INTRODUCTION
Business Roundtable is an association of more than 200 chief executive officers of leading U.S. companies working to promote sound public policy and a thriving U.S. economy. Business Roundtable member companies employ nearly 15 million people; produce more than $7 trillion in annual revenues; invest nearly $147 billion annually in research and development; pay nearly $296 billion in dividends to shareholders; and generate more than $488 billion in sales for small and medium-sized businesses annually. Business Roundtable companies also make more than $8 billion a year in charitable contributions.
Business Roundtable appreciates the opportunity to comment on the U.S. Department of Homeland Security’s (DHS) proposed regulation, “Registration Requirement for Petitioners Seeking To File H-1B Petitions on Behalf of Cap-Subject Aliens.” Business Roundtable welcomes U.S. Citizenship and Immigration Services (USCIS) efforts to find ways to increase efficiency and optimize resources for both the agency and companies. At the same time, Business Roundtable believes that the USCIS should make certain that its H-1B lottery reforms are consistent with implementation of the agency’s Electronic Immigration System (ELIS). The Roundtable also requests that the agency undertake additional testing and stakeholder engagement before introducing these reforms. Further detail and recommendations follow.