The OFCCP recently sent out the second round, for fiscal year 2009, of Corporate Scheduling Announcement Letters (CSAL) to corporations that had 2 or more establishments selected through the Federal Contractor Selection System (FCSS). This round, which is the second release from the FCSS in fiscal year 2009 to date, contained a list of 5,000 establishments.

On March 9th, the OFCCP regional offices began receiving their portion of the FCSS list, describing which contractors out of the 5,000 establishments fell within their individual region. The CSAL letter does not indicate that all of the establishments listed will go through a compliance review, but it should serve as a warning to the contractors receiving a letter that they could be targeted for an audit in the near future. Each of the establishments selected in the CSAL should be certain to review their AAPs in detail and consider conducting an internal "mock audit" to make certain that everything is in order in the event of an actual OFCCP compliance review.

Currently the FCSS is not designed to randomly select Functional Affirmative Action Plans (FAAPs) or Corporate Management Compliance Evaluations (CMCEs). As a result, CMCEs and FAAPs are selected through a separate process and are not subject to a CSAL notification. What this means for the contractor community is that even if they did not receive a CSAL, they could still have a single establishment selected for audit, they could be targeted for a CMCE, and/or have additional FAAPs selected for audits.

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