The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has sought to audit health care providers’ affirmative action plans (AAPs) for over a decade. Many health care providers remained beyond the OFCCP’s jurisdictional reach, protected by court rulings rejecting assertions that receipt of Medicare and Medicaid reimbursements triggered OFCCP coverage. Recently, however, the OFCCP issued Directive 293 and announced its intent to audit health care providers’ AAPs in instances where insurer provider agreements to provide health care services to federal employees under Medicare Advantage (Part C) and Prescription Drug (Part D) and, where health care services to TRICARE (military employees) and FEHBP (federal employees), are rendered.
The OFCCP’s interpretation of its powers may expand its jurisdiction to cover hospitals, outpatient facilities, insurers, pharmacies, claims processing services, and practice groups that are unfamiliar with the regulations, record keeping requirements, and monetary liability pitfalls contractors encounter under Executive Order 11246, Section 503 of the Rehabilitation Act, and VEVRAA. This webinar is designed to help health care providers assess their abilities to respond to an OFCCP audit letter, and identify data and documentation necessary to develop and implement compliant AAPs.
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