Wondering whether your organization has been selected for an upcoming audit as part of OFCCP’s recent Corporate Scheduling Announcement Letter (CSAL) list supplement? Well, wonder no more. OFCCP has made publicly available its most recent CSAL supplement as well as the two previous CSAL lists (2017 and 2018).
As a reminder, CSALs are a “courtesy notification to an establishment selected to undergo a compliance evaluation” and are sent in advance of the actual scheduling letter that initiates the audit.
Under The Freedom of Information Act (FOIA) a person has the right to request access to federal agency records or information. As a federal agency the Department of Labor (DOL) is required to disclose records requested in writing by any person, unless the information is protected by one of the exemptions provided for in the FOIA statute. By making this information available for public consumption, proactively, without the need for a FOIA request, OFCCP seems to be taking the position that the information is (1) of public interest, (2) sought often enough to warrant proactive disclosure, and (3) not protected by any of the available FOIA Exemptions.