OFCCP Publishes FY 2021 CSAL Audit Schedule

The Office of Federal Contract Compliance Programs (OFCCP) recently released its Fiscal Year (FY) 2021 CSAL audit schedule. Chiefly known as the Corporate Scheduling Announcement List (CSAL), the list identifies 750 specific contractors receiving future audit scheduling letters. Previously, the CSAL included 200 construction contractors and 2,200 supply and service contractors. Markedly, entities on the CSAL must provide documentation to show compliance with the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA). Additionally, federal contractors also need to comply with Section 503 of the Rehabilitation Act of 1973 (Section 503). Comparatively, both Acts prohibit federal contractors from discriminating in various employment situations. Also, contractors need to show compliance with the full range of their personnel activity and practices. Earlier this year, the OFCCP addressed race and sex stereotyping by rescinding former Executive Order 13950.

Overview of FY 2021 CSAL Audit Schedule

In March 2021, the OFCCP removed some contractor establishments previously included on the audit scheduling list for FY 2020. As a result, the majority of the affected contractors are on the FY 2021 CSAL Audit Schedule. Following the OFCCP's review, the size of the new list is now 750 establishments and includes only total compliance reviews. As it has done previously, the OFCCP published the methodology for developing the list and frequently asked questions.

Background on CSAL Investigations

Presently, contractors on the 2021 CSAL Audit Schedule will receive a scheduling letter initiating the audit after 45 days. In particular, the advance notice provided by the OFCCP can be a valuable opportunity for contractors. For example, the release of the CSAL before receiving a letter allows businesses to prepare for the upcoming audit. Subsequently to seeing the CSAL, contractors can collect data and documents required to submit to the OFCCP. Additionally, contractors can identify any potential compliance vulnerabilities that may exist and rectify them during the audit process. Finally, the OFCCP encourages contractors to initiate contact if they believe their scheduled audit is an error.