NIW Bearings
remandedFEB172021_03B52032021-02-17 · appeal · Texas Service Center

This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.

The Petitioner, a Brazilian-trained physician, initially proposed to work as a 'Physician Researcher' conducting medical research in women's and children's health, then later, in response to an RFE, changed her proposed endeavor to working as a nurse practitioner and nurse midwife providing patient care.

Field: medicine / women's and children's health · Read the decision (uscis.gov)

EB-2 threshold — addressed

The Director's RFE assumed advanced-degree eligibility based on a foreign medical degree, but the submitted credential evaluation was unclear and combined academics with five years of experience rather than establishing degree equivalence alone; the evaluator also appears to have copied experience directly from the resume rather than reviewing employer letters. AAO withdrew the Director's conclusion and remanded for a proper threshold determination.

Prong 1 — national importancenot established

we withdraw the Director's conclusions that the Petitioner has established the substantial merit of the proposed endeavor
Here, the Petitioner did not clarify her specific proposed endeavor, but rather changed it from that of a "physician researcher" to a "nurse practitioner and nurse midwife."
A petitioner may not make material changes to a petition in an effort to make a deficient petition conform to USCIS requirements.

AAO decision text

Prong 2 — well positionednot established

we withdraw the Director's conclusions that ... she is well positioned to advance the proposed endeavor.

AAO decision text

How the evidence was treated

  • degree · discounted
    it is not clear whether any of the Petitioner's degrees alone are the foreign equivalent of either a bachelor's or advanced degree.
    AAO decision text
  • resume experience · discounted
    We note that the section regarding her professional experience is copied directly from her resume.
    AAO decision text

Where this case turned

  • Endeavor too vague · p1described as a job role, not a defined undertaking
  • Material change of endeavor · p1the endeavor described on appeal is not the one filed
  • Material change of endeavor · p2the endeavor described on appeal is not the one filed
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Notable

The Petitioner materially changed her proposed endeavor mid-adjudication, shifting from 'Physician Researcher' to 'Nurse Practitioner and Nurse Midwife' in response to the RFE, without explanation. AAO invoked Matter of Izummi's bar on material changes to petitions and remanded for the Director to first resolve threshold EB-2 eligibility (which the Director had never actually addressed) before reaching the Dhanasar prongs.

Authorities this decision leans on

From the doctrinal survivor set — 187 authority tests across 47 distinct authorities cleared the differential-lift gates. Only those appear here.

  • 8 C.F.R. 103.2(b)(1)
  • 8 C.F.R. 103.2(b)(12)
  • 8 C.F.R. 103.2(b)(8)
  • 8 C.F.R. 204.5(k)(2)
  • 8 C.F.R. 204.5(k)(3)(ii)
  • INA 203(b)(2)
  • Matter of Izummi
  • Poursina v. USCIS

What this case teaches

Analyst reading of the decision text.

Decisive factor

Petitioner materially changed her proposed endeavor after the RFE (physician researcher to nurse practitioner/midwife), preventing any coherent Dhanasar prong-1 analysis; also unresolved EB-2 qualification threshold.

Transferable lesson

Define the specific proposed endeavor once, consistently, and early; never alter its core identity in response to an RFE, as this triggers the Izummi material-change bar.

Endeavor framing

vague

National-importance theory

public_health · field_advancement · geographic_or_shortage_area

Evidence targeting

person_focused

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