compliance reviews significantly more burdensome for federal contractors.  OFCCP’s current scheduling letter expires on April 20, 2023.

Please contact the authors of this client alert if you have further questions.