On March 27, 2013 OFCCP sent out a wave advance notice letters –referred to as CSAL’s – to employers across the country.  In November, 2012, OFCCP emailed more 1,750 CSALs.  We have learned the number of CSAL’s mailed last week exceeds the last round of notifications sent in November.  As result, employers can expect a significant increase in audits during the rest of OFCCP’s fiscal year 2013, which ends September 30th.

Like the last several rounds of CSALs issued, these advance notification letters have been send directly to the facility to be audited and are addressed ambiguously to “Human Resources Director.” Thus, it’s time once again to alert those in the field to keep their eyes open for correspondence from the OFCCP.

Given the Agency’s recent rescission of its systemic discrimination compensation standards and issuance of Directive 307 (“Procedures for Reviewing Contractor Compensation Systems and Practices”), we anticipate OFCCP will be aggressively reviewing compensation in this coming wave of audits.  Employers need to be vigilant in carefully reviewing their pay practices to ensure they can defend what we anticipate will be vigorous pay investigations by OFCCP going forward.  In addition, employers should ensure other “hot button” issues – such as adverse impact in hiring and outreach to veterans and disabled based recruitment services – are carefully reviewed before submitting an affirmative action plan to the Agency.