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OFCCP Publishes List of Contractors That Received CSALs

In an unprecedented move, the Office of Federal Contract Compliance Programs (OFCCP) earlier this week published a list of contractors that received corporate scheduling announcement letters (CSALs) in 2017 and 2018 to its Freedom of Information Act (FOIA) Library. CSALs are sent to service and supply contractors to provide them with advance notice that they may be selected for an OFCCP compliance review.

OFCCP justifies the publication of contractors on its scheduling list by citing the FOIA  Improvement Act of 2016, which states that federal agencies have an obligation to “make available for public inspection in an electronic format” records “that have been requested 3 or more times” and are “likely to become the subject of subsequent requests.” OFCCP also notes its CSAL list is not covered by relevant FOIA exemptions or exclusions.

The published lists cover three rounds of CSALs: one in 2017, one in February 2018, and the most recent earlier this month.   

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About this Author

T. Scott Kelly, Defense Contracting Attorney, Shareholder, Ogletree Deakins Law firm

Scott Kelly provides practical solutions for federal contractors and subcontractors across the United States to comply with the ever-changing affirmative action obligations imposed by doing business with the federal government.  He advocates on behalf of his clients in compliance evaluations and administrative enforcement actions triggered by the United States Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP).  Mr. Kelly assists manufacturing, transportation, construction, food processing, hospitality, healthcare, and financial institutions...