Without any formal announcement, and despite contractor privacy concerns, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has posted on its public website the lists of federal contractor establishments selected (but not necessarily yet scheduled) for audit that received a Corporate Scheduling Announcement Letter (CSAL) during the agency’s 2017 and 2018 fiscal years.
The act of publishing these advance notice letter lists is consistent with the vow of Acting OFCCP Director Craig Leen to make the agency and its practices more transparent, and perhaps illustrates how greater transparency can cut both ways.
In any event, despite concerns that publishing the lists might provide information that could be useful to competitors, vendors, and even plaintiffs’ attorneys, in light of the fact that OFCCP already publicizes information about closed audits, including the types of violations found and even copies of financial settlements, publication of the CSAL lists should probably come as no surprise.
That said, the name of an establishment on the CSAL list means nothing more than the facility has simply been targeted for an audit, and no conclusion can be drawn beyond that.
Members of the Center for Workplace Compliance (CWC) can read more here.