OFCCP Issues CSALs & New Extension Requirements

September 7, 2018

On September 7, 2018, OFCCP announced that it mailed 750 new Corporate Scheduling Announcement Letters (“CSALs”) to federal contractors as a supplement to the Fiscal Year 2018 Scheduling List released on March 19, 2018.  The agency stated that the CSALs are a “45-day” courtesy notice prior to sending the OMB-approved scheduling letters. Once the scheduling letters are received, contractors will have 30 days in which to submit their Affirmative Action Plans (AAPs) and the other items required by the scheduling letter and itemized listing. Therefore, according to OFCCP, “all contractors on the current list are receiving a minimum of 75 days advance notice to have their AAPs ready.”

In a change outlined in an FAQ entitled “ Requesting Extensions to Submit AAP(s) and Supporting Data ,”

OFCCP reinforced that contractors are obligated to submit their EO 11246, VEVRAA and Section 503 AAPs and supporting data within 30 days of the receipt of the Scheduling Letter and Itemized Listing.  In order to facilitate a timely submission, the assigned compliance officer will contact the contractor within 15 days of the contractor’s receipt of the Scheduling Letter to offer technical assistance and explain allowable extensions for the AAPs and supporting data.

With respect to allowable extensions, OFCCP will grant a one-time 30-day extension for supporting data related to the EO 11246, VEVRAA and Section 503 AAPs, provided the contractor:

  1. Requests the extension prior to the initial 30-day due date for the AAPs; and
  2. Timely submits the basic EO 11246, Section 503 and VEVRAA AAPs within the 30-day period after receiving the Scheduling Letter and Itemized Listing.

The FAQ makes clear that OFCCP will generally not allow extensions for the submission of EO 11246, Section 503 and VEVRAA AAPs, or allow extensions for supporting data if requested after the submission date for the AAPs has passed although it reserves discretion to grant such extensions in extraordinary circumstances.  Failure to submit AAPs and/or supporting data timely, with approved extensions, will result in an immediate Show Cause Notice.

In a separate release, the OFCCP provided an updated version of its Methodology for Developing the Supplement to the FY 2018 Supply & Service Scheduling List .

Please contact your FortneyScott attorney or send an email to  info@fortneyscott.com for more information on this new extension policy or for assistance in preparing AAPs and responses to Scheduling Letters.

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Join FortneyScott attorneys for a complimentary webinar on how employers should prepare for 2026 based on the significant changes in 2025. The Trump Administration begins 2026 with a quorum at the EEOC, new leadership at all the DOL agencies, and the likelihood that the NLRB quorum will be restored soon, so employers should expect aggressive action by all the workforce agencies. This session will provide critical insights into: What to expect from EEOC with its new quorum; An activated DOL, including the new Wage & Hour Division priorities, such as revisions to the Biden-era rules on white collar exemptions and joint employment; new Opinion Letters and compliance tools, how AI is being addressed, and expected developments; Whether OFCCP will survive in 2026, and changes affecting Federal contractors and grant recipients; and Practical steps employers should consider before 2026 begins. This is the final presentation in FortneyScott’s four-part Workplace Legal Compliance Webinar Series 2025, designed for in-house counsel, compliance professionals, HR leaders, and business executives.
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Understanding that everyone is going into Q4, which is the kickoff of your merit and compensation cycles, we want to support those compliance efforts. Join FortneyScott attorneys and our guest speaker, Rick Holt from Resolution Economics, on Thursday, October 23, 2025, at noon EDT for a discussion on strategies for reviewing compensation decisions under the governing legal standards and the Trump Administration’s enforcement priorities.  We will focus on discussing: Changes in legal enforcements; Legal considerations for conducting pay analyses; Recommendations on refreshing analysis models; and, Remediation strategies.
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Join FortneyScott attorneys for a complimentary webinar on how employers should prepare for 2026 based on the significant changes in 2025. The Trump Administration begins 2026 with a quorum at the EEOC, new leadership at all the DOL agencies, and the likelihood that the NLRB quorum will be restored soon, so employers should expect aggressive action by all the workforce agencies. This session will provide critical insights into: What to expect from EEOC with its new quorum; An activated DOL, including the new Wage & Hour Division priorities, such as revisions to the Biden-era rules on white collar exemptions and joint employment; new Opinion Letters and compliance tools, how AI is being addressed, and expected developments; Whether OFCCP will survive in 2026, and changes affecting Federal contractors and grant recipients; and Practical steps employers should consider before 2026 begins. This is the final presentation in FortneyScott’s four-part Workplace Legal Compliance Webinar Series 2025, designed for in-house counsel, compliance professionals, HR leaders, and business executives.
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December 18, 2025 at noon EDT CLICK HERE to Register Join FortneyScott attorneys for a complimentary webinar on how employers should prepare for 2026 based on the significant changes in 2025. The Trump Administration begins 2026 with a quorum at the EEOC, new leadership at all the DOL agencies, and the likelihood that the NLRB quorum will be restored soon, so employers should expect aggressive action by all the workforce agencies. This session will provide critical insights into: What to expect from EEOC with its new quorum; An activated DOL, including the new Wage & Hour Division priorities, such as revisions to the Biden-era rules on white collar exemptions and joint employment; new Opinion Letters and compliance tools, how AI is being addressed, and expected developments; Whether OFCCP will survive in 2026, and changes affecting Federal contractors and grant recipients; and Practical steps employers should consider before 2026 begins. This is the final presentation in FortneyScott’s four-part Workplace Legal Compliance Webinar Series 2025, designed for in-house counsel, compliance professionals, HR leaders, and business executives. To register for FortneyScott’s Workplace Legal Compliance training series, please click here .
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