OFCCP Targets 2,000 Establishments with FY 2025 CSAL: Key Steps for Contractors

On November 20, 2024, the Office of Federal Contract Compliance Programs (OFCCP) published its FY 2025 Corporate Scheduling Announcement List (CSAL) notifying 2,000 federal contractors and subcontractors about upcoming compliance reviews, giving them an opportunity to prepare before receiving an official scheduling letter.

The CSAL includes a list of federal contractors targeted for the following types of evaluations:

• 1,880 Standard Establishment Reviews
• 60 Corporate Management Compliance Evaluations (CMCE)
• 48 Functional Affirmative Action Program (FAAP) Reviews
• 12 University Reviews

The OFCCP has also confirmed that unscheduled cases from prior CSAL lists remain eligible for review. Since OFCCP transfers cases to balance workloads, contractors may receive notice from any district office in the region. 

Is Your Organization on the CSAL?

If you are targeted for an audit, know that the OFCCP may begin scheduling audits immediately. Your organization will be required to submit your affirmative action plan (AAP) and supporting data for the establishments under review within 30 days.

OutSolve experts advise the following steps:

1. Notify relevant parties that your organization is on the list.
2. Ensure you have a complete and updated AAP. If your AAP is six months or older, begin taking steps to update your plan.
3. Evaluate your AAP for compliance and determine potential areas of risk.
4. Organize your documentation and ensure all records are accurate and accessible.

How Were Contractors Selected?

OFCCP used a detailed methodology to create the FY 2025 CSAL:

1. Contract Eligibility: Only contracts worth $50,000 or more were considered, as identified on USAspending.gov.
2. Exclusions: Contracts with federal, state, and local governments, school districts, and construction-only contractors were excluded, along with healthcare contracts covered under TRICARE and Veterans Affairs moratoriums.
3. Employee Count Thresholds: U.S.-based establishments with at least 400 employees; those in U.S. territories required 50.
4. Prioritization: Establishments with the largest employee counts per district office jurisdiction were prioritized. Employee headcounts were sourced from 2022 EEO-1 filings.
5. Eliminations: OFCCP excluded establishments already under review, in a conciliation agreement monitoring period, within the exemption period after a closed review, pending review from prior lists, or covered by an active facilities waiver.
6. Caps and Limits: The list was capped at 10 establishments per parent company, with restrictions on reviews of hospitals and universities per region, as well as FAAP reviews (no more than four per parent company).

*Despite these guidelines, some anomalies were noted, including establishments within an audit closure exemption period and contractors with more than 10 audits.

Contractors who believe they were selected for an audit in error should email OFCCP Scheduling at ofccp-dpo-scheduling@dol.gov  

Although not guaranteed, OFCCP district offices generally reach out to contractors to obtain contact information in advance of sending out the Scheduling Letter. If you have been contacted by any OFCCP representative, please contact your OutSolve consultant.

The CSAL is a critical and only alert for contractors to prepare for compliance evaluations. Staying ahead of these reviews ensures contractors can meet regulatory requirements and avoid potential penalties.