Yes. When OFCCP revised its Veteran regulations in 2007, it made VERY clear in its comments to the Final Rule that organizations using third party agencies are required to post the job. https://www.govinfo.gov/content/pkg/FR-2007-08-08/pdf/E7-15385.pdf If you paste that into a brower, it will take you to the final rule, and on page 44398, you will read OFCCP's discussion about temp agencies. "A contractor’s use of an employment agency does not relieve the contractor of its obligation to comply with the mandatory job listing requirement. Section 60–250.5(a) expressly provides that ‘‘listing of employment openings with the appropriate employment service delivery system pursuant to this clause shall be made at least concurrently with the use of any other recruitment source or effort * * *’’ (Emphasis supplied.) Thus, the regulations generally require contractors to list with the appropriate employment service delivery system the jobs that also are provided to an employment agency. The only jobs listed with an employment agency that need not be listed with the employment service are those exempt from the mandatory job listing requirement. Section 60–250.5(a)6.i exempts from the mandatory job listing requirement positions that are executive and senior management, positions filled from within the contractor’s organizations, and positions lasting three days or less." Although the regulations at Part 250 were superseded by the regulations in Part 300, the OFCCP's motivation for the requirement to list remains true to this day.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.