The Petitioner, a public health specialist with 20 years at WHO, proposed to work with U.S. federal, state, and territorial agencies, NGOs, or international organizations on vaccination access and communicable disease prevention, without identifying a specific employer, project, or role.

Prong 1 — national importancenot established · dispositive

“the exact nature of [his] proposed endeavor is not apparent”

“the issue here is not the substantial merit and national importance of the field of public health...but rather the substantial merit and national importance of the specific endeavor the Petitioner proposes to undertake”

“the Petitioner has not sufficiently identified his proposed work for these organizations or shown that the specific public health projects he plans to undertake support a finding of national importance”

“Without sufficient information or evidence regarding any projected U.S. economic impact or job creation attributable to his future work, the record does not show..."substantial positive economic effects"”

“The Petitioner, however, does not explain the public health capacity in which he will work to address the U.S. coronavirus pandemic”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “a political science scholar, does not claim to be an expert in U.S. public health matters”

  AAO decision text
• resume experience · discounted

  “The Petitioner's skills, knowledge, and professional accomplishments relate to the second prong of the Dhanasar framework”

  AAO decision text
• other · discounted

  “the Petitioner has not identified the specific public health projects he plans to undertake in the United States”

  AAO decision text
• other · discounted

  “has not sufficiently identified his proposed work for these organizations or shown that the specific public health projects he plans to undertake support a finding of national importance”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

A supporting letter used NYSDOT-era terminology ('substantial intrinsic merit' and 'national in scope') rather than Dhanasar's framework; the AAO expressly noted this mismatch and clarified the correct standard. The AAO also rejected reliance on a COVID-era doctor/nurse shortage bill as establishing national importance for this petitioner's unrelated public health role.

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.

• INA 203(b)(2)
• Poursina v. USCIS

Cases in adjacent profiles

• The Petitioner proposed to work as an IT consultant in the United States, providing cybersecurity and digital transforma
• The petitioner proposed to establish his own company providing specialized business consultancy, auditing, and training
• The petitioner proposed to work as a consultant engineer through his own company, specializing in development projects t
• The Petitioner proposed to start a project management consultancy in the United States that would help small and mid-siz
• The Petitioner proposed to establish a legal consultancy in the United States focused on alternative dispute resolution