VEVRAA requires that contractors list all employment openings which exist at the time of the execution of the contract, and which occur during the performance of the contract, with the appropriate employment service delivery system (ESDS) where the opening occurs. Typically, the location of a job opening, or where a job opening “occurs,” is the location to which the employee must report for work. For a job opening that does not require the employee to report to, or work from, a specific location, a contractor may satisfy the job listing requirement by listing the job opening with the state or local ESDS where the work unit, division, department or supervisor to which the employee will report or be assigned is located. For example, if the position will report to a supervisor who is based in your Chicago office, then the position should be posted to the IL ESDS. As far as outreach goes, all of the examples of outreach and recruitment activities listed in the regulations reference recruitment and outreach to relevant agencies, service centers, and community-based organizations that are located near the contractor’s establishment. So at the very least, your outreach efforts should include organizations in that local area. For more information, you can view the OFCCP’s FAQ regarding posting remote positions here.

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.