When a health plan/HMO ("Plan") provides group health coverage to employers, including the federal government, the hospitals that treat federal employees under a contract with the Plan are government "subcontractors" subject...more
In December, 2011, the Office of Contract Compliance Programs (OFCCP) caused much consternation among the federal contracting community by publishing proposed changes to the affirmative action and nondiscrimination...more
On March 30, 2013, the U.S. District Court for the District of Columbia issued a decision imposing certain socio-economic contract requirements on subcontractors operating hospitals associated with the University of...more
In a significant victory for the U.S. Department of Labor (DOL), the U.S. District Court for the District of Columbia recently found providers of healthcare services are subject to federal equal employment opportunity...more
Hospitals, health care providers, and managers of other businesses across the country may be surprised to learn that under a new federal court ruling, their organizations may now qualify as government contractors or...more
On March 30, the US District Court for the District of Columbia held that three University of Pittsburgh Medical Center-affiliated hospitals were federal subcontractors to an HMO that provided a managed care health plan to...more
Over the years, the Office of Federal Contract Compliance Programs (OFCCP), which enforces affirmative action and equal opportunity regulations for federal contractors and subcontractors, has tried to assert jurisdiction over...more
Three Pittsburgh hospitals have been found to be federal subcontractors subject to the jurisdiction of the Office of Federal Contract Compliance Programs (OFCCP) because of the medical services they provide to a Health...more
Excerpt from Executive summary: The Issue: Having a federal government contract or subcontract can obligate a business to comply with substantial affirmative action obligations. Knowing whether such a contract triggers...more
After a relatively quiet year, the Office of Federal Contract Compliance Programs (OFCCP) has announced ambitious plans for 2013. The agency’s recently released Unified Agenda calls for the final release of sweeping new...more
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