Comment from Institute for Progress

Summary: The authors, Connor O’Brien, Jeremy Neufeld, and Amy Nice, argue that the Department of Labor's primary proposal (Blind Benchmarking) fails to prevent wage arbitrage and incorrectly classifies many H-1B workers. They strongly advocate for the Department's alternative proposal, Experience Benchmarking, which they argue would accurately protect American workers by anchoring wages to the actual earnings of similarly qualified native-born workers.