The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has published a new audit list for construction contractors. Follow the link, download the new list, and see if you’ve been scheduled for a happy little visit from the federal government.

Officially called the “Corporate Scheduling Announcement List,” or “CSAL” (pronounced “see-sal”) this is the government’s way of being nice and providing organizations with advanced notice that they have been selected, but not yet scheduled, for a compliance review. This is a courtesy, as the OFCCP will happily remind you, as they are not legally required to provide any notice at all before initiating an audit.

The generation of this list was fairly straightforward. First, it was limited to federal construction contracts. OFCCP searched the USAspending database for construction contracts valued at $10,000 or more, which is the contract dollar threshold for the obligation to prepare AAPs. For federally assisted construction projects, the agency was provided a list of contracts from the U.S. Department of Transportation.

Then the OFCCP limited the pool to contracts that are still active and will remain so for the following year. From there, they culled the contractor locations already scheduled for audit, where an audit is already underway, are still in a conciliation period after an audit that went south, or in the 24-month “grace period” the agency traditionally provides after an audit closes.

That still left a lot of contractors, so the OFCCP focused on those with the largest contract dollar valuations. So the more work you do for the feds, the greater your chance of being audited.

You haven’t been audited yet, though. The CSAL merely lists who is in line for an audit. The audit does not officially begin until you receive a Scheduling Letter. From that point, you will have just 30 calendar days to turn over a whole slew of documents, data, and information. So it is generally a good idea to check the list and start getting things in order sooner rather than later if you are on the list.

If you think your organization has been listed by mistake, shoot an email over to the OFCCP at ofccp-dpo-scheduling@dol.gov. They’ll look into it and let you know if they’re removing you from the list or keeping you on.

Note that most expect the OFCCP to generate a second 2023 CSAL for supply and service contractors sometime later this year. This is not that.

If you have questions about this or any other OFCCP-related matter, or you think you’ll need some help with an upcoming audit, feel free to drop us a line at BCGi@Biddle.com.