On December 16, 2010, the Office of Federal Contract Compliance Programs, US Department of Labor, issued a directive regarding the guidance for assessing when health care providers and insurers are federal contractors or subcontractors. Coverage is based on their relationship with a Federal health care program or participation in a Federal health care program.
The Directive No. 293, OFCCP Order No. ADM Notice/Jr, which is sent to OFCCP staff, indicates that this directive addresses contractor coverage in light of changes to health care programs and recent litigation. The directive applies to three health care programs: Medicare, TRICARE, and the Federal Employees Health Benefits Program (FEHBP).
For a copy of the directive, go to: http://healthcareemploymentcounsel.com/examining-room/OFCCPDirective293.pdf