On Sept. 8, 2023, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) publicized its most recent Corporate Scheduling Announcement List (CSAL) for supply and service contractors. The announcement marked pivotal changes for larger corporations and law firms as it designated 1,000 contractor and subcontractor locations for potential audit, as reported by McGuireWoods LLP.
The OFCCP’s role is to ensure that employers doing business with the Federal government comply with the laws and regulations requiring nondiscrimination. The CSAL comes as part of a broader push from the U.S. Department of Labor to increase transparency and collaboration with the Office’s stakeholders.
The list, which identifies contractors being selected to undergo OFCCP’s supply and service compliance evaluations, ensures these corporations and law firms remain in tune with the nondiscriminatory laws and regulations. However, the inclusion of a contractor on the CSAL does not automatically imply instances of discrimination or other legal violations.
It is crucial for contractors to comprehend this tool’s nature and purpose and understand that it is a planning tool used by the OFCCP for internal use. The publication of the CSAL provides the contractor a courtesy notice of a potential compliance review and gives them a minimum of a 45-day preparatory period before the OFCCP commences a scheduling letter.
With the sudden influx of new contractor locations susceptible to audits, the OFCCP’s announcement indicates a heightened emphasis on compliance for companies working together with the federal government. These companies must be conscious of the potential audit and take the necessary steps to prepare for this likelihood.
In conclusion, companies that may be affected by the recent OFCCP publication should start developing robust internal audit and compliance programs. Such preemptive measures will ensure they are not caught off-guard during the 45-day preparation period.