PERM Audit File Checklist and Preparation Guide

PERM AUDIT FILE CHECKLIST AND PREPARATION GUIDE

Employer: [________________________________]

Beneficiary Name: [________________________________]

Case Number: [________________________________]

Priority Date: [__/__/____]

Job Title: [________________________________]

SOC Code: [________________________________]

Filing Date: [__/__/____]

Prepared By: [________________________________]

SECTION 1: PRE-FILING DOCUMENTATION CHECKLIST

1.1 Prevailing Wage Determination (PWD)

☐ Original PWD from National Prevailing Wage Center (NPWC)

☐ PWD tracking number: [________________________________]

☐ PWD issue date: [__/__/____]

☐ PWD expiration date: [__/__/____]

☐ Wage level determination (I, II, III, or IV): [____]

☐ Prevailing wage amount: $[________________________________] per [____]

☐ SOC/O*NET code matches job duties: [________________________________]

☐ Geographic area of employment verified: [________________________________]

PWD Validity Notes: The PWD must be valid at the time of filing. PWDs are valid for 90 days to 1 year from determination date, depending on the prevailing wage source. Verify the PWD has not expired before filing and that the offered wage meets or exceeds the prevailing wage.

1.2 Job Requirements Documentation

☐ Written job description with essential duties

☐ Minimum education requirement: [________________________________]

☐ Minimum experience requirement: [________________________________]

☐ Any special skills or certifications: [________________________________]

☐ Travel requirements (if any): [________________________________]

☐ Supervisory responsibilities (if any): [________________________________]

☐ O*NET Job Zone level verified (SVP level): [____]

Requirements Verification:

• ☐ Requirements do not exceed SVP level for the occupation (or business necessity documented)
• ☐ Requirements are normal for the occupation in the industry
• ☐ Requirements are not tailored to the beneficiary's qualifications
• ☐ Beneficiary did not gain qualifying experience with the sponsoring employer (or exception applies)

1.3 Employer Documentation

☐ Federal Employer Identification Number (FEIN): [________________________________]

☐ Employer address matches PERM application: [________________________________]

☐ Number of employees: [________________________________]

☐ Year business established: [________________________________]

☐ Business structure verification (corporation, LLC, etc.): [________________________________]

☐ Annual gross revenue or financial statements (if ability to pay questioned)

☐ Corporate tax returns (if needed for ability to pay)

☐ Verification of no recent layoffs in same occupation within 6 months

☐ Strike/lockout verification (none in same or related occupation)

1.4 Beneficiary Qualifications

☐ Copy of beneficiary's resume

☐ Educational credentials and transcripts

☐ Credential evaluation (if foreign degree)

☐ Employment verification letters from prior employers

☐ Professional licenses or certifications (if required)

☐ Evidence beneficiary meets minimum requirements as of priority date

☐ Disclosure of any ownership interest in employer: ☐ Yes ☐ No

☐ Disclosure of any familial relationship with employer: ☐ Yes ☐ No

SECTION 2: RECRUITMENT DOCUMENTATION (All 10 Steps)

Recruitment Period Start Date: [__/__/____]

Recruitment Period End Date: [__/__/____]

PERM Filing Date: [__/__/____]

TIMING REQUIREMENTS

Per 20 CFR 656.17(e), recruitment must be conducted according to specific timing rules:

• Mandatory Steps (Job Order and Newspaper Ads): Must be completed at least 30 days, but no more than 180 days, before filing
• Additional Professional Steps: At least two must be completed more than 30 days before filing; only one may be completed within 30 days of filing
• Notice of Filing: Must be posted for 10 consecutive business days, completed between 30 and 180 days before filing

2.1 MANDATORY STEP 1: State Workforce Agency (SWA) Job Order

Regulatory Requirement: 20 CFR 656.17(e)(1)(i) - Placement of a job order with the SWA serving the area of intended employment for a period of 30 days.

☐ Job order placed with SWA

SWA Name: [________________________________]

Job Order Number: [________________________________]

Job Order Start Date: [__/__/____]

Job Order End Date: [__/__/____] (must be at least 30 days)

Documentation Required:
☐ Printout of job order confirmation from SWA
☐ Screenshot showing job order with dates visible
☐ Confirmation of 30-day posting period
☐ Documentation that job order was active and viewable by public

Content Verification:
☐ Job title matches ETA Form 9089
☐ Job duties match ETA Form 9089
☐ Wage offered meets or exceeds prevailing wage
☐ Job location/geographic area correct
☐ Application instructions clear

2.2 MANDATORY STEP 2: Two Sunday Newspaper Advertisements

Regulatory Requirement: 20 CFR 656.17(e)(1)(ii) - Placement of two print advertisements on two different Sundays in the newspaper of general circulation in the area of intended employment most appropriate to the occupation and the workers likely to apply for the job opportunity.

First Sunday Advertisement

☐ First Sunday ad placed

Newspaper Name: [________________________________]

Publication Date: [__/__/____] (must be Sunday)

Ad Placement Confirmation Number: [________________________________]

Documentation Required:
☐ Original tear sheet or full newspaper page showing ad
☐ Proof of publication from newspaper (affidavit or invoice)
☐ Invoice showing publication date and newspaper name
☐ Electronic tearsheet (if newspaper offers)

Second Sunday Advertisement

☐ Second Sunday ad placed

Newspaper Name: [________________________________]

Publication Date: [__/__/____] (must be Sunday, different from first)

Ad Placement Confirmation Number: [________________________________]

Documentation Required:
☐ Original tear sheet or full newspaper page showing ad
☐ Proof of publication from newspaper (affidavit or invoice)
☐ Invoice showing publication date and newspaper name
☐ Electronic tearsheet (if newspaper offers)

Advertisement Content Verification (Both Ads Must Include):
☐ Name of employer
☐ Direction to report or send resumes to employer
☐ Description of vacancy specific enough to apprise U.S. workers of job opportunity
☐ Geographic area of employment with sufficient specificity
☐ Wage rate not lower than prevailing wage (or silent on wage)
☐ Job requirements do not exceed those on ETA Form 9089
☐ Terms and conditions not less favorable than those offered to beneficiary

Note for Professional Occupations: If the job requires experience and an advanced degree, a professional journal may substitute for one Sunday newspaper ad per 20 CFR 656.17(e)(1)(ii)(B).

2.3 MANDATORY STEP 3: Notice of Filing / Internal Posting

Regulatory Requirement: 20 CFR 656.10(d) - Employer must provide notice of filing to bargaining representative or post notice for employees.

☐ Notice of Filing posted/provided

Method Used:
☐ Posted notice to employees (no bargaining representative)
☐ Notice to bargaining representative

Posting Start Date: [__/__/____]

Posting End Date: [__/__/____] (minimum 10 consecutive business days)

Posting Location(s):
☐ [________________________________]
☐ [________________________________]
☐ [________________________________]

Documentation Required:
☐ Copy of the posted notice
☐ Signed statement from employer confirming posting dates and locations
☐ Photographs of posted notice in location (recommended)
☐ If bargaining representative: copy of letter sent and proof of delivery

Notice Content Requirements (Must Include):
☐ Statement that application is being filed for permanent alien labor certification
☐ Statement that any person may provide documentary evidence to Certifying Officer
☐ Address of appropriate Certifying Officer
☐ Job title and duties
☐ Job location
☐ Rate of pay
☐ Application instructions

2.4 PROFESSIONAL RECRUITMENT: Three Additional Steps Required

Regulatory Requirement: 20 CFR 656.17(e)(1)(ii) - For professional occupations, employers must select three additional recruitment steps from the following list of ten options. At least two of these steps must be completed more than 30 days before filing.

Important Rules:

• Cannot "double count" any recruitment method
• Only ONE additional step may consist solely of activity within 30 days of filing
• All steps must be within 180 days of filing

OPTION 1: Job Fair Recruitment

☐ Job fair attended

Job Fair Name: [________________________________]

Job Fair Date: [__/__/____]

Location: [________________________________]

Documentation Required:
☐ Brochure or advertisement for the job fair
☐ Newspaper advertisement naming employer as participant
☐ Employer booth/table registration confirmation
☐ Photos of booth or participation (recommended)
☐ List of job fair attendees who expressed interest (if available)
☐ Copies of materials distributed at job fair

OPTION 2: Employer's Website Posting

☐ Employer website posting completed

Website URL: [________________________________]

Posting Start Date: [__/__/____]

Posting End Date: [__/__/____]

Documentation Required:
☐ Dated screenshot of job posting showing URL and date
☐ Printout of careers page showing posting
☐ Web archive link (Wayback Machine) if available
☐ IT department certification of posting dates (recommended)

Content Verification:
☐ Job posting content matches ETA Form 9089
☐ Application instructions included
☐ Dates visible in screenshot or documented

OPTION 3: Third-Party Job Search Website

☐ Third-party job website posting completed

Website Name: [________________________________] (e.g., Indeed, LinkedIn, Monster, CareerBuilder)

Posting Start Date: [__/__/____]

Posting End Date: [__/__/____]

Posting/Reference Number: [________________________________]

Documentation Required:
☐ Dated screenshot of job posting showing website name and date
☐ Invoice or receipt from job website
☐ Confirmation email of posting
☐ Printout of posting with date stamp

OPTION 4: On-Campus Recruiting

☐ On-campus recruiting conducted

University/College Name: [________________________________]

Campus Career Center Contact: [________________________________]

Date of Campus Recruitment: [__/__/____]

Documentation Required:
☐ Letter to campus placement office requesting posting
☐ Confirmation from campus career services
☐ Copy of job posting provided to campus
☐ Evidence of campus visit or career fair participation (if applicable)
☐ List of candidates referred by campus (if any)

Note: Campus placement offices may be used even if the position requires experience, as alumni with experience also use these services.

OPTION 5: Trade or Professional Organization

☐ Trade/professional organization posting completed

Organization Name: [________________________________]

Publication/Newsletter Name (if applicable): [________________________________]

Posting/Publication Date: [__/__/____]

Documentation Required:
☐ Copy of newsletter or trade journal pages containing advertisement
☐ Confirmation of posting from organization
☐ Invoice for advertisement placement
☐ Screenshot of online posting (if electronic)
☐ Membership verification (if required by organization)

OPTION 6: Private Employment Firm / Recruiter

☐ Private employment firm engaged

Firm/Recruiter Name: [________________________________]

Contact Person: [________________________________]

Date Engaged: [__/__/____]

Documentation Required:
☐ Contract or engagement letter with employment firm
☐ Invoice for services
☐ Correspondence showing recruitment activities
☐ List of candidates referred by firm
☐ Evidence of firm's active recruitment efforts

OPTION 7: Employee Referral Program with Incentives

☐ Employee referral program conducted

Program Announcement Date: [__/__/____]

Incentive Offered: [________________________________] (e.g., cash bonus, extra vacation days)

Documentation Required:
☐ Copy of company-wide email or notice announcing referral program
☐ Description of incentive for successful referrals
☐ Evidence employees were made aware of specific job opportunity
☐ Documentation separate from Notice of Filing (Notice of Filing alone is insufficient)
☐ Policy document or HR memo describing program

Important: DOL has specifically stated that the Notice of Filing is NOT sufficient to satisfy this recruitment step. A separate communication must be made to employees about the referral program and incentive.

OPTION 8: Campus Placement Offices (Separate from On-Campus Recruiting)

☐ Campus placement office notification sent

University/College Name: [________________________________]

Career Services Contact: [________________________________]

Date Contacted: [__/__/____]

Documentation Required:
☐ Copy of letter or email to campus placement office
☐ Copy of job posting provided
☐ Confirmation of receipt from career services
☐ Evidence posting was listed (screenshot or confirmation)

OPTION 9: Local and/or Ethnic Newspapers

☐ Local/ethnic newspaper advertisement placed

Newspaper Name: [________________________________]

Publication Type: ☐ Local ☐ Ethnic

Publication Date: [__/__/____]

Documentation Required:
☐ Tear sheet or copy of newspaper page with advertisement
☐ Proof of publication
☐ Invoice showing publication date
☐ Circulation information for newspaper

Note: This is separate from the mandatory Sunday newspaper advertisements and must be in addition to those requirements.

OPTION 10: Radio and/or Television Advertisements

☐ Radio/TV advertisement aired

Station Name: [________________________________]

Station Call Letters: [________________________________]

Broadcast Dates: [__/__/____] to [__/__/____]

Time Slots: [________________________________]

Documentation Required:
☐ Script of advertisement
☐ Written confirmation from station of broadcast
☐ Invoice showing dates and times of broadcast
☐ Station affidavit confirming airings
☐ Recording of advertisement (if available)

2.5 Summary of Additional Recruitment Steps Used

Step 1 Used: [________________________________]

• Date Completed: [__/__/____]
• ☐ More than 30 days before filing
• ☐ Within 30 days of filing

Step 2 Used: [________________________________]

• Date Completed: [__/__/____]
• ☐ More than 30 days before filing
• ☐ Within 30 days of filing

Step 3 Used: [________________________________]

• Date Completed: [__/__/____]
• ☐ More than 30 days before filing
• ☐ Within 30 days of filing

Timing Compliance Verification:
☐ At least two additional steps completed more than 30 days before filing
☐ No more than one additional step completed within 30 days of filing
☐ All steps completed within 180 days of filing

SECTION 3: RECRUITMENT REPORT TEMPLATE

Regulatory Requirement: 20 CFR 656.17(g) - The employer must prepare a recruitment report signed by the employer or the employer's representative describing the recruitment steps undertaken and the results achieved.

RECRUITMENT REPORT

Date of Report: [__/__/____]

Prepared By: [________________________________]

Title: [________________________________]

A. Case Information

B. Recruitment Steps Undertaken

C. Recruitment Results

Total Number of Applicants/Resumes Received: [____]

Total Number of Applicants Interviewed: [____]

Total Number of U.S. Workers Hired for This Position: [____]

Total Number of U.S. Workers Rejected: [____]

D. Applicant Disposition Log

(Add additional rows as needed)

E. Lawful Job-Related Reasons for Rejection

Acceptable reasons for rejection include (must be documented contemporaneously):

• Did not meet minimum education requirements
• Did not meet minimum experience requirements
• Did not possess required skills or certifications
• Unable to perform essential job duties
• Failed to respond to interview request
• Withdrew application
• Did not meet special requirements (with business necessity documentation)
• Salary/wage expectations exceeded offered wage
• Unable to work required hours/schedule
• Unable to work at job location
• Not authorized to work in the United States (for U.S. worker test)

Unacceptable reasons (will result in denial):

• Overqualified
• Beneficiary is "better qualified"
• Subjective assessments not tied to stated requirements
• Requirements not listed on ETA Form 9089
• Discriminatory reasons (age, race, national origin, etc.)

F. Attestation

I, the undersigned, hereby certify that:

1. The recruitment described above was conducted in good faith;
2. The job opportunity was described without unduly restrictive requirements;
3. All U.S. workers who applied were considered fairly;
4. Any U.S. workers rejected were rejected for lawful job-related reasons documented above;
5. The offered wage meets or exceeds the prevailing wage;
6. The recruitment documentation is accurate and complete.

Signature: ________________________________

Printed Name: [________________________________]

Title: [________________________________]

Date: [__/__/____]

SECTION 4: TIMING REQUIREMENTS AND DEADLINES

4.1 Critical Deadline Calendar

4.2 30-Day Recruitment Period Calendar

Start Date: [__/__/____]

End Date: [__/__/____]

Use this calendar to track your 30-day SWA job order posting period:

4.3 180-Day Filing Window Calendar

Recruitment Start (Earliest): [__/__/____]

Filing Deadline (180 days from earliest recruitment): [__/__/____]

30-Day Pre-Filing Cutoff: [__/__/____]

SECTION 5: BUSINESS NECESSITY DOCUMENTATION

Regulatory Requirement: 20 CFR 656.17(h) - Job requirements that exceed the normal requirements for the occupation or the SVP level assigned to the occupation require documentation of business necessity.

5.1 Business Necessity Checklist

☐ Review job requirements against O*NET SVP levels

☐ Identify any requirements that may trigger business necessity:

• ☐ Education exceeding O*NET Job Zone level
• ☐ Experience exceeding normal for occupation
• ☐ Foreign language requirement
• ☐ Travel requirements
• ☐ Specific certifications beyond industry standard
• ☐ Combination occupation duties
• ☐ Other specialized requirements

5.2 Business Necessity Memorandum Template

Date: [__/__/____]

Re: Business Necessity Documentation for [Job Title]

Case: [Beneficiary Name] / [Case Number]

Requirement Requiring Business Necessity: [________________________________]

Standard Requirement for Occupation: [________________________________]

Business Necessity Justification:

The above requirement is essential to perform the job duties in a reasonable manner for the following reasons:

1. Nature of Employer's Business:
   [________________________________]
   [________________________________]

2. Specific Job Duties Requiring This Skill:
   [________________________________]
   [________________________________]

3. Business Context and Client/Customer Needs:
   [________________________________]
   [________________________________]

4. Why Alternative Requirements Are Insufficient:
   [________________________________]
   [________________________________]

Supporting Documentation Attached:

☐ Client/customer communications demonstrating need
☐ Business contracts requiring specialized skills
☐ Industry publications showing requirement is standard in employer's niche
☐ Position descriptions from similar employers
☐ Evidence of non-English speaking customer/client base (for language requirements)
☐ Prior employee records showing requirement (for combination occupations)
☐ Other: [________________________________]

Certification:

I certify that the above requirement bears a reasonable relationship to the occupation in the context of [Employer Name]'s business and is essential to perform the job in a reasonable manner.

Signature: ________________________________

Printed Name: [________________________________]

Title: [________________________________]

Date: [__/__/____]

5.3 Foreign Language Business Necessity

If the position requires a foreign language, document:

☐ Nature of Occupation: Position is inherently language-based (translator, interpreter)

OR

☐ Customer/Client Base:

• Percentage of non-English speaking customers/clients: [____]%
• Languages required: [________________________________]
• Frequency of communication in foreign language: [________________________________]
• Evidence attached: ☐ Customer demographics ☐ Sales data ☐ Communication logs

OR

☐ Employee Communication:

• Percentage of non-English speaking employees supervised: [____]%
• Languages spoken by workforce: [________________________________]
• Evidence attached: ☐ Employee records ☐ HR documentation

SECTION 6: SUPERVISED RECRUITMENT FILE ORGANIZATION

6.1 Physical File Organization

Organize the PERM audit file in the following order:

Tab 1: Case Summary
☐ This checklist (completed)
☐ Case timeline summary
☐ Contact information sheet

Tab 2: PERM Application
☐ Signed ETA Form 9089 (filed version)
☐ PERM filing confirmation
☐ FLAG account screenshots

Tab 3: Prevailing Wage
☐ Prevailing Wage Determination
☐ O*NET/SOC code printout
☐ PWD request documentation

Tab 4: Recruitment Documentation
☐ SWA job order documentation
☐ Sunday newspaper ads (tear sheets, invoices)
☐ Notice of Filing documentation
☐ Additional recruitment step documentation (3 tabs)

Tab 5: Recruitment Report
☐ Signed recruitment report
☐ Applicant disposition log
☐ All resumes received (sorted by rejection reason)
☐ Interview notes

Tab 6: Business Necessity (if applicable)
☐ Business necessity memorandum
☐ Supporting documentation

Tab 7: Beneficiary Qualifications
☐ Resume
☐ Educational credentials
☐ Experience letters
☐ Licenses/certifications

Tab 8: Employer Documentation
☐ FEIN verification
☐ Financial documents (if applicable)
☐ Layoff/strike verification

Tab 9: Correspondence
☐ DOL correspondence
☐ Audit notices and responses
☐ Attorney correspondence

6.2 Electronic File Organization

/PERM_[LastName]_[CaseNumber]/
├── 01_Case_Summary/
│   ├── Checklist.pdf
│   └── Timeline.pdf
├── 02_PERM_Application/
│   ├── ETA_9089_Signed.pdf
│   └── Filing_Confirmation.pdf
├── 03_Prevailing_Wage/
│   ├── PWD.pdf
│   └── ONET_SOC_Printout.pdf
├── 04_Recruitment/
│   ├── 4a_SWA_Job_Order/
│   ├── 4b_Sunday_Ads/
│   ├── 4c_Notice_of_Filing/
│   └── 4d_Additional_Steps/
├── 05_Recruitment_Report/
│   ├── Recruitment_Report_Signed.pdf
│   └── Resumes_Received/
├── 06_Business_Necessity/
├── 07_Beneficiary_Docs/
├── 08_Employer_Docs/
└── 09_Correspondence/

SECTION 7: AUDIT RESPONSE LETTER TEMPLATE

[Date]

U.S. Department of Labor
Employment and Training Administration
Office of Foreign Labor Certification
[Address from Audit Letter]

Re: Response to Audit Letter
Case Number: [________________________________]
Employer: [________________________________]
Beneficiary: [________________________________]
Audit Letter Date: [__/__/____]

Dear Certifying Officer:

On behalf of [Employer Name], we respectfully submit this response to the audit letter dated [Date] regarding the above-referenced PERM application. Enclosed please find the documentation requested, organized as follows:

Tab A: Recruitment Documentation

1. SWA Job Order (30-day posting)
   - Job order confirmation showing posting from [Date] to [Date]
   - See Exhibit A-1

2. Sunday Newspaper Advertisements
   - First advertisement: [Newspaper], published [Date]
   - Second advertisement: [Newspaper], published [Date]
   - Original tear sheets and proof of publication attached
   - See Exhibits A-2 and A-3

3. Notice of Filing
   - Posted from [Date] to [Date] (10 consecutive business days)
   - Posting locations: [List]
   - See Exhibit A-4

4. Additional Professional Recruitment Steps
   - [Step 1]: [Description], dated [Date] - See Exhibit A-5
   - [Step 2]: [Description], dated [Date] - See Exhibit A-6
   - [Step 3]: [Description], dated [Date] - See Exhibit A-7

Tab B: Recruitment Report

Enclosed is the signed recruitment report describing:

• All recruitment activities undertaken
• Total applicants received: [Number]
• Total U.S. workers rejected: [Number]
• Lawful job-related reasons for each rejection
• See Exhibit B-1

Tab C: Resumes and Applicant Documentation

All resumes received have been sorted by reason for rejection:

• [Reason 1]: [Number] applicants - See Exhibit C-1
• [Reason 2]: [Number] applicants - See Exhibit C-2
• [Reason 3]: [Number] applicants - See Exhibit C-3

Tab D: Business Necessity Documentation (if applicable)

[Include if special requirements were listed]

• See Exhibit D-1

Tab E: Additional Documentation

[List any additional documents requested in audit letter]

We certify that the enclosed documentation is true and accurate and demonstrates full compliance with 20 CFR 656. Should you require any additional information, please do not hesitate to contact the undersigned.

Respectfully submitted,

________________________________
[Attorney Name]
[Firm Name]
[Address]
[Phone]
[Email]
[Bar Number]

Enclosures: As noted above

cc: [Employer Contact]

SECTION 8: COMMON AUDIT TRIGGERS AND HOW TO ADDRESS THEM

8.1 Documentation Issues

8.2 Job Requirement Issues

8.3 Employer/Beneficiary Relationship Issues

8.4 Recruitment Process Issues

8.5 Random Audit Response Strategy

Even for random audits, ensure:

☐ All documentation is organized and labeled clearly
☐ Recruitment report is signed and comprehensive
☐ All timing requirements are verifiable from documents
☐ Resumes are sorted by rejection reason
☐ Response is submitted within 30-day deadline
☐ Cover letter indexes all enclosed documents

SECTION 9: RECORD RETENTION REQUIREMENTS

9.1 Retention Period

Per 20 CFR 656.10(f), employers must retain PERM documentation for five (5) years from the filing date of the Application for Permanent Employment Certification.

Filing Date: [__/__/____]

Retention End Date: [__/__/____]

9.2 Retention Checklist

☐ PERM application (ETA Form 9089) - signed copy

☐ Prevailing Wage Determination

☐ All recruitment documentation:

• ☐ SWA job order
• ☐ Newspaper advertisements
• ☐ Notice of Filing
• ☐ Additional recruitment steps

☐ Recruitment report (signed)

☐ All resumes received

☐ Interview notes and evaluation documentation

☐ Business necessity documentation (if applicable)

☐ Audit correspondence and responses (if applicable)

☐ Final determination from DOL

9.3 Retention Calendar Reminder

Set reminders for:

SECTION 10: FINAL AUDIT-READINESS VERIFICATION

Pre-Filing Checklist

☐ PWD obtained and valid
☐ Job requirements reviewed against O*NET
☐ Business necessity documented (if applicable)
☐ No layoffs in same occupation within 6 months
☐ Beneficiary qualifications verified
☐ Ownership/familial relationships disclosed

Recruitment Checklist

☐ SWA job order completed (30 days)
☐ Two Sunday newspaper ads published
☐ Notice of Filing posted (10 business days)
☐ Three additional steps completed (professional occupations)
☐ All timing requirements met
☐ All advertisements match Form 9089 content

Documentation Checklist

☐ Tear sheets/proof of publication obtained
☐ Screenshots dated and saved
☐ Recruitment report prepared and signed
☐ All resumes logged and sorted
☐ Rejection reasons documented contemporaneously
☐ File organized per Section 6

Post-Filing Checklist

☐ Filing confirmation saved
☐ 30-day audit response deadline calendared
☐ 5-year retention calendar set
☐ Client notified of audit possibility

File Prepared By: ________________________________

Date: [__/__/____]

Attorney Review: ________________________________

Date: [__/__/____]

This checklist should be reviewed and updated as DOL regulations and guidance change. Consult current DOL resources and qualified immigration counsel for the most up-to-date requirements.