OFCCP Week In Review: September 10, 2018

Friday, September 7, 2018: Unemployment Rate Unchanged at 3.9%

The Bureau of Labor Statistics (BLS) released August’s ‘Employment Situation.’

“The August jobs report shows continued, strong job growth with 201,000 jobs created and an unemployment rate holding at 3.9%.  More than 4 million jobs have been created since November 2016.  Since 1970, the unemployment rate has registered below 4% just nine times; four of those months have been recorded during 2018. It is remarkable to see steady positive news regarding job growth month after month.” stated Secretary Acosta.

We’ve said it before, and we will say it again – target your outreach to individuals with disabilities!

Friday, September 7, 2018: 750 CSALs Mailed

OFCCP mailed 750 Corporate Scheduling Audit Letters (CSALs) to contractor establishments. These are a supplement to the FY2018 Scheduling List released on March 19, 2018, (FY18 First Release). For a refresher on this process, read here.

Included in this supplement:

• 445 companies
• 69 Corporate Management Compliance Evaluations (FAQ’s here)
• 66 Functional Affirmative Action Programs (FAQ’s here)

NOT included in this supplement:

• Universities (due to current workload)
• Focused reviews; However, focused reviews will begin in FY2019.

     Double Check Your Records (Not to be included):

• When combining the FY2018 First Release with this supplemental scheduling list, OFCCP limited its scheduling to no more than ten establishments of any parent company.
• No more than four establishments of a single contractor in a single district office.
• No establishment that received a CSAL, concluded a review, or concluded progress report monitoring resulting from a conciliation agreement or consent decree, within the last five years.

Timeline
Per the tightest timeline, the following could occur:

• 9/7/18 – CSALs mailed
• 10/22/18 (45 days) – Scheduling letters begin to mail out
• 11/21/18 (30 days) – AAPs begin to be due (based on receipt above)

Need an Extension?
OFCCP released a new policy on extensions, read it here. Short version – extensions will not be allowed, except under the following circumstance:

OFCCP will provide a 30-day extension for supporting data related to the EO 11246, VEVRAA and Section 503 AAPs, provided that:

1. the contractor requests the extension before the initial 30-day due date for the AAPs and
2. the contractor timely submits the basic EO 11246, Section 503 and VEVRAA AAPs within the initial 30-day period after receiving the Scheduling Letter and Itemized Listing.

This second requirement comes from Section 7 of Directive 2018–07 on the AAP Verification Program.

Tip: OFCCP mails a CSAL to the Human Resources Director (or designated point of contact) of each establishment on the scheduling list. Corporations may confirm whether an establishment was mailed a CSAL by emailing a written request on company letterhead to the Division of Program Operations at OFCCP-DPO-Scheduling@dol.gov. In the meantime, contact all your HR managers and alert them so they can be on the lookout for a possible CSAL!