On Friday September 7, 2018, the Office of Federal Contract Compliance Programs (OFCCP) mailed 750 corporate scheduling announcement letters (CSALs) to federal contractors and subcontractors. The agency mailed the letters to 445 companies and included 69 corporate management compliance evaluations. OFCCP did not include any universities in this round of CSALs "due to currently available compliance workload."
The agency sends CSALs to service and supply contractors to give them advance notice that they may be selected for an OFCCP compliance review, so contractors that receive CSALs may want to take particular care to verify that their affirmative action programs (AAPs) are up to date and compliant with applicable laws and regulations.
OFCCP does not appear receptive to requests for extensions regarding the submission of contractors' written AAPs, noting that contractors on the current list are already "receiving a minimum of 75 days advance notice" to have written AAPs ready. OFCCP's announcement points contractors to a new answer to a frequently asked question on requesting an extension for submission of AAPs and supporting data.
These upcoming compliance evaluations will not include focused reviews, which were announced in recent OFCCP Directive 2018–04, as they will be included in the Fiscal Year 2019 scheduling lists.
Ogletree Deakins' Affirmative Action and OFCCP Compliance Practice Group will continue to monitor further developments regarding CSALs and compliance reviews and will update the Affirmative Action/OFCCP blog with additional news.
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