When the Agency mailed the most recent round of CSALs in February 2018, it reported it would wait until March 19, 2018 to start issuing Scheduling Letters.  True to their word, we have learned that Scheduling Letters have started arriving, at least in some areas of the country.

As a reminder, OFCCP sends scheduling letters via certified mail to the HR manager at the location to be audited,  If you received a CSAL you should make sure those that receive mail at the location are on the look out.  Once the letters are received, Contractors have 30 days to submit the requested AAP and itemized data.  With the advance notification provided by the CSAL and waiting until now to send out the Scheduling Letters the Agency believes contractors have had ample time to prepare for the audits and hold the expectation contractors will be able to comply with the submission requirements in the provided response window.  As a result, it has posted on its website that

Given this advance notice, extensions to submit the AAP will not be granted for routine business reasons and [will] generally be limited to 15 days.

Under the leadership of Director Ondray Harris, OFCCP is working hard to restore its relationship with the contractor community.  With that said, they are still an enforcement agency with a job to do.  And initiating audits is the primary way it achieves its goal of evaluating the compliance of federal contractors.  It will be interesting to see what impact Director Harris and his vision for the Agency have on how these audits are conducted once they are initiated. We’ll be sure to bring you any updates or insights as we learn of them.

Tags: Corporate Scheduling Announcement Letters, Courtesy Scheduling Announcement Letters, CSAL, Director Harris, Itemized listing, OFCCP, Office of Federal Contract Compliance Programs, Ondray T. Harris, Scheduling Letters
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Photo of Laura A. Mitchell Laura A. Mitchell

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating…

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating legal risk. Laura is a guiding force in the firm’s most specialized and technical practice areas where she leverages an analytics-focused approach to partner with her clients in building legally compliant programs around which they can anchor their workplaces achieving productivity and stability.

Laura understands that creating a competitive advantage for employers in today’s workplace involves using a data-driven approach to counsel companies on the development of proactive and equitable non-discriminatory practices in hiring, promotions, separations and pay—and where advancements in technology can create both opportunities for efficiencies and risk that can be measured. Committed to putting her clients’ organizational goals first and foremost while balancing legal risk, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication. Staying the course with employers across their organizational journey while balancing legal compliance obligations throughout their employees’ lifecycle ensures Laura’s position as a go-to resource.

Laura works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize the combined vision of legal compliance, increased productivity and economic growth enhanced by a focus on pay equity.  As part of the pay equity journey, she advises employers on the evolving pay transparency landscape, working to align compliant practices with the practical realities of the business world.

Laura partners closely with government contractors to understand, implement and demonstrate compliance with their EEO regulatory and compliance obligations. She also works closely with non-government contractor clients to conduct risk assessments of their programs, policies, and training to align with federal and state anti-discrimination requirements.

Laura is the editor and a principal contributor of the GovCon Employment Exchange blog and presents on pay equity and government contractor obligations. To round out her days, Laura enjoys spending time with her family and friends attending sports events, working out, riding her bike, playing pickleball and taking in Colorado’s incomparable sunsets.

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