Assuming the position is classified as an employee (W-2 EE) and not an independent contractor (1099), the job is still subject to the mandatory listing requirement. The VEVRAA regulation states that, “As used in this clause: i. All employment openings 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.” While it doesn’t specifically define “day,” the regulation does say that this applies to part-time and temporary positions. For example, if the person is on your payroll, and they work for one hour each week for 23 weeks, you will have to keep them on your payroll for 23 weeks. That is the duration of their employment, which will not qualify it for the 3-day exemption.

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.