H-1B Third-Party Placement: Client Sites and LCAs

Updated 2026-10-213 min readNot legal advice in W X

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Yes, an H-1B employer can place you at a client site. It must meet USCIS rules for third-party placement and DOL rules for each worksite. The rules changed on January 17, 2025, when a DHS modernization rule took effect.

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When you count as staffed to a third party

Under 8 CFR 214.2, you are staffed to a third party when you fill a position in that company's organizational hierarchy.

Merely providing services to the client does not count. In that case, your employer's requirements govern the role.

When you are staffed, USCIS looks at the third party's requirements, not your employer's, to decide whether the job is a specialty occupation.

Itineraries are no longer required

Before 2025, petitions for offsite work had to include an itinerary. The modernization rule eliminated that requirement.

Instead, the employer must show a bona fide specialty occupation position available as of the requested start date.

The rule also says the employer need not prove specific day-to-day assignments for the whole petition period.

USCIS may still request contracts, work orders or similar evidence between all parties. These can show the role is real and its degree requirements.

Top H-1B sponsors, 2025US Department of Labor data

Employer	H-1B filings	Transfers	Median pay
Amazon.Com Services LLC	14,047	2,382	$155k
Cognizant Technology Solutions US CorpGC frozen	10,209	872	$110k
Ernst & Young U.S. LLP	9,808	269	$143k
Google LLC	7,899	844	$186k
Microsoft CorporationGC frozen	7,840	879	$173k
Tata Consultancy Services LimitedGC frozen	7,287	353	$86k

Every sponsor, with their open jobsSee the list ›

LCAs at the client site

DOL defines the place of employment as where you actually do the work. Generally, an LCA must be on file for each place of employment.

The LCA sets the prevailing wage for that worksite. Notice must also be posted at each worksite.

LCA data has a SECONDARY_ENTITY field. It shows whether workers will be placed with another company and names that company.

When a move needs a new filing

A move to a new area that needs a new LCA is a material change. Your employer must file an amended or new petition before you start there.

A move within the same area of intended employment on your current LCA does not need an amended petition, if nothing else materially changes.

Short assignments have an exception. DOL's short-term placement option allows up to 30 workdays in a year at an unlisted area.

That can extend to 60 workdays if you keep ties to your home worksite. The employer must pay lodging, travel and meals for those days.

Short visits and remote work

Brief travel is treated differently. DOL says short visits for a job function are not a new worksite in some cases.

Those visits can last up to five consecutive workdays for frequent travelers, or ten for occasional travelers.

Remote work is allowed. The regulation's definition of US employer includes a job offer for telework, remote work or other off-site work in the US.

But a remote worker who moves to a new area that needs a new LCA triggers a material change. The employer must file before the move.

Site visits

USCIS can inspect worksites, including third-party client sites. It may interview officials and review records.

If USCIS cannot verify facts because the employer or client refuses to cooperate, it may deny or revoke the petition.

Know your job duties, worksite and manager. Your answers should match the petition.

Pay and placement protections

Your employer must pay the required wage for your worksite, even when you sit idle between client projects for its reasons.

If the employer is H-1B dependent, it must ask the client about US worker displacement before placing you.

STEM OPT at a staffing or consulting firm

STEM OPT has stricter rules than H-1B. USCIS says staffing agencies and consulting firms may employ STEM OPT students, but only if they meet the program's conditions.

The employer must have a real employer-employee relationship with you and be enrolled in E-Verify. It must provide the training in your Form I-983 plan itself.

Work at a client site is allowed if the employer still meets every training duty. It cannot hand your training to the client, and the client's staff cannot be your trainers.

USCIS warns that labor-for-hire arrangements may not show a real employer-employee relationship. Its STEM OPT page does not mention PEOs, so ask your school's DSO before accepting that setup.

Checking a placement employer

Public filings show which employers place workers at client sites and at what pay. Compare them on our H-1B sponsors list.

A past H-1B filing doesn't guarantee an employer will sponsor a given role. Ask about the specific client and location.

Contract roles carry their own risks. See H-1B C2C and contract jobs. If you plan to switch to a direct employer, see H-1B transfer.

This article is general information, not legal advice. Confirm your situation with an immigration attorney.

Questions

Is an itinerary still required for H-1B client-site work?

No. The modernization rule effective January 17, 2025 eliminated it. USCIS may still ask for contracts or work orders.

Whose requirements decide if a client-site job is a specialty occupation?

If you are staffed to the client, USCIS looks at the client's requirements, not your employer's.

Does moving to a new client need a new petition?

If the new site is outside the area on your LCA and needs a new LCA, an amended or new petition is required first.

Can USCIS visit my client's office?

Yes. USCIS can inspect third-party worksites. Refusal to cooperate can lead to denial or revocation.

Can I work for a staffing agency or consultancy on STEM OPT?

Yes, if the agency is enrolled in E-Verify, has a real employer-employee relationship with you, and provides your training itself. It cannot delegate training to a client, and labor-for-hire setups may not qualify.