The petitioner, an assistant professor of medicine and internal medicine physician, proposed to continue clinical practice, physician training, and medical research aimed at improving primary care delivery and addressing physician shortages, chronic disease management, and non-opioid pain treatment.

Prong 1 — national importancenot established · dispositive

“the statement failed to provide specific insight as to what he intends to do as a physician”

“Because the Petitioner does not sufficiently explain his specific undertaking, we are precluded from determining whether the proposed endeavor has substantial merit and national importance”

“The Petitioner's reliance on broad, unsupported statements concerning the healthcare industry in the United States is insufficient to establish the substantial merit of his proposed endeavor.”

“a shortage in the occupation alone is insufficient to demonstrate the national importance of a proposed endeavor”

“The Petitioner has not described the specific focus of his proposed research, or where or by what means he would conduct his research.”

“The Petitioner's explanation on appeal does not add specificity to his proposed endeavor.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “these letters do not discuss his proposed endeavor”

  AAO decision text
• resume experience · discounted

  “The Petitioner makes general statements about his past career accomplishments”

  AAO decision text
• citations publications · discounted
• certification membership · credited
• other · discounted

  “a shortage in the occupation alone is insufficient to demonstrate the national importance of a proposed endeavor”

  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
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

AAO explicitly distinguishes the physician-specific national interest waiver shortage provisions at 8 C.F.R. 204.12 from the Dhanasar framework, clarifying that SCOPS's reference to those regulations was not a basis for denial but an explanation that occupational shortage alone is insufficient. A footnote also preemptively addresses prongs 2 and 3, stating the appeal would have been dismissed on those grounds as well even though the AAO formally declined to reach them.

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. 103.3
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(1)

Cases in adjacent profiles

• The Petitioner, a pharmacist, proposed to work in the United States through her own company providing pharmaceutical reg
• The Petitioner, a Brazilian-trained physiotherapist, proposed to work as a physical therapist and entrepreneur in the Un
• The Petitioner, a resident physician in New York holding a Chinese bachelor of medicine (MBBS) degree found equivalent t
• The Petitioner, a music therapist, proposed to establish and expand music therapy services and community music programs
• The Petitioner, a physical therapist, proposed to work as a physical therapist in the United States while operating his