Classifying Foreign Labor and Student Enrollment: A New NAICS Framework
In 2024, foreign-born workers comprised 27.4% of the U.S. labor force, contributing to industries such as high-tech, healthcare, construction, and agriculture.
Meanwhile, over 1.5 million international students on F-1, J-1, and OPT/CPT programs generated $46.2 billion in direct economic activity, supporting nearly 400,000 U.S. jobs in housing, education, services, and transportation (IIE Open Doors 2024).
Despite their significant economic impact, foreign labor and international student enrollment lack clear classification and oversight, operating in a regulatory blind spot compared to industries like finance or manufacturing.
Under OnShoringAmerica.com, the Industry Framework Paper proposes a pragmatic solution: classifying these sectors as standalone U.S. industries under the North American Industry Classification System (NAICS). This enables structured oversight, transparent reporting, and targeted taxation without altering immigration status or restricting legal participation.
Proposed NAICS Codes
- NAICS 561399 – Foreign Labor Placement and Management Services
Covers the placement, management, and payroll of 16.7 million documented non-citizen workers, including H-1B, H-2A/B, EAD, OPT/CPT, green card holders, and offshore labor.
- NAICS 611319 – International Student Enrollment and Compliance Services
Encompasses recruitment, admissions, SEVIS reporting, and visa compliance for over 1.5 million international students in U.S. universities.
Benefits of Classification
Formal NAICS classification allows the U.S. to:
- Track economic contributions and labor impacts.
- Apply levies to fund American worker training and student scholarships.
- Enhance national security vetting for sensitive roles and fields.
- Integrate with existing systems (SEVIS, IRS, E-Verify) for efficiency.
This approach focuses on economic accountability, not immigration politics, ensuring foreign labor and student enrollment serve U.S. interests in education, labor equity, and security.
Conclusion
Foreign labor and international student enrollment are multi-billion-dollar industries. By recognizing them under NAICS 561399 and 611319, the U.S. can regulate these sectors with transparency and efficiency, prioritizing American workers and students while leveraging existing infrastructure.