With great fanfare OFCCP announced in August at the ILG National conference in Hawaii that it would be forgoing the mailing of advance notification letters to employers in exchange for publishing the list of likely compliance reviews via the Agency’s website. Despite its previous announcement of a move to the web-based notification system, last week OFCCP mailed out hundreds of Corporate Scheduling Announcement Letters (CSALs) to ensuing employers.
As you may have experienced, rolling out a new system (of any type), takes time. By opting to send out hard-copy CSALs this time around, the Agency doesn’t have to experience any delay in slating companies for audits while waiting for the online notification system to get up and running.
Like the last round of letters, these CSALs appear to have been sent directly to the facility to be audited and are addressed ambiguously to “Human Resources Director.” Thus, it’s time again to get the word out to those in the field to keep their eyes open for correspondence from the OFCCP.
With Obama’s Re-election we anticipate OFCCP will continue to enhance its already vigorous enforcement efforts. This includes the Agency’s growing reluctance to grant extension requests. OFCCP likely will point to the latest round of CSALs as justification for continued denial of request for additional time to submit an audit response. Given this, employers who receive advance notification of a compliance review should take advantage of the “heads up” and start preparing for a compliance review . . . NOW.