April 17, 2006

UPTICK IN SCHEDULING LETTERS WITHOUT ADVANCE NOTICE

Thank you for your quick response to last week’s DCI PULSE question regarding scheduling letters that your companies have received for establishments not on the Federal Contractor Selection System (FCSS) list. In other words, for establishments for which there was no advance notice sent to your corporate headquarters.

Here is a summary of the results: Nearly half of the companies that responded have received scheduling letters with no advance notice at a total of 26 establishments.

DCI’s David Cohen contacted David Frank, Deputy Director with OFCCP, for an explanation, and here’s the response. In the letter that OFCCP sent to contractors’ parent organizations on January 6, 2006, the agency noted that the Corporate Scheduling Announcement Letter (CSAL) includes the use of federal contract data for specific establishments. Because the contract data did not include the EEO-1 number, OFCCP could not match each establishment with its parent organization.

OFCCP also noted in the letter that there may be additional establishments that are scheduled for compliance evaluations that are not included in the list enclosed with the CSAL.

So what is a Company’s EEO Identification Number? According to the EEOC’s Web site, the company’s EEO identification number is:

The number printed on ‘Company Name and Address’ sheet or the EEO-1 form as CO=XXXXXXX is the unique identification number assigned to your company. The number indicated in a company’s database located in the EEO-1 Online Filing System or printed on an EEO-1 form as U=XXXXXXX is the unique identification number for a company establishment. The Unit Number never changes for an establishment. [The] Company Number and Unit Number are used together to identify an establishment within a company.

IMPLICATIONS FOR DCI CLIENTS:
• Inform your management that it is very possible that some of your company’s establishments may receive scheduling letters with no advance notice.

• Be prepared for compliance evaluations where you don’t expect them.

We hope you find this information helpful. Please contact us if you have any questions or require additional information.

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