On November 15, 2024, the Office of Federal Contractor Compliance Programs (OFCCP) published its Corporate Scheduling Announcement List (CSAL) online, identifying contractors who will be receiving an audit scheduling letter in the coming year. Contractors were selected based on a variety of considerations, including higher employee count.
This CSAL includes 2,000 establishments of supply and service contractors with federal contracts. The list identifies the specific review types that contractors will be subject to, including 1,880 standard establishment reviews, 60 corporate management compliance evaluations, 48 functional affirmative action program reviews, and 12 university reviews. A full copy of the lists can be found here.
OFCCP does not make any promises regarding how soon each compliance review will be initiated and has stated it depends on the agency’s workload. Contractors on the CSAL can expect to receive a scheduling letter at any point after the CSAL is posted with some receiving notice quickly and others waiting many months. Contractors will have only 30 days to respond to the scheduling letter once received. Accordingly, the advance notice provided by the CSAL can be a valuable opportunity for contractors to prepare for an upcoming audit, collect the data and documents the contractor will be required to submit to OFCCP within a relatively short period after receipt of the scheduling letter, and identify any potential compliance vulnerabilities that may need to be addressed during the audit process.
Contractors named in the CSAL should consider consulting with experienced counsel to assist in preparing for the forthcoming audit scheduling letter and to take advantage of this valuable preparation time. Polsinelli regularly represents federal contractors and subcontractors in OFCCP audits, and is available for consultation with contractors identified in the CSAL.
