September 22, 2020

Volume X, Number 266

September 22, 2020

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September 21, 2020

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BREAKING NEWS: OFCCP Releases First CSAL of 2019

Today, OFCCP issued its first Corporate Scheduling Announcement List (CSAL) of 2019, providing advance notification of compliance reviews, including CMCEs, Section 503 Focused Reviews and compliance checks. True to expectations, the Agency vastly increased the number of locations subject to review to more than 3,500.

OFCCP continued its new policy of transparency by publishing the list of contractors undergoing reviews on its website. Contractors should review the CSAL as OFCCP, for the first time, will no longer send individual CSALs through the mail. Listed contractors should instead receive notice through e-mail. Today’s OFCCP CSAL publication starts a 15-day clock until Agency may begin issuing scheduling letters on April 9. Selected contractors should prepare now for upcoming audits.

Notably, this CSAL includes OFCCP’s first round of five-hundred Section 503 Focused Reviews of contractor’s corporate headquarters. These reviews will include an on-site review of policies, procedures, and documentation of affirmative action obligations for individuals with disabilities. In late 2018, OFCCP released a revised scheduling letter in anticipation of Section 503 Reviews, which requires submitting a subset of the data provided in a traditional review.

Here is a breakdown by the numbers:

  • 1208 unique companies,

  • 2345 Establishment Compliance Reviews,

  • 500 Compliance Checks,

  • 500 Section 503 Focused Reviews,

  • 83 CMCEs, and

  • 72 FAAP functional units

OFCCP also released its updated scheduling methodology as well as CSAL and CMCE FAQs. We will continue to monitor OFCCP developments, particularly those surrounding audits and implementation of the Agency’s numerous 2018 Directives.

Jackson Lewis P.C. © 2020National Law Review, Volume IX, Number 84


About this Author

Laura Mitchell, Jackson Lewis, Management Representation lawyer, Contractual Drafting Attorney

Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and government contractor compliance.

Ms. Mitchell is a Principal in the firm’s Affirmative Action and OFCCP Defense practice group, representing government and non-government contractors in Office of Federal Contract Compliance Programs (OFCCP) matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming...

James Mackey, Jackson Lewis Law Firm, Denver, Labor and Employment Law Attorney

James D. Mackey is an Associate in the Denver, Colorado, office of Jackson Lewis P.C. Mr. Mackey assists government contractors in creating affirmative action plans and defending clients during OFCCP investigations and audits.

During law school, Mr. Mackey interned with the Administrative Conference of the United States (ACUS), Human Rights Campaign, and in the Office of Equal Employment Opportunity Commission (EEOC) Commissioner Chai Feldblum. Mr. Mackey was a member of American University Law Review and participated in the Civil Advocacy Clinic and Mock Trial Honor Society.