Comment on DOS-2011-0080-0001

We have been informed that you are implementing new rules which will affect us in the following manner: Provide sponsors like InterExchange with proof of corporate documents and licensing including EIN#s and Worker's Compensation. Make hiring decisions earlier in the season. Each employer and job must be fully vetted by the sponsor before students may apply for their J-1 Visas. Enter a formal contract with the student and sponsor organization that commits the employer to ensuring the job and terms are adhered to. Forgo any sponsor-initiated incentive to hire international students, including attending recruitment tours and events arranged by the sponsor or international recruiting agent. Report to sponsor every student's employment status and any changes to agreement. Await sponsor approval before allowing any J-1 student to begin work. Pay overtime in accordance with state-specific and federal employment laws, in addition to the prevailing wage. Following is our response to each of these rules: The Sponsors with whom we worked asked us for our EIN and Worker's Comp #. We see no reason to send them a copy of our LLC document that is already on the web site of the Sec. of State for Colorado. Anyone can go check us out and see that we are a business in good standing with the state of Colorado. We made our decisions in March as I noted in my last email to you. Again - that seems to have made no difference to the Russian government which has yet to determine if the student we had planned to hire from there will be able to come. Also, we had a late request from another student who just wasn't sure if she had all her documents together early enough. We knew we couldn't hire someone else, but if she found another employer, she shouldn't be denied because she was a little late by your new system. Are you going to write up the contracts? We are already in receipt of the Employer Handbook and other materials sent to us by InterChange, and we are confident that they send o