Introduction This morning, the Department of Homeland Security proposed replacing the H-1B lottery with a weighted system that favors workers certified at higher Department of Labor (DOL) “Wage Levels.”1 On the surface, this seems like a merit-based reform: higher wages should mean higher skills. In reality, DOL’s Wage Levels are very different from actual wages. The Wage Level framework was never designed to compare wages across occupations because it measures relative seniority within a job ca...