Today OFCCP published its latest Corporate Scheduling Announcement List (CSAL). The new scheduling list identifies 1,000 Supply & Service compliance reviews, including reviews for 36 functional affirmative action plans, 30 corporate management compliance evaluations, and 12 university reviews. The remaining compliance reviews are establishment-based reviews.
As in previous years, OFCCP accompanied this announcement with a breakdown of the methodology used to identify contractors for audit. For establishment-based reviews (except for financial institutions, universities, and colleges), OFCCP used two primary criteria to identify federal contractors and subcontractors for review: (1) those contractors engaged in low-wage industries and (2) companies receiving the highest frequency of contract awards under the Bipartisan Infrastructure Bill. According to OFCCP’s website, this methodology resulted in the selection of contractors and subcontractors in the following NAICS sectors: Agriculture, Forestry, Fishing and Hunting; Manufacturing; Retail Trade; Professional, Scientific, and Technical Services; Administrative and Support and Waste Management and Remediation Services; Accommodation and Food Services; and Other Services (except Public Administration).
As it did with its last Supply & Service scheduling list, the OFCCP assigned multiple compliance reviews for the same parent company to a single OFCCP region “so that both the agency and the contractor can engage in these reviews in a coordinated manner.” University reviews were placed at the end of the list; all other scheduled reviews were randomly ordered within each OFCCP district office.
If you believe your company should not have been selected for evaluation, you should reach out to OFCCP immediately by emailing: firstname.lastname@example.org.
If you find that your company does appear on this list, visit our audit page to learn how Berkshire can support you through this process.
Audits scheduled from this list will receive OFCCP’s new Scheduling Letter and Itemized Listing, which was finalized just two weeks ago. One of the most important changes is that Scheduling Letters will now be emailed to most contractors, with the date of receipt based on the read receipt of the email. We encourage you to join us for a complimentary webinar next week to learn more about what OFCCP expects you to provide in audits going forward.