Hi Erich, Yes, the company must list all jobs occurring within the US, "except executive and top management, those positions that will be filled from within the contractor's organization, and positions lasting three days or less." It is possible to set up such a program. It is not necessarily easy, though. It is important to define this program as specifically as possible, e.g., for what jobs will the individuals be considered, what is the hiring process for this group, what are the qualifications, etc. Of course you would also want to keep a close eye on adverse impact analyses and ensure that there are no violations. It will also be important to understand the selection process of the school that sends the interns, much like with a staffing firm. Ensure all records are adequately retained. Pipelines in general make it difficult to stay in compliance, so perhaps consider a process where the students are applying for a particular position. If your company is subject to VETS and IWD compliance, those goals would have to be considered as well. Bottom line: it is possible, but would require time and attention to detail to set up and monitor. Hope this helps.

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