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Year after year, the Office of Federal Contract Compliance Programs (OFCCP) demands more and more of the federal contractors it audits. (See, for example, Circa’s blog on updates to the Supply and Service program Scheduling Letter and Itemized listing.) At the same time, many OFCCP Compliance Officers have become less forthcoming about how they review contractors’ audit submissions. (See Circa’s blog on the rescission of the “PDN rule” transparency provisions.)
Given this state of affairs, it is no wonder that Affirmative Action practitioners may groan on receiving a Corporate Scheduling Announcement List (CSAL) advance notice of audit. For these reasons,
