Is a Corporate Management Compliance Evaluation (CMCE) in Your Future?

Posts to LinkedIn have discussed a third version of the recent Corporate Scheduling Announcement Letters (CSAL) sent by the Office of Federal Contract Compliance Programs (OFCCP); a letter indicating that the establishment should expect a Corporate Management Compliance Evaluation (CMCE).  A CMCE (fka Corporate Management Review) focuses on whether there is discrimination in the selection process for mid-level and senior corporate management positions.

Supply and service contractors with 4,000 or more employees in the organization and more than one reporting subordinate establishment are included on the CMCE List. The headquarters establishments of contractors with fewer than 4,000 employees are included on the Federal Contractor Selection System (FCSS) lists for compliance evaluations.

The CMCE List is developed in two ways:

1. The results of the FCSS model is applied to the list of companies who completed corporate headquarters information in their most current EEO-1 Report and have never undergone a CMCE in the past. These facilities are rank ordered based on the criteria used to rank non-headquarters establishments.
2. Those corporate headquarters that have been reviewed at any time more than 24 months before the list was developed are next on the list, ranked from earliest date of evaluation completion to most recent date of evaluation completion.

The term "Corporate Management Compliance Evaluation" was adopted to reflect the overall compliance assessment process and the combination of investigative procedures authorized in 41 CFR 60-1.20. In that light, the term "Corporate Management Review" was renamed "Corporate Management Compliance Evaluation." In all other respects, the CMCE is the same as the Corporate Management Review.

Read FAQs about the CMCE

This information is intended to be educational and should not be considered legal advice on any specific matter.