Today, OFCCP issued its first Corporate Scheduling Announcement List (CSAL) of 2019, providing advance notification of compliance reviews, including CMCEs, Section 503 Focused Reviews and compliance checks. True to expectations, the Agency vastly increased the number of locations subject to review to more than 3,500.

OFCCP continued its new policy of transparency by publishing the list of contractors undergoing reviews on its website. Contractors should review the CSAL as OFCCP, for the first time, will no longer send individual CSALs through the mail. Listed contractors should instead receive notice through e-mail. Today’s OFCCP CSAL publication starts a 45-day clock until Agency may begin issuing scheduling letters on May 9. Selected contractors should prepare now for upcoming audits.

Notably, this CSAL includes OFCCP’s first round of five-hundred Section 503 Focused Reviews of contractor’s corporate headquarters. These reviews will include an on-site review of policies, procedures, and documentation of affirmative action obligations for individuals with disabilities. In late 2018, OFCCP released a revised scheduling letter in anticipation of Section 503 Reviews, which requires submitting a subset of the data provided in a traditional review.

Here is a breakdown by the numbers:

  • 1208 unique companies,
  • 2345 Establishment Compliance Reviews,
  • 500 Compliance Checks,
  • 500 Section 503 Focused Reviews,
  • 83 CMCEs, and
  • 72 FAAP functional units

OFCCP also released its updated scheduling methodology as well as CSAL and CMCE FAQs. We will continue to monitor OFCCP developments, particularly those surrounding audits and implementation of the Agency’s numerous 2018 Directives.

Tags: Corporate Scheduling Announcement List, CSAL, Director Craig Leen, OFCCP, OFCCP audits, Office of Federal Contract Compliance Programs, Section 503 Focused Reviews, Section 503 of the Rehabilitation Act of 1973
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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.

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