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.