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US Healthcare Employers Push Back on $100,000 H‑1B Fee

US Healthcare Employers Push Back on $100,000 H‑1B Fee

In September 2025, the Trump administration implemented a steep $100,000 fee on new H‑1B visas, a move that has sent shockwaves through hospitals, health systems, and medical schools across the country. While several lawsuits are challenging the legality of this H‑1B fee, it remains in effect for now and the healthcare industry is already feeling the impact.  

At VisaMadeEZ, an immigration law firm focused on helping healthcare organizations hire international nurses and other medical professionals, we are seeing firsthand how this policy is reshaping recruitment strategies, staffing plans, and long‑term workforce development.

Below, we break down what’s happening, who is pushing for exemptions, and what hospitals and international clinicians especially foreign‑educated nurses need to know right now.  

The $100,000 H‑1B Fee: A New Barrier for Healthcare Employers  

The 2025 proclamation imposed a $100,000 surcharge on new H‑1B petitions, on top of existing USCIS filing fees and legal costs. For most employers outside the tech industry, and particularly for hospitals operating on thin margins, this fee is simply not sustainable.

While the policy technically applies across industries, healthcare institutions are uniquely vulnerable:

- Many rely heavily on international medical graduates (IMGs) and foreign‑trained healthcare workers.  
- Physician shortages, especially in rural and high‑poverty areas, make it difficult to replace international clinicians with U.S. graduates.  
- The financial shock of a six‑figure fee per worker can derail recruitment plans for entire departments.  

This is one reason healthcare leaders are lobbying hard for exemptions specific to the health sector.  

AAMC Warns of Disruptions Ahead of 2026 Match Day  

In a recent article, the Association of American Medical Colleges (AAMC) sounded the alarm about the immediate impact of the H‑1B fee. With National Match Day approaching on March 20, 2026, hospitals are making crucial staffing decisions for incoming residents and fellows.

AAMC highlights a fall survey conducted by the Greater New York Hospital Association (GNYHA), which represents 260 hospitals across New York, New Jersey, Connecticut, and Rhode Island. The findings were troubling:

- 25% of hospitals reported pausing, deferring, or limiting recruitment of physicians who require H‑1B visas.  
- These institutions currently employ 1,100 H‑1B medical residents and 800 H‑1B attending physicians, illustrating the scale of potential disruption if hiring slows or stops.  

In other words, the $100,000 H‑1B fee is already changing behavior not in theory, but in real recruitment decisions affecting patient care.  

Do International Clinicians Displace U.S. Graduates?  

Opponents of employment‑based immigration often argue that foreign workers “take jobs” from American graduates.  
However, AAMC data tells a different story:

- 97.8% of U.S. MD seniors matched into residency positions in 2025. 

That match rate is extremely high. It indicates that foreign‑trained physicians are not displacing U.S. graduates, but rather filling gaps in specialties and locations where U.S. doctors are in short supply.

This reality is echoed in nursing as well. Many U.S. hospitals struggle to fill nurse vacancies, particularly in:

- Rural hospitals  
- Safety‑net and public health systems  
- Long‑term care and skilled nursing facilities  

International nurses and physicians are often the backbone of care in these underserved communities.  

The Role of International Medical Graduates in U.S. Healthcare  

International medical graduates (IMGs) are not a fringe group in the American system—they are central to it:

- IMGs make up about 25% of all practicing U.S. physicians.  
- In FY 2024, roughly 11,000 new H‑1B visas were approved for physicians alone.  
- These physicians are disproportionately represented in rural and high‑poverty counties, and are more likely to practice primary care, where shortages are most acute.  

When we overlay this with the national shortage of nurses and allied health professionals, the picture becomes clear:  
Limiting access to employment‑based visas or making them prohibitively expensive will compound an already serious health workforce crisis.  

Why Healthcare Organizations Are Pushing for Exemptions  

Given these realities, major education and healthcare groups have mobilized. The AAMC has:

- Cosigned multiple letters with medical associations, universities, and health professions education groups.  
- Formally urged the U.S. Department of Homeland Security (DHS) to exempt healthcare professionals and educators from the $100,000 H‑1B fee.  
- Sent a direct letter in December 2025 to DHS Secretary Kristi Noem, warning that the proclamation will:  
  - Worsen the existing healthcare workforce shortage  
  - Further strain the current healthcare workforce  
  - Ultimately undermine patient access to care  

These concerns apply not only to physicians, but also to the broader care team nurses, advanced practice providers, therapists, and technologists many of whom rely on employment‑based immigration pathways.  

What This Means for International Nurses  

While the current public discussion has largely focused on physicians and residents, international nurses are very much part of the same ecosystem. Many hospitals and long‑term care facilities rely on foreign‑educated nurses to maintain safe staffing levels and meet patient demand.

Key realities for international nurses and the employers who want to hire them:

1. Visa Pathways Are Already Complex  
   - Many nurses use the EB‑3 immigrant visa (green card) route.  
   - Some specialized roles may involve H‑1B visas, particularly in advanced practice or highly specialized units.  

2. Policy Ripples Affect All International Hiring  
   Even if a particular nurse is not directly subject to the H‑1B fee, hospitals are reevaluating budgets, timelines, and immigration strategies across all international recruitment due to the increased cost and uncertainty.

3.Delays and Caution Are on the Rise  
   Just as hospitals are pausing recruitment of H‑1B physicians, some are becoming more cautious about foreign nurse recruitment not because they don’t need nurses, but because they’re unsure how immigration rules will shift next.  

This is where specialized immigration counsel for healthcare organizations becomes critical.  

How VisaMadeEZ Helps Healthcare Employers Navigate the New Landscape  

At VisaMadeEZ, we focus exclusively on immigration solutions for healthcare organizations, with a particular emphasis on helping hospitals, health systems, and staffing agencies hire and retain international nurses.

In this rapidly changing environment, we help employers:

1. Evaluate the Best Visa Strategy  
We analyze whether a position and candidate are better suited for:

- EB‑3 immigrant visas for nurses  
- H‑1B visas (for qualifying advanced practice or specialized roles)  
- Alternative classifications where available  

Our goal is to minimize cost and risk, while aligning with the organization’s staffing needs and timelines.  

2. Reduce the Impact of High Fees and Policy Changes  
While the $100,000 H‑1B fee is currently in effect, there may be:

- Exemptions or exceptions that apply, depending on the type of employer or role  
- Strategic ways to time or structure filings to reduce exposure to unnecessary costs  

We stay on top of regulatory developments and court decisions so healthcare employers don’t have to.  

3. Support Long‑Term Workforce Planning  
Instead of treating immigration as a one‑off transaction, we work with hospitals and health systems to:

- Build long‑term international nurse recruitment pipelines  
- Plan for residency to employment transitions for international clinicians  
- Map out pathways from temporary status to permanent residency  

This strategic approach reduces last‑minute scrambling and helps maintain continuity of patient care.  

Why Immigration Strategy Matters More Than Ever  

As the AAMC and other national organizations have emphasized, the U.S. is facing:

- A persistent and growing shortage of physicians  
- A well‑documented shortage of nurses, especially in critical care, long‑term care, and rural settings  
- Increasing demand from an aging population and complex chronic disease burden  

Against this backdrop, policies like the $100,000 H‑1B fee don’t just raise administrative costs they directly affect:

- Whether a small rural hospital can keep its doors open  
- Whether a safety‑net hospital can staff its ICU  
- Whether patients in underserved areas can see a primary care provider at all  

For healthcare leaders, the message is clear:  
Immigration strategy is now inseparable from staffing strategy. 

For Hospitals and Healthcare Employers: Next Steps  

If your organization relies on or is considering the recruitment of international nurses or other foreign‑trained healthcare professionals, now is the time to:

1. Audit Your Current and Planned International Hires  
   Identify which roles may be affected by the H‑1B fee and which may be better served by other visa options.  

2. Develop a Resilient Immigration Plan  
   Work with an immigration law firm that specializes in healthcare, understands the realities of hospital operations, and can help build a sustainable workforce strategy.  

3. Stay Informed, But Don’t Freeze Hiring  
   While national organizations continue to push for exemptions from the H‑1B fee for healthcare professionals, patients still need care today. Thoughtful planning can allow continued recruitment within a rapidly evolving policy landscape.  

How VisaMadeEZ Can Help Your Organization Today  

VisaMadeEZ partners with hospitals, clinics, long‑term care facilities, and healthcare staffing agencies nationwide to:

- Design cost‑effective visa and green card strategies for international nurses  
- Navigate complex and changing H‑1B and employment‑based immigration rules  
- Support compliance while helping employers meet critical staffing needs  

If your organization is concerned about the impact of the $100,000 H‑1B fee or wants to expand its international nurse recruitment, our team is ready to help you evaluate options and move forward confidently.

To discuss your organization’s needs or explore immigration options for international nurses and other healthcare professionals, contact VisaMadeEZ for a consultation.