Recent Trend for 2017 OFCCP CSALs
As noted in a recent blog, 800 Corporate Scheduling Announcement Letters (CSAL or courtesy letter) were sent to contractor establishments on February 17, 2017. CSALs serve to give contractors advanced notice that one (or more) of their establishments appear in the list generated by the Federal Contractor Selection System (FCSS). DCI has noted a trend with the recent batch of CSAL letters: some CSALs are addressed to locations with open or recently closed OFCCP audits. In some cases, these locations also received CSALs during the last wave sent in 2014. This may not be representative of all letters, but it is unclear why establishments with open or recently closed audits would receive a CSAL.
As a reminder, if a scheduling letter is received for an establishment with an active audit, or an audit that closed within two years of the date of the new scheduling letter, you should reach out to OFCCP to administratively close the audit. A CSAL does not initiate an audit, thus there is nothing to administratively close or dispute necessarily. One thing to keep in mind is that if enough time passes and the scheduling letter is received two years or more from the close of the previous audit, then the audit can commence regardless of when the CSAL was received. If you have received a 2017 CSAL it is recommended that you reach out to your Consultant and/or Counsel to discuss.
By Amanda Shapiro, Senior Consultant, and Rachel Monroe, HR Analyst at DCI Consulting Group