by 1. The Office of Federal Contract Compliance Programs (OFCCP) has just published its ‘courtesy’ notice listing the federal contractor locations that will be reviewed in the next few months. More than 40 establishments in the upper Midwest are included in the recent listing. A few years ago, the OFCCP replaced individual courtesy letters with the publication of a list of upcoming reviews. It is found in the Department of Labor’s Freedom of Information Act Library on the DOL’s website. The list, known as the Corporate Scheduling Announcement List or CSAL, is a courtesy notification to an establishment selected to undergo a Compliance Review, Corporate Management Compliance Evaluation, Functional Affirmative Action Program Review, VEVRAA Focused Review, Accommodations Focused Review, Promotions Focused Review, or Compliance Check. It gives the establishment’s management and human resources department at least 45 days advance notice before the Scheduling Letter (also known as the 30-day Letter) is sent to start the review.
2. The System for Acquisition Management (SAM) website has been updated, integrating several other federal websites. SAM.gov has long been the website where federal contractors must register and provide information about revenue, employee data, policies, cybersecurity, and other compliance issues. In late May, the federal government completed a multi-year project to bring several other federal websites with federal contractor information and opportunities under the SAM.gov site. It is now the site to find contract opportunities (formerly found at fbo.gov); assistance listings (formerly found at cfda.gov); contract data reports (formerly found at fpds.gov); wage determinations (formerly found at wdol.gov); and other entity information. Navigating the site has changed and users are advised to spend some time learning the new features. Additional changes will be coming, including new identification requirements for the company’s SAM administrator and new identification numbers.
3. The online Affirmative Action Verification Interface (AAVI) may be coming soon. In September 2020, the OFCCP made a formal request for approval of a new information collection process to monitor affirmative action plans from federal contractors and subcontractors. The online interface between the OFCCP and contractors would require contractors to certify annual updates to their AAPs and provide a way for easy uploading of AAPs in a scheduled review or investigation. The proposal was in response to a GAO study that a high percentage of federal contractors and subcontractors did not, in fact, have affirmative action plans as required. There was some discussion among commentators that this proposal would be dropped under the new administration. This now appears unlikely since a few months ago the OFCCP website was updated with a new landing page for the Affirmative Action Plan Verification Interface. Announcing the AAVI was ‘coming soon,’ the page states:
Affirmative Action Plan Verification Interface (AAVI) is a secure web-based interface created to improve communication and the transfer of Affirmative Action Plan data, between Federal Contractors and the Office of Federal Contract Compliance Programs.
