OFCCP Sends Out Large Round of Corporate Scheduling Announcement Letters with a New Twist

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Two different types of advance notification letters sent to 2000 employers slated for audit

eQuest Compliance Update -

The Office of Federal Contract Compliance Programs has sent out a new round of Corporate Scheduling Announcement Letters (“CSALs”) to 2,000 employers identifying establishments slated for compliance review during OFCCP’s current fiscal year, ending September 30, 2012.

The CSALs provide employers advance notice of the locations slated for OFCCP audit. The CSAL does not initiate an audit. It identifies the location or locations that likely will undergo audit. Only after the employer receives a “scheduling letter” initiating an audit must it respond within 30 days by submitting its affirmative action plan to OFCCP.

The latest round of CSALs contains a new and surprising twist. This year, OFCCP has sent two types of advance notification letters: one to employers with two or more locations scheduled for audit and the other to employers with only one location slated for audit.

The first, traditional, version has been sent to companies’ corporate headquarters and contains a list of locations slated for audit (click here to see a sample).

The new version, to companies with only one location slated for audit, has been sent directly to the location to be audited (click here to see a sample). Therefore, employers should notify all locations, whether corporate or not, to be on the look-out for any letters from OFCCP or the U.S. Department of Labor, generally addressed to “Human Resource Director,” so the company can begin immediately to focus its resources on an impending audit.

Over the last two years, OFCCP has become more thorough in its audits while being noticeably less willing to extend the deadlines to submit information. OFCCP likely will point to the latest round of CSALs as grounds to deny requests for extensions to respond, even where requests are due to a CSAL going unnoticed at a non-corporate facility.

In addition, in its last fiscal year, OFCCP dramatically increased the number of violations issued. This resulted in Conciliation Agreements in almost 25 percent of all audits. Therefore, it is imperative employers take advantage of any advance notice and start preparations for each location slated for audit to ensure they are prepared when OFCCP comes knocking.
If you receive a CSAL, have questions about the latest round of CSALs, or any other OFCCP matter, please contact your attorney for any action to be taken.

The foregoing has been prepared for general information by Jackson Lewis LLP. It is not meant to provide legal advice with respect to any specific matter and should not be acted upon without professional counsel. If you would like to contact Jackson Lewis LLP they may be reached at: http://www.jacksonlewis.com/home.php

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May Ton
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