With OFCCP releasing the 2023 CSAL notifying 500 service and supply firms about upcoming audits, federal contractors should check it right away to see if any of their establishments are mentioned in it. Generally, the OFCCP sends out scheduling letters following the publication of the CSAL. The OFCCP will give only a window of 30 days after a contractor receives the scheduling letter to submit all the requested documents and details. Also, if any of your establishments are included in the list, you have to be well-prepared in advance to face the audit successfully. The OFCCP has also done away with the contractor’s default 30-day extensions to provide important details like employment, salary, and similar supporting data.
What can contractors do if they are on the 2023 CSAL list?
Federal contractors can become a bit anxious once the name of their establishment gets featured on the CSAL list. But by following a well-thought-out and structured plan, contractors can easily face the audit with all the necessary documents in place.
Understand the procedure
For preparing for the OFCCP audit, it is very important to be aware of the different processes involved in it. The OFCCP has given detailed information about the audit and the compliance requirements on its official website. They have also created a list of FAQs to help the contractors. Review this material carefully and in detail to ensure that you comprehend the procedure and understand the documents needed for the process.
Prepare the documents
The OFCCP stipulates that federal contractors submit different documents showcasing their compliance with the OFCCP directives. Make sure that all the documents are ready for a compliance check, including the ones indicating the company’s affirmative action initiatives and similar regulatory documentation or reports.
Coordinate with departments
Making a company AAP compliant is not the work of just the personnel working in HR, but the entire organization. The higher officials in the firm should also get involved in the audit preparations. Senior officials and EED coordinators should frequently check whether OFCCP has sent the establishment an itemized listing and the scheduling letter. The letters could be delivered by email or by US mail.
Preparing for multiple locations
If your firm has establishments in several locations and you receive the scheduling letter for multiple ones, it is highly likely that the audits can take place concurrently. In fact, there is also a possibility that the same office might be handling all these audits. In this case, it is very necessary to carefully prepare for all audits to avoid discrepancies and inconsistencies.
As per the new rule, the OFCCP will give the contractors only 30 days to prepare any and all documents required for the audit once they get the scheduling letter. This covers both the AAPs and other items that can be sought in the itemized listing, like proof of company outreach initiatives, pay data, and much more. Similarly, contractors also do not have a 45-day window between the release of CSAL and receiving the scheduling letter. The most crucial step is to prepare the audit responses soon after the release of CSAL.