Hi Monica, This is an excellent question and one that comes up often. In part, it depends on how you advertise them and what your business practice is. Are they advertised as temporary? Are any interns converted to permanent positions? However, there is no definition of "voluntary" or "involuntary" in the regulations, so it is important to come to a well-reasoned conclusion that the company feels comfortable standing behind and the term is used consistently.

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.