EB-2 NIW Proposed Endeavor: How to Build a Winning One

The heart of a successful EB-2 National Interest Waiver petition is not found in diplomas, publications, or recommendation letters on their own. It lies in the opening sentences you present to USCIS describing what you intend to accomplish in the United States. That section is the proposed endeavor, and its quality determines how every other element of the petition will be interpreted.

Denied NIW petitions or those subject to a Request for Evidence often share a common symptom: a poorly defined, generic proposed endeavor, or one tied too closely to the specific work of a single employer. This guide explains how to structure a strong proposed endeavor, which elements make up the correct definition under Matter of Dhanasar, and examples of what works and what fails.

The Endeavor Under Dhanasar

Matter of Dhanasar, the AAO’s 2016 precedent decision (26 I&N Dec. 884), redefined the NIW test around three prongs. The proposed endeavor is the subject of that test: what the petitioner proposes to do in the United States. It is not the profession, the job title, or the broad field of work, but a specific plan of action within that field.

USCIS evaluates, under Prong 1, whether the endeavor has substantial merit and national importance. Under Prong 2, whether the petitioner is well positioned to advance it. Under Prong 3, whether waiving the job offer and labor certification requirement benefits the United States. Without a defined proposed endeavor, none of the three prongs can be argued defensibly.

Endeavor Is Not a Profession

The most common mistake among self-represented petitioners is confusing endeavor with a job title or field of study. Stating that you intend to work as a software engineer, oncologist, or financial analyst describes a profession, not an endeavor. USCIS routinely denies petitions that present only a professional title as the subject of the request.

A proper endeavor answers three questions: what specific problem you propose to solve, what technical or methodological solution you intend to apply, and what the geographic or sectoral scope of the expected impact is. The three answers combined form the core of the narrative that runs throughout the entire petition.

Examples of Strong Endeavors

A strong endeavor is specific, measurable, and addresses a recognized need of the country. Examples that typically meet the Dhanasar standard:

• Develop AI-based phishing detection systems to protect hospital networks against ransomware attacks in the United States.
• Design machine learning platforms capable of predicting failures in regional power grids before they occur, reducing blackouts in states affected by extreme weather events.
• Build automated logistics systems to accelerate the delivery of perishable food to urban food deserts in the United States, reducing waste and improving food security.
• Implement deep learning-based medical imaging protocols for the early diagnosis of lung cancer in underrepresented populations in American clinical studies.

Each of these endeavors points to a verifiable problem of national interest, identifies a technical methodology, and establishes the benefited population. They allow the petitioner to support national importance with public health, cybersecurity, or energy infrastructure data.

Examples of Weak Endeavors

Weak endeavors are those that merely describe professional routine without identifying a problem, solution, or impact:

• Provide backend services for cloud software platforms.
• Work as a freelance web developer specializing in SEO and digital marketing.
• Provide IT support for small American businesses.
• Work as a researcher in a biotechnology laboratory.

These formulations fail for three reasons. First, they describe a function, not a plan. Second, they do not identify a collective beneficiary — only specific clients or employers. Third, they do not allow the petitioner to argue national importance, which requires impact beyond the immediate circle of employers or direct clients.

How to Build Yours

Start with the problem. Identify a concrete issue facing the United States in your field. Use government sources such as GAO, NIH, NSF, DOE, or DOD reports, or sector-specific regulatory agencies. White papers from think tanks, Bureau of Labor Statistics data, and reports from organizations such as the National Academies also serve as a foundation.

Define the solution in technical terms. What methodology, tool, system, or approach do you apply? The solution must be connected to your prior experience, demonstrable through publications, professional projects, patents, or documented contributions. Without that bridge, Prong 2 (well positioned to advance) collapses for lack of evidence.

Establish the scope. National importance does not require literal national scale. USCIS accepts endeavors with regional or sectoral impact, as long as the sector is recognized as a national priority. Public health, infrastructure, defense, clean energy, food security, STEM education, and cybersecurity are classic examples.

Common RFE Patterns

USCIS issues a Request for Evidence when the proposed endeavor is vague, describes only the profession, primarily benefits a single employer, or provides no measurable impact metric. Other common RFE patterns:

• The endeavor changed between the cover letter and the recommendation letters, creating narrative inconsistency.
• The execution plan does not connect concrete actions to the declared endeavor.
• Lack of evidence that the petitioner is the right person to carry out that specific endeavor, even when there is proof of generic qualification in the profession.
• National importance arguments based on statistics about the broad field, not the specific problem of the endeavor.

Endeavor and Execution Plan

The proposed endeavor must be supported by a credible execution plan. That plan describes concrete steps: planned partnerships, ongoing projects, future publications, events where you will present your work, organizations with which you already have contact. Without an execution plan, the endeavor appears to be an aspiration, not a commitment.

Recommendation letters must reinforce the endeavor with consistent language. Each referee must directly address the problem identified, validate the proposed methodology, and confirm the petitioner’s ability to execute it. Generic letters praising the profession without mentioning the endeavor carry little weight under Prong 2.

Connection to the Three Prongs

Under Prong 1, the endeavor supports substantial merit (the intrinsic value of the contribution) and national importance (relevance to the country). Under Prong 2, the endeavor defines what must be proven about the petitioner: education, experience, prior success, execution plan, and resources.

Under Prong 3, the endeavor explains why the traditional labor certification process is detrimental to the country: the work is flexible, multifaceted, urgent, or of a nature such that waiting for a specific employer delays collective benefits. Poorly formulated endeavors almost always fail under Prong 3 because they appear indistinguishable from any other work that could be done under H-1B.

Final Considerations

Set aside entire days to formulate the proposed endeavor before any other step of the petition. Test each version against critical questions: what exactly am I going to do, what problem does it solve, who benefits beyond me and my employer, and what evidence proves I am capable of executing this?

Read the Matter of Dhanasar decision in full before drafting the cover letter. Compare your endeavor with approved endeavors in decisions published by the AAO on the USCIS portal. When the endeavor can be explained in three clear sentences to a non-expert and still supports a fifty-page technical narrative, the foundation of the petition is built.

Victoria Harper

Editor-in-Chief

Meet the author

Leading journalism and editorial content at Visto n’ Visa, Victoria helps make immigration topics clear, trustworthy, and easy to understand. Her focus is on delivering useful, human, and relevant content for people exploring new paths abroad.