On September 11, 2020, the Office of Federal Contractor Compliance Programs (OFCCP) came out with its latest Corporate Scheduling Announcement List (CSAL) for federal contractors and subcontractors. The list includes 2,250 supply and service establishments, as well as 200 construction contractors.
All contractors and subcontractors on the CSAL have a 45-day window before OFCCP starts sending out audit scheduling letters. Once they receive this letter, these establishments have just 30 days to respond to OFCCP with their Affirmative Action Programs (AAPs) and supporting data.
This list is informing these contractors that their establishment will be audited in the near future. There will be seven different types of reviews for the Supply and Service Contractors, including two new types of audits:
OFCCP will take a deeper look at the reasonable accommodation practices and policies for individuals with disabilities. Additionally, they may also review the religious accommodations provided. Contractors should ensure all requests and actions related to these types of accommodations are documented. At this time, no further details have been released.
Up until now, OFCCP has focused on outreach and hiring practices when searching for discrimination. As expected, OFCCP is taking the next step in recognizing and correcting disparities in promotional practices within organizations. As with the accommodation reviews, a scheduling letter has not been created for the promotional reviews yet, so more information will be coming in the future.
The 200 construction contractors and subcontractors on the CSAL will be subject to a compliance check. These reviews are a scaled-down version of the full compliance audits, with the hope more will be finished. OFCCP has completed fewer than 700 compliance reviews of construction contractors in the past five years.
There will certainly be more information coming out of OFCCP in the coming weeks. In the meantime, you can be prepared by checking out the OFCCP Compliance Audit Checklist and the guide to responding to your scheduling letter.