A recruiter messages you on LinkedIn. The bill rate sounds reasonable. Maybe it even sounds good. But something in your gut says: is this number real, or is someone padding a margin and hoping I won't check?
Good news: there is public data that gives you a reference point. Bad news: most consultants either do not know it exists or misread it badly enough to blow up a negotiation over a number that was never meant to mean what they thought it meant.
Quick housekeeping before we dive in. If you have read our separate piece on vetting a sponsor's filing history for compliance red flags, this is a different exercise entirely. That article is about whether an employer has a track record of proper LCA filings. This one is about using wage figures in those same public records as a benchmark for your own rate conversation. Same data source, completely different question.
What the OFLC Disclosure Files Actually Are
The Department of Labor's Office of Foreign Labor Certification publishes case disclosure data on a quarterly basis. Every H-1B Labor Condition Application that DOL certifies becomes part of that public record. The files are downloadable flat files — spreadsheets, essentially — available at the DOL OFLC Performance Data page.
Each row in the file represents one LCA. The columns that matter most for this exercise are:
- SOC_TITLE and SOC_CODE — the occupational classification the employer used
- WAGE_RATE_OF_PAY_FROM — the wage offered on the filing
- WAGE_UNIT_OF_PAY — year, month, week, hour
- EMPLOYER_NAME — the entity that filed
- WORKSITE_CITY and WORKSITE_STATE — where the worker will actually work, not where the employer is headquartered
- PW_WAGE_LEVEL — the prevailing wage level certified (I through IV)
The files are large. The fiscal year 2024 H-1B file alone runs to hundreds of thousands of rows. You will want to filter in Excel or load into a tool like Google Sheets, Python, or even a free database viewer. The DOL also maintains a lighter-weight online search interface if you only need a handful of lookups.
Prevailing Wage Is a Floor, Not a Market Rate
This is the most important concept in the entire exercise. Read it twice.
The wage on an LCA is the wage the employer certified it would pay — and that wage must meet or exceed the applicable prevailing wage for that occupation in that geography. Prevailing wage is determined by the DOL's Foreign Labor Certification Data Center wage library, which itself is derived from Bureau of Labor Statistics Occupational Employment and Wage Statistics surveys.
Prevailing wage is a legal floor. It is the minimum the employer is permitted to pay. It is not the median. It is not the market rate. It is not what the employer is actually paying on average across its workforce.
A staffing firm that files a Level I prevailing wage for a senior Java developer in New York City is not telling you what senior Java developers earn in New York City. It is telling you it intends to pay at least the DOL-certified minimum for that role. Those are very different statements.
Level I corresponds roughly to entry-level positions. Level II is qualified. Level III is experienced. Level IV is fully competent. If you see a Level I or Level II wage on a filing for a role that the recruiter is describing as senior, that gap is worth noting — but it is not automatically evidence of bad faith. Employers sometimes file conservatively and pay above the certified wage.
How to Run a Triangulation in Practice
Here is a repeatable workflow. It takes about fifteen minutes once you know the data source.
- Download the latest OFLC quarterly disclosure file for H-1B from the DOL Performance Data page. Use the most recent full fiscal year file for the broadest sample.
- Filter by employer name. If the staffing firm or end-client has a large footprint, you will find dozens or hundreds of rows. Look for filings in your metro area and your SOC code.
- Filter by worksite state and city matching your engagement location. Remote roles complicate this — use the city listed on the LCA, which should be the worker's actual worksite.
- Note the wage range across filings. You are looking for a distribution, not a single number. What is the lowest wage certified? The highest? Is there a cluster?
- Cross-reference with BLS OEWS data for your occupation and metro area to see the broader market median. The BLS data covers all workers in the occupation, not just those on LCAs, which makes it a useful independent check.
What you end up with is a range: the floor implied by prevailing wage filings, and the broader market median from BLS. Your quoted rate — or the wage component of a W-2 engagement — should sit comfortably above the floor and make sense relative to the market median given your experience level.
What This Data Cannot Tell You
Here is where consultants get themselves into trouble. The LCA wage is the employee wage, not the bill rate the client is paying the staffing firm. Those two numbers are not the same, and they were never meant to be.
| Number | What It Represents | Is It Public? |
|---|---|---|
| LCA certified wage | Minimum wage the employer committed to pay the H-1B worker | Yes, in OFLC disclosure files |
| Actual employee wage | What the worker is actually paid — must be at or above LCA wage | No |
| Staffing firm bill rate | What the end-client pays the staffing firm per hour | No |
| Contractor take-home | Wage or 1099/C2C pay after the firm's margin | No |
Staffing firm margins vary widely. On a W-2 engagement, a firm might charge the client a bill rate that is 40% to 80% above the wage it pays the consultant, covering employer taxes, benefits, overhead, and profit. On a corp-to-corp arrangement, the math is different again because the consultant's entity absorbs its own overhead.
So if you pull an OFLC filing and see a wage of $95,000 annualized for a software engineer role at a staffing firm, you cannot conclude the bill rate is $45 an hour. You cannot conclude anything about the bill rate. You can only conclude the firm committed to pay at least $95,000 to the worker on that filing.
Use the data to sense-check whether the wage you are being offered is above the floor and in the right neighborhood of the market. Do not use it to reverse-engineer someone else's business model.
One Sanity-Check Framework You Can Actually Use
Before your next rate conversation, run this three-point check:
- Is the offered wage above the applicable prevailing wage level? Look up the DOL wage library for your SOC code and metro. If the offer is below Level II for a role described as mid-level, push back with specifics.
- Does the offered wage align with BLS OEWS median for your occupation and metro? If you are at or above median for your experience level, the number is defensible. If you are significantly below, you have a data-backed question to ask.
- For W-2 engagements: is the wage-to-bill-rate ratio plausible? You may not know the exact bill rate, but you can ask the recruiter directly. A firm that refuses to share the bill rate on a W-2 role is not obligated to disclose it — but you are not obligated to accept the offer either.
The goal is not to weaponize public data. It is to walk into the conversation knowing whether the number you were quoted is in the universe of plausible or obviously below it. That knowledge changes how you negotiate — or whether you bother.
If you want a second opinion on a rate you have been quoted, or you want to understand how engagement model (W-2, 1099, C2C) affects your effective compensation, the team at Josh Pros LLC is happy to talk it through. Reach out at contact@joshpros.com or visit https://joshpros.com — no pressure, just a straight conversation.
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