The OFCCP has just published a new “Corporate Scheduling Announcement List” (CSAL) for construction contractors, adding 400 more contractor establishments to the audit bingo ball hopper. The agency is still working off the 2020 construction CSAL, but according to the OFCCP’s published methodology, the various regional offices must exhaust the 2020 construction CSAL before scheduling any audits from the new 2021 list. The 2020 list had half as many contractor establishments, so some OFCCP regions may have already exhausted their 2020 list.
Note that the establishments in the 2020 construction CSAL were all selected for “compliance checks,” a much “lighter” form of audit in which the agency is primarily concerned with verifying the contractor’s ability to comply with the agency’s requirements. All establishments on the new, 2021 construction CSAL will be scheduled for full compliance reviews.
Most contractors on the new CSAL have only one establishment selected for review. A few dozen have two establishments selected, five contractors have three establishments selected, and one contractor will eventually oversee four audits from the new list.
The OFCCP’s announcement directs contractors to the agency’s FAQ page regarding construction contractor obligations. The agency also published a new and fairly robust “Technical Assistance Guide” for construction contractors that is probably the best and most current source of information regarding what the OFCCP will be looking for in a construction audit.
If your organization is on this or any other CSAL, review the information the OFCCP lists for your company and make sure it is correct. Any incorrect information should be brought to the OFCCP’s attention by email at email@example.com.
And if you have questions about this or any other OFCCP initiative, feel free to contact us at BCGi@Biddle.com.