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The Corporate Scheduling Announcement List (CSAL)

 

OFCCP has published the new CSAL list of 3,500 establishments for FY2019 on March 25, 2019. It includes compliance reviews (establishment based), Corporate Management Compliance Evaluations (CMCE), FAAP reviews, Section 503 Focused Reviews, and Compliance Checks.

This CSAL provides contractors a 45‐day courtesy notification prior to when OFCCP begins sending its OMB‐approved scheduling letter. After receiving the OMB‐approved scheduling letter, contractors will have the standard 30 days to submit their Affirmative Action Programs (AAPs). As a result, all contractors on the current list are receiving a minimum of 75 days advance notice to have the AAPs ready for submission. OFCCP will also grant a one‐time 30‐day extension for supporting data where AAPs are provided timely as indicated in OFCCP’s FAQ onrequesting an extension for submission of AAPs and supporting data, which should be reviewed for more information on this topic.

This data collection is approved by OMB under the Paperwork Reduction Act. OFCCP limited this scheduling list to no more than 15 establishments of any parent company.

No establishment that received a scheduling letter, concluded a review, or concluded progress report monitoring resulting from a conciliation agreement or consent decree, within the last two years, is included on this scheduling list.

 

Corporate Scheduling Announcement List – Questions and Answers

 

 


 

What is OFCCP’s Corporate Scheduling Announcement List (CSAL)?

The CSAL is a courtesy notification to an establishment that has been selected to undergo a compliance review, CMCE, FAAP review, Section 503 Focused Review, or Compliance Check. The review will start once the establishment receives OFCCP’s OMB approved scheduling letter. The purposes of the CSAL is to: Provide the contractor establishment’s internal EEO staff at least 45‐days advance notice to prepare for the compliance review; and, encourage contractors to take advantage of OFCCP compliance assistance offerings.

 


 

How is the CSAL different from a Scheduling Letter?

The CSAL is not required by law. It is a courtesy notification to a company establishment through which OFCCP provides resources and assistance through the district and regional offices.

The Scheduling Letter is the OMB‐approved letter sent to an establishment to start the compliance evaluation process and request submission of the contractor’s Affirmative Action Program(s) and the supporting data. The list is used to notify a particular contractor establishment that it has been scheduled for a compliance evaluation.

 


 

How does OFCCP determine the size and frequency of its Scheduling List?

The size and frequency of each scheduling release depends on the agency’s workload and resources. Scheduling lists in prior years have ranged from 2,500 to 5,000 establishments.

 


 

Is it possible for establishments not included on the CSAL to be scheduled for a compliance evaluation during the scheduling cycle?

Yes. The list of establishments is not all‐inclusive. For example, an establishment of a contractor not on the CSAL may be selected for evaluation because of a complaint, contract award notice or as a result of conciliation agreement or consent decree progress report monitoring.

 


 

How are Section 503 Focused Reviews different from CMCEs?

CMCEs cover the full scope of a contractor’s compliance with all three of OFCCP’s laws (E.O. 11246, Section 503, and VEVRAA) at the corporate level. Section 503 Focused Reviews cover only those obligations that are specified in Section 503 of the Rehabilitation Act of 1973.

The Section 503 Focused Reviews are scheduled at the headquarters of multi‐establishment companies and will be conducted onsite. More information on Focused Reviews is available at: https://www.dol.gov/ofccp/Section503-FocusedReviews/index.html.

OFCCP will not begin conducting the onsite portion of the Section 503 Focused Reviews until September 1, 2019 to allow contractors sufficient time to seek technical assistance from OFCCP’s regional and district offices.

 


 

What is a Compliance Check?

A Compliance Check determines whether a contractor maintains records consistent with their obligations.

 


 

Why is the exemption period for this scheduling list two years when the last list had a five‐year exemption?

OFCCP has no legal obligation to provide establishments with an exemption for a period of time after the establishment has completed a compliance evaluation.

OFCCP’s policy is and continues to be that once a contractor establishment concludes a scheduled compliance evaluation, it will not be eligible for scheduling for a two‐year period following the date on which the prior evaluation was closed, or monitoring under a conciliation agreement or consent decree was completed. The five‐year exemption applied to the FY2018 scheduling list and its Supplement were the exception to OFCCP’s historical practice. It was a one‐time decision. Starting this scheduling list, OFCCP has returned to its previous policy to exempting establishments for a period of two years only.

 


 

How did OFCCP select the three industries for this list and will they be focused on in every future list?

As stated in the scheduling list methodology, consistent with a recommendation contained in a Government Accountability Office (GAO) Report (GAO‐16‐750), OFCCP focused approximately one‐third of this scheduling list on industries that OFCCP determined as having the highest rates of discrimination findings. OFCCP used financial Conciliation Agreements (CA) that included discrimination findings as the neutral criteria that defines "discrimination finding." Applying this criteria, OFCCP reviewed the past five years of financial CAs and determined that the Agriculture, Manufacturing, and Wholesale Trade industries had the highest rates of discrimination findings. Only one‐third of the list was selected from these industries. The remainder of the scheduling list was compiled without any regard to industry. OFCCP has discretion to focus on particular industries, or no particular industries, in future scheduling lists.

 


 

Is there a regulatory or statutory limit on the number of establishments that can be scheduled per contractor?

No. There is no legal limitation on the number of establishments per contractor that OFCCP may schedule for a compliance review.

OFCCP may set limits on the number of establishments per contractor and on the types of reviews based on factors that include agency resources and local office workload.

 


 

Why does this scheduling list have a limit of 15 establishments per parent company when the last list had a limit of 10 establishments?

Generally speaking, the size of the scheduling list determines the maximum number of establishments of a single parent company that can be included in a scheduling list. Because the size of scheduling lists vary, so does the limit on establishments of a single parent company. Historically, OFCCP has developed scheduling lists that set a 25‐establishment limit per parent company. In this list, OFCCP implemented policy decisions to: (1) place less burden on contractors (i.e., no more than 15 establishments per parent company); and (2) reach more headquarter establishments. The FY 2018 scheduling list had only 1,000 establishments and a cap of 10 establishments per parent company. This scheduling list has 3,500 establishments and a cap of 15 establishments. Only 1.6% of parent companies on this list have 15 establishments.

 


 

How can a contractor obtain more information about the compliance evaluation process?

Questions about the compliance evaluation process should be directed to your district or regional OFCCP office. Addresses and contact information for the OFCCP Help Desk are available at https://www.dol.gov/ofccp/contacts/regkeyp.htm.

 


 

Why does OFCCP make the CSAL list available in its FOIA Library?

Pursuant to Freedom of Information Act (FOIA), 5 U.S.C. § 552, OFCCP is required to post the CSAL in an accessible electronic format. FOIA requires Federal agencies to "make available for public inspection in an electronic format" records "that have been requested 3 or more times" and are "likely to become the subject of subsequent requests." The CSAL is a frequently requested Federal record and is not covered by the FOIA exemptions and exclusions; accordingly, OFCCP is posting it in the FOIA Library.

 


 

What can I do if the establishment address is wrong or the facility is closed?

OFCCP collects contract data from the Federal Procurement Data System‐New Generation (FPDS‐NG) and establishment level data from the Employer Information Report (EEO‐1) filings. Sometimes, this information is old and needs an update. If your establishment address is incorrect or you have a different mailing address, you may send address corrections to the Scheduling Mailbox at: OFCCP-DPO-Scheduling@DOL.gov. If the facility is closed or has a different parent company, you may send this correction as well to the same mailbox with a copy of the most recent EEO‐1 report.