On September 8, 2023, OFCCP announced it posted a new Corporate Scheduling Announcement List (CSAL) for supply and service contractors. OFCCP announced that the list consists of 1,000 federal contractors and subcontractors selected for a Compliance Review (Establishment Review), Corporate Management Compliance Evaluation, Functional Affirmative Action Program Review or a University Review.

Note that the list merely notifies these contractors and subcontractors that they will be audited – audits will not commence until the entity receives a Scheduling Letter.  However, Scheduling Letters may be issued immediately (as opposed to the prior policy of not issuing Scheduling Letters earlier than 45 days from the publishing of the CSAL).  So, contractors on the list need to understand they are now “on the clock.” 

To see if your company was selected, you can access the list here.  Those selected should consult with counsel as necessary to be sure they are ready for when OFCCP knocks on the door (which could come at any time).  Please note that companies on this list will be subject to the new enhanced scheduling letter which demands significantly more information than the prior version – and requires that information be submitted within 30 days of receipt.  As such, it is imperative that companies selected take immediately steps to prepare for their impending audits.

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Photo of Guy Brenner Guy Brenner

Guy Brenner is a partner in the Labor & Employment Law Department and leads the Firm’s Washington, D.C. Labor & Employment practice. He is head of the Government Contractor Compliance Group, co-head of the Counseling, Training & Pay Equity Group and a member…

Guy Brenner is a partner in the Labor & Employment Law Department and leads the Firm’s Washington, D.C. Labor & Employment practice. He is head of the Government Contractor Compliance Group, co-head of the Counseling, Training & Pay Equity Group and a member of the Restrictive Covenants, Trade Secrets & Unfair Competition Group. He has extensive experience representing employers in both single-plaintiff and class action matters, as well as in arbitration proceedings. He also regularly assists federal government contractors with the many special employment-related compliance challenges they face.

Guy represents employers in all aspects of employment and labor litigation and counseling, with an emphasis on non-compete and trade secrets issues, medical and disability leave matters, employee/independent contractor classification issues, and the investigation and litigation of whistleblower claims. He assists employers in negotiating and drafting executive agreements and employee mobility agreements, including non-competition, non-solicit and non-disclosure agreements, and also conducts and supervises internal investigations. He also regularly advises clients on pay equity matters, including privileged pay equity analyses.

Guy advises federal government contractors and subcontractors all aspects of Office of Federal Contract Compliance Programs (OFCCP) regulations and requirements, including preparing affirmative action plans, responding to desk audits, and managing on-site audits.

Guy is a former clerk to Judge Colleen Kollar-Kotelly of the US District Court of the District of Columbia.