On February 1, 2018, the United States Department of Labor (“DOL”), Office of Federal Contract Compliance Programs (“OFCCP”) issued 1,000 Corporate Scheduling Announcement Letters (“CSAL”) to US federal contractor employers, indicating that the letter recipients have been selected for audit of their compliance with federal Affirmative Action regulations. CSAL recipients were selected through the Federal Contractor Scheduling System, a neutral (i.e., non-targeted) selection system.
CSALs are not considered formal notice of an audit. CSALs are intended to provide organizations with advance notice of an audit in order to allow them additional time to gather the organization’s Affirmative Action Plan (“AAP”) and supporting documentation, such as employee compensation records. The DOL also encourages contractors to self-audit and correct any compliance problems prior to the audit.
The DOL will begin sending formal audit scheduling letters on March 19, 2018. Contractors will have only 30 days from the date of the scheduling letter to provide the DOL with their AAP and any additional requested documents. The DOL notes it has certain parameters on its audit list, such that it will audit no more than 10 establishments of a single contractor; no single DOL district office will evaluate more than four establishments of a single contractor; and no establishment that has completed review within five years is included on the scheduling list.
CSALs were mailed to individual contractor establishments to the attention of the site’s Human Resource Director, or other designated contact. Contractors should keep an eye out for these, and in March, for scheduling letters. Note that CSALs are not required by law before an audit, therefore, contractors may still be subject to audit even if they did not receive a CSAL.