Constance A. Wilkinson, Selena M. Brady
Constance Wilkinson, a Member of the Firm in the Litigation and Health Care and Life Sciences practices, in the Washington, DC, office, and Selena Brady, an Associate in the Health Care and Life Sciences practice, in the Washington, DC, office, co-wrote an article titled “The Expansion of Federal Subcontractor Status to Health Care Providers.”
Following is an excerpt:
The Federal Government imposes significant socioeconomic obligations upon government contractors and subcontractors. The most significant is a suite of equal opportunity and affirmative action requirements. Because of the compliance burden of these requirements, whether a subcontract is “covered” and subject to equal opportunity and affirmative action laws is a crucial issue for potential subcontractors. Health care providers have historically viewed themselves as exempt from these equal opportunity and affirmative action requirements in the absence of direct contractual relationships with federal agencies.