The OFCCP has significantly revised the latest audit scheduling list, officially called the “Corporate Scheduling Announcement List” (CSAL), removing entities selected for focused reviews, along with a few other housekeeping/clean-up items. Rather than re-classify focused reviews as full audits or corporate management compliance evaluations (CMCEs), the agency simply removed the focused reviews from the schedule entirely.

The agency also went through the remaining list with a finer-toothed comb and removed a few that did not meet the methodology criteria used to generate the list originally. For instance, if an establishment had completed an audit within 24 months they might be removed from the list.

So if you had an establishment or function listed on the fiscal 2020 CSAL list and were slated for one of the varieties of focused reviews, you have likely been removed from the audit list altogether (for now). Even if you were not slated for a focused review it is worth looking over the list again because an establishment scheduled for a full audit or CMCE might have been removed as well.

However, if your focused review is already scheduled or underway, do not bank on getting an administrative closure. According to the OFCCP’s FAQs, the agency will proceed with focused review audits for which scheduling letters have already been sent.

Does This Mean the End of Focused Reviews?

Although the OFCCP has not quite said as much, this would appear to indicate that the era of the focused review has ended, at least for now. In announcing the revised CSAL the agency noted that it will “build on the successes and lessons learned from the Section 503 and VEVRAA Focused Review program to strengthen the enforcement of its laws…during comprehensive compliance evaluations” (emphasis added).

We should expect that this means the OFCCP will effectively add disability and focused reviews to their existing full audit protocols, likely leading to a more drawn-out audit process overall. Of course, time will tell.