On February 22, 2019, the Office of Federal Contract Compliance Programs (OFCCP) announced that it is on schedule to post its next Corporate Scheduling Announcement List (CSAL) in March 2019. The Fiscal Year (FY) 2019 CSAL List is the first that will be posted exclusively online, rather than sending advanced contractor notifications through the United States mail to individual establishments. As a result, OFCCP's announcement encourages contractors to subscribe to its email updates to receive notifications going forward.
The CSAL List names contractors and subcontractors identified for a potential compliance evaluation in the fiscal year (which will end on September 30, 2019). In addition to compliance reviews, the new CSAL List identifies contractors selected for Section 503 focused reviews, as described in Directive 2018-04. Focused reviews will be smaller in scale compared to OFCCP's standard compliance review, which evaluates compliance with Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, and the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA). OFCCP has announced that it will also be posting additional resources for contractors seeking to comply with Section 503 to help contractors prepare for the upcoming reviews.
The new list also identifies contractors selected for compliance checks as delineated in Directive 2018-07—the Affirmative Action Program Verification Initiative directive, which aims at ensuring covered contractors are annually preparing and implementing written affirmative action programs (AAPs).
The list will be published on OFCCP's Freedom of Information Act (FOIA) Library.
Ogletree Deakins' Affirmative Action and OFCCP Compliance Practice Group will monitor these developments and report on the CSAL List on the Affirmative Action/OFCCP blog when it is published in March.
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