Proskauer – On September 8, OFCCP posted a new Corporate Scheduling Announcement List (CSAL), consisting of 1,000 federal contractors and subcontractors selected for a Compliance Review, Corporate Management Compliance Evaluation, Functional Affirmative Action Program Review, or a University Review.

Note that the list merely notifies these contractors and subcontractors that they will be audited—audits will not commence until the entity receives a Scheduling Letter. However, Scheduling Letters may be issued immediately (as opposed to the prior policy of not issuing Scheduling Letters earlier than 45 days from the publishing of the CSAL). So, contractors on the list need to understand they are now “on the clock.”

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