Filing pattern observations
The following are statistical observations derived from public U.S. Department of Labor records.
None of them constitute accusations of wrongdoing. They are mathematical descriptions of filing
patterns, designed to help readers conduct their own due diligence.
Note on 2026 DOL NPRM
Historical wage-level filings reflect the original INA §212(p) framework:
Level I = 17th percentile, Level II = 34th, Level III = 50th, Level IV = 67th.
The 2026 DOL Notice of Proposed Rulemaking proposes raising these to the
34th, 52nd, 70th, and 88th percentiles respectively. Historical patterns must be
interpreted under the framework that was in force when the filings were made.
Foreign subsidiary expansion near layoffs
cross_dataset
Employer incorporates foreign subsidiaries (visible in SEC Exhibit 21) within ±12 months of WARN Act layoff events, suggesting geographic workforce restructuring.
Methodology
Cross-references SEC Exhibit 21 subsidiary jurisdiction data against WARN Act layoff event dates. Flags when foreign subsidiaries appear within a 12-month window of domestic layoffs. Severity: critical (3+ subs, 500+ affected workers), high (2+ subs, 100+), signal (1+).
Data sources
- SEC EDGAR Exhibit 21 (10-K annual reports)
- WARN Act notices (state government disclosures)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Executive compensation increase during workforce reduction
financial
CEO-to-median-worker pay ratio increased during a window in which the employer also filed WARN Act layoff notices. The data does not establish that compensation decisions were tied to layoffs; restructuring, sector mix, and unrelated business decisions can produce the same observable signal.
Methodology
Compares ceo_compensation.pay_ratio for fiscal_year Y vs Y-1, joined to warn_events (matched_employer = true) within a 3-year lookback (fiscal_year, Y-1, Y-2). Severity tiers: critical = ratio change > 20% AND workers in window > 500; high = ratio change > 10% AND any WARN in window; signal = current ratio > 500:1 AND any WARN on record. The signal tier intentionally drops the time-window constraint to honor the plan's 'any WARN on record' clause.
Data sources
- SEC DEF 14A proxy filings (CEO pay ratio, ceo_compensation table)
- DOL/state WARN Act notices (warn_events)
- Employer canonical-name resolution (employers)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
PPP loan followed by workforce reduction and immigration filing increase
financial
Employer received Paycheck Protection Program loan(s), subsequently filed WARN Act layoff notices, and recorded elevated H-1B/PERM filing activity in the 15 months following the WARN. The pattern is a co-occurrence of three federal datasets in a specific temporal sequence; cost-cutting after a payroll loan, restructuring, and unrelated business decisions all produce the same observable sequence.
Methodology
Sequence: ppp_loans.date_approved < warn_events.notice_date < post-WARN filing window (15 months). Per-employer aggregation sums all PPP loans, joins to warn_events on canonical-name match, picks the WARN with the largest workers_affected, and sums perm_quarterly + lca_quarterly filing_count whose fiscal-quarter start lands within 15 months of the WARN. Severity: critical = PPP > $5M AND workers > 500 AND post filings > 200; high = PPP > $1M AND workers > 100; signal = any PPP AND workers > 50.
Data sources
- SBA Paycheck Protection Program loans (ppp_loans)
- DOL/state WARN Act notices (warn_events)
- DOL OFLC PERM quarterly filings (perm_quarterly)
- DOL OFLC LCA quarterly filings (lca_quarterly)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Temporary labor concentration
immigration
This company hires mostly through temporary visas but rarely sponsors workers for green cards.
Methodology
Ratio = total_lca_count / total_perm_count. Critical: ratio > 50:1 AND LCA > 1,000. High: ratio > 20:1 AND LCA > 500. Signal: ratio > 10:1 AND LCA > 200.
Data sources
- H-1B LCA filings
- PERM filings
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Recruitment geography concentration
immigration
Employer draws an unusually high share of PERM-sponsored workers from a single country of citizenship, as reported on ETA Form 9089. Concentration is measured using the Herfindahl-Hirschman Index (HHI) of country shares.
Methodology
For each employer, compute the share of PERM filings by COUNTRY_OF_CITIZENSHIP (ETA-9089 field). HHI = sum of squared percentage shares across all countries. Range: 0 (perfectly distributed) to 10,000 (100% one country). Critical: top-country share > 90% AND total filings with country data > 100. High: top-country share > 80% AND total > 50. Signal: HHI > 5,000 AND total > 20. Legitimate reasons for single-country concentration include industry-specific talent pools, university recruiting pipelines, and intracompany transfers from a single origin office.
Data sources
- PERM filings (COUNTRY_OF_CITIZENSHIP, ETA-9089)
- DOL OFLC disclosure files (FY2008-present)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Multi-FEIN filing distribution
immigration
Parent company files PERM applications under 5+ subsidiary FEINs. Distributing filings across legal entities may affect per-entity H-1B dependency calculations.
Methodology
Groups PERM filings by parent entity (via parent_employer_id or name normalization) and counts distinct FEINs used. Severity: critical (10+ FEINs), high (7+), signal (5+).
Data sources
- PERM filings (DOL disclosure data, FEIN field)
- Employer entity resolution (Hire4Real matching)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Work location vs filing location wage differential
immigration
PERM filings list a worksite in a different state than the employer's primary address on a substantial fraction of filings. Prevailing-wage determinations are computed for the worksite metro; the gap between metro-area wage levels can be 40-60% for the same role. The data does not establish that the prevailing-wage determination was inappropriate; remote work, multi-site employers, and out-of-state expansion all produce the same observable pattern.
Methodology
Counts perm_filings per employer where employer_state and worksite_state are both populated and differ. Volume gate: total filings >= 20 (suppresses small-employer noise). Severity: high = mismatch > 50% AND mismatched filings > 50; signal = mismatch > 30% AND mismatched filings > 20. The headline reports the most common remote worksite state (via mode() WITHIN GROUP).
Data sources
- DOL OFLC PERM filings (perm_filings, employer_state + worksite_state)
- BLS area wage data (referenced for prevailing-wage context; not joined directly)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Worksite geographic cost migration
immigration
Employer PERM filing worksites shift from high-wage states to lower-wage states over time, accompanied by a decrease in average prevailing wage.
Methodology
Compares primary worksite state and average prevailing wage between pre-2021 and 2022+ filing periods. Flags when primary state changes AND average prevailing wage decreases by >$10k. Severity: critical (>$30k drop, 20+ filings), high (>$20k, 10+), signal (>$10k, 5+).
Data sources
- PERM filings (DOL disclosure data, worksite and prevailing wage fields)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Concurrent layoff and recruitment gap
immigration
Employer reports layoffs in area of intended employment on ETA-9089 while simultaneously filing PERM applications.
Methodology
Flags employers where LAYOFF_IN_AREA_OF_EMPLOYMENT=Yes rate exceeds thresholds. Severity based on rate and volume.
Data sources
- PERM filings (ETA-9089 Section I layoff disclosure)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
LCA-to-visa realization gap
immigration
Employer files many LCA applications but few result in actual USCIS H-1B petition decisions.
Methodology
Compares certified LCA count (DOL OFLC) against total USCIS H-1B petition decisions (initial approvals + denials). Realization rate = USCIS decisions / certified LCAs. Rate below 10% flagged as speculative flooding; below 25% as low realization.
Data sources
- DOL OFLC LCA Disclosure Data
- USCIS H-1B Employer Data Hub
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Minimal recruitment method selection
immigration
Employer consistently selects bare-minimum optional recruitment methods on ETA-9089 Section I.
Methodology
Groups employers by recruitment method combination. Flags when bare-minimum (<=2 methods) rate exceeds 60%.
Data sources
- PERM filings (ETA-9089 Section I items 13-22)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Senior title with entry-level requirements
immigration
PERM filings with senior-level job titles (Senior, Lead, Principal) but entry-level requirements: <=24 months experience, Bachelor only, Level I prevailing wage.
Methodology
Identifies filings where job_title matches senior keywords AND experience_months <= 24 AND education = Bachelors AND pw_wage_level = Level I. Calculates mismatch rate per employer. Severity: critical (20+ mismatches, >50% rate), high (10+, >30%), signal (3+).
Data sources
- PERM filings (DOL disclosure data, job title, experience, education, wage level fields)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Elevated denial rate
immigration
The government rejects this company's applications much more often than similar companies.
Methodology
deny_rate = denied / (certified + denied) * 100. Compared against industry NAICS 2-digit P90.
Data sources
- PERM filings (case_status)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Restrictive job requirements
immigration
Employer systematically rejects alternative fields of study and alternative experience combinations on ETA-9089, narrowing the applicant pool to match the sponsored worker profile.
Methodology
Flags employers where ACCEPT_ALT_FIELD=No AND ACCEPT_ALT_COMBINATION=No on >40% of filings. Severity: critical (>80%, >=20 filings), high (>60%, >=10), signal (>40%, >=5).
Data sources
- PERM filings (ETA-9089 Section H fields)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Micro-employer high filing volume
immigration
Employer reports very few employees (1-2) on ETA-9089 but files multiple PERM applications, suggesting the entity may exist primarily to sponsor visa workers.
Methodology
Flags employers where EMPLOYER_NUM_EMPLOYEES <= 2 AND perm_count >= 3. Severity: critical (10+ PERMs), high (5+), signal (3+).
Data sources
- PERM filings (EMPLOYER_NUM_EMPLOYEES, ETA-9089 Section D)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Staffing intermediary placement pattern
immigration
Staffing or consulting firm files PERM applications where the worksite is consistently different from the employer address, indicating worker placement at client sites.
Methodology
Identifies employers with staffing-related name keywords where worksite city/state differs from employer city/state. Flags when off-site rate exceeds 40%. Severity: critical (>80%, 50+ filings), high (>60%, 20+), signal (>40%, 10+).
Data sources
- PERM filings (DOL disclosure data, employer and worksite address fields)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Recruitment timing concentration
immigration
Employer compresses all recruitment activities into a near-identical timeline across many filings.
Methodology
Measures std dev of (first_ad_start_date - swa_job_order_start_date). Severity: critical (<2 days, 100+ filings), high (<3 days, 50+), signal (<5 days, 20+).
Data sources
- PERM filings (ETA-9089 SWA and advertisement dates)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Quarterly filing concentration
immigration
Employer concentrates filings in specific quarters, particularly Q2 (April-June) aligned with H-1B cap dates.
Methodology
concentration_ratio = max_quarter / avg_quarter. Critical: >4x in Q2. High: >2.5x in Q2.
Data sources
- PERM quarterly
- LCA quarterly
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Wage level concentration
immigration
Most workers at this company are offered the lowest pay the law allows for their job.
Methodology
Level I is the 17th percentile of BLS OEWS wage distribution (per INA Sec.212(p) and H-1B Visa Reform Act of 2004). The DOL NPWC assigns wage levels via a rigid 5-step point system evaluating experience, education, special skills, and supervisory duties against O*NET Job Zone baselines. A legitimate Level I filing occurs when job requirements fall within the lower SVP range for the SOC code. This pattern flags employers whose Level I percentage exceeds the 90th percentile for their industry. NOTE: Title inflation is common — "Senior Engineer" at Level I is legitimate when minimum requirements are Bachelor's + 2 years, which scores 0 points in the NPWC evaluation. NOTE: The 2026 DOL NPRM proposes raising Level I from the 17th to the 34th percentile. Historical filings reflect the 17th percentile framework.
Data sources
- PERM filings (pw_level_9089)
- BLS OEWS (baseline percentiles)
- O*NET Job Zone SVP ranges
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Wage level downshift over time
immigration
Employer PERM filings show a significant increase in Level I (entry-level) prevailing wage designations over a multi-year period while higher-level designations decrease.
Methodology
Compares Level I percentage in pre-2021 filings vs 2022+ filings. Flags when Level I share increases by >20 percentage points. Severity: critical (>40pp delta, 20+ recent filings), high (>30pp, 10+), signal (>20pp, 5+).
Data sources
- PERM filings (DOL disclosure data, prevailing wage level field)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Workplace safety record with high visa-dependent workforce
safety
Employer's denormalized OSHA safety facts (worker fatalities, severe-injury reports, total reportable cases from ITA Form 300A annual summaries) co-occur with substantial H-1B/H-2B filing volume. Visa-tied workers face barriers to reporting workplace safety concerns; the data does not establish that the employer exploited this dynamic. Sector mix (construction, food processing, manufacturing) drives both safety incidents and visa sponsorship at high baseline rates.
Methodology
Reads denormalized columns on the employers table populated by NIGHT_42 OSHA ingestion: osha_fatality_count, osha_severe_injury_count, osha_total_cases (ITA Form 300A reportable cases), osha_ita_filing_count. Plan-named columns (osha_inspection_count, osha_violation_count, osha_total_penalties) are not present in the live schema; the detector uses the closest analogs with documented tier mapping. Severity: critical = fatality_count > 0 AND total_lca_count > 100; high = severe_injury_count > 10 AND total_lca_count > 200; signal = total_cases > 5 AND total_lca_count > 100.
Data sources
- OSHA ITA Form 300A annual summaries (osha_ita_300a)
- OSHA Severe Injury Reports (osha_severe_injuries)
- DOL OFLC LCA filings (employers.total_lca_count)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Continued filing after wage enforcement action
safety
DOL Wage & Hour Division enforcement actions found H-1B wage underpayments at the employer, and DOL OFLC subsequently certified additional H-1B LCA applications for the same employer. The two DOL branches operate independently; the data does not establish that OFLC was aware of the WHD findings or that the certifications were improperly granted.
Methodology
Per-employer aggregation of whd_violations where h1b_back_wages > 0, joined to lca_quarterly on employer_id. post_violation_lcas counts filing_count from quarters whose start date is after the latest findings_end_date for the employer. Severity: critical = back wages > $500K AND post-violation LCAs > 500; high = back wages > $100K AND post-violation LCAs > 100; signal = any back wages AND post-violation LCAs > 50.
Data sources
- DOL Wage & Hour Division enforcement (whd_violations, h1b_back_wages)
- DOL OFLC LCA quarterly filings (lca_quarterly)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Filing name variation with performance delta
structural
Employer has filed PERM applications under multiple legal-name variations (linked by the same entity_id / FEIN), with measurably different denial rates across name variations.
Methodology
Per (employer_id, employer_name) deny rate computed from perm_filings (>=10 decided cases per name). delta = max(deny_rate) - min(deny_rate). Critical: delta > 25 pp AND >=3 names. High: delta > 15 pp. Signal: delta > 10 pp AND >=3 names.
Data sources
- PERM filings
- FEIN-grouped employer entities
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Accelerating filing volume
temporal
Employer immigration filing volume is increasing at an accelerating rate over multiple consecutive periods.
Methodology
Year-over-year filing volume growth rate per fiscal year. Flagged when 3+ consecutive years show >50% YoY growth. Severity: critical if peak YoY > 300% AND >=4 accelerating years; high if peak > 150% AND >=3; signal if peak > 50% AND >=3. Volume gate: latest year >=20 filings. Note: operates at annual granularity (plan specified quarterly; perm_quarterly fiscal_quarter is uniformly 0).
Data sources
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Industry filing share change
temporal
An industry sector's share of total national PERM filing volume has changed significantly between the prior 3-year window (2020-2022) and the recent 3-year window (2023-2025).
Methodology
share_change_ratio = (industry_recent / total_recent) / (industry_prior / total_prior). Flagged when ratio > 1.5 or < 0.7. Volume gate: 100+ filings in either window. Output stored in industry_patterns (industry-level, not employer-level).
Data sources
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Layoff-outsource-recruit pipeline
temporal
Employer had mass layoffs (WARN), DOL certified jobs shifted abroad (TAA), then filed green card applications for workers from the same country the jobs shifted to.
Methodology
Identifies employers where: (1) WARN Act notice for mass layoff, (2) TAA petition certified with shift to Country X, and (3) PERM filings for workers from Country X within a 3-year window. All three data points are from separate DOL/government sources.
Data sources
- WARN Act notices
- TAA petition decisions (DOL ETA)
- PERM filings (DOL OFLC)
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Post-layoff filing increase
temporal
This company laid off workers and then applied for new temporary work visas shortly after.
Methodology
Replacement ratio = sum(filings in 2 post-WARN years) / workers laid off * 100. Spike multiplier = max(annual filings post-WARN) / 4-year pre-WARN average. Critical: ratio > 50% AND spike > 3x. High: ratio > 25% OR spike > 2x. Signal: ratio > 10% OR spike > 1.5x. False-positive filters: organic growth (>20% YoY pre-WARN), seasonal floor (1.5x). Note: operates at annual granularity until perm_quarterly fiscal_quarter ingestion lands.
Data sources
- WARN events
- PERM annual filings
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.
Layoffs alongside visa applications
workforce_reduction
WARN Act layoff notice within 90 days of LCA visa applications
Methodology
For each WARN notice with 100 or more workers affected, count LCA filings by the same employer in the +/- 90 day window around the notice date. Trigger when the LCA count exceeds 50 (high) or 200 (critical).
Data sources
- DOL OFLC LCA
- State WARN Act notices
Filing patterns are statistical observations derived from public U.S. Department of Labor records. They do not constitute accusations of wrongdoing. Wage levels are determined by the DOL's rigid 5-step NPWC evaluation process based on O*NET Job Zone requirements. Use this information to inform your own due diligence.