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On January 20, 2023, OFCCP announced the release of the first Corporate Scheduling Announcement List (CSAL) of FY23. The list consists of 500 locations selected for a Compliance Review (Establishment Review), Corporate Management Compliance Evaluation, or Functional Affirmative Action Program Review.
Note that the list merely notifies these contractors that they will be audited – audits will not commence until the contractor receives a Scheduling Letter. However, OFCCP changed its policies in March 2022 so that Scheduling Letters may be issued immediately (as opposed to the prior policy of not issuing Scheduling Letters earlier than 45 days from the publishing of the CSAL). So, contractors on the list must understand they are now “on the clock.”
Contractors are advised to review the CSAL (available here) to see if they have been selected for an audit. Those selected should consult with counsel as necessary to ensure they are prepared for their upcoming compliance evaluation (which could come at any time).
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