Employment, Labor and Benefits Advisory: Hospitals and Medical Service Providers Take Note: You May be Subject to OFCCP Jurisdiction and Not Even Know It


Federal law imposes significant affirmative action obligations on many employers holding contracts or subcontracts to supply goods or services to the federal government.1 Specifically, federal law requires that all companies with at least $10,000 in federal government contracts or subcontracts engage in affirmative action to employ and advance in employment minorities and women, as well as qualified individuals with a disability. Companies with at least one contract or subcontract with the federal government valued at $100,000 or more2 must also engage in affirmative action to employ and advance qualified special disabled veterans, veterans of the Vietnam era, and any other veterans who served on active duty during a war or in a campaign or expedition for which a campaign badge has been authorized. Written affirmative action plans (AAP) pertaining to women and minorities and to qualified individuals with a disability must be developed and implemented by those companies with at least 50 employees and $50,000 in federal contracts or subcontracts; written AAPs pertaining to veterans must be developed and implemented by those companies with at least 50 employees and $100,000 in federal contracts.3 The laws are enforced by the Department of Labor (DOL), through the Office of Federal Contract Compliance Programs (OFCCP).

Please see full advisory below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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