The Department of Labor (DOL) is expected to implement a revised Labor Condition Application (LCA) between October 24 and October 31, 2018.

The revised form will require employers to name their end-client or vendor when submitting an application for an H-1B, H-1B1, or E-3 worker who will be placed at a third-party worksite. It will also require employers to indicate the number of foreign workers at a given worksite, and H-1B employers who are considered dependent or willful violators will be subject to additional requirements.

Until the revised form is available on iCERT, the online LCA filing system, employers and their immigration counsel will be able to continue using the current LCA. Even after the revised form is available on iCERT, DOL will have a grace period during which the prior version of the LCA can continue to be used. The length of the grace period will be announced in a future time.

Significantly, the revised LCA signifies the first time that DOL has inquired specifically about third-party placements and required employers to disclose end-client or vendor names.

Please do not hesitate to contact our office for any questions regarding this matter.