OFCCP Releases 2023 Pre-Audit Corporate Scheduling Announcement List

On January 20, 2023, the Office of Federal Contract Compliance Programs (OFCCP) released its 2023 Corporate Scheduling Announcement List (CSAL), which notifies 500 supply and service establishments (locations) of upcoming audits. Federal contractors should immediately review the 2023 CSAL because it serves as the only advance notification to contractors of upcoming audits.

The CSAL specifies the type of audit the contractor will undergo: Full Compliance Review (Establishment Review), Corporate Management Compliance Evaluation (CMCE) or Functional Affirmative Action Program (FAAP) Review.

Continue reading “OFCCP Releases 2023 Pre-Audit Corporate Scheduling Announcement List”

OFCCP Sends Notice of Intent to Release EEO-1 Data to Non-objecting Contractors

On August 19, 2022, as discussed in previous alerts, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) notified its federal contractor base that the OFCCP received a request under the Freedom of Information Act (FOIA) from the Center for Investigative Reporting (CIR) for all Type 2 Consolidated Employer Information Reports, Standard Form 100 (EEO-1 Report), filed by federal contractors and first-tier subcontractors (contractors) from 2016 to 2020. Contractors had until October 19, 2022, to file their individualized objections to the production of their EEO-1 reports.

Continue reading “OFCCP Sends Notice of Intent to Release EEO-1 Data to Non-objecting Contractors”

OFCCP Extends Deadline for Individualized Objections From Federal Contractors to Production of Their 2016-2020 EEO-1 Data in Response to FOIA Request

 As covered in a previous alert, on August 19, 2022, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) notified its federal contractor base that it received a request under the Freedom of Information Act (FOIA) from the Center for Investigative Reporting (CIR) for all Type 2 Consolidated Employer Information Reports, Standard Form 100 (EEO-1 Report), filed by federal contractors and first tier subcontractors from 2016-2020.

Contractors initially had until September 19, 2022, to file individualized objections to the production of their EEO-1 reports. Importantly, the OFCCP has extended the deadline to file an objection to October 19, 2022, to allow contractors sufficient time to ascertain whether they are covered by the FOIA request and submit objections.

Continue reading “OFCCP Extends Deadline for Individualized Objections From Federal Contractors to Production of Their 2016-2020 EEO-1 Data in Response to FOIA Request”

OFCCP Provides 30-day Notice Seeking Individualized Objections from Federal Contractors Before Response to FOIA Request

On August 19, 2022, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) alerted its federal contractor base that it received a request under the Freedom of Information Act (FOIA) from the Center for Investigative Reporting (CIR) for all Type 2 Consolidated Employer Information Reports, Standard Form 100 (EEO-1 Report), filed by federal contractors and first tier subcontractors from 2016-2020.  By issuing this alert, the OFCCP has met its obligation to notify contractors that it will be disclosing information unless contractors file an objection within 30-days.

Continue reading “OFCCP Provides 30-day Notice Seeking Individualized Objections from Federal Contractors Before Response to FOIA Request”

OFCCP Revises Recent Directive on Compensation Analysis

On August 18, 2022, the U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) revised Directive 2022-01 (DIR 2022-01) to clarify its earlier guidance addressing federal government contractors’ regulatory requirement to evaluate compensation as part of their affirmative action programming. Originally referred to as the “pay equity audit,” OFCCP Director Jenny Yang noted in her accompanying DOL blog post that the change in terminology from “pay equity audit” to “compensation analysis” was made to avoid any confusion regarding the nature of contractor obligations.

Continue reading “OFCCP Revises Recent Directive on Compensation Analysis”

OFCCP Publishes 2022 Corporate Scheduling Announcement List for Upcoming Audit

On May 20, 2022, the Office of Federal Contract Compliance Programs (OFCCP) released its 2022 Corporate Scheduling Announcement List (CSAL), which notifies 400 supply and service establishments (locations) of upcoming audits. Federal contractors should immediately review the 2022 CSAL because it serves as the only advance notification to contractors of upcoming audits.

The CSAL also specifies the type of audit the contractor will undergo: Full Compliance Review (Establishment Review), Corporate Management Compliance Evaluation (CMCE) or Functional Affirmative Action Program (FAAP) Review.

Continue reading “OFCCP Publishes 2022 Corporate Scheduling Announcement List for Upcoming Audit”