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 apetitioner 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. MatterofDhanasar,26l&NDec.884(AAO2016).
The Director of the Texas Service Center determined that the Petitioner qualifies for the underlying classificationandthathisproposedendeavorhassubstantialmerit. Nevertheless,theDirectordenied 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 awaiver of the requirement of ajob offer would be in the national interest. Accordingly, the Director determined that the Petitioner had not established eligibility for a national interest waiver.
Thematterisnowbeforeusonappeal. ThePetitionerreassertshiseligibility,arguingthattheDirector 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.
Legalframework
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 p. 2 classification requires that the individual's services be sought by a U.S. employer, a separate showing is required to establish that awaiver 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 interestwaiver.... [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) ofthe 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 aforeign 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 p. 3 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' sproposed 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 ajob offer and thus of a labor certification. See Dhanasar, 26 l&N Dec. at 888-91, for elaboration on these three prongs.
Analysis
A Advanced Degree Professional
In order to show that a petitioner holds aqualifying 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 IBecause 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 o f 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 thesecoursesarearequisitecomponentofabachelor'sdegreeeducationintheUnitedStates. Itisnot apparent how the evaluator arrived atthe conclusion that courses such as these are general studies courses or that they form arequisite component ofU.S. bachelor's degree programs. Accordingly, we conclude that this evaluation is of little probative value in this matter.
We may, in our discretion, use an evaluation ofa 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 resultedinthecompletionofanactualmaster'sdegreeeducation. Nordoestherecordestablishthat 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(lastvisitedDec.9,2021). ThedatabaseindicatedthatthePetitioner's four-year"TftulodeBacharel"inadministrationistheequivalentofaU.S.bachelor'sdegree. While the Petitioner has not provided sufficient evidence to support a finding that his foreign degree is the equivalent o f 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 confirmsthedatesofhisemployment. Accordingly,therecordestablishesbyapreponderanceofthe evidencethatthePetitionerhasatleastfiveyearsofpost-baccalaureateexperienceinhisfield. Assuch, 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.
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. ~ - - - - - ~ f u r t h e r 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 o f 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.No broader implications shown 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 p. 6 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 o f 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 fromj Jthe CEO and general superintendent of the Petitioner's former employer 11 rpraised the Petitioner's personalandprofessionalqualitiesandachievements.Support letters generic or unsupported HealsoassertedthatthePetitioner'sworkis 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.Job creation or economic claims unsupported 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 aU.S.jobsearch. AlthoughthePetitionerprovidedaletterfromaFloridabranchofI Iin which the manager for decision support and business development acknowledged the Petitioner's useful experience, he did not meaningfully describe the nature of howl Iwould 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 petitionermustidentify"thespecificendeavorthattheforeignnationalproposestoundertake." 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 p. 7 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 f r o m ~ - - - - - ~ 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 andsalescapabilities. However,thePetitionerhasnotexplainedwhatU.S.companiesareseekingto 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! fs 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 ble 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. H ere,~-----~'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" ofhis 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 economicallydepressedarea,forinstance,maywellbeunderstoodtohavenationalimportance." 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 basisoranalysisconcerninghowthePetitionerwillactuallygeneratesuchsavingsandbenefits. 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 p. 8 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 o f the Petitioner's proposed endeavor. Although the authors o f 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 organizationsheworkedwithorthespecificindividualstheyserved. Furthermore,theauthorsprovide insufficiently detailed examples of the Petitioner's work. For instance.I Ithe national managing director atl Iasserted that the Petitioner's strategy and management o f 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 ~ a t i o n 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.
AlthoughI Ioffers 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 Iexplained 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. Inexaminingtheworkproductexamplesofhisfinancialmodelsandreports,wefirstnote that they are not accompanied by English translations. In addition, they appear to be merely a table p. 9 o f f 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 providedestimatesofhowmanyorganizationsorindividualsareinterestedinhistraining. Evenifhe 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 importanceofhisspecificproposedendeavorasopposedtothefieldingeneral. Asalreadynotedby 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 becauseitwillenablemorepersonswithdisabilitiestobetreatedandreenterthelaborforce. 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 p. 10 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 o f "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 donotestablishthenationalimportanceofthePetitioner'sspecificproposedendeavor. Asstated, 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 demonstratedeligibilityforanationalinterestwaiver. Furtheranalysisofhiseligibilityunderthesecond 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.