Hall Render has become aware that the Department of Justice Office of Special Counsel for Immigration-Related Unfair Employment Practices (“OSC”) is currently investigating numerous hospitals across the country on the grounds that the hospitals’ advertisements for podiatric residency positions may be in violation of the Immigration and Nationality Act (“INA”). OSC, which is responsible for enforcing the anti-discrimination provision of the INA, has notified affected hospitals by letter that advertisements placed through the Centralized Application Service for Podiatric Residencies may be unlawful if they restrict podiatry residency positions to U.S. citizens.
Hospitals with podiatry residency programs should take immediate steps to determine whether they received a letter from OSC. Violations of the anti-discrimination provision of the INA can result in substantial civil monetary penalties.
If you have questions or would like assistance with responding to OSC’s inquiries, please contact:
- Jonathan C. Bumgarner at jbumgarner@wp.hallrender.com or (317) 977.1474;
- Delphine P. O’Rourke at dorourke@wp.hallrender.com or (610) 941.2785;
- Maryn T. Johnson at mjohnson@wp.hallrender.com or (317) 429.3651; or
- Your regular Hall Render attorney.
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