Many of my patients are veterans. Do I qualify as federal a contractor? Do I have to create an Affirmative Action Program?
Receiving monies from the Veterans Administration (VA) for patient care payments does indeed qualify you as a federal contractor and therefore your business may need to create an Affirmative Action Program (AAP) and follow the rules including yearly submissions that go with it.
Generally, if your business has a federal contract or subcontract with the Veterans Administration of $50,000 or more (this can be cumulative), and has 50 or more employees, then you would be responsible for developing and maintaining a written AAP under Executive Order 11246 and Section 503 of the Rehabilitation Act. If the contract has a value of $100,000 or more and 50 or more employees, then you would also be responsible for developing and maintaining a written AAP under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).
If you need more information about Office of Federal Contract Compliance Programs (OFCCP) or any other issue related to federal contractors on discrimination and affirmative action obligations, you can visit the OFCCP’s website at http://www.dol.gov/ofccp/