The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) announced on February 22, 2019, that it plans to release its next Corporate Scheduling Announcement List (CSAL) in mid-to-late March 2019. Unlike prior years, the OFCCP will not be sending its traditional advanced notification letters to government contractors (including subcontractors) identified as potential targets for compliance evaluations. Instead, the OFCCP will simply post the CSAL in the agency’s online Freedom of Information Act (FOIA) library for public viewing.
In addition to traditional compliance evaluations, the pending CSAL will also identify contractors who may be subject to new “focused reviews” under Section 503 of the Rehabilitation Act or limited affirmative action plan “compliance checks” pursuant to the OFCCP’s new verification initiative. Both of these programs were announced by the OFCCP in August 2018 via Directive 2018-04 and Directive 2018-07.
The CSAL announcement clearly signals that OFCCP is pushing forward with its revamped efforts to monitor affirmative action compliance under Executive Order 11246, Section 503, and the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA). In light of this announcement, government contractors should take immediate steps to fulfill all aspects of their annual affirmative action obligations, including completion of written affirmative action plans and assessments of veteran and disability hiring from the prior calendar year. By doing so, government contractors will be well-positioned in the event they are selected for OFCCP review.