The Office of Federal Contract Compliance Programs (OFCCP) announced that they will soon be releasing its Spring Corporate Scheduling Announcement Letters (CSAL). CSALs are essentially “heads-up” letters to inform federal contractors that one or a number of their establishments is/are scheduled for compliance evaluation. Traditionally, CSALs are mailed to the federal contractor’s designated point of contact at each establishment on the list. However, it seems that the OFCCP will cease to send out the CSAL letters starting with the 2019 spring batch and instead, will only make the list available through the FOIA library. It is therefore important for the contractors to check the library to determine if their establishment (or any of their multiple establishments) is expected to receive the compliance evaluation scheduling letter.
Needless to say, compliance evaluations can be daunting and also time-consuming. Through the CSAL, contractors are in essence provided with a 45-day window to get their “ducks in a row” prior to getting the official scheduling letter. Upon receipt of the scheduling letter, contractors have 30 additional days to submit to the OFCCP their Affirmative Action Plan (AAP) and supporting data. Smart contractors should utilize this 75-day window to prepare their AAP. Preparations should include reviewing and analyzing all the site’s data, compiling and evaluating all the Good Faith Efforts and their supporting documents, reviewing the company’s selection and compensation policies and procedures, and preparing the necessary explanations and plan of action for any concerns found during the self-audit.