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The executive order requires:

A. The head of every executive department and agency (agency) to review, contracts (including subcontracts) awarded by the agency in fiscal years 2018 and 2019 to check:

(i) If contractors (including subcontractors) used temporary foreign labor for contracts performed in the United States

(2) the nature of the work performed by temporary foreign labor on such contracts

(3) whether opportunities for United States workers were affected by such hiring

(4) and any potential effects on the national security caused by such hiring.

(5) whether contractors (including subcontractors) performed in foreign countries services previously performed in the United States, and, if so, whether opportunities for United States workers were affected by such off-shoring;

(6) whether affected United States workers were eligible for assistance under the Trade Adjustment Assistance program authorized by the Trade Act of 1974; and

(7) any potential effects on the national security caused by such off-shoring.

B. The head of each agency to determine negative impact of contractors’ and subcontractors’ temporary foreign labor hiring practices or off-shoring practices on the economy and efficiency of Federal procurement and on the national security, and propose action, if necessary and as appropriate and consistent with applicable law, to improve the economy and efficiency of Federal procurement and protect the national security.

C. The head of each agency to coordination with the Director of the Office of Personnel Management, in reviewing the employment policies of the agency to assess the agency’s compliance with Executive Order 11935 of September 2, 1976 (Citizenship Requirements for Federal Employment), and section 704 of the Consolidated Appropriations Act, 2020, Public Law 116-93.

D. The head of each agency within 120 days to submit a report to the Director of the Office of Management and Budget summarizing the results of the reviews required; recommending, if necessary, corrective actions that may be taken by the agency and timeframes to implement such actions; and proposing any Presidential actions that may be appropriate.

E. DOL and DHS within 45 days to take action, to protect United States workers from any adverse effects on wages and working conditions caused by the employment of H-1B visa holders at job sites (including third-party job sites), including measures to ensure that all employers of H-1B visa holders, including secondary employers, adhere to the requirements of section 212(n).

The order is likely to result in IT Services companies finding it difficult to renew or obtain federal contracts, and may result in end-clients be required to file an LCA, or some form of attestation to not replacing U.S. workers.