The Department of Labor, Office of Federal Contract Compliance Programs (OFCCP) sent out notices last week to 1,000 lucky Government contractors that they will be audited for compliance with all kinds of labor related rules and regulations such as EEO, affirmative action, veterans, disabilities, and many others.
These Corporate Scheduling Announcement Letters (CSALs) are notification to contractors that they have been selected to undergo a compliance evaluation during the scheduling cycle. The purpose of the CSALs is to give contractors a head start in ensuring compliance; to provide the contractor's internal EEO staff at least 45-days advance notice to obtain management support for EEO and self-audit efforts, to encourage contractors to take advantage of OFCCP compliance assistance offerings, to encourage contractors to focus on self-audit efforts that, if problems are adequately analyzed and corrected, saves OFCCP time and resources needed for its own audit, and to assist contractors in managing and budgeting the amount of time required for evaluation activities.
Compliance reviews are comprehensive analyses of the hiring and employment practices of Federal contractors, the written affirmative action program and the results of the affirmative action efforts undertaken by the contractor. Compliance reviews are typically performed in one or more of these stages; a desk review, an onsite review and an offsite analysis.
The OFCCP will be looking for statistical and anecdotal evidence of discrimination, indicators of potential discrimination such as patterns of individual discrimination, patters of systemic discrimination patterns of major technical violations such as record-keeping deficiencies or failure to maintain an affirmative action plan (AAP), and noncompliance with other labor and employment laws that may related to violations of the laws enforced by OFCCP.
Two areas of recent focus has been (i) pay equity to eliminate pay differences between women and men and (ii) compliance with VEVRAA (Vietnam Era Veterans' Readjustment Assistance Act). For both areas, there are extensive record-keeping requirements.
Sometimes these CSALs do not get to the right departments within contractors in a timely manner. If you want to find out for sure whether you are one of the 1,000 contractors selected (that is, find out before they show up at your door), you can call the OFCCP at 800-397-6251.