As a follow up to our post yesterday, there is additional information available regarding OFCCP’s recent mailing out of courtesy scheduling announcement letters.

After a hiatus for the past few years, OFCCP has officially confirmed it has once again sent out CSALs. dated February 17th.  Here are some additional details regarding this wave of notices:

  • OFCCP is characterizing this as the “first” release of CSALs
    • OFCCP has not confirmed if and when another round will go out
  • Approximately 800 notices were mailed
  • 375 distinct companies were noticed
    • This means some companies will receive notices for multiple establishments
  • The companies were from 29 different industries based on reported NAICS codes
  • 30 Corporate Management Compliance Evaluations (CMCEs) were included in the notices

It’s important to keep in mind that a CSAL does not commence an audit (only a scheduling letter can do that) and does not guarantee an audit.  Moreover, OFCCP can audit locations not listed on a CSAL.

Now that OFCCP has decided to once again give contractors advance notice of upcoming audits, its imperative that employers take advantage of this gift of extra-time to ensure they are prepared to submit a compliant AAP once their audit actually commences.

 

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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.