California Service Center started issuing RFE's on the H-1B petitions filed requesting copies of the contracts and work orders between all the layers involved in the contractual chain. This request is made irrespective of the fact that the Petitioner already gave the letters from the end client and all the layers involved clearly depicting the employer-employee relationship.

On February 22, 2018, USCIS issued a Policy memorandum on Contracts and Itineraries Requirements for H-1B Petitions Involving Third-Party Worksites. As per the memo, when a beneficiary will be placed at one or more third-party worksites, the petitioner must demonstrate that it has specific and non-speculative qualifying assignments in a specialty occupation for the beneficiary for the entire time requested on the petition. For such third-party, off-site arrangements, USCIS requires additional corroborating evidence, such as contracts and work orders between all the parties including the vendors and client, may substantiate a petitioner’s claim of actual work in a specialty occupation.