Schedule A, Group I: who qualifies and how to fast-track without PERM
Schedule A, Group I allows U.S. employers to sponsor medical professionals under EB-3 without going through PERM labor certification. The U.S. Department of Labor has pre-designated a persistent shortage for Registered Nurses (RN) and Physical Therapists (PT), so the employer files ETA-9089 (Schedule A, no DOL certification) together with I-140 directly with USCIS after posting the required Notice of Filing (NOF) at the worksite. Below you’ll find internal navigation, the fast-track flow, an employer checklist, profession-specific documents, FAQs, and common pitfalls.
Who qualifies under Schedule A, Group I
Registered Nurses (RN)
The position must qualify as a professional nurse. Evidence typically includes a CGFNS Certificate or state licensure/NCLEX, as applicable.
Physical Therapists (PT)
Requires an active state license or an official statement of eligibility/admission to licensure per the state regulator.
Note: Schedule A, Group II (exceptional ability in sciences or arts, excluding performing arts) is a different category and is not covered here.
How the fast-track works without PERM
- Prevailing Wage (NPWC): request the wage level appropriate to the role and location.
- Notice of Filing (NOF): post the notice at the worksite for 10 consecutive business days within the timing window before filing.
- I-140 (EB-3) + ETA-9089 (Schedule A): file directly with USCIS (no DOL certification step).
- Premium Processing (optional): expedites the I-140 decision; does not affect visa number availability.
- Concurrent I-485 (if “Current”): when the priority date is current, the beneficiary may file I-485 with EAD/AP.
- Health Care Worker Certification: required at the visa/entry stage for RN/PT and certain other HCW occupations under INA 212(a)(5)(C).
Employer checklist: readiness to file
Role and duties
- Title and functions clearly align with RN or PT.
- Detailed duty statement and minimum requirements are documented.
Wage level and PWD
- Offered pay meets or exceeds prevailing wage for location/level.
- NPWC determination retained in the file.
Notice of Filing (NOF)
- NOF posted for 10 business days.
- Photos/screenshots and internal posting copies preserved.
Beneficiary’s credentials
- Degrees, transcripts, resume, employment letters collected.
- RN: CGFNS/NCLEX/state license. PT: state license/eligibility letter.
Petition filings
- I-140 with attached ETA-9089 (Schedule A).
- Premium Processing if appropriate.
- I-485/EAD/AP if priority date is current.
Compliance and timelines
- Monitor Visa Bulletin and beneficiary status.
- Maintain a complete evidence file for audits/review.
Documents by profession: typical inclusions
Registered Nurses (RN)
- Degrees and transcripts; credential evaluation if needed.
- CGFNS Certificate or state license/NCLEX proof.
- Health Care Worker Certificate (e.g., VisaScreen).
- Resume and letters confirming duties and experience.
Physical Therapists (PT)
- Degrees and transcripts; evaluation if required.
- Active state license or eligibility/approval to sit for licensure.
- Health Care Worker Certificate, where applicable.
- Resume and employer letters verifying experience.
Employer evidence
- Signed ETA-9089 (Schedule A) and I-140.
- Job offer confirming permanent, full-time employment.
- Prevailing wage support and internal payroll/wage documents.
- Financials as needed to show ability to pay.
NOF and procedure evidence
- Photos/screenshots of NOF posted for 10 business days.
- Copies of internal postings or notifications, if used.
- Timeline of NOF, PWD, I-140, and any I-485 filings.
- I-693 medical exam for I-485, when applicable.
FAQ: common questions
Can other healthcare roles (e.g., radiology techs, lab techs) use this path?
No. Group I includes only RN and PT. Other roles generally proceed via standard PERM or potentially NIW where justified.
Is PERM-style recruitment still required?
No. Only the worksite NOF for 10 business days is required, within the proper filing window. PERM advertisements/job orders are not needed.
Will Premium Processing speed up green card issuance?
Premium accelerates the I-140 decision only and does not change visa number availability. It can help coordinate with I-485/EAD/AP when dates are current.
Is a Health Care Worker Certificate required?
For RN/PT and several HCW categories, the certificate is required at the visa/entry stage. It verifies education, English, and licensure.
Can the beneficiary file I-485 with I-140?
Yes, if the priority date is current for the category and country of chargeability. EAD/AP for the family can be filed concurrently.
Practical differences from standard PERM?
No PERM recruitment or DOL certification wait; the employer files directly with USCIS based on a pre-designated shortage for RN/PT.
Common mistakes and how to avoid them
Incorrect role alignment
The job must be RN or PT. Other clinical roles are not eligible for Group I.
NOF defects
Post for 10 business days, retain evidence, and observe the filing window.
Wage below PWD
Document the NPWC determination and ensure offered pay meets or exceeds it.
Missing HCW certificate
For RN/PT and certain HCW roles, the certificate is mandatory at the visa stage.
Weak education/experience evidence
Collect diplomas, transcripts, employer letters, and evaluations where needed.
Incorrect job offer status
The offer must be permanent, full-time; reflect this clearly in filings.
Schedule A vs PERM
Schedule A (Group I)
- Professions limited to RN and PT.
- No PERM recruitment; worksite NOF (10 business days) required.
- ETA-9089 is filed directly with USCIS together with I-140.
- Premium Processing available for I-140 decisions.
Standard PERM
- Broad range of occupations.
- Recruitment required (ads, job order, etc.).
- ETA-9089 must be certified by DOL before USCIS filing.
- Timelines depend on PWD and DOL processing queues.
If your role is not RN/PT, use the standard PERM path. For a clear overview, see: PERM — your path to U.S. talent.
What to do next
Verify role eligibility
If the position is not RN/PT, proceed with standard PERM.
Confirm licensing requirements
RN: CGFNS/NCLEX/state license. PT: license or eligibility. Include HCW certificate requirements.
Plan a realistic timeline
Account for NOF (10 business days), PWD, I-140 (including Premium), and Visa Bulletin movement.
Explore PERM for other roles
Full guide: PERM made easy.
Official sources
- 20 CFR §656.5 — Schedule A (DOL eCFR)
- USCIS Policy Manual — Schedule A designation
- ETA-9089 Instructions (NOF timing and posting)
- USCIS — Health Care Worker Certification
- USCIS — EB-3 overview
- 8 CFR §212.15 — Foreign health care worker certificates
Current as of September 29, 2025. Always recheck USCIS/DOL updates before filing.
