Be careful where you tread

Let me pose a question to you? How many of you are Federal Contractors in your business? Let me rephrase that. How many of you are Federal Contractor and don’t know it? Consider this scenario– You are a HR provider or a relocation provider and you contract with say a relocation management firm to provide services to their government client. According to some recent government rulings you may be also considered a federal contractor and subject to EEO/Affirmative Action regulations.

The Jackson Lewis Law Firm reported the following result of the scenario we suggested: 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 Labor???s Administrative Review Board (ARB) has upheld an administrative law judge???s (ALJ???s) 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. OFCCP v. UPMC Braddock, No. 08-048 (DOL ARB May 29, 2009).
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