Federal contractors should immediately review the new 2019 Corporate Scheduling Announcement List (CSAL), released March 25, 2019 by the Office of Federal Contract Compliance Programs (OFCCP), to see if they have been selected for an upcoming compliance evaluation (audit). As previously reported, this is the first time the OFCCP released the CSAL in an electronic format only instead of also mailing the notice to selected federal contractors.
This CSAL notifies over 3,500 establishments that they will undergo a future audit. The CSAL includes not only the traditional establishment review, Corporate Management Compliance Evaluation (CMCE) review and Functional Affirmative Action Program (FAAP) review, but introduces the new Section 503 focused review and compliance checks. Among other things, the OFCCP also published its 2019 scheduling methodology and FAQs regarding CSALs and CMCEs.
The OFCCP publishes the CSAL 45 days before it starts issuing the OMB-approved scheduling letter, which begins the audit. After receiving the scheduling letter, applicable contractors will have only 30 days to submit their Affirmative Action Plans (AAPs) and other supporting information to the OFCCP. As a result, this is an important opportunity for contractors to use the notice to ensure their AAPs are legally compliant and begin gathering and evaluating the additional required information.
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