There are two requirements that contractors need to comply with that are relevant to your question. The first is the mandatory job listing requirement under VEVRAA, which requires contractors to list their job openings with the local Employment Service Delivery Systems (ESDS) where their jobs are located. All jobs need to be listed with the exception of three categories: 1) executive and senior management positions, 2) positions that will be filled internally, and 3) positions lasting three days or less. If the positions you are referring to will be filled by individuals who are already on your organization’s payroll, then there is no need to post these positions with the ESDS, as these are considered as jobs filled internally. The second requirement is the periodic review of your personnel processes which is a required component of a contractor’s affirmative action plan. As a contractor, you will need to ensure that regardless of whatever criteria you use, your criteria, processes, and decisions on promotions, transfers, selection for training, and other personnel actions or employment decisions, do not discriminate against protected groups and do not limit their access to these opportunities. It is also important to have these criteria and processes documented and apply these consistently. You are required to periodically review these processes and document this review, with a description of the review and any modifications to your processes based on the results of your review. You can find more information on this under the “Equal Opportunity Clause” and “Required Contents of Affirmative Action Programs” in the final VEVRAA rule

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.