In an opinion released today, the en banc ARB panel tasked with reviewing last years’s ARB plurality decision  – which held Florida Hospital was not subject to OFCCP jursidiction after passage of the NDAA (National Defense Authorization Act) – has found Florida Hospital is still subject to OFCCP jursidiction based on application of the first prong of the definition of a subcontract found in OFCCP’s regulations.

We are in the process of reviewing the decision and will provide more insight on the implications of the decision in the coming days . . . stay tuned.