CRS Report R47164 • Analysis

What Congress's Own Researchers Found —
and What They Left Out

The Congressional Research Service documented the H-1B and employment-based immigration system for Congress. Here is what it confirms, what it glosses over, and what only ground-level data reveals.

Source: CRS Report R47164, updated Nov. 2024 Published: June 2026 GuestWorkerVisas.com

What Is CRS Report R47164?

The Congressional Research Service is Congress's nonpartisan think tank — staffed by lawyers, economists, and policy analysts who produce research exclusively for Members of Congress and their committees. Their reports are not advocacy. They are meant to be the most objective, authoritative summary of a policy area available to lawmakers.

Report R47164, U.S. Employment-Based Immigration Policy, is CRS's comprehensive treatment of how the United States admits, tracks, and manages foreign workers — covering green card preference categories, the H-1B specialty worker visa, L-1 intracompany transferees, Optional Practical Training (OPT) for foreign students, and the decades-long policy debate around all of it. It was first published in 2022 and most recently updated in November 2024.

It is, in short, what Congress officially knows about this system. That makes the gaps in it just as informative as the content.

Direct from CRS R47164

"Increasingly, H-1B workers are hired by a small group of very large firms in the scientific and business services, computer, and information technology staffing industries with expertise in navigating the H-1B application process. These large employers are not typical of U.S. employers; they are a selected group."

That sentence is the entire universe this site's H-1B database and scorecard are built around. CRS treats it as a methodological footnote — a "selection problem" that complicates academic research. We treat it as the policy problem itself.

What CRS Confirms

On several points, R47164 is remarkably direct. These are not contested findings — they are documented in the official record that Congress has in hand.

The EB queue is a labor control mechanism — CRS just doesn't call it that

The report documents that the employment-based green card queue stood at 870,000 people as of September 2021, and that workers from India face waits of decades — in some EB categories, over 100 years at current processing rates. Workers stuck in this queue are sponsored by specific employers. If they leave that employer, they lose their place in line. CRS describes this situation factually. What it does not explore is the structural consequence: an employer who holds your green card sponsorship holds enormous leverage over your wages, your ability to complain about working conditions, and your willingness to organize.

EB queue size (2021)
870K
Approved but waiting
Indian EB wait (some categories)
100+
Years at current rates
Annual EB cap (set in 1990)
140K
Unchanged in 34 years
US GDP since 1990
2×+
Cap has not kept pace

OPT grew nearly 10x — CRS notes it, but not its implications

The report documents that Optional Practical Training enrollment grew from under 25,000 in CY2007 to over 214,000 in CY2023. OPT has no annual cap, no prevailing wage requirement, and no Labor Condition Application process. Employers who hire OPT students pay no H-1B fees and face none of the attestation requirements that theoretically protect American workers.

2007
<25K
<25,000
2015
~80K
~80,000
2019
~155K
~155,000
2023
214K
214,000

OPT enrollment, CY2007–CY2023. Source: ICE SEVIS via CRS R47164. No annual cap. No prevailing wage requirement.

Staffing firm concentration is documented — but treated as an academic problem

CRS explicitly notes that H-1B usage is increasingly concentrated among a small number of IT staffing and outsourcing firms. The report describes this as a complication for labor economists trying to measure H-1B impacts, because these firms are not "typical" employers. What it does not discuss is why this concentration matters for American workers, wage-setting, or the fundamental purpose of the prevailing wage requirement — which is largely meaningless if the dominant employers in a market are all submitting H-1B applications at similar wage floors.

What CRS Glosses Over

A nonpartisan briefing document for Congress presents all sides fairly. That is its job. But "presenting all sides" can obscure what ground-level data makes obvious. Here are the places where R47164 is technically accurate and practically incomplete.

The wage attestation problem

CRS notes that H-1B employers must pay the greater of the actual wage or the prevailing wage. What it does not examine is how prevailing wages are calculated — using the Department of Labor's four-tier wage level system, where the majority of H-1B petitions are filed at Level 1 (the bottom 17th percentile of wages for that occupation). A system that defines "prevailing wage" as the wage most workers in a field earn more than is not a wage protection — it is a floor set below the market. Our H-1B database lets you check any employer's filed wages against prevailing wages directly.

The queue as a retention tool

The 870,000-person EB queue is framed in R47164 primarily as a humanitarian issue — workers from India and China waiting unreasonably long for green cards they were promised. That framing is real. But the queue also functions as a retention mechanism that benefits employers, not workers. A software engineer five years into a ten-year green card wait does not negotiate for a raise or quit for a competitor. CRS documents the queue's existence and scale. It does not examine this dynamic at all.

OPT's role in the pipeline

CRS treats OPT as a student benefit and an immigration pathway. It does not examine OPT as a labor market instrument — a mechanism that allows employers to hire highly educated workers with no wage floor, no cap, no attestation requirement, and a tax advantage (OPT workers on STEM extension are exempt from FICA taxes). The 214,000 OPT workers in 2023 represent a workforce larger than many entire industries, operating almost entirely outside the labor protections that are supposed to govern the H-1B program they typically feed into.

Throughout R47164, the report references "labor market needs" and "tight labor markets" as the rationale for employment-based immigration. It does not examine the evidence for those claims in the specific occupations — particularly software development and IT — where H-1B usage is most concentrated. Our work visas vs. new jobs report shows that in nearly every year from 2008 to 2024, total work-authorized visa issuances ran at or above the total number of net new jobs created in the entire U.S. economy. That is not a picture of a labor market so tight it requires unlimited foreign worker pipelines.

What Only Ground-Level Data Shows

CRS works from aggregate statistics and published research. This site works from the transactional records — the actual LCA filings, the actual contract awards, the actual employer names and dollar amounts. Here is what that ground-level view adds.

The same ecosystem runs federal contracts

In June 2026, we pulled all USASpending.gov awards matching the keyword "staffing" across all federal agencies for FY2026. The result was $4.1 billion in contracts — and the contractor list looks strikingly familiar to anyone who has spent time in the H-1B data. Tribal and Native-owned IT staffing firms that dominate H-1B filings at the State Department are the same firms winning government staffing contracts there. The H-1B ecosystem and the federal contracting ecosystem are not separate worlds.

1
CRS documents the policy framework
R47164 describes the H-1B program, its wage attestation requirements, the EB queue, and the concentration of usage among staffing firms.
2
Our H-1B database shows who's using it and how
Search any employer's actual LCA filings: wage levels, prevailing wage gaps, job titles, locations, and petition counts — the transactional record CRS summarizes but doesn't show.
3
USASpending shows those same firms winning government contracts
$4.1B in federal staffing contracts in FY2026. The dominant H-1B users at the State Department are the same entities winning the largest staffing awards. The pipeline runs from visa approval to government contract.
4
The math on new jobs completes the picture
Work-authorized visa issuances have run at or above total net new U.S. jobs in nearly every year since 2008 — a comparison CRS's report never makes because it sits across two different datasets.

The prevailing wage problem is visible in actual filings

In our H-1B filings database, covering FY2026 Q2, the wage gap between offered wages and prevailing wages is measurable for tens of thousands of individual petitions. You can look up any employer and see the spread. CRS notes the wage attestation requirement exists. Our data lets you see how it performs in practice — employer by employer, job title by job title.

"CRS tells Congress that the H-1B system has a prevailing wage requirement. Our database lets you check whether any given employer is honoring it — or filing petitions at Level 1 wages that sit 40% below what American workers in the same occupation actually earn."

CRS R47164 vs. What This Site Provides

This is not a criticism of CRS. Their job is nonpartisan synthesis for policymakers. Our job is transparent data for the public. They are different tools.

Topic CRS R47164 GuestWorkerVisas.com
H-1B wage attestation ◑ Describes requirement Searchable by employer — actual offered vs. prevailing wages for every LCA filing
Staffing firm concentration ◑ Acknowledges it Quantified — top employers, petition volumes, wage patterns
OPT growth ◑ Documents the numbers Charted with sourced data; FICA exemption and wage floor absence noted
EB queue as labor leverage ✗ Not examined Documented: workers cannot leave sponsoring employer without losing queue position
Visas vs. job creation ✗ Not in scope Year-by-year comparison, FY2008–FY2024, all work-authorized categories
Federal contracting overlap ✗ Not in scope $4.1B FY2026 contracts — same employers, same ecosystem, searchable
Foreign-born vs. native-born employment ✗ Not in scope 19 years of BLS Table A-7 data, including the COVID baseline problem
Individual employer lookup ✗ Not possible Search any employer's full LCA history, wages, and job titles

Citing CRS in Your Own Research

Because CRS is nonpartisan and Congress-facing, citing R47164 in your own writing carries weight that citing an advocacy organization does not. Several of its findings are directly useful when making the case that this system warrants serious scrutiny:

Useful citation 1 — Staffing firm concentration

"Increasingly, H-1B workers are hired by a small group of very large firms in the scientific and business services, computer, and information technology staffing industries." (CRS R47164, updated Nov. 2024) — This is Congress's own think tank confirming that the program is dominated by intermediaries, not the "best and brightest" employer-by-employer narrative that is usually offered in its defense.

Useful citation 2 — The 870,000-person queue

The queue of approved-but-waiting EB immigrants totaled 870,000 as of September 2021, with Indian nationals in some categories facing waits of over 100 years. (CRS R47164) — Useful context for discussing why workers cannot simply "vote with their feet" if an employer underpays or mistreats them.

Useful citation 3 — OPT growth

F-1 students working under OPT grew from fewer than 25,000 in CY2007 to over 214,000 in CY2023. (CRS R47164) — The growth of a no-cap, no-wage-floor pipeline that feeds directly into the H-1B system is documented in the official record.

For all three of these, you can then link directly to this site's tools to show what those documented trends look like at the employer level — making the connection between the policy abstraction and the actual filings.

"R47164 tells you the system exists and roughly how it works. This site tells you who is using it, what they are paying, and where the money flows." — GuestWorkerVisas.com, June 2026