On March 25, 2019, the Office of Federal Contract Compliance Programs (OFCCP) published its FY 2019 Corporate Scheduling Announcement List (CSAL). The CSAL provides federal contractors with at least 45 days' notice of an impending compliance evaluation (audit) by the OFCCP. Accordingly, compliance evaluation Scheduling Letters issued pursuant to this CSAL will be sent to contractors no earlier than May 9, 2019. Importantly, unlike in past years, OFCCP will not accompany the CSAL with letters to contractors further alerting them to the coming audit. Instead, the list will merely be posted on the OFCCP's website.
The CSAL includes 3,500 establishments encompassing 1,208 companies, and includes 2,345 establishment reviews, 83 Corporate Management Compliance Evaluation reviews, 72 Functional Affirmative Action Program reviews, 500 Section 503 Focused Reviews, and 500 Compliance Checks. This is the first time the list has included Section 503 Focused Reviews, which will concentrate on contractor policies and procedures specifically related to recruitment, hiring, and accommodation of individuals with disabilities. With respect to Compliance Checks, OFCCP briefly explained, "[a] Compliance Check evaluates the contractor's efforts in meeting its affirmative action goals, outreach activities, and recruitment efforts for protected groups."
Federal contractors should carefully review the CSAL for facilities and subsidiaries within their organizations and ensure affirmative action plans for those facilities are promptly prepared with extra care. In addition, federal contractors should review the compliance practices at those facilities and—especially for facilities identified for Section 503 focused reviews—log and assess recruitment and outreach practices for year-over-year efficacy.
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