Saving Clients Time, Money, and Effort
A health care client had combined several hospital and clinic facilities owned by multiple, but related, legal entities into one affirmative action program (AAP). The client submitted the entire AAP to the Office of Federal Contract Compliance Programs (OFCCP) after the OFCCP issued a scheduling letter to only one of the client’s clinics. The OFCCP announced that it found a significant shortfall in minority and female hires in various job groups and was on the road to requiring the hiring of numerous rejected applicants along with payment of multiple years of back pay for each applicant.
The client called us. We convinced the OFCCP to halt its investigation and obtained administrative closure of the review. The alleged problem areas related to facilities and/or legal entities other than the one that the OFCCP scheduled for audit. We convinced the OFCCP that it did not have jurisdiction over these other facilities and entities. We provided the OFCCP with a revised AAP covering just the facility that originally had been scheduled for the audit and showed that no discrimination had occurred at that facility. We saved our client significant time, effort, and money, being that it did not have to try to defend its allegedly discriminatory hiring practices at other facilities and by other legal entities.