Webinar: Model Your Prevailing Wage Exposure with AI
On Tuesday, June 9, Manifest Law AI Legal Architect Nicole Gunara walked through how to calculate the impact of the federal government’s proposed prevailing wage rule, which could raise required wages by $20,000 or more for some sponsored roles.
Gunara demonstrated how to model your exposure to the rule using AI tools. The timeline is uncertain, but the rule could be finalized quickly. Here are the key takeaways from Tuesday’s webinar.
1. The clock is ticking
The federal government’s comment period on the proposed prevailing wage rule closed May 26.
Now there are two deadlines employers face. First, prevailing wages refresh every year on or around June 30, regardless of this rule. Any LCA filed from July 1 uses new wage levels.
Second, the proposed rule could take effect quickly. A recent comparable rulemaking—the wage-weighted lottery rule—went from closed comment period to final rule in about two months. If this rule follows a similar pace, a final rule could be published this summer and take effect this fall.
“The government seems to be accelerating a lot of these processes compared to prior administrations, so it’s better to be prepared,” Gunara said.
2. H-1B and PERM require different playbooks
If you sponsor workers through both H-1B and PERM processes, the proposed rule hits each one differently.
For H-1B, E-3, and H-1B1 workers, employers and their attorneys have input on how a role is classified, including the occupational code and wage level. That creates room to strategize.
One option is filing renewals or amendments early. The earliest you can file an H-1B extension is six months before the current approval expires. Filing early locks in today’s wage floors for up to the next three years.
PERM is less flexible. Once you submit a prevailing wage request, the Department of Labor determines the occupational code and wage floor that applies. Counsel can suggest a classification, but the government makes the final call. Because of this, PERM cases require earlier planning.
“On the H-1B side, there’s more levers that are within our control,” Gunara said. “On the PERM side, we are not the ultimate judgement makers.”
3. See your exposure now
Manifest’s prevailing wage calculator lets you model the impact of the proposed rule by job title, wage level, and metro area. Enter a current salary and it shows you the current wage floor, the estimated new floor, and the gap between the two in seconds.
▶️ Try it now
If you have a larger workforce to assess, Gunara walked through a method for running a wider analysis using a spreadsheet and an AI prompt to flag every worker likely to need a salary adjustment, broken down by geography and job title.
The spreadsheet template, the AI system prompt, and the full webinar recording are available below. Drop your email and we’ll send the full toolkit.