Womble Bond Dickinson released a memo last week warning that AI‑powered algorithms could cross‑check H‑1B petitions against AR‑11 address filings and detect mismatches.
The memo cites two typical scenarios: an employer amends a petition to move a worksite after an employee has already filed an AR‑11, and the reverse, where a worker moves but the employer never updates the petition.
Such mismatches are especially problematic for remote workers who shift home addresses while remaining in the same role. The difference between an address change and a new worksite can trigger a new LCA and petition amendment.
Indian nationals, who make up a large share of the H‑1B pool, face heightened scrutiny because even minor date or location differences can flag a discrepancy.
The firm urges employers to audit their records before filing extensions and to train HR staff on dual filing requirements.
Employees should promptly notify employers and file AR‑11s within 10 days of moving. The next step for USCIS is to pilot the AI system in upcoming review cycles.