OCT052017_01D2101Decided 2017-10-05I-129

The AAO dismissed the appeal of an IT staffing company seeking H-1B status for a PeopleSoft technical analyst, finding…

Dismissed Useful for: avoid these mistakes
H-1BField: information technology; PeopleSoft technical analyst
The outcome

This appeal was not successful at this stage

The appeal was dismissed because the petitioner failed to establish that the proffered PeopleSoft technical analyst position qualifies as a specialty occupation and failed to demonstrate sufficient non-speculative work for the entire requested three-year validity period.

In plain English

An information technology company petitioned to continue employing a beneficiary as a PeopleSoft technical analyst under H-1B status. The AAO upheld the denial on two independent grounds: first, the petitioner failed to describe the position's duties in sufficient detail and relied on a broad, generalized degree requirement (including 'business' or 'science') that did not establish a specialty occupation; second, the client contracts on record expired well before the requested 2020 end date, and the petitioner's stated plans for future in-house work were speculative. Because the beneficiary was to work at third-party client sites, documentation from those clients specifying duties and educational requirements was essential but was not provided in a form specific to the beneficiary. The decision reinforces that IT staffing companies must supply detailed, client-specific documentation and concrete work assignments for the entire validity period when petitioning for H-1B workers placed at end clients.

What worked & what failed

What failed: 1. The petitioner listed 'business' and 'science' as acceptable degree fields without sufficient specificity, which is inadequate to establish a specialty occupation. 2. No client-specific documentation tied the beneficiary to defined duties or educational requirements at the end-client sites. 3. Client contracts expired in 2017, far short of the 2020 validity period requested, and plans for future work were found to be speculative.

Takeaway: IT staffing companies placing workers at end-client sites must obtain client-specific statements of work and duty descriptions that clearly mandate a specialized degree for H-1B petitions, and must provide contracts or letters of intent covering the entire requested validity period to avoid denial for speculative employment.

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 H-1B criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • The petitioner listed 'business' and 'science' as acceptable degree fields without sufficient specificity, which is inadequate to establish a specialty occupation
  • No client-specific documentation tied the beneficiary to defined duties or educational requirements at the end-client sites
  • Client contracts expired in 2017, far short of the 2020 validity period requested, and plans for future work were found to be speculative.
Find more H-1B cases with similar evidence patterns →
Evidence that persuaded the AAO

Past relationship between the petitioner and end clients CB and PJ was acknowledged

Prior Standard Contract Amendment with CB (August 2013 to August 2016) demonstrated an established business relationship

Where the evidence fell short

Petitioner's own annotated duty list was insufficient to establish the substantive nature of the proffered position

Client documentation from CB and PJ was not specific to the beneficiary and lacked adequate detail about job duties and minimum education requirements

Statement of Work from PJ only covered 600 hours within calendar year 2017, well short of the three-year validity period requested

CB Standard Contract Amendment expired August 21, 2017, far short of the 2020 end date

Newest CB Standard Contract Document lacked required signatures, undermining its reliability

Petitioner's claim that the beneficiary would join an in-house development team for future unspecified projects was deemed speculative

Degree requirement stated as 'business' or 'science' without specialization was insufficient to establish specialty occupation

How the case moved

Completed

I-129 filed

PeopleSoft technical analyst performing IT project work for end clients

Completed

California Service Center — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2017-10-05

AAO decision — Dismissed

The appeal was dismissed because the petitioner failed to establish that the proffered PeopleSoft technical analyst position qualifies as a specialty occupation and failed to demonstrate sufficient non-speculative work for the entire requested three-year validity period.

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. § 214.2(h)(4)(ii)8 C.F.R. § 214.2(h)(4)(iii)(A)8 C.F.R. § 103.2(b)(1)
ChawathePreponderance of the evidence is the applicable standard of proof
Royal Siam Corp.A specialty occupation degree requirement must relate directly to the duties of the position; a general-purpose degree requirement without more is insufficient
DefensorWhere work is performed for third-party clients, evidence of the client companies' job requirements is critical to establishing specialty occupation
Michael Hertz Assocs.A generalized degree title such as 'business' without further specification does not establish a position as a specialty occupation
Michelin Tire Corp.A visa petition may not be approved at a future date after the petitioner becomes eligible under a new set of facts; eligibility must exist at time of filing
Tapis Int'lA general-purpose bachelor's degree requirement without more is insufficient to establish an H-1B specialty occupation
63 Fed. Reg. 30,419Speculative or undetermined prospective employment is not permitted as a basis for H-1B classification