OFCCP Provides New FAQs Regarding Employer-Employee Relationship



For some federal contractors, identifying whom to include/exclude from their Affirmative Action Plans (AAPs) becomes a bit of a challenge. The common question is: “Who are my true employees?” It goes without saying that making this decision can have a direct impact on the results of the analyses and, in turn, have a direct impact on the corrective steps an organization takes.

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New Ways to Contact Office of Federal Contract Compliance Programs (OFFCP)

Trying to contact the OFFCP?  Effective this month (July 2014), the OFCCP has made available alternative self-service contact methods.  Federal contractors will be able to electronically submit questions and/or check the status of previous correspondence with the OFCCP.

The new self-service systems can be located by visiting the following links:

These new systems will also be incorporated on the Department of Labor’s OFCCP homepage (http://www.dol.gov/ofccp/index.htm).


Over the past decade the OFCCP has made concerted efforts to cultivate partnerships with the Federal Contracting community and this latest effort certainly seems to foster the partnering mentality.  While we don’t expect an immediate response to each question submitted we do expect to see responses codified in the OFCCP’s FAQs, thus creating a unified message on which contractors may rely.

Bear in mind, however, the OFCCP is an enforcement agency, and if you are unsure about the question you would like to submit to the OFCCP or would like to get a second opinion, Biddle Consulting Group advises clients to contact their consultant prior to submitting questions on-line.

Corporate Scheduling Announcement Letters (CSAL)

CSAL ALERT – The OFCCP has issued its latest round of CSAL’s, dated January 31, 2014.

Take a few minutes now to read the OFCCP’s CSAL FAQ page.

What is OFCCP’s Corporate Scheduling Announcement Letter (CSAL)?

The CSAL is notification to an establishment that has been selected to undergo a compliance evaluation during the scheduling cycle. The list is generated from OFCCP’s Federal Contractor Selection System (FCSS). It is not a letter scheduling a compliance evaluation. The purposes of the CSAL are to:

  • Provide the contractor establishment’s internal EEO staff notice to obtain management support for EEO and self-audit efforts;
  • Encourage contractors to take advantage of OFCCP compliance assistance offerings;
  • Encourage contractors to focus on self-audit efforts that, if problems are adequately analyzed and corrected, saves OFCCP time/resources when we do an evaluation; and
  • Help contractors manage/budget the amount of time required for evaluation activity.

If you have any questions, feel free to contact us. We’re happy to help.

How Does the OFCCP Select a Federal Contractor’s Establishment for a Compliance Evaluation?


One of the most common questions from federal contractors is, “How does the OFCCP select a federal contractor’s establishment for a compliance evaluation?”

In a nutshell, the OFCCP uses a facially neutral selection system called the FCSS (Federal Contractor Selection System).  This electronic selection system uses data feeds from several information sources including EEO-1, federal procurement databases, Dun & Bradstreet data and more.  Once the data is in the system, the National Office of the OFCCP organizes the data in an orderly and neutral fashion and houses locations selected for evaluation within the system.  At selected intervals (typically October and May/June) contractor locations are released by the FCSS and district offices are responsible for scheduling the compliance review.

To learn more about the OFCCP’s FCSS click on the following link:  http://www.dol.gov/ofccp/regs/compliance/faqs/fcssfaqs.htm