The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has released its Corporate Scheduling Announcement List (CSAL) for the 2021 fiscal year. Included in the list are 750 federal contractor and subcontractor establishments that will be audited by the OFCCP.

Of the 750 total audits, there will be 668 establishment reviews, 19 corporate management compliance evaluations (CMCE), 57 functional affirmative action plans (FAAP), and 6 university reviews.

This is a rather small list, in comparison to previous years where thousands of contractors were named. Part of the reduction can be attributed to the elimination of the focused reviews and compliance checks. In addition, the current CSAL only identifies supply and service contractors. According to the National Law Review, a separate announcement for construction contractors will be issued at a later date.

In selecting the contractors named in the CSAL, the OFCCP leveraged the following methodology:

  1. No parent company with more than nine establishments 
  2. No company with a Functional Affirmative Action Program (FAAP) agreement with OFCCP to have more than three functional units on the list 
  3. Select establishments with large employee counts where all available establishments are ordered by employee count within each district office
  4. No district office to have more than two establishments/functional units of the same parent company 
  5. No district office to have more than one CMCE review
  6. Establishments within a specific region will not have more than one university review

As a reminder, the CSAL is a courtesy notification sent to establishments that the OFCCP will be auditing your business. This is the precursor notice to the official Scheduling Letter, which is the letter approved by the Office of Management and Budget (OMB). The OFCCP sends the official Scheduling Letter to an establishment to start the evaluation process.

The OFCCP issued its CSAL on July 1. Organizations in the CSAL should note that Scheduling Letters are generally issued 45 days after the CSAL is made public. Employers should be receiving the Scheduling Letter any day now.

Employers named in the CSAL list should begin preparing for the audit as soon as possible, as the full establishment reviews are comprehensive and far-reaching. Based on the appointment of the agency’s new Director, Jenny R. Yang, the compliance reviews for the named contractors will likely include evaluations of employee demographic data, including pay data.

The agency has expressed a renewed focus on pay equity and gender pay gaps, which is part of the reason why the number of named contractors in the CSAL has dropped significantly.

Instead of performing more, higher-level reviews, the agency has stated it will instead allocate its finite resources to perform more detailed reviews of organizational practices, including compensation systems. Contractors are encouraged to get ahead of the audit process by acting now. Best practices include reviewing your workforce compensation data prior to the OFCCP audit.

If your organization needs assistance conducting an audit of this nature, contact us to learn how PayParity can help your business achieve pay equity, while also fostering a diverse and inclusive workforce. 

To learn more about achieving pay equity and implementing a plan that will set your organization up well for the OFCCP audit, download our white paper, Designing a Successful Pay Equity Policy for your Organization.

Organizations looking to disclose pay equity, diversity, and inclusion data information should do so within an ESG reporting framework. Download our white paper, DEI in ESG Reporting to learn about the different standards you can leverage for sharing your progress.

Leave a Comment