Jurisdiction is often tricky both for contractors and the agency. Being an FQHC doesn’t necessarily make a company required to comply with the laws enforced by OFCCP, but it doesn’t mean that the company is not a federal contractor either. Likely, a little more research needs to be done based on the facts of your situation.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.