The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) recently released a wave of “heads up” letters that are designed to place government contractors on notice that certain facilities will be selected for an actual OFCCP compliance review during the next several months.

Unlike the old “CSAL” or Corporate Scheduling Announcement Letter mailings, which traditionally were sent to the company’s CEO with a listing of all facilities that could be audited – thereby providing government contractors with an efficient way of tallying the number of anticipated audits and marshaling internal resources accordingly – some of these new letters (pdf) have gone only to individual facilities, and they contain no attached listing of other company sites to be audited.

It is unclear whether “traditional” CSAL letters have gone out, too. If those have not gone out, and corporate CEOs will not be receiving the traditional listing of all sites to be audited, it will place an increased burden on consolidated compliance functions to track down internally the total tally of anticipated audits and allocate resources.

Facilities that received these “heads up” letters do not have to do anything in response to them, yet. The OFCCP’s district and regional offices will send an actual 30-day scheduling letter at some point in the near future, which will trigger the obligation to submit the requested affirmative action plans and support data within 30 days of the company’s receipt of the letter by certified mail. Those facilities that received “heads up” letters should alert their mail rooms to look for the DOL’s official certified letter any time in the next few months.

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