Israel, Great questions - there is not very clear guidance on these issues in the regulations. Converting a temp employee depends on the circumstances. First, as you are probably aware, regulations enforced by OFCCP require, "Listing of employment openings with the appropriate employment service delivery system." This includes, "all positions except executive and senior management, those positions that will be filled from within the contractor's organization, and positions lasting three days or less. This term includes full-time employment, temporary employment of more than three days' duration, and part-time employment." Therefore, there should have been a listing and competition (i.e. an applicant pool) for the temp position. If that was the case, and this person is already an employee, then it could be a transfer or promotion, depending on how your company has those defined, and as shown above, positions to be filled within the company are not required to be listed. If this person is not already an employee, then the job should be listed in accordance with regulations. There are no time limits given in the regulations, but in my experience most agencies list jobs for 30 days. Hope this helps.
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