Comment from Economic Innovation Group
Economic Innovation GroupOpposeAdvocacy
Summary: The Economic Innovation Group (EIG) opposes the Department's primary proposal for "Blind Benchmarking" because it fails to account for worker credentials and could increase the use of H-1B visas by IT outsourcing firms. They instead advocate for "Experience Benchmarking," arguing it is more economically grounded, legally consistent with the INA, and less administratively burdensome.
Dear Sir or Madam,
The Economic Innovation Group (EIG) is a bipartisan public policy organization dedicated to forging a more dynamic and entrepreneurial American economy. We thank you for the opportunity to submit comments on the proposed rule “Improving Wage Protections for the Temporary and Permanent Employment of Certain Foreign Nationals in the United States.”
Our public comment consists of two letters outlining why Experience Benchmarking is a preferable alternative to the Department’s primary proposal. The first attachment explains why Experience Benchmarking is stronger than the primary proposal on legal and implementation grounds. This document also provides guidance for the Department on how to implement Experience Benchmarking.
The second attachment assesses the multiple methodological and conceptual issues behind the proposed rule and explains why Experience Benchmarking is the more favorable alternative on economic grounds.
We look forward to your response and the opportunity to work with you on this rulemaking.