HR Policy Association strongly opposes a proposal by the Department of Labor to establish new reporting burdens for employers regarding communications with their employees. Under long-standing interpretations of the Labor-Management Reporting and Disclosure Act, employers only have to report on the use of outside consultants to the U.S. Department of Labor if those consultants make direct contact with their employees in order to ensure transparency that what is being presented is being directed the employer. The Association believes that employees recognize that companies are not completely self-sufficient and that their employers use outside consultants and independent contractors to assist them in many if not most aspects of their operations. Employees are fully capable of assessing their employer's communications on their own terms without needing to know who is on the employer's communications team. The Department of Labor's rules will result in ambiguity and uncertainty with regard to whether many lawful and appropriate activities must be reported, with a potential for criminal liability, adding an unnecessary layer of paperwork for employers while doing nothing to enhance the protection of employees' rights or interests.