Federal Contractor Update – Audit List, Mandatory Reporting for Construction Contractors

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The U.S. Department of Labor and its Office of Federal Contract Compliance Programs announced several matters of significance to federal contractors and subcontractors this month. These include the following:

  • CSAL (Corporate Scheduling Announcement List). The OFCCP has posted its most recent list of upcoming audits of supply and service contractors on its Scheduling List Resources webpage. OFCCP audit Scheduling Letters are already being sent out, and once a contractor receives a letter, it will have 30 days in which to provide the requested information, which will be extensive. We recommend that those on the list take steps now to ensure that they are ready to submit the required information and that they have taken other appropriate actions to demonstrate compliance with the relevant requirements.

Monthly Employment Utilization Report for Construction Contractors. As of March 1, 2025, the OFCCP is reinstating the requirement that construction contractors and sub-contractors file the Monthly Employment Utilization Report (CC-257) that provides information on monthly work hours and employee count by race/ethnicity, gender, and trade. This requirement had been discontinued in 1995 due to the agency’s inability to assess and use the data from the reports, but new technologies may address that issue. This will likely be quite an onerous task for construction (sub)contractors, and it is possible that this decision may be reversed under the Trump administration. In the meantime, the OFCCP intends to provide compliance assistance to covered contractors, including a webinar in early 2025.