The Office of Federal Contract Compliance Programs (OFCCP) just published its latest Corporate Scheduling Announcement List (CSAL) for supply and service contractors. These evaluations may take the form of an Establishment Review, Corporate Management Compliance Evaluation (CMCE), Functional Affirmative Action Program (FAAP) Review, or University Review.
The CSAL encompasses a diverse array of organizations, including:
- — 30 companies selected for Corporate Management Compliance Evaluations
- — 24 organizations chosen for Functional Affirmative Action Program Reviews
- — 6 universities identified for compliance reviews
Additionally, many enterprise-level organizations are featured on the list, indicating a broad scope of compliance assessments across various sectors. OutSolve knows this is a critical time for organizations like yours and we have created a CSAL resources page to answer your questions and provide important information about this process.
New Scheduling Letter and Itemized Listing
On August 25, 2023, OFCCP introduced an updated Combined Scheduling Letter and Itemized Listing [see prior blog]. This new format requires federal contractors to submit a more extensive range of information—expanded from 22 to 26 comprehensive categories—within 30 days of receiving the Scheduling Letter. Extensions are only granted under "extraordinary circumstances."
Key additions and expansions include:
- Item #7: Documentation of action-oriented programs to correct identified problem areas related to women/minorities.
- Item #8: Expanded documentation for outreach and positive recruitment activities for individuals with disabilities.
- Item #12: Expanded documentation for outreach and positive recruitment activities for protected veterans.
- Item #16: Higher education institutions must submit three years of IPEDS Human Resources Survey Component data.
- Item #18e: Data on the total number of employees by race/ethnicity and gender, by job title or job group, working at the start of the prior AAP year.
- Item #19: Compensation data for all employees, including full-time, part-time, contract, per diem or day labor and temporary employees, for two specific points in time: date of prior year and current year organizational display or workforce analysis.
- Item #21: Information on recruitment, screening, and hiring policies, including the use of AI and automated systems.
- Item #22: Detailed compensation analysis as per OFCCP Directive 2022-01.
- Item #23: Documentation of reasonable accommodation policies, requests, and their resolutions.
- Item #24: Copies of equal employment opportunity (EEO) policies and related documents.
If you believe your company has been incorrectly selected for evaluation, email the OFCCP Scheduling Mailbox at ofccp-dpo-scheduling@dol.gov promptly to address the issue. Resources are also available through the OFCCP including the methodology for developing the CSAL list as well as frequently asked questions (FAQs).
The updated Scheduling Letter and Itemized Listing signal a significant shift towards more detailed and proactive compliance evaluations. It is imperative for federal contractors to adapt their compliance strategies to meet these new demands, ensuring they stay ahead of potential risks and remain in good standing with OFCCP requirements. Please review the CSAL FAQs we've prepared. OutSolve stands ready to assist you and can provide invaluable support in navigating these changes and maintaining robust compliance practices. We can help you to develop a strategy to address the new compliance requirements, focusing on reducing vulnerabilities and ensuring thorough documentation of all relevant policies and actions.