OFCCP today released its much-anticipated Fiscal Year 2019 audit scheduling list for supply and service contractors. The list identifies 3,500 federal contractor establishments (or functions) selected not only for routine compliance reviews, but also for corporate management compliance evaluations (CMCE), compliance checks, and importantly, OFCCP’s recently announced focused reviews of compliance with Section 503 of the Rehabilitation Act.
The scheduling list, which is available on OFCCP’s website, indicates the specific type of compliance evaluation that each of these 3,500 establishments or functions will undergo. OFCCP has confirmed that no more than 15 establishments (or functions) per parent company will be scheduled for a review as part of this scheduling list, and that consistent with past practice, there will be a 45-day period between publication of the scheduling list (today) and the day OFCCP will begin sending scheduling letters.
In addition to publishing the scheduling list itself, OFCCP also posted a document laying out the methodology it used to generate that list. This document reveals that OFCCP has begun implementing another recommendation contained in a 2016 report by the Government Accountability Office. This recommendation urged OFCCP to target industries that, based on the agency’s audit experience, have had higher overall rates of discrimination findings. The methodology document states that OFCCP reviewed past conciliation agreements and determined that federal contractors in three industries – Agriculture, Manufacturing, and Wholesale Trade – had the highest rates of discrimination findings over the past five years. As a result, approximately one-third of the establishments and functions on OFCCP’s FY19 scheduling list come from these three industries.
CWC will issue a memo later this week providing more details about OFCCP’s new scheduling list, scheduling methodology, answers to new frequently asked questions, and the practical implications to our members. We will also be hosting a members-only web workshop on Thursday, April 4, 2019, from 1:00 to 3:00 p.m. EDT to address the new scheduling list. This web workshop also will provide our members with step-by-step guidance on preparing for OFCCP’s new Section 503 focused reviews. The web workshop is open only to CWC members, and there is no cost to attend.
To register, please visit: https://cwc.org/cwc/Training/Web_Workshops.aspx.
In the meantime, if you have any questions, please feel free to contact one of our compliance policy experts at 202-629-5650 or firstname.lastname@example.org.
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