by Keli Wilson, Senior Consultant, DCI Consulting Group
OFCCP Director of Program Operations Tom Dowd and Counsel Consuela Pinto presented a webinar April 25, 2012 titled “Status of Pending Compliance Evaluations of Entities that Participate in TRICARE Networks.” The webinar was brief, but answered several operational questions on how the OFCCP will enforce compliance evaluations until a decision is made in the litigated Florida Hospital case.
OFCCP will be sending out letters by early next week to federal contractors with a pending compliance evaluation to notify them if there is a basis for jurisdiction other than TRICARE. If your organization receives this notification, you will have 30 days from the date of receipt and must submit the plan requested in the original Scheduling Letter. If the OFCCP initiates any new compliance reviews, this same policy will be enforced until a decision is made in the case.
Tom Dowd clarified that reimbursements through Medicare part A/B are not considered contracts and do not automatically make you a contractor/subcontractor. Additionally, Consuela Pinto announced that Directive 293 was rescinded by the OFCCP, effective today.