OutSolve quoted within article in Bloomberg BNA regarding CSAL.
The following discussion can be found under the articles in the November newsletter within "Bloomberg BNA's Affirmative Action Compliance Manual for Federal Contractors." The newsletter is very useful for Fedreal contractors and readers can subscribe here to the manual and newsletter: http://www.bna.com/affirmative-action-compliance-p6721/.
OFCCP Mails Latest Round of CSALs,
Causes Confusion for Some Contractors
The Department of Labor's Office of Public Affairs
has confirmed that the Office of Federal Contract
Compliance Programs recently issued approximately
1,762 Corporate Scheduling Announcement Letters
(CSALs) dated Nov. 14 and 15.
The CSAL provides advance notice to federal contractors
that one or more of their establishments may
be slated for compliance audits during the OFCCP's
current fiscal year.
In 2011, OFCCP announced that it would send
CSALs to all contractors that appear on the agency's
compliance evaluation scheduling list, as opposed to
just contractors with two or more establishments.
Letters Sent to Single Establishments. A DOL spokesman
Nov. 27 told Bloomberg BNA that the November
letters were sent to the address of the establishment
that may be slated for a compliance audit. The letter is
similar to the May 2012 letter that was sent to contractors
with one location, he explained.
''The formal notice of a compliance review comes in
the form of the OFCCP Scheduling Letter. The CSAL
has always been a courtesy notification,'' the spokesman
said. The release of the CSALs comes a month after
OFCCP started its current fiscal year, which commenced
on Oct. 1.
''The only version of this advanced warning letter we
have seen to date is the individual establishment edition
that is sent to the 'Human Resource Director' at the address
provided in the letter,'' Chris Lindholm, the vice
president of compliance at OutSolve, a Louisiana-based
affirmative action consulting firm, told BNA Bloomberg
''Contractors should take note that there is no guarantee
of receiving advanced warning of an audit and I
expect many sites to receive standard scheduling letters
in the coming months without prior notification,'' he
Follow-Up With OFCCP, If Necessary. The November
CSALs have also created confusion among some contractors.
According to Lindholm, a series of scheduling
letters went out with a Nov. 6, 2012, date only to be followed
by an advanced warning letter issued on Nov. 14
for the same location.
He claimed that in these cases, the original scheduling
letter was then recalled and certain contractors received
a new scheduling letter dated Nov. 16, ''changing
the due date of the audit and eliminating any value
gained by the advanced warning letter.''
Lindholm said, ''If you receive a form letter from the
OFCCP regarding an audit, I highly recommend contacting
your local OFCCP office and getting clarification
in writing regarding the expected operating dates of the
Contacting OFCCP is not going to trigger unexpected
activity and ''the last thing a contractor wants to
do in today's compliance environment is to miss a deadline,''
Contractors may confirm whether OFCCP mailed a
CSAL to them by faxing a written request on company
letterhead to the agency's Division of Program Operations
at (202) 693-1305.
BY LYDELL C. BRIDGEFORD
Samples of the OFCCP's latest corporate scheduling
announcement letters are reproduced in the Manual at