On Feb. 17, 2017, the Office of Federal Contract Compliance Programs (OFCCP) issued its Corporate Scheduling Announcement Letters (CSALs) to federal contractors and subcontractors. These letters provide contractors with an advance courtesy notice that they may be selected for a compliance review. The CSAL is not required by law for the OFCCP to audit a company. Though the CSAL does not initiate an audit, it does identify contractors that are likely to undergo one. That being said, contractors may also be scheduled for an audit and not receive a CSAL. Only after the OFCCP issues a “scheduling letter,” which initiates the audit, will an employer have to respond by submitting its affirmative action plan.
Contractors that have received a CSAL should ensure that their affirmative action plans are up-to-date and fully compliant with all relevant laws and regulations. Employers should review adverse impact data and pay disparities in particular, as the OFCCP has been aggressive in those areas over the past few years.
For more information, please contact a member of Taft's Labor & Employment group.