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Excellent question, Heather. There is no requirement to make an additional inquiry at the time a current employee is selected for a new position. This assumes, however, that the other requirements of 41 CFR 60-741.42 and 41 CFR 60-300.42 are being followed. Specifically, we solicit self-ID info pre-offer, post-offer, every five years, and once between the five year intervals. OFCCP has a form that is required for disability self-ID and a compliant sample form for Veteran self-ID on their website.
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.