Contractors need to keep an eye out for audit scheduling letters that are sent at irregular intervals.
OutSolve was interviewed by Business and Legal Resources (BLR) for the July issue of their popular newsletter Affirmative Action Solutions. The topic was about changes in the Corporate Scheduling Announcement Letter (CSAL) and what Federal contractors need to know.
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August 01, 2012
More contractors receiving advance notice of OFCCP audits
The Office of Federal Contract Compliance Programs (OFCCP) has started sending corporate scheduling announcement letters (CSALs) to contractors with single establishments selected for potential audit. That, in and of itself, is good news for contractors, because they are getting advance notice that an audit of that location will likely take place, says consultant Chris Lindholm. The bad news is, since these letters are not going to the corporate office, they might be overlooked by field office staff.
Two new versions of CSALs
In the past, OFCCP has sent CSALs only to contractors with two or more locations slated for possible audit, and the CSALs went directly to the CEO or other executive, says Lindholm, vice president of compliance for OutSolve! (www.outsolve-hr.com). "Single establishments have always been getting audited, but they didn't necessarily receive advance notice."
Lindholm says OFCCP also sent out two new versions of CSALs this spring. The first new version, which indicates that only one location (a field location) is likely to be audited, was sent to contractors' field office rather than their corporate office.
However, OFCCP seems to have an "ulterior motive" in providing advance notice to more contractors, Lindholm says, noting that OFCCP has "a very strong intolerance" for granting extensions to contractors who request an extension to prepare for an audit. "By providing advance notice [via a CSAL], OFCCP is saying, 'You better be prepared when the [scheduling] letter does show up.'"
The other new version of the CSAL is similar to the standard version except that, in addition to identifying location(s) for a "regular" audit, it states that the corporate office is being selected for a Corporate Management Compliance Evaluation (CMCE), a so-called "glass ceiling audit," Lindholm says.
Given that OFCCP is doing more in-depth desk audits than in the past and is considering changes to the scheduling letter that would require more detailed information upfront, receiving a CSAL is "far more daunting than in the past," Lindholm says. "In today's audit environment, it's a big deal."
Although receipt of a CSAL does not initiate an audit, it all but guarantees that the contractor will be audited at some point within the next 12 months, he says. "When a contractor receives a CSAL, it is extremely likely they will be audited."
This article originally appeared in Affirmative Action Solutions, a publication of Business & Legal Resources (BLR). BLR has been helping HR professionals with legal compliance and professional support resources for over 35 years. For more information visit http://hr.blr.com or www.blr.com.