OFCCP Update – CSAL List, Focused Review FAQs, and Veterans’ Hiring Benchmark
The Office of Federal Contract Compliance Programs has had a busy month, with the issuance of the following items of interest to government contractors and subcontractors:
- CSAL (Corporate Scheduling Announcement List). In the past, the OFCCP has sent letters to contractors on its Corporate Scheduling Announcement List (CSAL), informing them of its intent to conduct a compliance audit; this year, the OFCCP has instead chosen to post the list on its website. In addition to the traditional broad-based compliance review that examines compliance under various Executive Orders and laws, the OFCCP will also be doing more limited Section 503 Focused Reviews and Compliance Checks, among other things. For contractors on the list, the OFCCP will begin sending out individual letters of the actual audits in about 45 days. 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.
- Focused Review FAQs. In light of the upcoming implementation of Section 503 focused reviews, the OFCCP has created a new Section 503 landing page, which includes FAQs to explain what employers can expect during a review, as well as other relevant resources.
- Veterans’ Hiring Benchmark. The Office of Federal Contract Compliance Programs has announced an updated hiring benchmark for veterans of 5.97%, based on recently-released data from the Bureau of Labor Statistics. Under revised Vietnam Era Veterans’ Readjustment Assistance Act regulations effective in March 2014, covered government (sub)contractors must set a veterans hiring benchmark for each of their establishments, either by using the OFCCP’s benchmark as set forth in its VEVRAA Benchmark Database,or by developing their own individualized benchmarks.