dismissed EB-2 NIW Case: Administrative And Financial Management

U.S. Citizenship 
and Immigration 
Services 
In Re: 19586126 
Appeal of Texas Service Center Decision 
Non-Precedent Decision of the 
Administrative Appeals Office 
Date: DEC. 09, 2021 
Form 1-140, Immigrant Petition for Alien Worker (Advanced Degree, Exceptional Ability, National 
Interest Waiver) 
The Petitioner, an administrative and financial manager, seeks second preference immigrant 
classification as an individual of exceptional ability in the sciences, arts or business, as well as a 
national interest waiver of the job offer requirement attached to this EB-2 classification. See 
Immigration and Nationality Act (the Act) section 203(b)(2), 8 U.S.C. § 1153(b)(2). After a petitioner 
has established eligibility for EB-2 classification, U.S. Citizenship and Immigration Services (USCIS) 
may, as matter of discretion, grant a national interest waiver if the petitioner demonstrates: (1) that the 
foreign national's proposed endeavor has both substantial merit and national importance; (2) that the 
foreign national is well positioned to advance the proposed endeavor; and (3) that, on balance, it would 
be beneficial to the United States to waive the requirements of a job offer and thus of a labor 
certification. Matter of Dhanasar, 26 l&N Dec. 884 (AAO 2016). 
The Director of the Texas Service Center determined that the Petitioner qualifies for the underlying 
classification and that his proposed endeavor has substantial merit. Nevertheless, the Director denied 
the petition, concluding that the evidence did not establish that the proposed endeavor is of national 
importance, that he is well positioned to advance his endeavor, or that a waiver of the requirement of 
a job offer would be in the national interest. Accordingly, the Director determined that the Petitioner 
had not established eligibility for a national interest waiver. 
The matter is now before us on appeal. The Petitioner reasserts his eligibility, arguing that the Director 
did not properly weigh the evidence and erred in the decision. 
In these proceedings , it is the Petitioner's burden to establish eligibility for the requested benefit 
Section 291 of the Act, 8 U.S.C. § 1361. Upon de nova review, we will dismiss the appeal. 
I. LEGAL FRAMEWORK 
To establish eligibility for a national interest waiver, a petitioner must first demonstrate qualification 
for the underlying EB-2 visa classification (emphasis added), as either an advanced degree 
professional or an individual of exceptional ability in the sciences, arts, or business. Because this 
classification requires that the individual's services be sought by a U.S. employer, a separate showing 
is required to establish that a waiver of the job offer requirement is in the national interest. 
Section 203(b) of the Act sets out this sequential framework: 
(2) Aliens who are members of the professions holding advanced degrees or aliens of 
exceptional ability. -
{A) In general. - Visas shall be made available ... to qualified immigrants who are 
members of the professions holding advanced degrees or their equivalent or 
who because of their exceptional ability in the sciences, arts, or business, will 
substantially benefit prospectively the national economy, cultural or 
educational interests, or welfare of the United States, and whose services in the 
sciences, arts, professions, or business are sought by an employer in the United 
States. 
(B) Waiver of job offer -
(i) National interest waiver .... [T]he Attorney General may, when the Attorney 
General deems it to be in the national interest, waive the requirements of 
subparagraph (A) that an alien's services in the sciences, arts, professions, or 
business be sought by an employer in the United States. 
Section 101 (a)(32) of the Act provides that "[t]he term 'profession' shall include but not be limited to 
architects, engineers, lawyers, physicians, surgeons, and teachers in elementary or secondary schools, 
colleges, academics, or seminaries." 
The regulation at 8 C.F.R. § 204.5(k)(2) contains the following relevant definitions: 
Advanced degree means any United States academic or professional degree or a foreign 
equivalent degree above that of baccalaureate. A United States baccalaureate degree 
or a foreign equivalent degree followed by at least five years of progressive experience 
in the specialty shall be considered the equivalent of a master's degree. If a doctoral 
degree is customarily required by the specialty, the alien must have a United States 
doctorate or a foreign equivalent degree. 
Exceptional ability in the sciences, arts, or business means a degree of expertise 
significantly above that ordinarily encountered in the sciences, arts, or business. 
Profession means one of the occupations listed in section 101(a)(32) of the Act, as well 
as any occupation for which a United States baccalaureate degree or its foreign 
equivalent is the minimum requirement for entry in the occupation. 
In addition, the regulation at 8 C.F.R. § 204.5(k)(3)(ii) sets forth the specific evidentiary requirements 
for demonstrating eligibility as an individual of exceptional ability. A petitioner must submit 
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documentation that satisfies at least three of the six categories of evidence listed at 8 C.F.R. 
§ 204.5(k)(3)(ii). 
Furthermore, while neither the statute nor the pertinent regulations define the term "national interest," 
we set forth a framework for adjudicating national interest waiver petitions in the precedent decision 
Matter of Dhanasar, 26 l&N Dec. 884 (AAO 2016). In announcing this new framework, we vacated 
our prior precedent decision, Matter of New York State Department of Transportation, 22 l&N Dec. 
215 (Act. Assoc. Comm'r 1998). Dhanasar states that after a petitioner has established eligibility for 
EB-2 classification, U.S. Citizenship and Immigration Services (USCIS) may grant a national interest 
waiver as matter of discretion. See also Poursina v. USCIS, 936 F.3d 868, 2019 WL 4051593 (9th 
Cir. 2019) (finding USCIS' decision to grant or deny a national interest waiver to be discretionaiy in 
nature). As a matter of discretion, the national interest waiver may be granted if the petitioner 
demonstrates: (l) thatthe foreign national' s proposed endeavor has both substantial merit and national 
importance; (2) that the foreign national is well positioned to advance the proposed endeavor; and (3) 
that, on balance, it would be beneficial to the United States to waive the requirements of a job offer 
and thus of a labor certification. See Dhanasar, 26 l&N Dec. at 888-91, for elaboration on these three 
prongs. 
11. ANALYSIS 
A Advanced Degree Professional 
In order to show that a petitioner holds a qualifying advanced degree, the petition must be accompanied 
by"[ a ]n official academic record showing that the [individual] has a United States advanced degree 
or a foreign equivalent degree." 8 C.F.R. § 204.5(k)(3)(i)(A). Alternatively, a petitioner may present 
"[a]n official academic record showing that the [individual] has a United States baccalaureate degree 
or a foreign equivalent degree, and evidence in the form of letters from current or former employer(s) 
showing that the [individual] has at least five years of progressive post-baccalaureate experience in 
the specialty." 8 C.F.R. § 204.5(k)(3)(i)(B). 
The Director concluded that the Petitioner qualifies for the underlying classification. The record contains 
evidence that the Petitioner earned a four-year foreign degree in administration.,!D....fil!m?ort of the U.S. 
eauivalencyof his foreign education, the Petitioner submitted an evaluation from L__Jevaluatorl I I I Because USCIS does not accept equivalency evaluations of work experience, we examine the 
evaluation for the academic equivalency portion of the evaluation only. The evaulation largely contains 
temp lated language found in numerous evaluations provided by other evaluation service providers and 
submitted on behalf of other petitioners. Aside from the names of his universities and the academic 
programs he attended, the only information specific to the Petitioner's education is a bulleted list of 
several courses from the Petitioner's transcript. This list, and the evaluator's conclusions following it, are 
insufficient to establish the U.S. equivalency of the Petitioner's education. To illustrate, the evaluator 
lists some of the Petitioner's courses including "introduction to operations research," "business 
economics," and "personnel management and industrial relations." The evaluator then concludes that 
these courses are a requisite component of a bachelor's degree education in the United States. It is not 
apparent how the evaluator arrived atthe conclusion that courses such as these are general studies courses 
or that they form a requisite component of U.S. bachelor's degree programs. Accordingly, we conclude 
that this evaluation is of little probative value in this matter. 
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We may, in our discretion, use an evaluation of a person's foreign education as an advisory opinion. 
Matter of Sea, Inc., 19 I&N Dec. 817, 820 (Comm'r 1988). However, where an opinion is not in 
accord with other information or is in any way questionable, we may discount or give less weight to 
that evaluation. Id. Here, the evaluator does not demonstrate specific knowledge of the Petitioner's 
foreign university or how his credit hours, grades, and the content of his courses translate to a U.S. 
education, nor does the evaulator offer sufficient analysis or support for the conclusions contained in the 
evaluation. As such, we conclude thatthis evaluation is insufficientto establish theacademicequivalency 
of the Petitioner's foreign education. 
We acknowlege an advisory opinion of the Petitioner's eligibility under the national interest waiver 
framework, which the Petitioner obtained froml c I, a professor aOuniversity. This 
advisory opinion references the Petitioner's foreign education, but does not offer any analysis of it and 
therefore is not probative of its U.S. equivalency. While the Petitioner also submitted evidence of three 
professional certificates, one in business management and two in health management, the record does 
not reflect that this education rises to the level of any U.S. degree. We acknowledge that the business 
management professional certificate includes "MBA" in its description and may have involved 
master's level coursework; however, the record is insufficient to conclude that this coursework 
resulted in the completion of an actual master's degree education. Nor does the record establish that 
such coursework is the equivalent of a U.S. master's degree. 
Based on the information contained in the record, the Petitioner has not met his burden to establish the 
U.S. equivalency of his foreign education in accordance with 8 C.F.R. § 204.5(k)(3)(i)(B). The 
Petitioner should be prepared to address this evidentiary shortcoming in any future filings. 
Nevertheless, we reviewed the AACRAO EDGE database to determine whether the Petitioner's 
foreign education is comparable to any U.S. degree. The AACRAO EDGE database is a reliable 
resource concerning the U.S. equivalencies of foreign education. For more information, visit 
https://www.aacrao.org/edge (last visited Dec. 9, 2021 ). The database indicated that the Petitioner's 
four-year "Tftulo de Bacharel" in administration is the equivalent of a U.S. bachelor's degree. While 
the Petitioner has not provided sufficient evidence to support a finding that his foreign degree is the 
equivalent of U.S. bachelor's degree, we accept and rely upon the information found in the AACRAO 
EDGE database to conclude that he holds the equivalent of a U.S. bachelor's degree. 
In response to the Director's request for evidence (RFE), the Petitioner provided a letter from his former 
employer, which describes the Petitioner's work experience in the administrative and financial 
management field of endeavor. The letter summarizes the Petitioner's duties in his former position and 
confirms the dates of his employment. Accordingly, the record establishes by a preponderance of the 
evidence that the Petitioner has at leastf iveyears of post-baccalaureate experience in his field. As such, 
we conclude that the Petitioner qualifies for the underlying classification as a member of the professions 
holding an advanced degree. The remaining issue to be determined is whether he qualifies for a national 
interest waiver. 
For the following reasons, we agree with the Director that the evidence does not establish that the 
Petitioner qualifies for a national interest waiver. While we do not discuss each piece of evidence 
individually, we have reviewed and considered each one. 
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B. National Interest 
The Petitioner stated on his Form 1-140 that he intends to plan, direct, and coordinate the services of 
an organization. In his initial filing, he offered few specifics about his proposed endeavor but 
described it in terms of his past work and the national interest he believes his endeavor will have. He 
stated in his initial letter that he has unique expertise, vast experience, and a proven record of success 
in business administration, financial management, health management, relationship management, 
strategic planning, and consulting in the healthcare administration field in Brazil. The Petitioner 
concluded that his qualifications are of substantial merit and importance to the United States and 
further concluded that the "merit and importance of my work for U.S. companies doing business or 
planning to do business in Brazil would be even greater given the current context of political 
turbulence and challenging economic conditions in Brazil." I ~noted in his evaluation 
of the Petitioner's eligibility for a national interest waiver that business and financial managers with 
knowledge of the business, health, and financial industries in Brazil are of substantial mer it and 
national importance. ~-----~further commented that the high and growing demand for 
business and financial managers and the benefits they can offer U.S. companies establishes the 
national importance of the Petitioner's endeavor. 
The Director's RFE informed the Petitioner that, among other deficiencies, the evidence did not 
establish the national importance of the proposed endeavor. Specifically, the Director noted that the 
evidence did not establish that the endeavor would have implications beyond the specific employer 
and clients the Petitioner wou Id work with, nor did the Petitioner's assertion concerning the demand 
for financial managers establish that the Petitioner's proposed endeavor would have broader 
implications in the field rising to the level of national importance. In his RFE response, the Petitioner 
provided a personal plan and statement outlining the services he will provide U.S. companies. While 
we will not repeat each one here, we acknowledge that among such services, the Petitioner plans to 
create innovative financial analysis tools; develop and implement customized tools to maximize 
growth and improve business performance; and implement best practices and methodologies in 
business management. In addition, the Petitioner offered additional information concerning his 
endeavor, including that he will: 
[W]ork as an independent Administrative Manager providing business and financial 
management consulting services to medium and large sized nonprofit organizations, 
especially ones in the healthcare[] industry ... continue to develop and implement 
innovative financial and business management solutions for organizations, with the 
goal of reducing their costs, optimizing business processes, increasing revenues, and 
preventing unnecessary expenses ... work closely with his vast professional network 
to develop partnerships and offer his services ... provide training services to U.S. 
organizations and business professionals by conducting workshops, seminars, lectures, 
and training sessions, with the objective of spreading his unique expertise and 
knowledge to other professionals in the field. 
The Petitioner also offered numerous explanations for why his proposed endeavor has national 
importance, including that through the Petitioner's training of other professionals, they will be able to 
learn and replicate histechniqueswithin their own organizations, which would generate abroad impact 
in his field. He stated that "[b]yeliminating losses and mitigating financial risks, companies will have 
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more money to invest in other initiatives, generating more jobs in the U.S. economy and providing 
vital care for people in the United States." 
The Petitioner provided financial projections for the cost savings and financial benefits that he intends 
to generate for U.S. organizations, which included a financial forecast of 14.4 million dollars by year 
five of his proposed endeavor. The Petitioner provided these financial projections to an independent 
economic analysis consulting organization, which analyzed his projections and described them in 
terms of their macroeconomic impact. The consulting organization concluded that the five-year total 
economic impact across all industries in the United States is estimated at 28.5 million dollars and the 
total employment impact is the creation of 246 full-time jobs. The consulting organization further 
estimated that the proposed endeavor "has the potential of generating substantial economic impact in 
the United States, including increase in economic activity, creation of hundreds of jobs, increase in 
wages and salaries, and increase in tax revenue for the federal, state, and local governments." 
In addition, the Petitioner provided a letter from j J the CEO and general 
superintendent of the Petitioner's former employer 11 r praised the Petitioner's 
personal and professional qualities and achievements. He also asserted that the Petitioner's work is 
critically important because the improvement of non prof it healthcare organizations' operations and 
financials enable them to provide more care for people that cannot afford to pay for health insurance 
or medical treatments.I I provided helpful nonprofit healthcare background information and 
also concluded that the Petitioner will bring extraordinary financial gain and results to the companies 
he works for in the United States. 
After a thorough review of the evidence, the Director concluded that it was insufficient to establish 
the national importance of the proposed endeavor because it did not demonstrate how the Petitioner's 
work would affect or advance the broader industry or otherwise impact his field. The Director 
acknowledged the Petitioner's claims of economic and job creation impact but determined that the 
evidence provided did not support such claims. We agree. 
In our de nova review of the record, we conclude that the Petitioner has not established the national 
importance of his proposed endeavor. Although we recognize that having a job or a job offer is not 
an eligibility requirement for a national interest waiver, the Petitioner has not offered sufficient 
evidence of the viability of his proposed work such that he has substantiated his claims about its 
impact. The purpose of the national interest waiver program is not to enable a petitioner to engage in 
a U.S. job search. Although the Petitioner provided a letter from a Florida branch of I I in 
which the manager for decision support and business development acknowledged the Petitioner's 
useful experience, he did not meaningfully describe the nature of howl I would engage 
with the Petitioner in the future. In addition, the manager specifically stated that the Petitioner's 
permanent residence is a prerequisite to any further discussion. The Petitioner has not offered the 
names of any other specific organizations that he will work with or how he will provide his consulting 
services to U.S. companies. This is significant, as it is not apparent which nonprofit companies, if 
any, have the need for his financial and administrative management. In Dhanasar, we held that a 
petitioner must identify "the specific endeavor that the foreign national proposes to undertake." Id. at 
889. While the Petitioner's administrative and financial management consulting services may be 
useful, the impact of such services is difficult to ascertain without a sufficient showing of how the 
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companies the Petitioner plans to work with are currently managed and whether such companies 
already implement the administrative and financial methods that the Petitioner would provide. 
In examining the opinion letter from~-----~ we observe that he based his conclusions 
concerning national importance upon an assumption that the Petitioner's in-depth knowledge of 
business and financial management in Brazil will offer U.S. companies the ability to seize market and 
investment opportunities in Brazil. He concluded that this would enhance U.S. companies' marketing 
and sales capabilities. However, the Petitioner has not explained what U.S. companies are seeking to 
expand their business into Brazil or Latin America or how this would function in the administrative 
and financial management or healthcare contexts. Accordingly, weconcludetha~ l's 
conclusions on this topic are unsubstantiated. We also acknowledge! f s assertions 
concerning the demand for administrative and financial managers and the estimated growth of this 
field; however, in determining national importance, the relevant question is not the importance of the 
industry or profession in which the individual will work. Instead, we focus on the "the specific 
endeavor that the foreign national proposes to undertake." Id. at 889. As a matter of discretion, we 
may use opinion statements submitted by the Petitioner as advisory. Matter of Caron Int'!, Inc., 19 
I&NDec. 791,795 (Comm'r 1988). However, we will reject an opinion or give it less weight if it is 
not in accord with other information in the record or if it is in any way questionable. Id. We are 
ultimately res po nsi b le for making the final determination regarding an individual's eligibility for the 
benefit sought; the submission of expert opinion letters is not presumptive evidence of eligibility. Id. 
Here,~-----~'s opinions are of little probative value as he has not offered sufficient 
evidence to substantiate them. 
In Dhanasar, we noted that "we look for broader implications" of the proposed endeavor and that 
"[ a ]n undertaking may have national importance for example, because it has national or even global 
implications within a particular field." Id. We also evaluate whether the Petitioner's proposed 
endeavor satisfies the national importance requirement by looking to evidence that documents the 
"potential prospective impact" of his work. To illustrate, "[ a ]n endeavor that has significant potential 
to employ U.S. workers or has other substantial positive economic effects, particularly in an 
economically depressed area, for instance, may well be understood to have national importance." See 
Dhanasar, 26 l&N Dec. at 890. 
The Petitioner offered specific financial cost savings projections but little basis for such numbers. 
Although he provided the total savings his proposed endeavor would create each year for five years, 
the Petitioner has not explained how he will achieve these figures, which would necessarily depend 
on the number of organizations he plans to work with and their individual financial situations. As the 
record currently stands, these projections appear to be little more than conjecture. Furthermore, as the 
independent consulting organization's impact analysis report relied upon the figures the Petitioner 
provided without inquiring into their basis or accuracy, the conclusions provided in the report offer 
little meaningful information about the actual impact of the Petitioner's proposed endeavor. To 
illustrate by example, the report stated that in the first year, the Petitioner"plans to generate" $635,000 
in cost savings and financial benefits to U.S. organizations; however, the report offered no independent 
basis or analysis concerning how the Petitioner will actually generate such savings and benefits. As 
such, we question the validity of the report's projections concerning the number of jobs created and 
the effect the proposed endeavor will have across industries. We conclude that the Petitioner's 
7 
financial projections and the corresponding financial analysis report are of little to no probative value 
in this matter as neither first establishes the validity and basis for the figures provided. 
The Petitioner highlighted his past achievements in order to illustrate how his proposed endeavor 
might achieve a similar impact. In so doing, he provided recommendation letters from former 
colleagues who offer praise of the Petitioner's personal and professional qualities but do not 
demonstrate knowledge of the Petitioner's proposed endeavor. Although the authors of the letters 
highlight the Petitioner's past achievements, there is little indication from the letters that his 
achievements impacted the field of administrative and financial management as a whole, nor do the 
authors' examples suggest that the Petitioner's impact extended beyond the nonprofit healthcare 
organizations he worked with or the specific individuals they served. Furthermore, the authors provide 
insufficiently detailed examples of the Petitioner's work. For instance.I I the 
national managing director atl I asserted that the Petitioner's strategy and management of the 
organization enabled it to be active and productive, provided a source of hope and pride for the city, 
and operated at a surplus, but the author did not offer details of the Petitioner's specific strategy or 
management. Similarly,.__ ________ __. mentioned how the Petitioner negotiated an 
alteration to a city-wide resolution, which opened new sources of funding, but the letter lacks an 
~ation of what exactly the Petitioner did in the negotiations. Finally.I I 
L__Jdescribed how the Petitioner liaised with local politicians and the community, but she did not 
provide sufficient specific details aboutwhatthe Petitioner did to cooperate with these entities or what 
funding he received and how. Overal I, even if we accept th at the Petitioner transformed the nonprofit 
healthcare sector in Brazil, the Petitioner has not explained how his past achievements would suggest 
future success in the United States, a country which features a vastly different healthcare landscape 
along with differenttax and financial regulations. 
Although I I offers some specific information on the results the Petitioner produced for 
,___ _ ___,] none of the achievements or results a pear to have impacted the field of administrative and 
financial mana ement as a whole. asserted that the Petitioner's methods were innovative, 
while.__ ________ ___, a public prosecutor in Brazil, similarly wrote that the Petitioner 
offers uniquetechniques. However, neither! lnorl I explained what 
the Petitioner's innovative methods and unique techniques are. Although the authors hold the 
Petitioner in high regard, we conclude that generalized conclusory statements that do not identify a 
specific impact in the field have little probative value. See 1756, Inc. v. U.S. Att'y Gen., 745 F. Supp. 
9, 15 (D.D.C. 1990) (holding that an agency need not credit conclusory assertions in immigration 
benefits adjudications). The submission of reference letters supporting the petition is not presumptive 
evidence of eligibility; USCIS may evaluate the content of those letters so as to determine whether 
they supportthe petitioner's eligibility. Id. See also Matter ofV-K-, 24 l&N Dec. 500, n.2 (BIA2008) 
(noting that expert opinion testimony does not purport to be evidence as to "fact"). 
Likewise, while we acknowledge the Petitioner's claims in his personal plan and statement that he has 
developed sophisticated solutions and tools, as well as unique solutions and methods, these claims 
have not been substantiated. Although the Petitioner's professional plan and statement included 
methodologies and best practices for his proposed endeavor, the examples provided appear to be basic 
and straightforward business and financial management concepts, such as a balanced financial 
scorecard. In examining the work product examples of his financial models and reports, we first note 
that they are not accompanied by English translations. In addition, they appear to be merely a table 
8 
off igureswith no explanation of how they are the product of innovative, unique, orsophisticatedtools 
and techniques. Accordingly, we conclude that the evidence does not support a finding that the 
Petitioner has developed tools, models, methods, or techniques that have impacted the field of 
administrative and financial management. 
The Petitioner has also not substantiated how his proposed activities of training other professionals 
will have broader implications in the field that would rise to the level of national importance. He has 
not explained how his methods are different from those already used in the United States, nor has he 
provided estimates of how many organizations or individuals are interested in his training. Even if he 
provides such training, the Petitioner has not established how such work would be on a scale so 
substantial as to rise to the level of national importance. In Dhanasar, we determined that the 
petitioner's teaching activities did not rise to the level of having national importance because they 
would not impact his field more broadly. See Dhanasar, 26 l&N Dec. at 893. Here, the Petitioner has 
also not established how his training would impact the field more broadly. 
On appeal, the Petitioner asserts that, in part, his proposed endeavor is nationally important due to the 
importance of helping those with disabilities. While we acknowledge that improving the 
administrative and financial health of nonprofit healthcare entities may result in better service to the 
patients requiring treatment, the Petitioner has not substantiated how the results he will achieve would 
be on such a scale as to rise to the level of national importance. We agree that healthcare and treating 
individuals with disabilities is important; however, the Petitioner must establish the national 
importance of his specific proposed endeavor as opposed to the field in general. As already noted by 
the Director, while the proposed endeavor may impact the specific organizations that employ the 
Petitioner's services and the clients that they serve, this does not establish that the proposed endeavor 
is nationally important, as such an impact lacks broader implications for the field or the nation as a 
whole. The Petitioner argues on appeal that his proposed endeavor will strengthen communities 
because itwill enable more persons with disabilitiesto be treated and reenter the labor force. However, 
the Petitioner has not provided corroborating details on how many people will be treated as a result of 
his proposed endeavor activities, how many of those individuals will experience success in their 
treatments, or how many of those individuals will enter the labor market following treatment. In 
addition, simply entering the labor market does not establish that jobs will be created or available to 
them as a result of the proposed endeavor. Therefore, the community and economic impact of his 
proposed endeavor has not been substantiated. 
The Petitioner again emphasizes his past achievements with his former employer in Brazil to assert 
that he can achieve similar results in the United States. Although we acknowledge the Petitioner's 
past successes, including the number of patients his former employer treated while under the 
Petitioner's management as well as the cost savings he achieved for the organization, he has not 
identified how these achievements translate to the national importance of the proposed endeavor. The 
Petitioner has not supported his proposed endeavor with specific information on which organizations 
he will serve, their financial health, the number of patients that will be affected, or how he would 
replicate his success within the context of the U.S. healthcare system. 
On appeal, the Petitioner argues that the Director incorrectly determined that his financial projections 
over a five-year period lacked supporting evidence in how they were calculated. In response, the 
Petitioner offers circular reasoning by referring our attention to the economic analysis impact report 
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as a basis for his calculations. As previously explained, the author of this report based his conclusions 
on the figures the Petitioner provided and did not explain how those original figures were calculated. 
The Petitioner further explains that he based his projections on his past experience performing similar 
work in Brazil. We thoroughly examined the record and conclude that although he offers the figures, 
the Petitioner provides little explanation or justification for how he calculated them. Furthermore, the 
Petitioner has not explained how his performance in Brazil provides an adequate foundation for 
calculations in the United States, a country which operates in a different financial and healthcare 
system. The Petitioner must support his assertions with relevant, probative, and credible evidence. 
See Matter of Chawathe, 25 l&N Dec. 369, 376 (AAO 2010). 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 that benefits to the U.S. regional or national economy resulting from the 
Petitioner's projects would reach the level of "substantial positive economic effects" contemplated by 
Dhanasar. See Dhanasar, 26 l&N Dec. at 890. 
We acknowledge the additional evidence the Petitioner submits on appeal, including transcripts of his 
television interviews in Brazil, information on the U.S. government's emphasis on healthcare and 
protections for Americans with disabilities, as well as industry articles, reports, and studies. The 
transcripts and interviews reflect the publicity, fundraising, and success of the Petitioner's former 
employer in Brazil, as well as the healthcare services it provided to the community, but the Petitioner 
has not sufficiently connected this organization's success or his performance in his previous job to the 
national importance of the proposed endeavor in the United States. Likewise, the articles, reports, and 
studies provide useful background information on the fields of financial planning and healthcare but 
do not establish the national importance of the Petitioner's specific proposed endeavor. As stated, 
while the field may be nationally important, the Petitioner must establish that his specific proposed 
endeavor within the field is nationally important. The Petitioner has not met that burden. 
The documentation in the record does not establish the national importance of his proposed endeavor as 
required by the first prong of the Dhanasar precedent decision. Therefore, the Petitioner has not 
demonstrated eligibility for a national interest waiver. Further analysis of his eligibility under the second 
and third prongs outlined in Dhanasar, therefore, would serve no meaningful purpose. Because the 
identified reasons for dismissal are dispositive of the Petitioner's appeal, we decline to reach and 
hereby reserve the Petitioner's remaining arguments concerning his eligibility under the second and 
third Dhanasar prongs. See INS v. Bagamasbad, 429 U.S. 24, 25 (1976) ("coutis and agencies are not 
required to make findings on issues the decision of which is unnecessary to the results they reach"); 
see also Matter of L-A-C-, 26 l&N Dec. 516, 526 n.7 (BIA 2015) (declining to reach alternative issues 
on appeal where an applicant is otherwise ineligible). 
Ill. CONCLUSION 
As the Petitioner has not metthe requisitef irstprong of the Dhanasar analytical framework, we conclude 
that he has not established he is eligible for or otherwise merits a national interest waiver as a matter 
of discretion. The appeal will be dismissed for the above stated reason. 
ORDER: The appeal is dismissed. 
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