The federal government has decided to discontinue its Web-based job posting board, America's Job Bank ("AJB"), due to the lack of funding. As you may know, AJB offered free, one-stop shopping to fulfill a federal government contractor's posting requirements. Federal government contractors are those companies with 50 or more employees and one of the following:

1.  A federal contract or subcontract of $50,000 or more; or

2.  Government bills of lading that in any 12-month period total or can reasonably be expected to total $50,000 or more; or

3.  Serves as a depository of government funds in any amount; or

4.  Is a financial institution that is an issuing and paying agent for U.S. savings bonds and savings notes in any amount.

Companies meeting these requirements are required, among other things, to post job openings for positions in all job groups other than Officials & Managers with either the appropriate state employment agency or with AJB. You may continue to use AJB until July 1, 2007. The Department of Labor's Office of Federal Contract Compliance Programs ("OFCCP") (the enforcement arm for regulations governing Affirmative Action and relevant to federal government contractors or subcontractors) has not yet offered guidance on this issue and is the only agency which can approve an alternative job posting method.

Nevertheless, we think it likely the OFCCP will accept several alternatives.

Option #1 - Post job openings with the appropriate state agency. This posting option is free and some states permit online posting. However, some states are not yet automated and may require you to notify it of openings via fax or other communication. Additionally, you will need to add a veterans and a disabled referral source in addition to posting with the state agency.

Option #2 - Use America's Job Exchange (http://www.americasjobbank2.com/ ). This site is free and is operated by NaviSite. NaviSite owned the technology rights to the software used by AJB and is calling itself "the successor to America's Job Bank." The OFCCP has not yet indicated if posting with America's Job Exchange would satisfy posting requirements. However, because it will be virtually identical to AJB, we believe the agency will accept America's Job Exchange as a posting option.

Option #3 - Use a fee-based online service to post required positions. While this option will have a cost associated with it, some of the paid services have significant "bells and whistles" that AJB or NaviSite's America's Job Exchange do not offer. To increase the likelihood of your fee-based online service being deemed acceptable by the OFCCP, you should ensure the service posts your openings automatically with appropriate state agencies, minority and female referral sources as well as veterans and disabled referral sources. One example of an online provider is Direct Employers. There is a fee for using this service and the Web address for it is: http://www.directemployers.org/