The right answer to this question is that the candidate should be required to apply again. That's not the answer that recruiters and others involved in finding and selecting candidates like to hear, but it's unquestionably the best practice in this regard. Shifting candidates between requisitions can be a dangerous business. If you shift one candidate to a new requisition without requiring that individual to make a formal application, it would not be unreasonable for OFCCP or another regulatory agency to say that ALL candidates on the previous requisition are candidates for the new requisition. You would then be required to consider and re-disposition all of these candidates. Requiring a candidate to express interest in an open position, whether by the candidate's choice or at your suggestion, makes sure that you can appropriately compare interested candidates to the position at hand.

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.