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Hospitals Office of Federal Contract Compliance Programs

K&L Gates LLP

Health Care Triage: OFCCP Enforcement in the Health Care Space

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Health Care partners Sarah Carlins and Jackie Hoffman interview Labor, Employment, and Workplace Safety partner Craig Leen in this episode of Triage, recorded in collaboration with our Working Wise podcast. As the former...more

Cozen O'Connor

2016/2017 Labor & Employment Observer

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Activist NLRB Created More Problems For All Employers in 2016 - What Happens Under President Trump? During 2016, the National Labor Relations Board (NLRB or the Board) maintained its generally pro-union, anti-employer...more

Fisher Phillips

Hospitals Are Still In The OFCCP's Crosshairs

Fisher Phillips on

On February 12, 2015, U.S. Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) underscored its intent to continue to scrutinize hospitals, including nonprofit hospitals. The OFCCP found that Lahey Clinic...more

Proskauer - Government Contractor Compliance...

DC Circuit Dismisses Appeal By Three Hospitals Challenging Subcontractor Status

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

Williams Mullen

The OFCCP Calls a Moratorium on Enforcement Activities Against TRICARE Providers

Williams Mullen on

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

PilieroMazza PLLC

Victory in House of Representatives for Improvements to WOSB Federal Contract Program

PilieroMazza PLLC on

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

Littler

Does OFCCP Have Jurisdiction Over TRICARE Participants? Stay Tuned. The Answer Lies Years In The Future

Littler on

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

Fisher Phillips

OFCCP Setting Its Sites On TRICARE Providers?

Fisher Phillips on

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

Proskauer - Government Contractor Compliance...

OFCCP Withdraws Claim Regarding TRICARE Jurisdiction

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

FordHarrison

TRICARE Complaint Dismissed Against Florida Hospital

FordHarrison on

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

Sherman & Howard L.L.C.

Affirmative Action Comes to a Hospital Near You

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Hospital Jurisdiction Revisited—ARB Finds Florida Hospital Is Subject to OFCCP Jurisdiction

In another chapter in the long-running saga of Florida Hospital of Orlando and the Office of Federal Contract Compliance Programs (OFCCP), the U.S. Department of Labor’s Administrative Review Board (ARB) recently released an...more

Proskauer - Government Contractor Compliance...

ARB Reconsiders Florida Hospital Ruling

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

Littler

OFCCP Scores Surprising Victory in its Continuing Battle for Jurisdiction Over Healthcare Providers Based on TRICARE Participation

Littler on

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

McAfee & Taft

Court rules employers who provide services to federal government employees subject to federal contracting regulations

McAfee & Taft on

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

Sherman & Howard L.L.C.

Let the Seller Beware: Hospitals Treating HMO Patients Employed by the Federal Government are “Subcontractors” Governed by...

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

Fisher Phillips

Healthcare Update, No. 2, May 2013 - Court Upholds OFCCP's Jurisdiction Over Healthcare Providers

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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

K&L Gates LLP

OFCCP Enforcement Powers Expanded Over Healthcare Industry

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In a case closely monitored by the healthcare industry, a recent decision from the United States District Court for the District of Columbia expanded the jurisdiction of the Office of Federal Contract Compliance Programs...more

BakerHostetler

District Court Sides With DOL in Dispute Over Whether Healthcare Providers Are Government Contractors

BakerHostetler on

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

Davis Wright Tremaine LLP

Court Ruling May Subject Hospitals and Health Care Providers to OFCCP Regulation

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

Foley & Lardner LLP

Health Care Providers Beware — You May Be a Governmental Contractor

Foley & Lardner LLP on

Executive Order 11246 (Order) was first issued in September 1965 by President Johnson. Its purpose was to prohibit race, religion, color, and national origin discrimination by federal contractors and subcontractors and...more

King & Spalding

Hospitals that Provide Services to Government Employees Through an HMO are Government Contractors, Court Rules

King & Spalding on

Healthcare providers who treat government employees through a health maintenance organization are government subcontractors subject to the jurisdiction of the Office of Federal Contract Compliance Programs (OFCCP), according...more

Mintz - Health Care Viewpoints

Health Care Services Providers to Federal Health Plan Members Subject to Federal Affirmative Action Compliance Audit

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

Cozen O'Connor

Hospitals Providing Medical Care to Federal Employees Covered by HMOs May Be Subject to OFCCP’s Affirmative Action and Other...

Cozen O'Connor on

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Health Care Case Makes Clear That Specific Contractual Language Is Not Necessary for OFCCP Jurisdiction

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

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