> This is a de facto shutdown of the program

Is it? $100k per hire isn't much of a cost to pay for large companies. Smaller companies may -- may -- end up having some trouble with this, but consider that $100k often amounts to less than a yearly base salary (and will pretty much always be less than a year of total comp/total employee cost), not to mention the costs of legal staff that they're already paying to deal with this stuff.

What this may do is cause some of the "body shop" consultancies to drop some of their "low end" business, so they'll focus more on targeting positions with higher salaries. That's... probably a good thing.

And yeah, we may see some higher rates of offshoring, but I don't think that will be significant. And I'm not even really convinced: offshoring is already possible, and in strict dollar terms is already cheaper than going through the H-1B process to bring someone to the US. If companies preferred offshoring, they'd be doing it; clearly the already-higher-cost H-1B program is still their preference.

I agree that this isn't going to fix the H-1B visa system, and is not a reform or even a particularly positive step toward a reform, but I think you're overestimating the negative impact. I really don't think this will change things much at all.