Nurses have an alternative certification process. A foreign nurse may present a certified statement from the Commission on Graduates of Foreign Nursing Schools or an approved equivalent independent credentialing organization verifying that the foreign nurse:
Organizations Authorized to Issue Health Care Worker Certifications
The following organizations are authorized to issue certifications for the following health care occupations:
Providing Valid Health Care Worker Certification
A foreign national worker in an affected health care occupation must present a valid health care worker certification each time he or she:
The certification requirement is no longer applicable once the worker is a lawful permanent resident.
Renewing the Health Care Certification
A foreign worker’s certification must be used for any admission into the United States, extension or change of status within the United States, or adjustment of status within 5 years of the date that it is issued. For this reason, the certification is only valid for 5 years. This ensures that the individual continues to meet the regulatory requirements for issuance of the certification. Therefore, if the foreign worker has not used the certification because he or she has not been admitted into the United States or adjusted his or her status within 5 years of when the certification was obtained, a new certification is required at the time he or she seeks adjustment of status, to change or extend status with USCIS, or when seeking visa issuance by DOS or admission at the port of entry.
Please note that certification does not remove requirements for licensure, if applicable.
However, the credentialing organization must have a formal policy for renewing the certification if an individual’s original certification expires before admission to the United States or application for adjustment of status. The credentialing organization is limited to updating information on licensure to determine the existence of any adverse actions and the need to re-establish English competency, and therefore does not re-evaluate the educational credentials when renewing the certification.
Nonimmigrant Petitions
For nonimmigrant petitions seeking admission, an extension of stay, or a change of status, there are two considerations:
Consideration 1: The petitioning employer files a Form I-129, Petition for a Nonimmigrant Worker, for approval of the foreign national worker’s classification as a nonimmigrant. In adjudicating the petition for the classification requested, USCIS reviews all eligibility requirements, including licensure, if applicable. The health care certification must be presented at the time of visa issuance or admission (if the foreign national worker is visa-exempt).
Consideration 2: If the foreign national is already in the United States, Form I-129 may also serve as an application to extend the period of the foreign national's authorized stay or to change his or her status. Although the Form I-129 petition classification may be approved, the application for an extension of stay or change of status will be denied if the petitioner fails to submit the health care worker certification required by law.
Please note: USCIS does not accept health care worker certification as the sole evidence that the foreign worker has met the minimum requirement for the given position and is, therefore, eligible for the requested visa classification. While the health care worker certification verifies the worker’s credentials for admissibility into the United States under INA 212(a)(5)(C), it is not binding on DHS. See 8 CFR 212.15(f)(1)(iii).
A nurse on TN should not have an intention of remaining permanently in the U.S.
H-1B Status
H-1B visa category for temporary workers in a “professional specialty occupation” is not available to RNs per se because most states allow nurses to take the licensing examination after completion of a two-year associate degree. General staff RNs are not classifiable as H-1B. However, the following specialties would qualify for H-1B:
Thus, H-1B visa status can be used for nursing jobs that require at least a four-year bachelor’s degree.
Finally, physical and occupational therapists are both recognized as qualifying for H-1B classification. Physical therapists were previously required to have at least a bachelor’s degree. Subsequently, master’s degree became the industry standard. Now, efforts are seen to raise the standard to a new type of doctoral degree, the Doctor of Physical Therapy.
Immigrant Petitions
For immigrant petitions, there is a two-step process:
Step 1: Generally, Form I-140, Immigrant Petition for Alien Worker, is first filed by an employer on behalf of the prospective foreign national worker. In adjudicating the I-140 petition, USCIS reviews all eligibility requirements. This review includes examination of the beneficiary’s educational qualifications.
Step 2: If the foreign national worker is in the United States, he or she may file a Form I-485, Application to Register Permanent Residence or Adjust Status. It is only upon the filing of an I-485 that the health care worker certification is required and will be used to determine admissibility for adjustment of status.
If the foreign national worker is living outside the United States or living in the United States, but chooses to apply for an immigrant visa abroad, USCIS will send the approved petition to the Department of State’s (DOS) National Visa Center (NVC), where it will remain until an immigrant visa number is available. The foreign national worker must present the health care certification to the consular officer at the time of visa issuance.
Some states require the foreign nurses pass the CGFNS examination before taking the state RN licensing (NCLEX) examination. However, the number of such states is on the decline. This is due to the fact that it is now possible to take the NCLEX abroad.
The employer to begin with submits an immigrant visa petition (I-140) to USCIS. The petition is accompanied by Labor Department Form ETA-9089, a posting notice, a prevailing wage determination and by other required documents along with the filing fee. If the petition is found approvable, USCIS mails the approved visa petition to the National Visa Center (NVC) in Portsmouth, New Hampshire. The nurse receives the fee bill. After fees are paid, the NVC forwards a packet to the nurse or her attorney, and a list of documents which must be submitted. The U.S. Consulate schedules an appointment for the nurse and her family for permanent residence.
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