Corporate Scheduling Audit Letter Suspended for 2009 Audit Cycle

Berkshire Associates Inc.

 

Berkshire Associates has confirmed the Corporate Scheduling Audit Letter (CSAL) implemented under the Bush administration, has been suspended for the 2009 audit cycle. Patricia Shiu assumed the director position of the OFCCP in late September, and this is the contractor community's first insight into her vision of a new agency direction. 

 

The CSAL was designed to assist large federal contractors by providing a "heads up" to those with multiple sites scheduled for audit during the OFCCP's fiscal year. The agency has not issued a formal announcement regarding the cancellation, but Berkshire's experts anticipate the letter will not be a part of the agency's compliance efforts under the Obama administration.

 

There are other possible changes on the horizon that may impact HR professionals:

·       Increased focus on compensation, including a possible revision to the initial "tipping point test" in audits 

·       Revival of the Equal Opportunity Survey, which was suspended in 2003 and formally eliminated in 2006

Additionally, our experts are monitoring trends of conducting adverse impact calculations by favored group rather than traditional protected group status.

 Berkshire recommends annual and updated affirmative action plans are put in place to ensure your organization is ready to respond to random audits. With only 30 days notice to compile an audit submission, contractors should be on the alert to proactively review their plans for OFCCP activity.

 

For more information on any of these changes, or to strengthen your compliance efforts through effective affirmative action planning, please contact Berkshire Associates at 800.882.8904 or email bai@berkshireassociates.com.