In recent years, the U.S Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) has aggressively argued that healthcare providers that participate in one of three federal healthcare...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
On March 7, 2014, the Office of Federal Contractor Compliance Programs (OFCCP) issued Directive 2014-01, TRICARE Subcontractor Enforcement Activities concerning the affirmative action obligations of subcontractors of...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
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
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
The U.S. Department of Labor’s Administrative Review Board has found that the Office of Federal Contract Compliance Programs (OFCCP) lacks jurisdiction over Florida Hospital of Orlando, a TRICARE health services provider,...more