Excela Health
MANAGER BIOMEDICAL ENGINEERING
Excela Health, Greensburg, Pennsylvania, us, 15605
Description
Job Summary
The Manager, Biomedical Engineering manages and supports the Biomedical Technology Management program and provides leadership and assistance in the operation and support of clinical technology. Manages the day-to-day activities of reporting technicians, and provides the daily coordination between the Biomedical Departments and users of the department's services.
Essential Job Functions
Support the execution of company strategy across business segments to optimize experience and results.
Establish and maintain a safe working environment; assure staff comply with safety, environmental, and infection control guidelines.
Assure proper use of safety equipment and devices; hold individuals accountable if non-compliant.
Assure completion of staff competencies including mandatory education and programs relative to job specific criteria.
Promptly investigate and resolve Significant Occurrence Reports and incident reports as necessary.
Align strategic compass with department goals; write compelling SMART goals in support of the organization's mission, vision, and values. Help employees understand importance of aligning goals with Excela Health mission.
Equitably and consistently apply and practice policies and procedures for all staff.
Practice and encourage staff readiness in compliance with agency regulations and guidelines.
Improve HCAP scores according to fiscal year targets; demonstrate year after year improvement in service to internal and external customers.
Respond to client service recovery issues within required time frame and to the satisfaction of the customer.
Hold regular department meetings, assuring off shifts and satellite offices receive timely and accurate information.
Maintain a daily meeting board for purpose of displaying problem solving activity.
Build and strengthen relations through the fostering of two-way communication; diffuse sources of conflict.
Provide opportunities for staff to actively provide input into decision making process; seek input before decision is made.
Encourage commitment of quality work throughout areas of responsibility.
Understand and effectively deploy the LEAN tools to streamline work processes, eliminating waste and redundancy while improving productivity.
Act on most urgent tasks; prioritize and delegate workable systems.
Use critical thinking skills to proactively resolve key issues that are possible de-railers to productivity and engagement.
Lead at least one process improvement initiative for department per year; participate in at least one LEAN project per year outside of department.
Clearly articulate what is expected of individuals and provide them with the materials and equipment to do their work.
Adhere to Premier benchmarks for own department.
Utilize employee engagement survey results in carrying out impact plans; demonstrate employee engagement by employee satisfaction results from survey to survey.
Establish performance measures to equitably evaluate staff using objective and job-based criteria; coach towards compliance and address variances.
Provide regular feedback, praise, and recognition; reward accomplishments and results appropriately.
Hold staff accountable for consistently modeling the behavioral standards.
Identify, evaluate, and select internal and external talent, assuring an acceptable fit with Excela Health’s desired culture; effectively match right person to right job.
Provide opportunities for the education, training, and development of staff to help them reach their highest potential.
Offer stretch assignments; create actionable development plans; encourage learning from setbacks and for future development.
Actively support and participate in succession planning initiatives; identify high potentials and prepare them for possible future leadership opportunities within Excela Health.
Take responsibility for own professional growth and development; attend required EHA leadership programs; network with colleagues to seek out best practices.
Introductory, transfer and periodic appraisals are required to be completed timely adhering to performance management guidelines. All Performance Management must be completed in a designated electronic format.
Consider financial impact of decisions; use financial concepts for decision making; monitor financial performance.
Develop and manage department budget at or below budget expectations and consistent with adjusted volume variations.
Identify and implement revenue enhancement opportunities.
Seek opportunities to reduce operating costs while balancing quality resources.
Submit timely variance reports that display knowledge of expenses and demonstrate continual plans to reduce variances; operate each year more effectively than one before.
Stretch capital resources by extending life of existing assets.
Coordinate the selection of vendors through established internal procurement procedures in an effort to drive down supplier costs while maintaining quality standards.
Specialty Job Functions
Oversee operations of the Independence Health- Westmoreland Hospital, Latrobe Hospital and Frick Hospital Biomedical Engineering department by: conducting quarterly department head meetings; ensuring that client reports are delivered in a timely manner; providing a working environment that meets all OSHA guidelines; and completing and maintaining all performance indicators at or above program targets. Ensure smooth communications and reporting to and from each outside account (clinics).
Conducts regular department head visits and meetings to review performance of Biomedical Engineering program; maintaining PM/CM completion at or above expectations; being actively involved in capital asset planning, purchasing, etc., and other committees as assigned; conducting customer satisfaction surveys as required. Grows the program by gaining the confidence of clinical department heads and maintaining positive relationships.
Ensures financial performance of Independence Health Westmoreland by: attaining all expense budgets and cost containment targets; ensuring that expenditure authority and level are adhered to; and forwarding, in a timely manner, all appropriate PO’s, invoices and financial details to the appropriate sources. This role will actively analyze contract spend, parts expenses, and outside services to maintain a cost to value ratio that meets benchmark goals.
Identify, manage and oversee an effective and professional technical staff capable of maintaining high end equipment through personnel recruitment, training and development. This includes holding all necessary staff meetings; training technical staff; providing written measurable objectives; and performing annual performance evaluations. Provides professional team and personal growth that meets the needs of the customer and employees.
Work alongside technical staff assisting as necessary. Analyzes interrelated elements of problems and works systematically to solve them, uses sound judgment to develop efficient and feasible resolutions to challenging issues.
Manages, assigns, directs, and assists staff.
Assigns staff to all hospital related Biomedical Equipment for routine maintenance and related activities
Coordinates biomedical activities in support of, and around construction projects as required.
Develops repair methods, secure materials, and direct non-routine and emergency repairs for biomedical equipment.
Ensures quality of work meets specifications, complies with safety standards, hospital standards and all pertinent regulations (D.O.H. and JCAHO).
Assigns preventative maintenance duties to staff at intervals appropriate to the maintenance of a variety of biomedical equipment.
Develops procedures and schedules for equipment maintenance.
Develops preventive maintenance (PM) schedules for all new and existing Biomedical Equipment as required.
Audits database, purges obsolete information.
Utilizes computer-based PM system for scheduling, tracking and reporting of Biomedical work activity
Monitors effectiveness of the PM schedules; Records unplanned maintenance; Analyzes equipment failure data. Adjust PM schedules as necessary.
Audits reports and schedules for timely completion of scheduled work; Addresses variances. Other duties as assigned.
Develops procedures for the PM system based on manufacturer guidelines
Other duties as assigned.
Required Qualifications
Associate’s Degree in Biomedical Engineering, Electrical Technology, or related field and five (5) years of relevant experience in healthcare environment.
Two (2) to Four (4) years supervisory/management experience in medical equipment filed.
Strong leadership ability, good organizational skills, independent and critical thinking skills, sound judgment.
Strong ability to communicate complex and/or controversial topics and concepts to a wide and diverse audience.
Broad knowledge of Biomedical/Clinical Engineering equipment.
Proficient in computers, network and electronics, including solid state technology (linear and digital circuit operations).
Knowledge of all applicable Federal, State, ACR, JACHO, OSHA and NFPA regulations, standards and guidelines.
Preferred Qualifications
Bachelor’s Degree in Biomedical Engineering, Electrical Technology, or related field
Understanding of equipment management principles including life cycle management, technology assessment, strategic technology planning, technology education and maintenance support.
License, Certification & Clearances
Certified Biomedical Engineering Technician (CBT) preferred.
Valid Pennsylvania Driver’s License (if out of state hire current Department of Motor Vehicle record report required and obtain PA Current Driver License within 30 days of hire).
Act 34-PA Criminal Record Check from the PA State Police system.
Managerial Responsibilities
This position has direct supervisory responsibilities and serves as a coach and mentor for other positions in the department.
Management responsibilities include hiring, coaching, skills development, recognition and rewards, staff productivity and performance management.
Position Type/Expected Hours of Work
Incumbent will be scheduled based on operational need (rotate shifts, standby, on-call, etc.).
Travel may be expected locally between Independence Health locations.
LEAN
Actively promotes a Lean work culture by performing team member duties to encourage consistent use of LEAN principles and processes, including continually seeking work process improvements. Recognizes the necessity of taking ownership of one’s own motivation, morale, performance and professional development. Strives for behavior consistent with being committed to Independence’s missions, vision and values.
AAP/EEO
Independence Health is an Equal Opportunity Employer. It is the policy of Independence Health to prohibit discrimination of any type and to afford equal employment opportunities to employees and applicants, without regard to race, color, religion, sex, national origin, age, marital status, non-job related disability, veteran status, or genetic information, or any other protected class. Independence Health will conform to the spirit as well as the letter of all applicable laws and regulations.
Ability to perform the Essential Functions listed on the Physical Conditions and ability to perform the Essential Functions on the Working Condition chart below.
Work Environment
Effective March 2020 or during pandemic: goggles, face shield and mask are required according to CDC guidelines
When lift requirement is in excess of 50#, lift assistance (2 person) and/or transfer device is required.
Essential – Absolute Necessity.
Marginal – Minimal Necessity.
Constantly – 5.5 to 8 hours or more or 200 reps/shift.
Frequently – 2.5 to 5.5 hours or more or 32-200 reps/shift.
Occasionally – 0.25 to 2.5 hours or 2-32 reps/shift.
Rarely – Less than 0.25 hours or less than 2 reps/shift.
Physical Condition
Essential
Marginal
Constantly
Frequently
Occasionally
Rarely
Never
Extreme Heat
x
Extreme Cold
x
Heights
x
x
Confined Spaces
x
Extreme Noise(>85dB)
x
x
Mechanical Hazards
x
x
Use of Vibrating Tools
x
x
Operates Vehicle (Company)
x
Operates Heavy Equipment
x
Use of Lifting/Transfer Devices
x
Rotates All Shifts
x
x
8 Hours Shifts
x
10-12 Hours Shifts
x
x
On-Call
x
Overtime(+8/hrs/shift; 40/hrs/wk)
x
Travel Between Sites
x
x
Direct Patient Care
x
Respirator Protective Equipment
x
x
Eye Protection
x
x
Head Protection (hard hat)
x
x
Hearing Protection
x
x
Hand Protection
x
x
Feet, Toe Protection
x
Body Protection
x
x
Latex Exposure
x
x
Solvent Exposure
x
x
Paint (direct use) Exposure
x
x
Dust (sanding) Exposure
x
x
Ethylene Oxide Exposure
x
Cytotoxic (Chemo) Exposure
x
Blood/Body Fluid Exposure
x
x
Chemicals (direct use) Exposure
x
x
Mist Exposure
x
Wax Stripper (direct use)
x
Non-Ionizing Radiation Exposure
x
Ionizing Radiation Exposure
x
Laser Exposure
x
x
Physical Demands
When lift requirement is in excess of 50#, lift assistance (2 person) and/or transfer device is required.
Essential – Absolute Necessity.
Marginal – Minimal Necessity.
Constantly – 5.5 to 8 hours or more or 200 reps/shift.
Frequently – 2.5 to 5.5 hours or more or 32-200 reps/shift.
Occasionally – 0.25 to 2.5 hours or 2-32 reps/shift.
Rarely – Less than 0.25 hours or less than 2 reps/shift.
Physical Condition
Essential
Marginal
Constantly
Frequently
Occasionally
Rarely
Never
Bending (Stooping)
x
x
Sitting
x
x
Walking
x
x
Climbing Stairs
x
x
Climbing Ladders
x
x
Standing
x
x
Kneeling
x
x
Squatting (Crouching)
x
x
Twisting/Turning
x
x
Keyboard/Computer Operation
x
x
Gross Grasp
x
x
Fine Finger Manipulation
x
x
Hand/Arm Coordination
x
x
Pushing/Pulling(lbs. of force)
x
35#
50#
Carry
x
x
Transfer/Push/Pull Patients
x
Seeing Near w/Acuity
x
x
Feeling (Sensation)
x
x
Color Vision
x
x
Hearing Clearly
x
x
Pulling/Pushing Objects Overhead
x
x
Reaching Above Shoulder Level
x
x
Reaching Forward
x
x
Lifting Floor to Knuckle
x
30#
Lifting Seat Pan to Knuckle
x
Lifting Knuckle to Shoulder
x
30#
Lifting Shoulder to Overhead
x
30#
When lift requirement is in excess of 50#, lift assistance (2 person) and/or transfer device is required.
Equal Opportunity Employer/Protected Veterans/Individuals with Disabilities
The contractor will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor’s legal duty to furnish information. 41 CFR 60-1.35(c)
Job Summary
The Manager, Biomedical Engineering manages and supports the Biomedical Technology Management program and provides leadership and assistance in the operation and support of clinical technology. Manages the day-to-day activities of reporting technicians, and provides the daily coordination between the Biomedical Departments and users of the department's services.
Essential Job Functions
Support the execution of company strategy across business segments to optimize experience and results.
Establish and maintain a safe working environment; assure staff comply with safety, environmental, and infection control guidelines.
Assure proper use of safety equipment and devices; hold individuals accountable if non-compliant.
Assure completion of staff competencies including mandatory education and programs relative to job specific criteria.
Promptly investigate and resolve Significant Occurrence Reports and incident reports as necessary.
Align strategic compass with department goals; write compelling SMART goals in support of the organization's mission, vision, and values. Help employees understand importance of aligning goals with Excela Health mission.
Equitably and consistently apply and practice policies and procedures for all staff.
Practice and encourage staff readiness in compliance with agency regulations and guidelines.
Improve HCAP scores according to fiscal year targets; demonstrate year after year improvement in service to internal and external customers.
Respond to client service recovery issues within required time frame and to the satisfaction of the customer.
Hold regular department meetings, assuring off shifts and satellite offices receive timely and accurate information.
Maintain a daily meeting board for purpose of displaying problem solving activity.
Build and strengthen relations through the fostering of two-way communication; diffuse sources of conflict.
Provide opportunities for staff to actively provide input into decision making process; seek input before decision is made.
Encourage commitment of quality work throughout areas of responsibility.
Understand and effectively deploy the LEAN tools to streamline work processes, eliminating waste and redundancy while improving productivity.
Act on most urgent tasks; prioritize and delegate workable systems.
Use critical thinking skills to proactively resolve key issues that are possible de-railers to productivity and engagement.
Lead at least one process improvement initiative for department per year; participate in at least one LEAN project per year outside of department.
Clearly articulate what is expected of individuals and provide them with the materials and equipment to do their work.
Adhere to Premier benchmarks for own department.
Utilize employee engagement survey results in carrying out impact plans; demonstrate employee engagement by employee satisfaction results from survey to survey.
Establish performance measures to equitably evaluate staff using objective and job-based criteria; coach towards compliance and address variances.
Provide regular feedback, praise, and recognition; reward accomplishments and results appropriately.
Hold staff accountable for consistently modeling the behavioral standards.
Identify, evaluate, and select internal and external talent, assuring an acceptable fit with Excela Health’s desired culture; effectively match right person to right job.
Provide opportunities for the education, training, and development of staff to help them reach their highest potential.
Offer stretch assignments; create actionable development plans; encourage learning from setbacks and for future development.
Actively support and participate in succession planning initiatives; identify high potentials and prepare them for possible future leadership opportunities within Excela Health.
Take responsibility for own professional growth and development; attend required EHA leadership programs; network with colleagues to seek out best practices.
Introductory, transfer and periodic appraisals are required to be completed timely adhering to performance management guidelines. All Performance Management must be completed in a designated electronic format.
Consider financial impact of decisions; use financial concepts for decision making; monitor financial performance.
Develop and manage department budget at or below budget expectations and consistent with adjusted volume variations.
Identify and implement revenue enhancement opportunities.
Seek opportunities to reduce operating costs while balancing quality resources.
Submit timely variance reports that display knowledge of expenses and demonstrate continual plans to reduce variances; operate each year more effectively than one before.
Stretch capital resources by extending life of existing assets.
Coordinate the selection of vendors through established internal procurement procedures in an effort to drive down supplier costs while maintaining quality standards.
Specialty Job Functions
Oversee operations of the Independence Health- Westmoreland Hospital, Latrobe Hospital and Frick Hospital Biomedical Engineering department by: conducting quarterly department head meetings; ensuring that client reports are delivered in a timely manner; providing a working environment that meets all OSHA guidelines; and completing and maintaining all performance indicators at or above program targets. Ensure smooth communications and reporting to and from each outside account (clinics).
Conducts regular department head visits and meetings to review performance of Biomedical Engineering program; maintaining PM/CM completion at or above expectations; being actively involved in capital asset planning, purchasing, etc., and other committees as assigned; conducting customer satisfaction surveys as required. Grows the program by gaining the confidence of clinical department heads and maintaining positive relationships.
Ensures financial performance of Independence Health Westmoreland by: attaining all expense budgets and cost containment targets; ensuring that expenditure authority and level are adhered to; and forwarding, in a timely manner, all appropriate PO’s, invoices and financial details to the appropriate sources. This role will actively analyze contract spend, parts expenses, and outside services to maintain a cost to value ratio that meets benchmark goals.
Identify, manage and oversee an effective and professional technical staff capable of maintaining high end equipment through personnel recruitment, training and development. This includes holding all necessary staff meetings; training technical staff; providing written measurable objectives; and performing annual performance evaluations. Provides professional team and personal growth that meets the needs of the customer and employees.
Work alongside technical staff assisting as necessary. Analyzes interrelated elements of problems and works systematically to solve them, uses sound judgment to develop efficient and feasible resolutions to challenging issues.
Manages, assigns, directs, and assists staff.
Assigns staff to all hospital related Biomedical Equipment for routine maintenance and related activities
Coordinates biomedical activities in support of, and around construction projects as required.
Develops repair methods, secure materials, and direct non-routine and emergency repairs for biomedical equipment.
Ensures quality of work meets specifications, complies with safety standards, hospital standards and all pertinent regulations (D.O.H. and JCAHO).
Assigns preventative maintenance duties to staff at intervals appropriate to the maintenance of a variety of biomedical equipment.
Develops procedures and schedules for equipment maintenance.
Develops preventive maintenance (PM) schedules for all new and existing Biomedical Equipment as required.
Audits database, purges obsolete information.
Utilizes computer-based PM system for scheduling, tracking and reporting of Biomedical work activity
Monitors effectiveness of the PM schedules; Records unplanned maintenance; Analyzes equipment failure data. Adjust PM schedules as necessary.
Audits reports and schedules for timely completion of scheduled work; Addresses variances. Other duties as assigned.
Develops procedures for the PM system based on manufacturer guidelines
Other duties as assigned.
Required Qualifications
Associate’s Degree in Biomedical Engineering, Electrical Technology, or related field and five (5) years of relevant experience in healthcare environment.
Two (2) to Four (4) years supervisory/management experience in medical equipment filed.
Strong leadership ability, good organizational skills, independent and critical thinking skills, sound judgment.
Strong ability to communicate complex and/or controversial topics and concepts to a wide and diverse audience.
Broad knowledge of Biomedical/Clinical Engineering equipment.
Proficient in computers, network and electronics, including solid state technology (linear and digital circuit operations).
Knowledge of all applicable Federal, State, ACR, JACHO, OSHA and NFPA regulations, standards and guidelines.
Preferred Qualifications
Bachelor’s Degree in Biomedical Engineering, Electrical Technology, or related field
Understanding of equipment management principles including life cycle management, technology assessment, strategic technology planning, technology education and maintenance support.
License, Certification & Clearances
Certified Biomedical Engineering Technician (CBT) preferred.
Valid Pennsylvania Driver’s License (if out of state hire current Department of Motor Vehicle record report required and obtain PA Current Driver License within 30 days of hire).
Act 34-PA Criminal Record Check from the PA State Police system.
Managerial Responsibilities
This position has direct supervisory responsibilities and serves as a coach and mentor for other positions in the department.
Management responsibilities include hiring, coaching, skills development, recognition and rewards, staff productivity and performance management.
Position Type/Expected Hours of Work
Incumbent will be scheduled based on operational need (rotate shifts, standby, on-call, etc.).
Travel may be expected locally between Independence Health locations.
LEAN
Actively promotes a Lean work culture by performing team member duties to encourage consistent use of LEAN principles and processes, including continually seeking work process improvements. Recognizes the necessity of taking ownership of one’s own motivation, morale, performance and professional development. Strives for behavior consistent with being committed to Independence’s missions, vision and values.
AAP/EEO
Independence Health is an Equal Opportunity Employer. It is the policy of Independence Health to prohibit discrimination of any type and to afford equal employment opportunities to employees and applicants, without regard to race, color, religion, sex, national origin, age, marital status, non-job related disability, veteran status, or genetic information, or any other protected class. Independence Health will conform to the spirit as well as the letter of all applicable laws and regulations.
Ability to perform the Essential Functions listed on the Physical Conditions and ability to perform the Essential Functions on the Working Condition chart below.
Work Environment
Effective March 2020 or during pandemic: goggles, face shield and mask are required according to CDC guidelines
When lift requirement is in excess of 50#, lift assistance (2 person) and/or transfer device is required.
Essential – Absolute Necessity.
Marginal – Minimal Necessity.
Constantly – 5.5 to 8 hours or more or 200 reps/shift.
Frequently – 2.5 to 5.5 hours or more or 32-200 reps/shift.
Occasionally – 0.25 to 2.5 hours or 2-32 reps/shift.
Rarely – Less than 0.25 hours or less than 2 reps/shift.
Physical Condition
Essential
Marginal
Constantly
Frequently
Occasionally
Rarely
Never
Extreme Heat
x
Extreme Cold
x
Heights
x
x
Confined Spaces
x
Extreme Noise(>85dB)
x
x
Mechanical Hazards
x
x
Use of Vibrating Tools
x
x
Operates Vehicle (Company)
x
Operates Heavy Equipment
x
Use of Lifting/Transfer Devices
x
Rotates All Shifts
x
x
8 Hours Shifts
x
10-12 Hours Shifts
x
x
On-Call
x
Overtime(+8/hrs/shift; 40/hrs/wk)
x
Travel Between Sites
x
x
Direct Patient Care
x
Respirator Protective Equipment
x
x
Eye Protection
x
x
Head Protection (hard hat)
x
x
Hearing Protection
x
x
Hand Protection
x
x
Feet, Toe Protection
x
Body Protection
x
x
Latex Exposure
x
x
Solvent Exposure
x
x
Paint (direct use) Exposure
x
x
Dust (sanding) Exposure
x
x
Ethylene Oxide Exposure
x
Cytotoxic (Chemo) Exposure
x
Blood/Body Fluid Exposure
x
x
Chemicals (direct use) Exposure
x
x
Mist Exposure
x
Wax Stripper (direct use)
x
Non-Ionizing Radiation Exposure
x
Ionizing Radiation Exposure
x
Laser Exposure
x
x
Physical Demands
When lift requirement is in excess of 50#, lift assistance (2 person) and/or transfer device is required.
Essential – Absolute Necessity.
Marginal – Minimal Necessity.
Constantly – 5.5 to 8 hours or more or 200 reps/shift.
Frequently – 2.5 to 5.5 hours or more or 32-200 reps/shift.
Occasionally – 0.25 to 2.5 hours or 2-32 reps/shift.
Rarely – Less than 0.25 hours or less than 2 reps/shift.
Physical Condition
Essential
Marginal
Constantly
Frequently
Occasionally
Rarely
Never
Bending (Stooping)
x
x
Sitting
x
x
Walking
x
x
Climbing Stairs
x
x
Climbing Ladders
x
x
Standing
x
x
Kneeling
x
x
Squatting (Crouching)
x
x
Twisting/Turning
x
x
Keyboard/Computer Operation
x
x
Gross Grasp
x
x
Fine Finger Manipulation
x
x
Hand/Arm Coordination
x
x
Pushing/Pulling(lbs. of force)
x
35#
50#
Carry
x
x
Transfer/Push/Pull Patients
x
Seeing Near w/Acuity
x
x
Feeling (Sensation)
x
x
Color Vision
x
x
Hearing Clearly
x
x
Pulling/Pushing Objects Overhead
x
x
Reaching Above Shoulder Level
x
x
Reaching Forward
x
x
Lifting Floor to Knuckle
x
30#
Lifting Seat Pan to Knuckle
x
Lifting Knuckle to Shoulder
x
30#
Lifting Shoulder to Overhead
x
30#
When lift requirement is in excess of 50#, lift assistance (2 person) and/or transfer device is required.
Equal Opportunity Employer/Protected Veterans/Individuals with Disabilities
The contractor will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor’s legal duty to furnish information. 41 CFR 60-1.35(c)