Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
The Department of Labor’s Office of Federal Contract Compliance Programs’ (OFCCP) newest Corporate Scheduling Announcement Letter (CSAL) (pdf) indicates for the first time that companies could be subject to an unlimited number of compliance audits per year. The CSAL is intended as a courtesy notice to federal contractors that have at least two facilities that the OFCCP has identified for possible compliance evaluations in the coming fiscal year. The new letter states that “there will be no limit on the number of new compliance evaluations of your company’s facilities that the OFCCP will conduct during a fiscal year.” In the past, the OFCCP limited itself to initiating a yearly maximum of 25 establishment audits per employer.
According Alissa Horvitz, Co-Chair of Littler’s OFCCP Practice Group:
OFCCP is signaling that if it discovers compliance lapses or systemic discrimination at one location, it does not want to be limited in its ability to investigate whether those same concerns exist elsewhere in the company, raising the stakes for all government contractors to be proactive in evaluating their policies, practices, and records in advance of receiving the audit scheduling letter.
This entry was written by Ilyse Schuman.
Photo credit: Jostaphot