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The Catalyst

A letter to MUSC employees

MUSC strives to be a good neighbor and a responsible business partner to the surrounding Tri-county region. As one of the area’s largest employers, we understand the economic impact we have on South Carolina and the Lowcountry. Since much of our business is with the federal government, we strictly adhere to federal laws and regulations dealing with the workplace, including nondiscrimation.

The Office of Federal Contract Compliance Programs within the U.S. Department of Labor is responsible for ensuring that employers comply with the laws and regulations requiring nondiscrimination. OFCCP administers and enforces several legal authorities that require equal employment opportunity, including Executive Order 11246, as amended, and Section 503 of the Rehabilitation Act of 1973, as amended. These authorities prohibit federal contractors like MUSC and subcontractors from discriminating on the basis of race, color, religion, sex, national origin, disability, and protected veteran status.

Recent updates to these regulations have been made as they relate to the recruitment and employment of qualified individuals with disabilities.

These newly revised regulations, enforced by OFCCP, require us to do more outreach to try to increase the number of qualified individuals with disabilities in our workforce. We are also required to report to OFCCP the number of qualified individuals that we are able to reach and hire.

As a part of our reports, we are required to invite current employees to declare their current disability status (not specific disability).  This can be done online by logging into “My Records” at for University employees or via for Medical Center employees, under the Personal Information Tab. Please complete the update before Dec. 31.

Why did OFCCP revise its Section 503 regulations?
OFCCP revised the Section 503 regulations to update and strengthen employers’ affirmative action and nondiscrimination responsibilities. The framework articulating employers’ Section 503 responsibilities has been in place since the 1970s. However, both the unemployment rate of working age individuals with disabilities and the percentage of those that are not in the labor force remain significantly higher than for those without disabilities. A substantial disparity in the employment rate of individuals with disabilities continues to persist despite years of technological advancements that have made it possible for individuals with disabilities to apply for and successfully perform a broad array of jobs. In addition, we are finding more Section 503 violations during compliance investigations. This seems to indicate that the current compliance framework is not as effective as hoped.

Several factors contribute to limiting the ability of individuals with disabilities to seek, find, keep, and thrive in jobs.

The existence of an outdated framework that does not reflect the realities of today’s workplace or current disability rights law; the persistent unemployment and underutilization of individuals with disabilities; and certain institutional and process barriers are all limiting factors. These factors highlight the need for new regulations.
The information will not be shared and will be kept confidential, other than for reporting requirements.

Should there be any questions, please contact my office at 792-1568 or via email at


Wallace Bonaparte
Director, Office of Equal Employment Opportunity and Affirmative Action Compliance

December 7, 2014



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