Quick Hit: According to published reports, OFCCP will not mail out Corporate Scheduling Announcement Letters ("CSAL") this year, but rather will post the lists on its website.
Key Takeaway: CSALs provide contractors with advance notice of an upcoming compliance evaluation. Because, unlike in years past, OFCCP will not mail CSAL letters to contractors in 2019 and will, instead, publish the CSAL lists on its website, contractors need to check OFCCP's website to find out if they have been selected for a compliance evaluation. Failure to do so will deprive contractors of additional time to prepare for OFCCP's scheduling letter which initiates the compliance evaluation.
More Detail: CSALs notify contractors that they have been be selected for a compliance evaluation. CSALs were provided as a courtesy, giving contractors advanced notice to prepare for the impending compliance evaluation. Previously, CSALs were mailed to contractors, with the first batch issued in February of each year.
In a change to this practice, according to an article in Bloomberg Law News, OFCCP will not mail out CSALs to contractors when they are issued in 2019. Instead, contractors will have to check OFCCP's website to determine if they have been selected for a compliance evaluation. This new approach is consistent with OFCCP's efforts at increasing efficiency – an initiative discussed during Proskauer's recent webinar on OFCCP developments (which is available here). OFCCP had already taken the step of publishing the list of contractors selected for compliance evaluations on its website. By directing contractors to check its website, OFCCP saves the time and cost of sending out CSALs directly to impacted contractors.
As a result, contractors should proactively monitor OFCCP's website to see if they have been selected for an evaluation. This year's CSAL list has not yet been posted. We plan to report to our readers when the OFCCP updates its website to announce the contractors selected for compliance evaluations.
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