OFCCP “Courtesy” Audit Letters to Replace CSAL?
Last week, the OFCCP sent out letters to federal contractors and subcontractors as “courtesy” notification of a supply and service compliance evaluation. Historically, the OFCCP sends a Corporate Scheduling Announcement Letter (CSAL) to the corporate contact when multiple establishments are selected for a compliance evaluation during the scheduling cycle. However, these letters are being sent to individual establishments, and NOT the headquarters location. Further, the addressee on the letter is not the corporate compliance contact, but rather the letter is generically addressed to the “Human Resources Director”.
It is important to note that this is not a scheduling letter; it is a courtesy letter to provide prior notification of a scheduled future audit. It is also important to note that this letter is not necessarily all-inclusive; meaning some establishments may not receive the notification letter, but still may be scheduled for an audit. It is unclear why the letter is being sent to individual establishments rather than the corporate contact. However, some may remember that there were issues with some of the CSAL letters sent to contractors earlier this year. It is possible that individual notification letters are being utilized to help avoid previous issues or to update the CSAL process. If you receive one of these “courtesy” letters, it is important that that both corporate and establishment contacts are aware of the possible audit.
By Joanna Colosimo and Amanda Shapiro, DCI Consulting Group