Nothing in the OFCCP regulations limits the amount of offers that a company may make. Of course ensuring the potential outcomes for offers is prudent under other laws and regulations. Careful record keeping and proper dispositioning of the applicants, offers and any changes to the offer would be very helpful should your company be audited. While the process appears facially neutral, it is a good idea to take a look to ensure no particular group is impacted by any changes to the offers. (I don't see anything in your question that would indicate any issues, but not knowing anything more about your process, it is worth mentioning as I expect the OFCCP could take a look at impact in an audit.) It is important to make the regulations fit with your business practices and from the facts in your question, the practice seems compliant.
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.
