JUN242021_02B5203Decided 2021-06-24I-140

The AAO remanded an EB-2 NIW petition filed by a business manager because the Director had erroneously accepted a…

Remanded Useful for: appeal strategy
EB-2-NIWField: business management
The outcome

Good news — this case cleared the first bar

The AAO withdrew the Director's decision and remanded the case because the Director had not properly evaluated whether the petitioner qualified for EB-2 classification as an advanced degree professional or individual of exceptional ability — the threshold determination required before reaching the national interest waiver analysis.

In plain English

A business manager sought an EB-2 National Interest Waiver based on advanced degree status and, alternatively, exceptional ability. The Texas Service Center Director found the petitioner qualified as an advanced degree professional based on a third-party credential evaluation, then denied the NIW on the merits. The AAO withdrew that finding because the evaluator had not reviewed employment letters required to establish progressive post-baccalaureate experience and there were unexplained discrepancies in the degree description. The Director also never addressed the petitioner's exceptional ability claim. The AAO remanded for the Director to properly evaluate the EB-2 threshold question before reaching the NIW analysis.

What worked & what failed

What failed: The credential evaluation from USA Evaluations was insufficient because it relied only on the petitioner's resume — not employer letters — to document work experience needed for an equivalent master's degree, and it contained an unexplained discrepancy about the petitioner's undergraduate degree. The petitioner's bachelor's degree alone did not satisfy the advanced degree requirement. The NIW prongs were not met on the record presented.

Takeaway: When relying on a combination of a bachelor's degree plus five years of progressive experience to establish an advanced degree equivalent for EB-2, petitioners must submit formal employer letters documenting that experience — a credential evaluator's reliance on a resume alone is insufficient. Any discrepancies between original foreign academic documents and the evaluator's characterization must be explained with objective, independent evidence.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating EB-2-NIW criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • The credential evaluation from USA Evaluations was insufficient because it relied only on the petitioner's resume — not employer letters — to document work experience needed for an equivalent master's degree, and it contained an unexplained discrepancy about the petitioner's undergraduate degree
  • The petitioner's bachelor's degree alone did not satisfy the advanced degree requirement
  • The NIW prongs were not met on the record presented.
Find more EB-2-NIW cases with similar evidence patterns →
Where the evidence fell short

USA Evaluations credential evaluation concluding petitioner held U.S. MBA equivalent — rejected because the evaluator did not review employment letters to verify work experience and relied solely on petitioner's resume for professional experience, and there was an unexplained discrepancy between the diploma (which listed 'administration') and the evaluator's characterization (bachelor's in business administration with a major in management).

Petitioner's bachelor's degree diploma and transcript — insufficient on its own to demonstrate an advanced degree under 8 C.F.R. § 204.5(k)(3)(i)(A).

Officer errors the AAO found

The Director accepted a third-party credential evaluation as proof of an advanced degree equivalent without verifying that the evaluator had reviewed employment letters to confirm progressive post-baccalaureate work experience, as required by 8 C.F.R. § 204.5(k)(3)(i)(B).

The Director failed to address the petitioner's alternative claim for classification as an individual of exceptional ability under 8 C.F.R. § 204.5(k)(3)(ii).

The Director proceeded to the NIW analysis without properly establishing the underlying EB-2 threshold classification.

How the case moved

Completed

I-140 filed

Business manager

Completed

Texas Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2021-06-24

AAO decision — Remanded

The AAO withdrew the Director's decision and remanded the case because the Director had not properly evaluated whether the petitioner qualified for EB-2 classification as an advanced degree professional or individual of exceptional ability — the threshold determination required before reaching the national interest waiver analysis.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

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Authorities the office relied on
8 C.F.R. § 204.5(k)(2)8 C.F.R. § 204.5(k)(3)(i)(A)8 C.F.R. § 204.5(k)(3)(i)(B)8 C.F.R. § 204.5(k)(3)(ii)
DhanasarEstablishes the three-prong framework for adjudicating national interest waiver petitions: (1) substantial merit and national importance of proposed endeavor, (2) petitioner well-positioned to advance the endeavor, and (3) beneficial on balance to waive the job offer and labor certification requirement.
NYSDOTPrior NIW precedent vacated by Dhanasar.
PoursinaUSCIS's decision to grant or deny a national interest waiver is discretionary in nature.
Matter of HoPetitioner must resolve discrepancies and ambiguities in the record with independent, objective evidence pointing to where the truth lies.