The National Defense Authorization Act for Fiscal Year 2012 [pdf] puts an end to OFCCP’s effort to impose subcontractor status on retail pharmacies and health care providers serving TRICARE beneficiaries. The controversy had been brewing for some time. As we discussed in an earlier client alert, the October 2010 decision in OFCCP v. Florida Hospital,

The Office of Federal Contract Compliance Programs has been busy the past few months and anticipates heightened activity in the months to come. New OFCCP initiatives include: (1) asserting jurisdiction over healthcare providers, (2) revamping efforts to identify workers misclassified as contractors; (3) proposing new affirmative action regulations for construction contractors; and (4) increasing enforcement