The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has released a Corporate Scheduling Announcement List (CSAL) for the 2019 fiscal year for 3,500 establishments.
This is the first time OFCCP issued the list only through the Freedom of Information Act (FOIA) library. Previously, OFCCP mailed individual corporate scheduling announcement letters (CSALs) to federal contractors and subcontractors notifying them that they could be subject to an OFCCP audit, such as a focused review, compliance check, or Corporate Management Compliance Evaluation (CMCE). The CSAL is the precursor to the Scheduling Letter and Itemized Listing, which is the letter approved by the Office of Management and Budget (OMB) that OFCCP sends to an establishment to start the evaluation process and to formally request submission of the contractor’s EO 11246, Section 503, and VEVRAA Affirmative Action Program(s) and the supporting data.
A scheduling list released by OFCCP on its website shows that reviews will include 500 Section 503 Focused Reviews and 500 compliance checks, more than 2,000 establishment reviews, 72 Functional Affirmative Action Program (FAAP) reviews, and 83 CMCEs Section 503 and compliance check reviews had not been conducted previously by the OFCCP as part of the CSAL.
Contractors that are part of this CSAL can expect OFCCP to send an OMB-approved scheduling list in early May, 45-days after the CSAL was published on March 25. After receiving the scheduling list, OFCCP will provide contractors the standard 30 days to submit their Affirmative Action Program (AAP). This will provide contractors on the current CSAL a minimum of 75 days advance notice to have the AAP ready for submission. OFCCP will contact contractors within 15 days of the contractors’ receipt of the Scheduling Letter and Itemized Listing to establish a compliance officer as the primary point of contact for the evaluation, offer technical assistance on OFCCP requirements, and explain allowable extensions for the AAPs and supporting data.
Contractors may request a one‐time 30‐day extension for supporting data for the AAP if the extension is requested during the standard 30 days prior to submitting the AAP and the AAP is submitted within the 30-day window.
Additionally, the OFCCP has updated their Frequently Asked Questions on CSAL and CMCE’s. Contractors should review these pages to ensure they are up to date.
The OFCCP is providing a dedicated page on Section 503 reviews, including frequently asked questions, best practices, regulations, and other resources. The Section 503 focused review page and related resources can be viewed here.
To view frequently asked questions on CSAL, click here.
To view frequently asked questions on CMCE, click here.
For an explanation of the methodology used by OFCCP for selection to the CSAL, click here.
The OFCCP enforces EO 11246, Section 503 and VEVRAA, which prohibit contractors and subcontractors from discriminating on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or status as a protected veteran. In addition, these laws require federal contractors to take steps to ensure equal employment opportunity in their employment processes.
To learn more about achieving pay equity, and to receive a free pay gap risk assessment, click here.