The Office of Federal Contract Compliance Programs (OFCCP) is tasked with holding federal contractors and subcontractors responsible for complying with non-discrimination regulations, amongst other things. As part of this effort, the OFCCP requires certain federal contractors and subcontractors with 50 or more employees to develop and submit an affirmative action plan (AAP) detailing their compliance with legal non-discrimination requirements. OFCCP audits 500 contractors and subcontractors that failed to complete their annual AAP certification at least annually.

The second 2023 Courtesy Scheduling Announcement List (CSAL) has been released (see FY 2023 CSAL Supply & Service Scheduling List, Release – 2, here), listing the contracting entities that have been selected for an upcoming audit. The courtesy CSAL provided by OFCCP gives contractors notice that a Scheduling Letter is forthcoming, which triggers a 30-day deadline to submit an AAP and other documentation.

For the contractors listed on the CSAL, the time to begin preparations is now – submission extensions will only be permitted for “extraordinary circumstances”. The recent changes to OFCCP’s scheduling letter and itemized listing that went into effect August 24, 2023 (here) have significantly expand the volume of information contractors are required to submit in their AAPs.

Any contractors listed on the CSAL are encouraged to reach out to our attorney for assistance with their OFCCP audits. Michael Best's Government Procurement team is ready to help.