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If your company has appeared on the Corporate Scheduling Announcement List (CSAL) – you might be worried. You’re likely wondering what it means and what steps to take next. While now isn’t the time to panic if you’ve prepared, you do need to be ready.

The CSAL is a “courtesy” notification from the Office of Federal Contract Compliance Programs (OFCCP). It is an indication that your company has been selected for an upcoming compliance evaluation. 

While the CSAL is an official heads up, your actual compliance evaluation does not start until your organization receives OFCCP’s approved scheduling letter. There is time to act – but you should get started quickly.

Remember: The purpose of the CSAL is to provide the contractor with notice to prepare for the compliance evaluation. They also use this as a way to encourage contractors to take advantage of OFCCP compliance assistance offerings. 

Once you receive the scheduling letter, you will have 30 days from that point to submit Affirmative Action Program(s) & Itemized Supporting Data.

What Does Being on the CSAL Mean?

The first thing you need to do is understand just what the CSAL is and what it means for your organization. As explained, the CSAL is a notification from the OFCCP that your company was selected to undergo a compliance evaluation. 

Here’s what it means in the short term:

  • Increased scrutiny: Being on the CSAL means your company is on OFCCP’s radar for potential compliance issues. 
  • Opportunity to prepare: The CSAL provides a chance to proactively review your affirmative action plan (AAP) and compliance procedures. This is a sign that the OFCCP doesn’t want you to fail this audit.

Are you set up for audit success? If you aren’t, you need to call in a support system. Mitratech Circa can help you implement your AAP in the right way.

Steps to Take After Scheduling Announcement

You have learned your company is on the CSAL, so what are your next steps?
How can you ensure that your organization passes this audit without a technical or financial violation?  

Every organization will take different steps based on how they’ve prepared, but here’s a general guide:

  1. Don’t Panic: While the CSAL can be alarming, it’s essential to remain calm and organized. This courtesy notification is actually providing you more time to get prepared!
  2. Assess Your AAP: Review your AAP to ensure it’s up-to-date, accurate, and compliant with OFCCP regulations.
  3. Gather Documentation: Compile necessary records, including job descriptions, hiring data, promotion records, and compensation information. 
  4. Seek Expert Advice: Consider consulting with an employment attorney or compliance consultant to assess your company’s readiness for a potential audit. Have your AAP consultant run a pre-audit. (Ideally this is done BEFORE getting a scheduling letter!) It allows you to proactively look for issues and fix BEFORE submitting data.
  5. Develop a Compliance Action Plan: Create a plan to address any identified compliance gaps and improve your overall affirmative action program.

Preparing for an OFCCP Audit

Now that you’re prepared, you need to ensure everyone else is as well. While it is better to have taken these steps before being on the list, it may not be too late if you act quickly.

Here’s what you can do right now:

    • Train Employees: Conduct training sessions on OFCCP regulations and the company’s AAP.
    • Review Hiring and Promotion Practices: Ensure fair and equitable practices are in place.
    • Update Recordkeeping: Maintain accurate and complete employment records.
  • Review Your Data: Work with your vendors and AAP provider to pull all your data early. The three most common OFCCP violations revolve around recordkeeping, job listing and hiring missteps. 
  • Prepare for Document Requests: Be ready to provide requested documents promptly and efficiently.

Leveraging the CSAL as an Opportunity

While being on the CSAL can be stressful, it also presents an opportunity to enhance your company’s compliance posture. By addressing potential issues and strengthening your affirmative action program, you can improve your chances of a successful audit and demonstrate your commitment to equal employment opportunity.

Remember: The CSAL is a notification, not a condemnation. By taking proactive steps, you can turn this potential challenge into an opportunity to strengthen your company’s compliance program.

How Mitratech Circa Can Streamline Mandatory Job Listing Requirement and Good Faith Outreach for Your AAP

Mitratech Circa is a powerful tool designed to simplify the complex world of compliance, particularly when it comes to mandatory job listing requirements and implementing good faith outreach efforts for your Affirmative Action Plan (AAP).

Mandatory Job Listing Requirement 

When a contractor meets the minimum threshold for VEVRAA with a contract of $150K it must list all of its employment openings with the state workforce agency job bank (also known as the employment service delivery system) where the openings occur. This can be a time-consuming and error-prone process. 

Mitratech Circa streamlines this by:

    • Centralized Platform: Providing a single platform and in-house compliance support team to create, manage, and work with all state job bank accounts on your behalf.
    • Automated Posting: Automating the job posting & reposting process, saving time and reducing the risk of errors across all state job banks.
    • Compliance Tracking: Ensuring compliance with state-specific regulations and deadlines. Electronic on-demand reporting with the highest proof of documentation available.
  • Above & Beyond: Increase veteran exposure with veteran priority referrals and targeted local veteran outreach to make sure your jobs get into the hands of veterans! 

By leveraging Circa, organizations can effectively meet their state job bank listing obligations while minimizing administrative burdens and going above and beyond checking the box for compliance.

Good Faith Outreach for AAP

Good faith outreach is a critical component of an effective AAP. A Good Faith Efforts program defines quantitative goals based on the availability of targeted qualified applicants. 

It involves proactively seeking qualified candidates from underrepresented groups which typically fall into one or more of four groups recognized as facing significant barriers to employment including Women, Minorities, Veterans, and Individuals with Disabilities. 

Mitratech Circa supports these efforts by:   

    • Automated Local Outreach: Providing turn-key skill match outreach to a vast network of over 15K diverse talent pools and community-based organizations.  
    • Outreach Platform: Enabling employers to proactively create & manage direct, meaningful outreach to community organizations to track targeted efforts and measure effectiveness.
  • Targeted Messaging: Ability to create message templates and targeted email feeds to omit manual tasks of sending open job listings to community contacts.
  • Documentation: Generating on-demand reports and documentation to demonstrate compliance with AAP requirements.   

Our platform empowers organizations to implement robust good faith outreach strategies, enhance diversity and inclusion initiatives, and mitigate compliance risks.

By combining these features, Mitratech Circa offers a comprehensive solution for managing mandatory job listings and executing effective good-faith outreach efforts, ultimately helping organizations build a more diverse and inclusive workforce. Click here to request a demo.

Author

Noel Diem

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