Office of Federal Contract Compliance Programs Update Web Seminar DVD
New OFCCP directive, recent audit activity, clarifying "federal contractor" designation



Web Seminar Recorded Live March 24, 2011
Program Rated 4.5 out of 5 by participants 

If your hospital receives Medicare and Medicaid, are you considered a federal contractor? It’s a frequently asked question and the answer may be changing.

Historically, the Department of Labor, which oversees the Office of Federal Contract Compliance Program (OFCCP), has said no. But a new OFCCP directive indicates that receipt of Medicare Part C or D may trigger contractor status. In addition, a recent administrative law decision found Florida Hospital to be a federal contractor because they were a provider under the Department of Defense’s TRICARE health care program.

With these recent developments, hospitals nationwide are now focusing their attention on the issue of federal contractor status. Increased audit activity has been noted in California and adds weight to this concern.

Whether your hospital is a stand-alone, or part of a larger system, it’s important to understand whether or not you are considered a federal contractor, and if so, what you need to do to comply.

Participants to the web seminar will learn:

  • Situations that may or may not trigger federal contractor status — Medicare, Medicaid, federal research grants, TRICARE
  • Compliance obligations for federal contractors
  • Overview of the audit process — what’s involved, from desk audit through on-site facility review
  • Recent enforcement activity — status of the TRICARE case and implications for California hospitals
  • Potential OFCCP rulemaking — what’s on the horizon

Recommended for:
Chief operating officers, human resources executives, legal counsel and risk managers


Jane Suhr, District Director, Los Angeles District Office, U.S. Department of Labor, Office of Federal Contract Compliance

G. Roger King, Partner, Jones Day

Gail Blanchard-Saiger, Vice President, Labor and Employment, California Hospital Association