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Management Rotation & Job Posting

Anonymous - Nov 02, 2020
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We are a federal contractor and have a question about job postings. We are considering implementing a small management rotational program where high-potential leaders would be rotated to similar-level managerial positions on a one-year basis for development purposes. We do not intend to post these internal rotational assignments, which is typically outside our standard practice.

I understand VEVRAA requires federal contractors to list all 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).

In this case, these positions would be internal-only and one could argue they are senior management positions, so unless we are missing something, they would be exempt from posting to the ESDS. From an EEO/AA perspective, are there any other regulations that we should be reviewing/considering that might prevent us from proceeding with this program without posting these opportunities internally? Thank you.

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