The worksite is a legal coordinate, not an address field
A Labor Condition Application ties a wage obligation to a place of employment. That coordinate determines the prevailing wage, the notice requirement, and the scope of the certification. For a workflow consultancy whose engineers may sit at a client's operations center for a discovery phase and then work from the employer's own office for build and hardening, the worksite is a moving object — and each move has to be evaluated before it happens, not after.
The practical test is where the employee is actually performing work, including a client site or a home office in a different metropolitan area. Remote work does not remove the obligation; it relocates it. A consultant who moves residence across an area of intended employment may require a new or amended filing even though nothing about the project changed.
Short-term placement and when it stops applying
Short-term placement provisions allow limited work at a location not listed on the certified LCA, subject to day limits and to payment of travel and subsistence costs. The provision is genuinely useful for discovery workshops and go-live support, and genuinely dangerous when treated as a general-purpose exemption. Once a placement stops being short-term, or once the location becomes a regular work location, the provision no longer covers it.
Consultancies should track placement days per employee per area rather than per project. Two separate engagements in the same metropolitan area accumulate against the same limit, and project-based tracking hides that.
The public access file is the operational discipline
The public access file has to be assembled within one business day of filing and retained for the required period. It contains the certified application, wage rate documentation, the prevailing wage determination method, notice documentation, and a summary of benefits. None of this is difficult; all of it is easy to leave incomplete when an engagement starts quickly.
The most reliable fix is procedural: no engineer is scheduled onto a new worksite until someone confirms coverage, notice, and file completeness. Building that check into the staffing workflow — the same way you would gate a production deployment — turns compliance from a periodic scramble into a routine step.
Key takeaways
- Worksite means where work is actually performed, including client sites and home offices.
- A move to a new area of intended employment may require an amended filing before the move.
- Track short-term placement days per employee per metropolitan area, not per project.
- Assemble the public access file within one business day of filing.
- Gate staffing changes on a worksite-coverage check, the way you gate a deployment.
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