This question came up at a previous ILG meeting I attended in Chicago, and I'll share the answer that the Chicago OFCCP office shared with us who attended the meeting. To summarize, OFCCP basically said that it depends. If you are reposting some positions that are seasonal, but not all, then you need to be consistent and post all of the jobs. You cannot cherry-pick what postings to advertise. However, OFCCP cautioned that you also need to consider your demographic data at the time of hire. In other words, it needs to be representative of the best and most qualified candidates in the market – at the time of hire. And just to toss in another idea, if you hire an EE from seasonal to FT, then you need to follow the traditional hiring process your organization follows for consistency purposes.
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.