When the Agency mailed the most recent round of CSALs in February 2018, it reported it would wait until March 19, 2018 to start issuing Scheduling Letters.  True to their word, we have learned that Scheduling Letters have started arriving, at least in some areas of the country.

As a reminder, OFCCP sends scheduling letters via certified mail to the HR manager at the location to be audited,  If you received a CSAL you should make sure those that receive mail at the location are on the look out.  Once the letters are received, Contractors have 30 days to submit the requested AAP and itemized data.  With the advance notification provided by the CSAL and waiting until now to send out the Scheduling Letters the Agency believes contractors have had ample time to prepare for the audits and hold the expectation contractors will be able to comply with the submission requirements in the provided response window.  As a result, it has posted on its website that

Given this advance notice, extensions to submit the AAP will not be granted for routine business reasons and [will] generally be limited to 15 days.

Under the leadership of Director Ondray Harris, OFCCP is working hard to restore its relationship with the contractor community.  With that said, they are still an enforcement agency with a job to do.  And initiating audits is the primary way it achieves its goal of evaluating the compliance of federal contractors.  It will be interesting to see what impact Director Harris and his vision for the Agency have on how these audits are conducted once they are initiated. We’ll be sure to bring you any updates or insights as we learn of them.

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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.