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The Corporate Scheduling Announcement Letter (CSAL) Update

 

750 CSAL letters were mailed to contractor establishments on September 7, 2018, as a supplement to the FY2018 Scheduling List released on March 19, 2018, (FY18 First Release).

This CSAL provided contractors a 45–day courtesy notice prior to OFCCP beginning to send OMB approved scheduling letters. After receiving the OMB approved scheduling letter, contractors will have the standard 30 days to submit their Affirmative Action Program (AAP). As a result, all contractors on the current list are receiving a minimum of 75 days advance notice to have the AAP ready. OFCCP will also grant a one-time 30-day extension for supporting data where AAPs are provided timely as indicated in OFCCP’s FAQ on requesting 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.

When combining the FY2018 First Release with this supplemental scheduling list, OFCCP limited its scheduling to no more than 10 establishments of any parent company.

No more than four establishments of a single contractor are included in a single district office on this supplement.

The supplement includes 445 companies, 69 CMCEs, and 66 FAAP functional units. Universities were not included in this supplement due to currently available compliance workload. As per OFCCP Directive 2018–04, focused reviews of E.O. 11246, Section 503, and VEVRAA will be included in Fiscal Year 2019 scheduling lists. Accordingly, this supplement does not include such focused reviews.

No establishment that received a CSAL, concluded a review, or concluded progress report monitoring resulting from a conciliation agreement or consent decree, within the last five years, is included on this supplement.

 

Corporate Scheduling Announcement Letter – Questions and Answers

 

 


 

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

The CSAL is notification to an establishment that has been selected to undergo a compliance evaluation once it receives OFCCP’s OMB approved scheduling letter. The list is generated from OFCCP’s Federal Contractor Selection System (FCSS). It is not a letter scheduling a compliance evaluation. The purposes of the CSAL are 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:

  • A notice sent directly to the establishment to be selected to undergo a compliance review; and,
  • An invitation to contractors to utilize the various compliance assistance resources and activities provided by OFCCP through its website, and through the district and regional offices.

The Scheduling Letter is the OMB–approved letter sent to an establishment to start the evaluation process. The letter is used to:

  • Notify a particular contractor establishment that it has been scheduled for a compliance evaluation; and,
  • Request submission of the contractor›s Affirmative Action Program(s) and the supporting data.

 


 

Will the corporate headquarters of establishments on the scheduling list receive a CSAL?

No. CSALs are mailed only to the establishments identified on the scheduling list.

 


 

Is it possible for establishments other than those receiving a CSAL to be scheduled for a compliance evaluation during the scheduling cycle?

Yes. The list of establishments receiving a CSAL is not all–inclusive for a variety of reasons. For example, the CSAL is not sent when an establishment of a contractor is selected for evaluation because of a contract award notice, a focused review, or as a result of conciliation agreement or consent decree progress report monitoring.

 


 

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

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

 


 

Is there an operational limit on the number of establishments that can be scheduled per contractor?

From list to list, OFCCP may set caps or limits on the number of establishments per contractor that can be scheduled for review. The decision to set caps or limits is based on factors including agency resources and local office workload.

 


 

Do contractors with a FAAP agreement receive a CSAL?

OFCCP’s current scheduling supplement for supply and service contractors includes contractors with FAAP agreements. As such, CSALs dated September 7, 2018, were mailed to contractors with FAAP agreements who have functional or business units selected for compliance evaluation on this scheduling list.

 


 

How can a contractor confirm whether it should have received a CSAL?

OFCCP mails a CSAL to the Human Resources Director (or designated point of contact) of each establishment on the scheduling list. Companies may review the CSAL lists from FY 2017 to the present, which are available in the OFCCP FOIA Library.

 


 

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 telephone numbers are available at https://www.dol.gov/ofccp/contacts/regkeyp.htm.

 


 

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

OFCCP is required to post the CSAL list in an accessible electronic format since it is frequently requested and a Federal record not covered under any of the FOIA exemptions. The Freedom of Information Act (FOIA) Improvement Act of 2016, 5 U.S.C. § 552, 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 information in the CSAL list is not covered by the FOIA exemptions and exclusions in 5 U.S.C. § 552; OFCCP is posting the CSAL lists in their entirety.