Covered veterans were originally only Vietnam era veterans and special disabled veterans, but now include other protected veterans (veterans who served in a military campaign) and recently separated veterans.
VEVRAA enforces giving covered veterans priority in referrals to job openings and requires contractors and subcontractors to list their job openings with the local State Employment Delivery Service (SES).
However, if the contractors' or subcontractors’ jobs meet one of the following, they do not need to list their jobs with the SES:
- Jobs that are filled by internal candidates
- Executive positions
- Jobs that last less than 3 days
The mandatory job listing is enforced by the Office of Federal Contract Compliance Programs (OFCCP) within the United States Department of Labor (DOL).
Previously, contractors and subcontractors used America’s Job Bank (AJB) as a one stop shop to meet the mandatory job listing; however, AJB ceased operation on July 1, 2007. This left contractors and subcontractors with two options:
- Cross-posting the jobs onto the SES manually and documenting it
- Outsourcing the aforementioned to a third party vendor
For contractors and subcontractors who have minimal hiring, posting the jobs themselves is reasonable. But what about contractors and subcontractors who have hundreds, and in some cases, thousands of job openings annually, and in multiple locations?
Since each SES has their own computer system, special requirements, and standards for posting jobs, this can lead to a cumbersome process. In addition, when contractors and subcontractors are manually cross-posting, they need to document it.
“Document it” means contractors and subcontractors need to ensure they are:
- Keeping the reference number provided from the SES after the job was cross-posted
- Taking screen-shots of all cross-posted jobs with the date in which the jobs were cross-posted. If the job had hyperlinks in the ad, those hyperlinks also need screen-shots taken of the information in them
- Will you cross-post my jobs onto the appropriate SES websites?
- How do you cross-post the jobs on my behalf? (Manually, email, fax, etc.)
- Do you provide reports that collect the cross-posting data?
- Do the reports include screen-shots of all cross-posted jobs with the date, time, and reference number (provided from the SES)?
- Are the reports available 24/7?
Lastly, if contractors and subcontractors are using staffing agencies, head-hunters and/or recruitment process outsourcing (RPO), contractors and subcontractors are ultimately responsible for ensuring the required jobs are cross-posted and documented.
Remember to inquire about those five vital questions and contractors and subcontractors will get their compliance review off to a good start.