If they are just using the program to pay less than they otherwise would for labor that does exist in the us, well, then we have another issue.
I would modify the proposal to include a larger annual fee rather than an application fee, so that the initially sponsoring company isn’t solely bearing the cost. There should also be a floor pay rate for the visa holder, something the 75th or 80th percentile of both the company and of income in the MSA the visa holder is located in.