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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) announced on February 22, 2019, that it plans to release its next Corporate Scheduling Announcement List (CSAL) in mid-to-late March 2019. Unlike prior years, the OFCCP will not be sending its traditional advanced notification letters to government contractors (including subcontractors) identified as potential targets for compliance evaluations. Instead, the OFCCP will simply post the CSAL in the agency’s online Freedom of Information Act (FOIA) library for public viewing.

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In addition to traditional compliance evaluations, the pending CSAL will also identify contractors who may be subject to new “focused reviews” under Section 503 of the Rehabilitation Act or limited affirmative action plan “compliance checks” pursuant to the OFCCP’s new verification initiative. Both of these programs were announced by the OFCCP in August 2018 via <a href="https://www.dol.gov/ofccp/regs/compliance/directives/dir2018_04.html?utm_campaign=directive201903&amp;utm_medium=email&amp;utm_source=govdelivery" target="_blank" rel="noopener">Directive 2018-04</a> and <a href="https://www.dol.gov/ofccp/regs/compliance/directives/dir2018_07.html?utm_campaign=directive201903&amp;utm_medium=email&amp;utm_source=govdelivery" target="_blank" rel="noopener">Directive 2018-07</a>.

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The CSAL announcement clearly signals that OFCCP is pushing forward with its revamped efforts to monitor affirmative action compliance under Executive Order 11246, Section 503, and the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA). In light of this announcement, government contractors should take immediate steps to fulfill all aspects of their annual affirmative action obligations, including completion of written affirmative action plans and assessments of veteran and disability hiring from the prior calendar year. By doing so, government contractors will be well-positioned in the event they are selected for OFCCP review.

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Thompson Hine will continue to monitor the situation and provide an update once the CSAL is released in March 2019. For additional information regarding the OFCCP’s compliance initiatives, as well as affirmative action obligations for government contractors, please contact:

Matthew R. Kissling 216.566.5586 <a href="mailto:Matthew.Kissling@ThompsonHine.com">Matthew.Kissling@ThompsonHine.com</a>

or any member of our <a href="http://www.thompsonhine.com/services/labor-amp-employment">Labor &amp; Employment</a> group.

This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel.

This document may be considered attorney advertising in some jurisdictions.

OFCCP to Post CSAL Electronically in March 2019

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