OFCCP issues new CSAL list twice

On September 14, 2020, the Office of Federal Contract Compliance Programs (OFCCP) posted a new corporate scheduling announcement letter (CSAL) list singling out 2,251 establishments for a variety of different audits.

In addition to the establishment audits, Section 503 focused reviews, and Functional Affirmative Action Program (FAAP) and corporate management reviews, the OFCCP announced promotion and accommodation focused reviews. The agency doesn’t yet have an Office of Management and Budget-approved scheduling letter for either the promotion or the accommodation focused reviews, so it‘s unclear when they might begin. The agency also listed construction compliance checks on the new CSAL list now that their scheduling letter has been approved.

After posting the list, the OFCCP determined some of the establishments were already under audit. As a result, it posted an updated list on September 17 with more than 80 revisions.

In the methodology for selection published with the CSAL list, the OFCCP noted it was continuing to “focus its scheduling efforts on those contractors that may be more likely to violate [its] laws.” Toward that end, it matched the establishments on its list against the publicly available enforcement databases of the U.S. Department of Labor’s (DOL) Occupational Safety and Health Administration (OSHA) and Wage and Hour Division to determine “if any of these establishments had nontechnical violations.”