USDOL H-2A and H-2B Programs

Comparing Application Filing Requirements

H-2A and H-2B application filing requirements comparison graphic

General Filing Tips & Issues

  • Ensure all required fields on the ETA-9142A/B are completed prior to submission
  • Review your application package carefully and ensure all required documents are included or uploaded electronically
    • Use a “checklist cover sheet” that identifies all items submitted for processing with your application package
    • For more efficient processing, upload separate electronic documents for each document type (e.g., job order, agent agreement) rather than one large file
  • Provide legible copies of supporting documentation — this is a particular problem with contractor documents (e.g., FLC registrations, H-2A surety bonds)
  • Try to file your job order and application as early as the regulatory timeframes permit
  • In H-2B, employer must have a valid prevailing wage determination issued by the NPWC; otherwise application will be rejected
  • Make sure the dates of need, number of workers being requested for certification, and worksite locations match between the job order and Form ETA-9142A/B
  • If using a template to submit applications and the CO issues a Notice of Deficiency (NOD), employers must amend the template to avoid repeating the same NOD for each application
  • Ensure the size of workforce and period of employment (start and end dates) represents a bona fide business need
  • Requesting a start date of work based on “expected government delays” is not acceptable
  • Changes to the period of employment (especially more than 2 weeks) must include an explanation and may require supporting documents
  • In H-2B, job contractors must demonstrate their OWN temporary need, not just the employer-client’s need, and must file based on seasonal or one-time occurrence

H-2A Agricultural Program Application Filing Checklist (non-emergency situation)

Employer will submit the following documents:

  • ETA 9142A
  • Appendix A - signed and dated
  • Itinerary of worksites (if applicable)
  • Workers compensation coverage
  • SWA housing inspection report(s) or documentation showing housing meets standards
  • Agent agreement/documentation demonstrating authority to represent the employer and MSPA registration (if applicable)

Additional documentation for H-2A labor contractors:

  • Name and location of each fixed-site employer, expected work dates, and crop/activity description
  • Copy of fully executed work contracts with each fixed-site employer
  • Copy of MSPA FLC Certificate of Registration (if required)
  • Proof of financial ability via an original surety bond document
  • Where housing or transportation is provided, proof that:
    • Housing meets applicable standards and is SWA-certified
    • Transportation complies with federal, state, and local laws

Filing Tips for H-2A Labor Contractors

H-2A Labor Contractors must:

  • Organize housing and transportation well in advance
  • Provide documentation that housing meets local, state, or federal standards
  • Prepare for time needed to obtain or renew FLC documents
  • Ensure all worksites are within the same area of intended employment
  • Applications covering multiple employment areas will not be accepted
 
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