The OFCCP uses an administratively neutral process called the Federal Contractor Selection System (FCSS) to select contractor establishments for audit. Contractors selected by the FCSS historically have been sent Corporate Scheduling Announcement Letters (CSALs) as a courtesy, giving them advance notice that the establishment has been selected for a compliance evaluation.
After the most recent round of CSALS were issued in November 2014, no new CSALs were issued in 2015 or 2016. The CSAL is not required by law, and there has been no indication from the OFCCP when, or if, new CSALs will be issued.
As the OFCCP has worked through auditing the 2500 establishments on the 2014 CSAL list, we at DCI have noticed a sharp decrease in the number of audits initiated over the past year.
However, recently, we have seen a slight uptick in new audit activity, without the issuance of new CSALs. Specifically, we have seen several Functional Affirmative Action Plan (FAAP) audits, which are selected by a random number generator rather than by the FCSS. We also have clients who have received scheduling letters for establishments which were not included in the November 2014 CSAL.
By Dave Sharrer, Senior Consultant at DCI Consulting Group