Corporate Scheduling Announcement Letter (CSAL) To Continue

Today, the chair of the National Industry Liaison Group for Affirmative Action Planning sent notice out to the regional ILG's that after a short delay, OFCCP has elected to continue sending out the Corporate Scheduling Announcement Letter (CSAL). As recently as October Pat Shiu, Director of OFCCP, stated at the National Employment Law conference in San Francisco that she would be considering the CSAL in the future but there was no clear direction at this time.

The release of the CSAL is welcome news to Federal contractors as the letter provides advance notice to the contractor regarding the number and location of establishments that can expect to receive a desk audit letter in the near future. While there has been concern from various agencies in the past that the CSAL might allow contractors to focus on compliance only in establishments where they know an audit letter may show up, it is the experience of BCG that the CSAL heightens overall compliance awareness.

Contractors should also be reminded that the previous cap of 25 establishment no longer exists and that OFCCP is not bound by the CSAL in determining which sites they may choose to audit. In the recent past, BCG has found that the desk audits typically follow the CSAL listing, although it is not a certainty that the various OFCCP regions will only audit sites on the list.

To read more about the guidelines associated with the CSAL, see the OFCCP Frequently Asked Questions link here:

http://www.dol.gov/ofccp/regs/compliance/faqs/csalfaqs.htm

The quote from the NILG regarding the pending release of a new round of CSALs is here:

"The NILG Chair confirmed with Director Shiu's office that the OFCCP will continue sending CSALs as advance notice for establishments that have been identified for potential compliance reviews. The OFCCP has stated that the next round of CSALs will be mailed out in the next two months. Please share this information with your members."