Our organization uses minimum/required job qualifications during the posting process to determine candidates that self-select that they are or are not qualified for the job (i.e. do they meet the required job qualifications or not?). We have two non-exempt positions with the following required qualifications: Level 1 Position – no experience required (must be over the age of 18) and Level 2 Position – 1 year of experience in XYZ required (inserting XYZ, as the actual experience doesn’t matter in this example). However, business unit leaders would like to change the required qualifications for the Level 2 position to be different depending on whether the candidate is internal or external to allow candidates in the level 1 position to progress to the level 2 position faster. The updated level 2 position qualifications would be externally the same (1 year of experience in XYZ) and internally they would be 6+ months of experience in XYZ and the successful completion of a documented progression plan. In other words, they are placing more value on internal experience in the role, allowing candidates to have lessor experience than an external candidate hired into the same role.

I’m curious on how the OFCCP may view differing qualifications for external and internal candidates and what, if any, criticism we might be exposed to if we decide to move forward with this change. Thank you!

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