OFCCP Announces New CSAL: Implications for Supply and Service Contractors

In an update that will grab the attention of legal professionals with corporate clients, the Office of Federal Contract Compliance Programs (OFCCP) announced on September 8, 2023, that it has posted a new Corporate Scheduling Announcement List (CSAL) for supply and service contractors. Announced on the industry platform JD Supra, the list consists of 1,000 federal contractors and subcontractors who have been selected for one of four types of compliance reviews.

The reviews in question include Compliance Review (Establishment Review), Corporate Management Compliance Evaluation, Functional Affirmative Action Program Review or a University Review. These audits are instrumental for the OFCCP to ensure that entities are complying with statutory and regulatory requirements, as well as obligations tied to their federal contracts.

For corporate clients, particularly those in the supply and service sectors who hold or are subcontracting federal contracts, this round of audits could have significant implications. Legal teams will need to ensure their clients are prepared for the audit and that they meet all the required obligations.

As of this time, there has been no indication as to the schedule for these audits or specific details about the selection process. This uncertainty may heighten anxiety within organizations and lead to increased demand for legal counsel, particularly from those specializing in federal contract compliance. Legal professionals should therefore familiarize themselves with the CSAL and be prepared to guide their clients through the process.

The announcement made by OFCCP serves as an important reminder for corporations engaged in federal contracts or subcontracts, stressing the importance of maintaining compliance with federal guidelines and statutes. The audits will not only play a crucial role in weeding out non-compliance but will also be instrumental in maintaining the integrity of federal contract processes.