Publication
Legal Alert: Potential New OFCCP Affirmative Action Requirements for Health Care Providers
The United States Department of Labor’s Office of Federal Contract Compliance Programs (“OFCCP”), the federal government’s affirmative action enforcement agency, has long sought to expand its jurisdiction to health care providers. The OFCCP requires federal government contractors and subcontractors to develop and maintain workforce affirmative action plans. For nearly 25 years, many health care providers avoided affirmative action obligations by relying on a court ruling that Medicare and Medicaid reimbursements did not trigger coverage. The OFCCP has had recent success extending coverage in two cases in Pennsylvania and Florida that focused on the evolution of contractual relationships for health care services. While those cases are being appealed, the OFCCP has issued a directive signaling its intent to enforce affirmative action regulations against more health care providers.
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Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 17 locations throughout the United States and in Mexico, including Los Angeles, Orange County, Palo Alto and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
