PERM AUDIT FILE CHECKLIST

• ETA Form 9089 copy (filed version).
• Prevailing Wage Determination (PWD) and O*NET/SOC code used.
• Recruitment steps (professional vs. non-professional):
• Two Sunday newspaper ads (copies + tear sheets/invoices).
• State Workforce Agency (SWA) job order (printout with dates).
• Internal posting/notice of filing (ten business days) with dates and posting locations.
• Three additional professional recruitment steps (if required): [e.g., employer website, job search site, campus recruitment, trade journal, employee referral program with incentives, radio/TV, private employment firm].
• Recruitment report summarizing results, lawful reasons for rejection, and signatory.
• Evidence of business necessity (if applicable) for special requirements.
• Resume log and copies of resumes received; interview notes.
• Notice to bargaining representative or, if none, evidence of in-house posting to employees.
• Employer financials (if ability to pay may be questioned).
• Audit-response cover letter template and contact info.
• PERM filing confirmation, PERM account screenshots (if online).
• Copies of any prior audit responses or supervised recruitment correspondence (if relevant).
• FEIN verification responses (if obtained).
• For roving positions/telecommuting: geographic area rationale; itinerary language.
• Retention calendar tickler (5-year retention from filing date).

[// GUIDANCE: Keep the file organized and ready for DOL audit. Ensure consistency between recruitment, PWD, job duties, and minimum requirements. Document lawful rejection reasons contemporaneously.]