From: Affirmative Action Articles
For many years, health systems reasonably assumed that arrangements
with a non-governmental entity to provide services or benefits to
federal employees would not invoke the jurisdiction of the Office
of Federal Contract Compliance Programs (OFCCP), and thus would not
mandate federal equal employment and affirmative action
obligations.



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Hospitals Providing Medical Services to Federal Employees Through an HMO are Covered Subcontractors Under OFCCP's Jurisdiction.
For many years, health systems reasonably assumed that arrangements
with a non-governmental entity to provide services or benefits to
federal employees would not invoke the jurisdiction of the Office
of Federal Contract Compliance Programs OFCCP, and thus would not
mandate federal equal employment and affirmative action
obligations. pa
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Affirmative Action Regulations May Cover Hospitals Servicing Federal Employees Through HMO's.
The broad reach of the Office of Federal Contract Compliance
Programs may extend even further under a recent federal
administrative board decision. The U.S. Department of Labors
Administrative Review Board ARB has upheld an administrative law
judges ALJs finding that three hospitals receiving payments from a
health plan for providing medical services to U.S. government
employees are federal subcontractors required to comply with OFCCP
requirements. pa
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OFCCP Reevaluates Affirmative Action Regulations Related to Individuals with Disabilities.
The Office of Federal Contract Compliance Programs (OFCCP) has
issued a notice inviting the public to provide input on how the
OFCCP can strengthen the affirmative action requirements of the
regulations implementing Section 503 of the Rehabilitation Act of
1973. The law prohibits discrimination and requires employers with
federal contracts or subcontracts that exceed $10,000 to take
affirmative steps to hire, retain, and promote qualified
individuals with disabilities.



Federal Contractor Compliance with Veterans, Disabled Individuals Affirmative Action Obligations.
The Office of Federal Contract Compliance Programs has begun
scrutinizing federal contractorsÂ’ compliance with the
affirmative action obligations relating to covered veterans and
individuals with disabilities. Federal contractors must employ and
advance in employment covered veterans and individuals with
disabilities pursuant to the Vietnam-Era Veterans Readjustment
Assistance Act (VEVRAA) (for veterans) and Section 503 of the
Rehabilitation Act (for disabled individuals). As part of routine
compliance reviews, OFCCP is focusing on contractorsÂ’
outreach to these two groups and actively reviewing
contractorsÂ’ leave and accommodation policies. While
contractors have always had these obligations, this latest Agency
enforcement initiative represents a distinct departure from
OFCCPÂ’s pr...
Federal Contractor Compliance with Veterans, Disabled Individuals Affirmative Action Obligations.
The Office of Federal Contract Compliance Programs has begun
scrutinizing federal contractorsÂ’ compliance with the
affirmative action obligations relating to covered veterans and
individuals with disabilities. Federal contractors must employ and
advance in employment covered veterans and individuals with
disabilities pursuant to the Vietnam-Era Veterans Readjustment
Assistance Act (VEVRAA) (for veterans) and Section 503 of the
Rehabilitation Act (for disabled individuals). As part of routine
compliance reviews, OFCCP is focusing on contractorsÂ’
outreach to these two groups and actively reviewing
contractorsÂ’ leave and accommodation policies. While
contractors have always had these obligations, this latest Agency
enforcement initiative represents a distinct departure from
OFCCPÂ’s pr...