On November 14, 2014, the United States Court of Appeals for the District of Columbia dismissed as moot an appeal by three hospitals affiliated with the University of Pittsburgh Medical Center. The hospitals had challenged...more
On May 7, 2014, a Directive of the Office of Federal Contract Compliance Programs (“OFCCP”) placed a five-year moratorium on enforcement activities regarding health care providers that are TRICARE subcontractors. TRICARE is...more
On May 7, 2014, the Office of Federal Contract Compliance Programs (OFCCP) issued Directive 2014-01, instituting a five-year moratorium on the OFCCP enforcement over TRICARE subcontractors. The moratorium applies to health...more
Over the past several years, we have written repeatedly about the efforts of the Office of Federal Contract Compliance Programs (the OFCCP) to gain jurisdiction over health care providers based solely on providers'...more
Healthcare providers are waiting anxiously to see the Office of Federal Contract Compliance Programs’ (OFCCP) most recent position on whether it will continue trying to assert jurisdiction over them on the basis of...more
Last week, the Office of Federal Contract Compliance Programs (OFCCP) dismissed OFCCP’s 2008 complaint against Florida Hospital of Orlando. In its Order of Dismissal, the Administrative Law Judge (ALJ) reported that OFCCP...more
On March 28, 2014, the OFCCP withdrew its jurisdictional Complaint against Florida Hospital of Orlando after several years of litigation. OFCCP alleged it had jurisdiction to conduct an audit because the Hospital...more
Does the OFCCP have jurisdiction over hospitals that contract to provide medical services to members of the military? We hoped we were done with this issue when the Congress enacted the National Defense Authorization Act...more
Last week, a divided Department of Labor Administrative Review Board (“ARB”) agreed to reconsider its ruling that the Office of Federal Contract Compliance Programs (“OFCCP”) did not have jurisdiction over a federal...more
On July 22, 2013, the Office of Federal Contract Compliance Programs (OFCCP) won a surprising victory before the Department of Labor’s (DOL) Administrative Review Board (ARB), breathing new life into the agency’s efforts to...more
A federal court recently ruled that hospitals affiliated with the University of Pittsburgh Medical Center became “federal subcontractors” when they entered into contracts with an HMO that provided health services for federal...more
A federal district court has confirmed the position of the Office of Federal Contract Compliance Programs (OFCCP) finding that three hospitals providing medical services to U.S. government employees, and receiving payments...more
On October 19, 2012, the Department of Labor's Administrative Review Board concluded that Florida Hospital of Orlando did not have federal contractor affirmative action obligations arising out of its participation in TRICARE...more