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OFCCP Scheduling List Updated March 2021 – Is Your Company Scheduled for Audit?

The Department of Labor's Office of Federal Contractor Compliance Programs (OFCCP) periodically releases "Scheduling Lists" to notify the public which companies are scheduled for audit. The size and frequency of the scheduling lists depends on the agency's workload and resources, but generally consists of 2,000 to 5,000 establishments. The OFCCP most recently updated its Supply & Service Scheduling List in March 2021. The amended list is available here: Corporate Scheduling Announcement List (CSAL). The OFCCP removed previously scheduled focus reviews and compliance checks for the stated purpose of building on the successes and lessons from the review program focused on Section 503 (relating to individuals with disabilities) and Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) (relating to protected veterans) to strengthen enforcement during the comprehensive compliance evaluations.

Although the OFCCP's removal of focus reviews and compliance checks may seem like a win for employers (and likely is, for employers whose scheduled audits are now cancelled), the goal of better utilizing the agency's resources may mean that the remaining audits will be more comprehensive and laborious than ever, with a smaller pool of audits. The change does not impact any ongoing audits.

OFCCP audits generally at least start life as a "desk audit," in which the OFCCP submits written requests for documents to the contractor and reviews responses to those requests (and the existing affirmative action plan) remotely. Depending on the findings of the desk audit, the agency may choose to initiate an in-person audit or even an enforcement proceeding.

If you have any questions on this topic, please contact the authors or any member of Baker Donelson's Labor & Employment Group.

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