I would be worried about Equal Opportunity Employment requirements and
Affirmative Action requirements. I think if you accept government money
(grants) you might be obligated to have an in place and functioning
Affirmative Action and Equal Opportunity Employment plan. If you have less
than 50 employees and volunteers you shouldn't have to file the plan with an
Affirmative Action Office, but you still need to have one.
While not advertising the job or performing a search may in itself be legal,
it might raise flags if you ever have an Affirmative Action or Equal
Opportunity Employment claim.
Trent Litchfield
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