Today, OFCCP published its FY 2019 Corporate Scheduling Announcement Letter (CSAL) supplemental list containing establishments that will be scheduled for a compliance review. It lists 500 establishments, all of which are slated for VEVRAA Focused Reviews. This list is in addition to the first FY 2019 CSAL list issued last March which had 3,500 establishments.
Companies whose establishments were in the March 2019 scheduling list were excluded from this list. Those who received the 2018 VETS Medallion Award as well as companies with contracts expiring on or before December 31, 2019 were also excluded from the scheduling list. You can learn more about how establishments were selected from the Scheduling Methodology published on OFCCP's website.
This is the first time that OFCCP is conducting Focused Reviews to audit federal contractor compliance specific to their obligations under the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA).
A Focused Review is a type of compliance evaluation that is restricted to "one or more components of the contractor's organization, or one or more aspects of the contractor's employment practices." Focused Reviews will include an onsite review as well as interviews with managers and employees. The VEVRAA Focused Reviews will focus solely on assessing compliance with all elements of the VEVRAA regulation.
If your company is on this list, what can you do to prepare? OFCCP published a VEVRAA Focused Reviews landing page that includes answers to frequently asked questions, best practices, and compliance resources to help companies prepare for the audit.
By publishing this list, OFCCP has essentially given companies a 45-day courtesy notice before it begins sending out the Scheduling Letter, which could be mailed out as early as December 23, 2019.
The VEVRAA Scheduling Letter is still pending with the Office of Management and Budget (OMB) but you might want to review and be familiar with the proposed letter to be proactive.
Once you receive the Scheduling Letter, your company will have 30 days to submit your Affirmative Action Plan (AAP). So make sure your AAP is updated and review compliance with your obligations under VEVRAA. Are you listing your jobs with the state Employment Service Delivery System (ESDS)? Are you conducting outreach to protected veterans? Are you evaluating your outreach efforts on an annual basis? Are you collecting the required applicant and hire data on protected veterans? Are you inviting applicants to self-identify their status as a protected veteran? For a comprehensive list of your compliance obligations, feel free to refer to our Compliance Audit Checklist.