Thanks for tuning in to HudsonMann’s OFCCP compliance updates for Q1 2019. In this video we’ll cover OFCCP’s recent CSAL list, changes to the veterans hiring benchmark and other important updates. As always, we’ll start with audits. If you followed our updates last year, you’ll know that we’ve been expecting an increase in OFCCP audit activity, and it’s here.
For the first time in the history of CSALs, OFCCP published the list of establishments that can anticipate an audit instead of sending the notification through the mail. Under OFCCP’s latest directives, this courtesy announcement provides contractors with at least 45 days advance notice before the actual scheduling of an audit. This year’s first CSAL list includes 3,500 records. 2,345 are traditional Establishment Reviews, 500 are the new Section 503 Focused Reviews, 500 are Compliance Checks, 83 are Corporate Management Compliance Evaluations, and 72 are Functional AAP Reviews.
Additionally, OFCCP has focused one third of the compliance reviews on three industries in particular: Agriculture, Manufacturing and Wholesale Trade.
Next up is the Veterans Hiring Benchmark.
As of 3/31/2019 this figure has been revised to 5.9%. This represents the annual national percentage of veterans in the civilian labor force as calculated by the bureau of labor statistics.
In February, OFCCP announced a new policy directive aimed at high-performing federal contractors. The Voluntary Enterprise-wide Review Program, or VERP, provides contractors with an alternative to OFCCP’s establishment-based compliance evaluations.
Under the program, top-performing contractors with model corporate-wide compliance, diversity, and inclusion programs could be exempt from the standard audit scheduling process for up to five years. The OFCCP expects to begin accepting VERP applications in the fall.
Next up is the EEO-1 filing cycle.
The EEOC opened the EEO-1 filing portal on March 18th. The deadline for filing is May 31st. Right now the portal will only accept reports on Component 1 of the EEO-1. Due to a recent ruling by a federal judge, there remains some uncertainty on whether Component 2, which collects compensation data, will be required during this filing cycle.
Be sure to subscribe to our OFCCP compliance updates email newsletter for the latest information and compliance tips.