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I believe you are referring to the mandatory listing requirement under the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA) which requires federal contractors to list their all of their job openings, except for a) executive and senior management positions, 2) jobs lasting 3 days or less, or 3) internal positions, to the appropriate state Employment Service Delivery System (ESDS) or State Job Bank. There are 55 state-run job banks across the country. The requirement is to list jobs with the ESDS/State Job Banks. The regulations do not govern the posting of jobs to a company's own career website. This requirement, which can be found in the Equal Opportunity Clause of the VEVRAA regulation states 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 and shall involve the normal obligations which attach to the placing of a bona fide job order, including the acceptance of referrals of veterans and nonveterans.” The regulation has not changed since they were updated on March 24, 2014. By "concurrently," this means that a contractor must list or post their jobs with the Employment Service Delivery System (ESDS) as soon as they start recruiting for it, and keep the posting active until it is filled. The regulations do not specify a minimum or maximum number of days that jobs must be posted on the ESDS, but you do need to keep it active for as long as you are recruiting for it, so ESDS representatives working to place veterans can continue to refer qualified protected veterans to your open jobs. As for listing managerial positions, the exemption is for "executive and senior management positions." First, make sure that the management position you have falls within the definition stated in the regulations. If it does, then there is no requirement for you to list the job. If it doesn't, but the position is being filled by an internal candidate, you are also not required to list it. If the job does not fall under any of the three exemptions, you have a requirement not just to list it, but also to undertake the required outreach. Keep in mind that the purpose of the VEVRAA mandatory job listing and outreach requirements are to provide an opportunity for qualified protected veterans to compete for federal contractor jobs. When OFCCP sees 1:1 applicant-to-hire ratios for a job, it may raise questions about record keeping, adverse impact, or whether or not you performed the required outreach and listed it to notify veterans of your opportunity. How was that one candidate sourced? Was that candidate an employee referral? Or part of the applicant pool for a different job opening? A temp-to-perm hire? Depending on the circumstances, your applicant pool may be expanded by OFCCP to include the original source pool that candidate was selected from. As a best practice, if a position is not exempt, outreach and listing should be undertaken.
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.