Unfortunately, it is that time of year again! The OFCCP has begun sending audit letters to federal contractors who are required to have Affirmative Action Plans (“AAPs”). According to the DOL website, the OFCCP has mailed 1,000 Corporate Scheduling Announcement Letters (“CSALs”) to various contractors. These announcement letters give the contractors receiving them advance notice that they’ve been selected by the Federal Contractor Selection System to be evaluated for compliance with certain federal employment law issues including, but not limited to, their AAP. This notice letter, which is not legally required, is typically followed by a scheduling letter that establishes the official date, time and place for the audit and the information that must be supplied in connection with the audit.
The CSALs provide contractors with a window of time in which to confirm that everything is in order with their AAPs and other employment policies and practices. Many contractors will choose to perform a self-audit upon receiving the CSAL to make sure they put their best foot forward when the actual audit occurs.
To ease the administrative burden for employers, the OFCCP has determined that no single contractor will have more than 10 establishments included in the scheduling list and that no contractor who has had an establishment audit closed in past five years will be placed on the scheduling list this year. In any given year, the OFCCP will audit approximately 1-2 percent of all federal contractors.