The DOL has been issuing Audits for PERM cases where the work location is listed as the company headquarters and client sites.
The following questions and answers can be used to formulate the response to the PERM Audit.
Question #1: Is the employee permitted and/or expected to perform the job duties of the job opportunity listed on the ETA Form 9089 from his residence and/or place of his/her choosing?
Answer: No. The employee must be able to move to the client site. That is the reason we entered “and client sites” in the work location.
Question #2: Is the employee permitted and/or expected to perform the job duties of the job opportunity from some place other than the employer’s headquarters or the worksite listed on the ETA Form 9089?
Answer: No.
Question #3: Will the employer be expected to work at multiple worksites in this job?
Answer: Yes. That is the reason we entered “and client sites” in the work location.