The Office of Federal Contract Compliance Programs (OFCCP) announced recently that it mailed a new set of audit scheduling letters and Corporate Scheduling Announcement Letters (CSAL) as a courtesy to federal contractors and subcontractors.
The Scheduling Letter, which is the OMB-approved letter that initiates a review, now requires contractors and subcontractors to submit 22 items for desk audit that is comprised of individualized–opposed to aggregated–employee compensation data, including job title, job group, EEO-1 category, base salary or wage rate, hours worked in a typical week and any other compensation such as bonuses or commissions and other documents of its Affirmative Action Plan(s).
In addition, the Scheduling Letter now includes a warning that failure to preserve records through the final disposition of the compliance review “constitutes non-compliance.”
Unlike normal Scheduling Letters, CSALs are not required by law and do not launch an audit. Instead, CSALs only alert a contractor or subcontractor that it has been selected for review with the purpose to provide the contractor’s or subcontractor’s internal EEO staff notice to obtain management support for EEO and self-audit efforts, encourage contractors and subcontractors to take advantage of OFCCP compliance assistance offerings, encourage contractors and subcontractors to focus on self-audit efforts that, if problems are adequately analyzed and corrected, saves OFCCP time/resources when we do an evaluation and help contractors and subcontractors plan the amount of time required for evaluation activity.
Contractors and subcontractors needing to confirm whether one or more of their establishments received a CSAL may fax a written request on company letterhead to OFCCP’s Division of Program Operations at (202) 693-1305. And, failure to respond can lead to a more extensive audit, a conciliation agreement or a consent decree.
Regardless if you received an OFCCP audit Scheduling Letter or a CSAL, it is best to have a compliant Affirmative Action Program for the current year in place. Lincoln Tyler can provide the professional support to conduct meaningful outreach for protected classes, veterans and disabled, keep applicant tracking systems and logs up to date, keep all job posting print screens and extend voluntary “Self ID Forms” as early as possible in the applicant process.