Articles and Blogs

The Administrative Review Board (“ARB”) ruled on July 22, 2013 that Florida Hospital of Orlando (“Florida Hospital”) is a covered federal subcontractor subject to Office of Federal Contract Compliance Programs’ (“OFCCP”) jurisdiction by virtue of its participation as a network provider under TRICARE.  The ruling comes nine months after the same panel of judges... READ MORE

OFCCP continued its courtesy of providing advance notice to companies it plans to schedule for affirmative action compliance reviews.  OFCCP mailed the notices, known as Corporate Scheduling Announcement Letters (“CSALs”), on March 27, 2013.  Consistent with its recent practice, the notices are addressed to the “Human Resource Director” at local establishments as opposed to... READ MORE

OFCCP Lacks Jurisdiction over TRICARE The health care industry scored a significant litigation victory over OFCCP recently when the Administrative Review Board (ARB) ruled that Florida Hospital of Orlando’s TRICARE network agreement did not cause it to be a covered subcontractor subject to OFCCP’s affirmative action rules.  The ruling overturns an earlier Administrative Law Judge... READ MORE

OFCCP announced today the rescheduling of a webinar concerning how the agency intends to address TRICARE based compliance audits.  The webinar is in follow up to Congress’ recent action to carve out TRICARE network agreements from OFCCP’s jurisdictional reach.  It was previously scheduled and then canceled by OFCCP, and will now be conducted on... READ MORE