Posting Job Openings Internally for Companies Receiving Federal Grant Contracts

Does anyone know if companies who receive federal grant contracts may post job openings internally only without violating the EEO requirements? Or does the EEO require that jobs be posted internally and externally simultaneously?


Comments

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  • I think that it depends on the circumstances. One of the factors that enforcement agencies will look at will be whether or not your recruiting is wide enough to attract a diverse candidate group, so if there are areas which might be deficient, restricting to internal postings would be a problem. On the other hand, posting jobs (preferably a consistent policy of posting) for jobs that are promotional opportunities for current employees is usually a good thing and accepted as proper. You could look at your employment population, identify what might be problems and predict what will be OK and what will not.
  • If you file reports like EEO-1 and have an AAP, you'll certainly be expected to advertise in a geographic area that is representative of your population. While you can certainly post internally-only for some vacancies (e.g. where a planned succession plan is in place), I would NOT do this for the majority of your position vacancies. EEO views things like that as prima facie evidence and you'll be trying to explain with very poor evidence.
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