The Office of Federal Contract Compliance (OFCCP)—the Department of Labor agency charged with enforcing affirmative action and equal employment opportunity requirements imposed on certain federal contractors and subcontractors—has sent Courtesy Scheduling Announcement Letters (CSAL) that provide contractors with advance notice of future audits. Tom Dowd, Acting Interim Director of the OFCCP, announced recently that the letters will provide warning to the selected establishments that they have been chosen for compliance reviews. The OFCCP has not issued these letters since 2014.

Each year, the OFCCP generates a list of contractors with establishments to be audited based on neutral selection criteria. In the years where CSALs were sent out, the OFCCP would subsequently issue notices to federal contractors that one or more of their facilities had been selected to be audited at some point during the fiscal year (October 1-September 1).

At this point, the scope and focus of the reviews to be conducted remains unclear. Therefore, all federal contractors and subcontractors should consider their compliance with federal affirmative action and equal employment opportunity requirements and remain on the lookout for a CSAL.

Ballard Spahr's Labor and Employment Group routinely helps employers comply with their obligations as federal contractors.

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