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Employer Site Visit Notice of Intent to Revoke

FDNS Compliance Review — Proposed Revocation

Did a USCIS site visit lead to a Notice of Intent to Revoke?

USCIS uses administrative site visits to verify information contained in immigration benefit requests. If information collected during a visit appears inconsistent with an approved petition, USCIS may later take adjudicative action. The response should determine exactly what the officer observed, what people at the site said, how USCIS has interpreted those facts, and whether any discrepancy actually supports revocation under the rule governing the petition.

Send Us Your Site Visit NOIR
Site Visit NOIR Analysis

Compare three records: the petition, the visit, and the NOIR.

Petition What did USCIS approve?
Visit What actually occurred?
Statements Who said what?
Discrepancy Is it real and material?
Revocation Which regulatory ground applies?
A site visit is an information-gathering event. It does not by itself supply a universal legal ground for revoking every type of immigration petition.
Administrative Site Visits

What is USCIS trying to verify?

USCIS's Fraud Detection and National Security Directorate conducts unannounced administrative site visits as part of compliance review programs covering specified immigration benefit requests.

Depending on the petition, the officer may seek information concerning the petitioning organization, work location, beneficiary, employment, job duties, compensation, supervision, corporate operations, facilities, staffing, projects, or other facts represented to USCIS.

Some visits occur before adjudication and others may relate to an already approved petition. A visit therefore does not necessarily mean USCIS suspects fraud and does not automatically mean revocation will follow.

If USCIS later issues a NOIR, however, the site-visit information should be compared carefully with the complete approved petition and the actual circumstances existing when the visit occurred.

What May Be Verified

A site visit can test whether real-world facts match the immigration filing.

The relevant questions depend on the petition type and representations made to USCIS.

Employer

Does the Petitioning Organization Exist?

USCIS may verify the business location, signs, offices, employees, operations, business activity, organizational structure, and other facts concerning the petitioner.

Beneficiary

Is the Worker Where USCIS Expects?

The officer may seek to verify whether the beneficiary works at the reported site, is currently employed, and performs services consistent with the approved petition.

Job Duties

What Work Is Actually Performed?

Job duties, projects, management responsibility, specialized knowledge, specialty occupation work, supervision, and day-to-day responsibilities may be compared with the petition.

Compensation

Is Employment Occurring as Represented?

Payroll, wages, hours, employment status, work schedules, benefits, and other records can become relevant depending on the classification and NOIR allegations.

Worksite

Does the Location Match the Filing?

USCIS may compare the actual work location with the petition, LCA, itinerary, client placement, corporate records, or other location information in the file.

Business Operations

Do the Company's Activities Match the Record?

Staffing, customers, facilities, revenue-producing activity, projects, management structure, contracts, and other operations may become important in classifications that depend on those facts.

Site Visit vs. NOIR

The site visit is not the legal revocation ground.

The underlying petition's revocation regulation still controls.

USCIS may use information collected during a site visit as evidence in a later adjudication. But the legal authority for revoking the petition comes from the regulation governing that particular approved classification.

For example, H-1B, L-1 and O-1 petitions each have category-specific revocation provisions. An employment-based immigrant petition may instead involve the immigrant-petition revocation framework.

A strong response therefore does more than show that the employer is a real business. It asks whether the particular site-visit fact cited by USCIS actually satisfies the revocation ground stated in the NOIR.

Common Site Visit Discrepancies

What did USCIS find that allegedly conflicts with the petition?

Work Location

Beneficiary Was Not at the Expected Site

The beneficiary may have been remote, traveling, temporarily assigned elsewhere, on leave, working at a client site, or permanently relocated. The reason and duration matter.

Job Duties

Interview Answers Differ From Petition Language

A beneficiary, manager, receptionist, coworker, or HR employee may describe the work differently from the terminology used in the immigration filing.

Supervision

Reporting Structure Appears Different

USCIS may question who supervises the beneficiary, who assigns work, whether subordinate staff exists, or whether management authority matches the approved petition.

Payroll

Wages or Employment Status Raise Questions

A temporary payroll interruption, leave period, start-date issue, corporate payroll arrangement, or genuine compliance problem may need to be separated and documented accurately.

Business Operations

Office Appears Smaller or Different

USCIS may compare physical premises, staffing, equipment, customer activity, business records, and operating structure with representations in the approved petition.

Third Party

Client or Project Cannot Be Verified

Client contacts, statements of work, contracts, purchase orders, invoices, project records, and evidence of actual services may become important where third-party work is part of the case.

Reconstruct the Visit

Find out what actually happened before responding to USCIS's version.

01
Identify everyone who spoke with USCIS Interview the beneficiary, receptionist, HR personnel, managers, coworkers, client representatives, and anyone else who interacted with the officer.
02
Determine the questions asked The context of an answer matters. Determine the actual question rather than relying only on the NOIR's shortened description.
03
Determine what documents were requested or reviewed Identify payroll, identification, business records, organizational charts, contracts, employee records, photographs, or other information seen during the visit.
04
Document conditions on that particular day Travel, remote schedules, office moves, holidays, leave, client work, construction, staffing changes, or other temporary circumstances may explain what the officer observed.
05
Compare the visit with the actual petition language Do not accept USCIS's characterization of the petition without checking the original forms, support letter, exhibits, amendments, and prior responses.
A Site Visit Is a Snapshot

One observation may require context.

Explain temporary facts without overstating them.

A site visit ordinarily captures conditions at a particular place and time. The beneficiary may have been absent that day. A manager may have been traveling. An office may have recently moved. Employees may work hybrid schedules. A project may have ended shortly before the visit.

Those facts can be legitimate explanations, but they should be documented rather than asserted. Calendars, travel records, remote-work policies, leases, payroll, project records, client records, emails, and other contemporaneous evidence can establish what was happening.

At the same time, a response should not invent a temporary explanation if the employment arrangement really changed. If a material change occurred, determine what filing obligation resulted and address it directly.

Rebuttal Evidence

What evidence can answer site-visit findings?

Employment

Payroll & HR Records

Pay statements, payroll reports, tax records, benefits, personnel records, time records, leave records, and employment documentation can establish the actual employment relationship.

Job Duties

Work Product & Project Records

Technical materials, reports, emails, project plans, deliverables, meeting records, calendars, approvals, and other contemporaneous work evidence can show what the beneficiary actually does.

Organization

Management & Staffing Evidence

Organizational charts, subordinate records, job descriptions, payroll, reporting structures, budgets, delegation records, and management documents may resolve staffing or supervision questions.

Worksite

Location Evidence

Leases, utility records, photographs, access logs, remote-work policies, client records, travel documentation, LCAs, and amended petitions can clarify where work occurred.

Business

Operating Company Evidence

Tax returns, bank statements, invoices, contracts, customers, licenses, payroll, leases, financial statements, and operating records may establish genuine business activity.

Witnesses

People Who Were Present

Detailed statements from people who personally interacted with the officer can explain the questions asked, answers given, documents reviewed, and conditions observed.

Derogatory Information

The NOIR should give a meaningful opportunity to address the adverse information.

Identify what USCIS actually says the officer learned.

When USCIS plans an adverse decision based on derogatory information unknown to the benefit requestor, USCIS policy requires disclosure of the adverse information in sufficient detail to provide a meaningful opportunity to rebut or explain it, subject to applicable legal limitations.

That does not necessarily require USCIS to provide every internal note, report, investigative document, source identity, or complete government record.

The response should determine whether the NOIR identifies the substance of the alleged discrepancy clearly enough to address it and should point out a material lack of detail when the allegation cannot meaningfully be understood.

At the same time, respond as fully as possible to the facts that USCIS has actually disclosed rather than depending exclusively on a procedural objection.

NOIR Response Strategy

Six principles for responding after a USCIS site visit.

01

Get the Approved Petition

Review exactly what USCIS approved before deciding whether the site-visit information is genuinely inconsistent.

02

Interview Everyone Involved

Reconstruct the visit promptly while the questions, answers, and observations are still fresh.

03

Separate Observation From Inference

A beneficiary not being physically present is an observation. A conclusion that the person never works there is an inference requiring additional analysis.

04

Use Contemporaneous Records

Payroll, emails, projects, calendars, contracts, access records, leases, and other preexisting records can objectively resolve disputed facts.

05

Apply the Correct Revocation Rule

A site visit does not create one universal NOIR standard. Use the regulation governing the approved H-1B, L-1, O-1, I-140, or other petition.

06

Address Real Changes Directly

If employment, duties, location, ownership, staffing, or other material facts actually changed, determine whether a required amendment or other filing was made.

Response Deadline

Site-visit evidence may take time to reconstruct, but the NOIR deadline is short.

The general maximum USCIS NOIR response period is 30 days.

The actual notice controls the filing deadline. Category-specific regulations may also expressly provide a 30-day rebuttal period.

Begin collecting payroll, business records, contracts, project documents, organizational evidence, travel records, declarations, worksite records, and other third-party evidence immediately.

Do not assume USCIS will provide a second opportunity to explain the site visit before issuing its final decision.

Site Visit Questions

USCIS site visit NOIR FAQs

Common questions when information from a USCIS compliance visit leads to a proposed revocation.

Does a USCIS site visit mean the employer is suspected of fraud?
No. USCIS uses administrative site visits as compliance reviews for specified immigration benefit requests. A visit by itself does not establish fraud or mean that USCIS will revoke the petition.
Are USCIS site visits announced in advance?
USCIS states that FDNS officers conduct unannounced site visits under its administrative site-visit programs.
What if the beneficiary was not at the office when USCIS visited?
Absence from the site is a fact that may require explanation, but its significance depends on the approved petition and actual work arrangement. Travel, remote work, leave, client work, or another legitimate circumstance should be documented if applicable.
What if the receptionist gave USCIS incorrect information?
Identify what USCIS says was stated, speak with the person involved, determine the actual question and answer, and provide objective evidence showing the correct facts. Explain why the individual may or may not have had personal knowledge of the beneficiary's work.
Can a site visit cause USCIS to revoke an approved petition?
Information developed during a site visit can contribute to later adjudicative action. Any revocation must still be based on the legal revocation framework applicable to the particular petition.
How long do we have to respond to a site-visit NOIR?
The general maximum USCIS response period for a Notice of Intent to Revoke is 30 days. Follow the exact deadline and submission instructions printed on the notice.