In remote/hybrid and multi-location PERM, audits often turn on a simple question: does your file describe one consistent job location story, or several competing ones? When PWD describes one footprint, ads describe another, NOF points to a third, and ETA-9089 locks a fourth, the case can look internally inconsistent even if recruitment steps were otherwise clean.
This page is a control framework. It helps you define where work is actually performed, set clear boundaries for additional worksites or travel, and keep that meaning aligned from PWD → recruitment → NOF → ETA-9089 without “fixing it at the end.”
Key terms used in this guide (as control points):
Disclaimer: Educational content only; not legal advice. Rules and agency practices can change. Always align your approach with your counsel and the official regulations and form instructions.
Contents
Jump to the section you need. Each section maps to a practical audit-file control.
90-second answer (the control most teams should implement)
If you implement one thing, make it a Location Memo plus a strict re-sync rule.
- Decide where work is actually performed (home office vs employer office) before PWD or recruitment starts.
- Create a one-page Location Memo: primary worksite, work mode, known additional worksites, travel boundaries.
- Standardize one approved location sentence and require it across job order, ads, and internal postings.
- Do not widen geography by accident (avoid “remote anywhere” unless your wage/recruitment strategy truly supports it).
- Re-sync if facts change before filing: relocation, remote ↔ hybrid shift, new regular worksite, expanded travel footprint.
The sections below show how to translate those controls into consistent PWD, recruitment, NOF evidence, and ETA-9089 entries.
1) Choosing the primary worksite in 2025–2026: remote, hybrid, multi-office, and roving roles
Start with the question an auditor will implicitly apply to every artifact: where is the work actually performed most of the time? That answer becomes the anchor for wage geography, recruitment wording, NOF posting logic, and the final ETA-9089 snapshot.
Most location problems begin as “helpful flexibility.” A recruiter changes the posting to “remote,” an internal page says “hybrid,” a manager expects monthly office visits, and later the filing needs a precise location record. The file then contains multiple versions of the job opportunity. The solution is to decide the primary worksite first and treat everything else as bounded, measurable extensions.
A) Fully remote (telecommute / WFH)
Anchor the role to the employee’s home office because that is where the work is performed.
- Be concrete: city/state/ZIP (or your counsel’s defined geographic approach) and keep that meaning consistent everywhere.
- Office visits must be bounded: state frequency/purpose (for example, “quarterly meetings”) so the role doesn’t drift into hybrid without anyone noticing.
- Avoid accidental widening: “remote anywhere” changes the market story; don’t use it unless the wage/recruitment approach supports that scope.
B) Hybrid (fixed or regular onsite days)
Pick the primary worksite (home or office) based on where most work occurs, then lock one cadence statement.
- One cadence everywhere: keep the same onsite frequency + office location meaning across job order, ads, and internal postings.
- Stop channel drift early: “remote role” in one place and “onsite required” in another is a classic mismatch pattern.
- Change control: if onsite expectations change before filing, treat it as a re-sync event (do not “patch wording” at the end).
C) Multi-office (2+ employer offices)
Choose a single primary office; treat other regular offices as planned worksites, not “maybe.”
- Primary first: define the main office as the baseline for location story and downstream artifacts.
- Regular vs occasional: a scheduled recurring pattern (e.g., weekly) is very different from rare travel for meetings—describe accordingly.
- Common failure: adding a regular office mid-process without re-syncing PWD/recruitment/NOF/ETA-9089.
D) Roving roles (client sites / travel)
Travel is not a substitute for location clarity. Define it so it cannot be read as an undisclosed regular worksite.
- Measurable travel: typical % or frequency plus geographic scope (states/region). Avoid “significant travel” without boundaries.
- Known recurring sites: if client sites are predictable and ongoing, plan them as known worksites rather than “unanticipated.”
- Keep terms clean: distinguish temporary visits from regular worksites; don’t let “travel” hide a second primary location.
High-risk re-sync triggers before filing: employee relocation (new home office), remote ↔ hybrid shift, adding a regular office/worksite, or materially expanding travel geography. When these occur, assume you must re-align the chain so the audit file does not contain competing location narratives.
Build a one-page Location Memo (baseline control)
A Location Memo is an internal single source of truth so multiple teams don’t describe the job four different ways.
Keep the memo short and factual. The objective is operational alignment: if HR, recruiting, and business leaders can repeat the same location story without improvising, your file is far less likely to drift.
| Memo field | What to write (location-focused) |
|---|---|
| Primary worksite | Home office or employer office (city/state/ZIP) where work is performed most of the time. |
| Work mode | Remote / Hybrid (onsite cadence) / Multi-office / Roving (client-site travel). Use one stable description. |
| Known additional worksites | List regular, anticipated locations (not hypothetical) and how often they are used. |
| Travel boundaries | Typical % or frequency plus geographic scope (states/region). Keep it measurable. |
| Change control | Owner + approval path + re-sync triggers (relocation, cadence change, new regular office/site, expanded travel). |
Once this memo exists, the rest of PERM becomes a consistency exercise: PWD should reflect the same worksites, recruitment should communicate the same geography, NOF should be posted for the right facility/location, and ETA-9089 should match it all.
2) The “alignment spine”: one geography version across PWD → Ads → NOF → ETA-9089
Treat the file like a chain. If one link uses broader, narrower, or different geography language, the record can read like multiple different job opportunities. The fix is to lock a single location storyline and enforce it everywhere.
Your location storyline has three parts: (1) primary worksite (where work is actually performed), (2) work mode (remote/hybrid/multi-office/roving), and (3) boundaries (known additional worksites and travel scope). The audit-safe objective is consistent meaning across artifacts — even if the exact words vary slightly.
Lock the facts before you start clocks
- Confirm the primary worksite and whether any additional worksites are regular (recurring) or merely occasional.
- For hybrid, lock a cadence sentence (onsite frequency + office location + remote allowance) and treat it as controlled text.
- For travel, define typical %/frequency plus geography (states/region). “Open-ended travel” is hard to reconcile later.
PWD: define geography you can defend (and respect validity)
- PWD is tied to a specific location story; if your location facts change, your case may require a re-sync to avoid mismatch.
- Keep the area of intended employment consistent with where work will be performed and any known regular worksites.
- Remember the PWD is time-bounded (validity is not open-ended). Treat it as a clock that should not outlive your facts.
Recruitment: communicate the same story to the market (and stay within timing windows)
- Use the approved location sentence consistently across job order, ads, and internal postings.
- Do not let one channel imply a broader labor market than your intended employment geography.
- Recruitment steps have timing rules relative to filing; treat timing and wording as a single compliance package, not separate tasks.
NOF: post at the right facility/location and document it cleanly
- NOF is tied to the facility/location of employment story you are certifying.
- Operational baseline: posted for 10 consecutive business days with clean evidence (dates, placement, visibility).
- If you use in-house media distribution, keep distribution evidence consistent with the same facility/location logic.
ETA-9089: treat it as the filing snapshot (not a place to “patch”)
- ETA-9089 becomes the official record of where work will be performed and how additional worksites/geographies are described.
- Late-stage wording “fixes” often look like inconsistencies; align the story earlier so ETA-9089 simply reflects what’s already supported.
Practical re-sync rule: if the primary address, work mode, regular worksites, or travel footprint changes before filing, pause and re-align PWD → recruitment → NOF → ETA-9089 so your file describes one job opportunity, not multiple versions.
Mini case (example): remote + bounded office visits + limited travel
Facts: employee works from home in San Jose, CA; office visit once per month to employer office in San Francisco, CA; travel up to 10%, primarily within California.
- PWD: geography supports work from the home office location story (with bounded additional presence).
- Ads: “Telecommuting permitted from the employee’s home office in California; monthly onsite in San Francisco, CA; travel up to 10% within CA.”
- NOF: posted per the facility/location logic used for the case; evidence ties to that same story.
- ETA-9089: reflects the same where-performed snapshot (primary + bounded visits + bounded travel).
What must match across documents (location-critical mapping)
Use this as a pre-launch checklist, then repeat it before filing ETA-9089.
| Artifact | Location language it contains | What must be consistent | Common mismatch pattern |
|---|---|---|---|
| PWD (ETA-9141) | Primary worksite + area of intended employment + any planned worksites/travel footprint. | Geographic scope matches where work will be performed and any known regular worksites. | “Client sites anywhere” while wage/recruitment story is narrow or bounded. |
| Recruitment ads | Job location + remote/hybrid phrasing + travel language. | Same meaning as PWD; avoid widening/narrowing geography across channels. | One channel implies “remote anywhere,” another implies fixed onsite. |
| NOF | Posting tied to facility/location of employment; posting dates and visibility evidence. | Posting location and evidence match the same location story you are certifying. | NOF evidence references a different facility than the file’s primary worksite narrative. |
| ETA-9089 | Where work will be performed + additional worksites/geographic areas (if used). | Final record mirrors the worksites and boundaries already used in PWD and recruitment. | Attempting to add a regular worksite at filing that wasn’t part of recruitment story. |
If you spot a mismatch, don’t paper it over with new words. Re-align the underlying location story, then make every artifact match it.
3) Scenario matrix + audit-file pack: keeping recruitment ads and NOF consistent
Use this matrix as a pre-flight check. If you can’t describe a scenario with bounded, consistent geography, you don’t yet have a stable location storyline.
The matrix prevents “location drift” by forcing one discipline: PWD geography, recruitment wording, NOF posting logic, and ETA-9089 worksite entries must all describe the same job opportunity. If a location element is not true and planned, don’t imply it in one artifact and omit it in another.
| Scenario | Worksite + PWD (geography) | Recruitment + NOF (what you say & post) | Risk pattern + control |
|---|---|---|---|
| Fully remote home office |
Primary = home office (anchor). Any regular additional worksite must be planned up front and reflected consistently. PWD geography matches where work will be performed. | One bounded remote statement across channels. NOF evidence matches the same employment-location logic used in the case. |
Risk: ad implies “remote anywhere” while wage story is bounded. Control: approved location sentence + re-sync trigger for address changes. |
| Hybrid onsite + remote |
Primary = where most work occurs (home or office). PWD reflects the real onsite cadence and office location. | One cadence sentence everywhere (example below). NOF posted and documented per facility/location logic. |
Risk: “remote” wording in one channel and “onsite required” in another. Control: cadence lock + pre-publish checklist. |
| Multi-office 2+ offices |
Primary = main office. Other regular offices are planned worksites, not “optional.” | Recruitment describes the same planned structure; do not hide a second regular office behind vague language. |
Risk: adding a regular office after recruitment starts. Control: freeze planned worksites before launch; re-sync if reality changes. |
| Roving client sites |
Travel is measurable (typical %/frequency + states/region). PWD and narrative anticipate the real footprint. | Recruitment states travel scope clearly. NOF tied to employer facility and documented cleanly. |
Risk: vague travel language that effectively describes regular multi-state worksites. Control: measurable travel statement + change control for new regions. |
Fully remote (home office)
- Worksite + PWD
- Primary = home office anchor. Plan any regular additional worksite up front; align wage geography to where work is performed.
- Recruitment + NOF
- One bounded remote statement across channels; NOF evidence matches the same employment-location logic.
- Risk + control
- Risk: “remote anywhere” drift. Control: approved location sentence + re-sync on address change.
Hybrid (onsite + remote)
- Worksite + PWD
- Primary reflects where most work occurs; PWD aligns to real onsite cadence and office location.
- Recruitment + NOF
- One cadence sentence everywhere; NOF posting and evidence align to facility/location logic.
- Risk + control
- Risk: channel drift (remote vs onsite). Control: cadence lock + pre-publish review.
Multi-office (2+ offices)
- Worksite + PWD
- Pick one primary office; treat other regular offices as planned worksites, not optional.
- Recruitment + NOF
- Recruitment describes the same planned structure; NOF evidence stays consistent with facility/location story.
- Risk + control
- Risk: adding a regular office late. Control: freeze worksites pre-launch; re-sync if changed.
Roving (client sites / travel)
- Worksite + PWD
- Travel is measurable (typical %/frequency + states/region). Avoid open-ended footprints.
- Recruitment + NOF
- Ads state travel scope clearly; NOF tied to employer facility and documented.
- Risk + control
- Risk: vague travel that reads like undisclosed regular worksites. Control: measurable boundaries + change control.
Audit-file essentials + wording controls (location drift prevention)
These items reduce the chance that multiple teams accidentally create conflicting location narratives.
Audit-file essentials (keep together)
- Location Memo: primary, mode, known worksites, travel boundaries, owner, re-sync triggers.
- Recruitment proof set: copies of each ad/job order + placement evidence + timestamps; consistent location meaning across all items.
- NOF proof set: posted notice copy + posting dates + where it was posted + visibility evidence (clean and readable).
- Internal alignment: job description and remote/hybrid policy language do not contradict what your PERM artifacts say.
- Change log: if relocation/work-mode/worksite facts change, record the decision and what was re-synced.
Practical test: if a reader can look at public job language and reasonably infer a different work location than what you’ll certify on ETA-9089, you have avoidable risk.
Approved location sentences (examples you can standardize)
These are examples, not magic phrases. The value is that one approved sentence is reused consistently across channels. Use real facts and avoid broadening geography unintentionally.
- Remote (bounded): “Telecommuting permitted from the employee’s home office in California, with quarterly onsite meetings at San Francisco, CA.”
- Hybrid (clear cadence): “Hybrid schedule: onsite 2 days/week at Austin, TX; remaining time remote.”
- Travel (measurable): “Travel up to 10%, primarily within Texas and neighboring states.”
High-risk patterns (common drift triggers)
- “Work from anywhere in the U.S.” when your wage/recruitment story is tied to a narrower area.
- One channel says “remote” and another says “onsite required,” without a single stable cadence statement.
- “Significant travel” without %/frequency and geography.
Operational control: store the approved location sentence inside the Location Memo and require recruiters to copy it verbatim into each channel. Treat any deviation as a compliance review item.
4) Risk hotspots, self-check, FAQ, and official sources
Use this section as triage. It highlights where teams most often create conflicting location narratives across PWD, recruitment, NOF, and ETA-9089.
The chart below is not a government metric. It is a practical triage map: where mismatch risk is typically higher, enforce stronger controls (approved location sentence, tighter review gates, and a re-sync rule).
Practical rule: “High” items deserve controlled wording + documented review before anything is published; “Medium” items still need consistency, but usually involve fewer moving parts.
Quick self-check (location alignment)
A lightweight screen for common mismatch patterns. It does not replace legal review.
Results
Select inputs and click “Run check” to see risk flags and controls to apply.
FAQ (remote, hybrid, and multi-location PERM)
Short, control-oriented answers focused on preventing document-to-document inconsistency.
Can PERM be filed for a fully remote (telecommute) role?
Yes. Fully remote does not mean locationless. Your file still needs a consistent “where performed” story across PWD, recruitment wording, NOF evidence, and ETA-9089. The cleanest operational approach is to anchor the role to the home office location and keep any office visits bounded and consistently described.
For hybrid roles, should the office or the home be treated as the primary worksite?
Use the fact pattern: primary should reflect where most work occurs. Then lock a single cadence statement (onsite frequency + office location + remote allowance) and require that meaning across job order, ads, and internal postings.
What if a new regular office/worksite is added before filing?
Treat it as a re-sync trigger. The critical distinction is “regular and recurring” vs “occasional.” A regular worksite should not first appear at filing. Re-align the location storyline early so PWD, recruitment, NOF, and ETA-9089 remain consistent.
How should travel be described for roving/client-site roles?
Use measurable boundaries: typical % or frequency plus geographic scope (states/region). Avoid vague “significant travel.” The travel footprint should not read like unlimited future worksites that were never planned in the case narrative.
What single control prevents most “location drift”?
A one-page Location Memo plus one approved location sentence reused across all recruitment channels, with a strict re-sync rule if facts change before filing.
Primary sources (official)
Regulations and form instructions that anchor the location concepts referenced in this guide.
Regulations & program pages
-
20 CFR Part 656 (PERM regulations, eCFR)
Core PERM framework, including wages, recruitment, and notice requirements.
https://www.ecfr.gov/current/title-20/chapter-V/part-656 -
20 CFR 656.10 (General instructions; Notice of Filing rules)
Notice requirements and posting logic tied to employment location.
https://www.ecfr.gov/current/title-20/chapter-V/part-656/section-656.10 -
20 CFR 656.17 (Basic labor certification process)
Core process, including recruitment framework and timing constraints.
https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-C/section-656.17 -
20 CFR 656.40 (Prevailing wage determination)
PWD request rules and validity constraints.
https://www.ecfr.gov/current/title-20/chapter-V/part-656/subpart-E/section-656.40 -
FLAG — PERM overview
Official DOL program overview and navigation.
https://flag.dol.gov/programs/perm -
DOL — Prevailing Wage Information and Resources
Prevailing wage concepts and resources tied to area of intended employment.
https://www.dol.gov/agencies/eta/foreign-labor/wages
Form instructions
-
ETA-9089 Instructions (PDF)
Worksite/where-performed concepts and form guidance.
https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/ETA-9089-Instructions.pdf -
ETA-9141 (PWD) General Instructions (PDF)
PWD geography details and Appendix A (additional areas/worksite guidance).
https://www.dol.gov/sites/dolgov/files/ETA/oflc/pdfs/Form%20ETA-9141%20-%20General%20Instructions%20-%20508%20Compliant%20-%20Expires%2007-31-2026.pdf
Operational reminder: before recruitment begins, cross-check public job postings and internal remote/hybrid policy language against your Location Memo. A mismatch between “public story” and “filing story” is one of the easiest ways to create avoidable inconsistency.
