On February 17, 2017, the U.S. Department of Labor’s Office of Federal Contract Compliance Program (OFCCP) sent its first release of Corporate Scheduling Announcement Letters (CSALs) for FY 2017. The CSALs provide a courtesy warning to 800 establishments for 375 distinct companies that have been neutrally selected for an impending OFCCP compliance review (audit).
Typically, these letters are mailed to the establishment’s human resources director (or designated points of contact) and provide at least one month advance notice of the impending OFCCP review, which is likely to occur within the agency’s fiscal year (October 1-September 31). In recent years, however, the OFCCP’s significantly slower pace of audit processing has resulted in delayed audit starts since the last advance notice letters were issued in 2014.
Nevertheless, it is imperative that federal contractors who receive a CSAL use this notice period wisely to prepare for a likely upcoming audit by ensuring that their affirmative action programming is in compliance with federal regulations, including recent revisions such as the expansion of the protected classes to include sexual orientation and gender identity, the pay transparency rule, and the OFCCP’s Final Rule updating its sex discrimination guidelines.