In a significant decision with implications beyond the healthcare industry, the D.C. District Court upheld a ruling by the U.S. Department of Labor’s Administrative Review Board (ARB) deeming three Pennsylvania hospitals government subcontractors subject to the Office of Federal Contract Compliance Programs’ (OFCCP) jurisdiction. UPMC Braddock v. Harris, No. 1:09-cv-01210-PLF (D.D.C. Mar. 30, 2013).
Every now and then a subject comes along that seems much more complicated than it ought to be. The issue of who is a government “subcontractor” is one of those subjects. One would think that a single, straightforward definition of “subcontractor” could be consistently applied across federal contracts. If only it were that simple. Uneven