When the Agency mailed the most recent round of CSALs in February 2018, it reported it would wait until March 19, 2018 to start issuing Scheduling Letters. True to their word, we have learned that Scheduling Letters have started arriving, at least in some areas of the country.

As a reminder, OFCCP sends scheduling letters via certified mail to the HR manager at the location to be audited, If you received a CSAL you should make sure those that receive mail at the location are on the look out. Once the letters are received, Contractors have 30 days to submit the requested AAP and itemized data. With the advance notification provided by the CSAL and waiting until now to send out the Scheduling Letters the Agency believes contractors have had ample time to prepare for the audits and hold the expectation contractors will be able to comply with the submission requirements in the provided response window. As a result, it has posted on its website that

Given this advance notice, extensions to submit the AAP will not be granted for routine business reasons and [will] generally be limited to 15 days.

Under the leadership of Director Ondray Harris, OFCCP is working hard to restore its relationship with the contractor community. With that said, they are still an enforcement agency with a job to do. And initiating audits is the primary way it achieves its goal of evaluating the compliance of federal contractors. It will be interesting to see what impact Director Harris and his vision for the Agency have on how these audits are conducted once they are initiated. We’ll be sure to bring you any updates or insights as we learn of them.