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The Association for Advancing Physician and Provider Recruitment (AAPPR) is redefining recruitment to retention and is the only professional organization where physician and provider recruitment leaders and others who influence recruitment, onboarding and retention can connect, learn and advance their careers.
Congress is back from its August recess, but only briefly. The House is in session for its final legislative week before the midterms, and the Senate is scheduled to stay through the end of the month. Congress has already passed a stopgap funding bill that keeps the government open through December 11, so there is no shutdown pressure this month. The Senate has spent its limited floor time on unrelated issues such as cryptocurrency and college sports legislation. Government funding and other major priorities, including those affecting our members, will likely be decided in the lame duck session between the election and the start of the new Congress in January. In the meantime, there is plenty of legislative and regulatory activity we are tracking and covering below.
On September 10, AAPPR joined the National Association Medical Staff Services (NAMSS) for its 12th annual industry roundtable, focused on building pathways for internationally trained physicians (ITPs). AAPPR was the only physician recruitment organization at a table that included certifying and accrediting bodies, credential verification organizations, hospital and physician associations, and state medical boards. ITPs are physicians who completed their medical education, postgraduate training, and licensure outside the United States, distinct from international medical graduates who enter ACGME-accredited training here. Twenty-seven states and two territories have now enacted alternative licensure pathways for this population, with more legislation pending.
The discussion covered what organizations need in place to onboard these physicians, spanning credential verification, immigration, state licensure, medical staff appointment, and payer enrollment. AAPPR contributed the recruitment and onboarding perspective. The group agreed that NAMSS should develop resources on the topic, and AAPPR will continue to participate as that work moves forward.
AAPPR has endorsed a Congressional Review Act resolution of disapproval targeting the DHS rule that would end “duration of status” for J-1 physicians and other international students.
The Congressional Review Act gives Congress a formal mechanism to overturn a recently issued federal regulation. The resolution was introduced by Senator Dick Durbin (D-IL) with Senate cosponsors and a House companion led by Representatives Pramila Jayapal (D-WA) and Jamie Raskin (D-MD), and is endorsed by a broad coalition that includes the AAMC, the American Academy of Family Physicians, the American Academy of Pediatrics, the American Osteopathic Association, and more than forty other organizations.
We supported the resolution because the rule would replace open-ended admission for J-1 physicians with fixed periods capped at four years at a time, requiring anyone who needs more time to apply to USCIS and wait. That creates real risk of disruption for residents in longer training programs, physicians moving from residency into fellowship, and programs managing routine situations like medical or parental leave.
Separately, a federal court issued a nationwide injunction on September 14 blocking the rule from taking effect while litigation proceeds. That is a temporary hold rather than a final resolution, and the government is expected to appeal, so we are continuing to engage on both fronts and will keep members updated.
Congress created the Rural Health Transformation Program in the 2025 budget reconciliation law. The program provides $50 billion over five years ($10 billion annually from FY2026 through FY2030) to strengthen rural health care. CMS approved all 50 states for funding, with first-year awards averaging about $200 million per state.
States now distribute the money to hospitals, practices, and training programs through their own lead agencies. Recruiting and retaining clinicians in rural communities is one of the program’s approved uses. Members recruiting in rural markets may want to check their state agency’s award lists and upcoming funding rounds. Below are two notable examples from the last month:
Please reach out if you have any questions on this fund or any other issues.
The Association for Advancing Physician and Provider Recruitment (AAPPR) has released its annual Physician and Provider Recruitment Benchmarking Report: Search Dynamics and Trends, offering new insights into physician and advanced practice provider (APP) recruitment activity across the United States.
The 2026 report shows that physician and provider search volume held roughly steady in 2025 following earlier highs, while recruitment teams continue to face significant workloads, lengthy hiring timelines and persistent physician vacancies. The typical organization managed 100 searches in 2025, compared with a peak of 115 in 2023. Recruiters individually managed a median of 36.5 searches, essentially unchanged from 35.6 in 2024. Meanwhile, the median annual budget for internal physician recruitment departments declined 7.4% year over year, from $553,376 in 2024 to $512,500 in 2025.
“We’re watching the physician shortage move from concern to reality,” said Carey Goryl, CEO of AAPPR. “Without meaningful changes to how we train and recruit physicians, patients will feel this first as longer waits for critical care increase. Our data shows that searches in high‑impact specialties like cardiology, urology, neurology, anesthesiology, and gastroenterology are increasingly difficult to fill. This a clear warning sign that our physician pipeline isn’t keeping up.”
The research includes data on more than 10,000 physician and provider searches active in 2025 from recruitment teams that collectively recruit for more than 21,000 unique healthcare locations. Nearly 60% of reported searches were for physicians.
Notable findings from the 2026 AAPPR Physician and Provider Recruitment Benchmarking Report include:
Median time to fill for APP searches declined from 80 days in 2024 to 65 days in 2025. Physician searches took a median of 119 days, with significant variation by specialty. Endocrinology/Metabolism took the longest at a median of 321 days, followed by Oncology at 244 days.
The typical physician began work 229 days after the position was posted, highlighting the additional time required for credentialing, privileging, licensing and onboarding.
Family Medicine accounted for 11.6% of physician searches in 2025, followed by Hospital Medicine at 10.9% and general OB/GYN at 6.6%.
As of Dec. 31, 2025, 50% of physician searches remained open, up from 49% in 2024 and 47% in 2023. By comparison, 31.8% of APP searches remained open at the end of 2025.
By the end of 2025, 28.3% of urology searches were filled, while only about one-third of neurology and cardiology searches were filled. Anesthesia (40.1%) and gastroenterology (40.5%) searches were also filled less than half of the time.
The industry-level data equips healthcare organizations with benchmarks to evaluate recruitment performance, resources and workforce planning strategies. Participants in the survey gain complimentary access to the AAPPR Benchmarking Portal, which includes advanced search tools, time-to-fill and compensation calculators, and customizable benchmarking capabilities.
The complete 2026 AAPPR Physician and Provider Recruitment Benchmarking Report: Search Dynamics and Trends is available for purchase online. The companion 2026 AAPPR Recruitment Team Professional Compensation Benchmarking Report is also available, providing additional insight into recruiter compensation and recruitment team structures. To access AAPPR benchmarking research and resources, visit www.aappr.org/research/benchmarking.
Congress is in recess this month but has no shortage of issues when it returns after Labor Day. We are less than three months from the upcoming midterms elections so the expectation when Congress returns is that they will focus on funding the government and then return to the campaign trail. That said, members are angling for key policy issues to be positioned to advance in the lame duck session, which means clearing committee hurdles and or advancing from one chamber to the other before Congress leaves town again.
The DHS rule ending “duration of status” takes effect September 15, and we are continuing to monitor it closely for potential disruption to the J-1 physician pipeline. A few things worth knowing as of the latest guidance from the State Department and Intealth:
We will keep you posted as federal guidance develops. Please let us know if you have any questions.
The $100,000 fee on certain H-1B petitions is not being charged right now. A federal court struck it down in June, ruling the government didn’t have the authority to impose it. In July, an appeals court declined to put the fee back in place while the case moves forward. The government has stopped collecting for now, but says it will resume if the ruling is reversed.
While the fee only hit petitions for candidates who were outside the U.S. seeking a H-1B visa, this isn’t over as a different court upheld the fee last December, appeals are still pending, and things could change again.
The proclamation that established the fee in September 2025 expires next month, unless the Administration extends it. We will follow up as we learn whether it will be renewed.
AAMCNews profiles a WVU Medicine clinic in Glenville, West Virginia, where neurologists drive 90 minutes from Morgantown once a month so that patients across nine rural counties don’t have to make the trip themselves. The piece uses that clinic as a window into the projected shortfall of roughly 70,000 specialty physicians by 2036, and reviews the policy levers in play, from expanding Medicare-funded residency slots to rural residency tracks and greater use of specialist NPs and PAs.
Last Updated: July 27, 2026
On July 24, the U.S. Court of Appeals for the First Circuit denied the Trump Administration’s request to stay a lower court order that vacated the $100,000 H-1B fee, clearing the way for that ruling to take effect. What this means in practice is that the $100,000 payment is no longer required on covered H-1B filings for the time being, even as the broader legal fight continues.
Here is a quick look at how we got here:
The bottom line from the appeals court is that it is Congress’s job, not the president’s, to impose new fees on immigrant visas.
In September 2025, a presidential proclamation imposed a $100,000 payment requirement on new H-1B visa petitions filed on or after September 21, 2025. The fee was a one-time charge at filing for those not currently in country, with potential for exceptions if deemed in the national interest, which the Administration never exercised. It did not apply to renewals, previously filed petitions, or current H-1B holders. You can read previous updates on the H-1B policy here.
This is a significant development for health care employers, physician and provider recruitment teams, and international medical graduates. The $100,000 fee had created a major cost barrier for H-1B sponsorship, and its removal eases a critical pressure point for organizations working to fill physician, IMG, and specialty provider gaps.
We expect USCIS to adjust its filing instructions to reflect the decision in the coming weeks. In the meantime, organizations with H-1B petitions in the pipeline should connect with their immigration attorneys to understand how the ruling affects their specific filings.
That said, we are not out of the woods yet. The government is still pressing its appeal in the First Circuit, and related lawsuits remain active in both the Northern District of California and the D.C. Circuit. This case reaching the Supreme Court is possible. But the trajectory is encouraging as the fee has been struck down, the emergency stay has been refused, and the appeals court has indicated that the legal arguments supporting the fee face an uphill battle.
AAPPR will continue to closely monitor this case and support efforts, including H.R. 7961, the H-1Bs for Physicians and the Healthcare Workforce Act, to permanently exempt health care professionals from the $100,000 H-1B fee so health care employers can recruit the physicians, IMGs, and other providers their communities need.
Congress is about two weeks away from adjourning for its August recess, and lawmakers are hoping to address several outstanding items before leaving Washington. When they return in September, they will have less than a month in session before attention shifts again to the midterm elections. While there are some areas of bipartisanship, there are also points of intraparty tension, particularly between the House and Senate. The key question is whether Congress can come together to fund the government by September 30, likely through a continuing resolution that extends beyond the midterms and avoids another painful government shutdown.
Last month, AAPPR leaders took to Capitol Hill to meet with lawmakers to discuss key issues impacting provider recruitment and retention. We met with over 50 congressional offices across the political spectrum to highlight four pieces of bipartisan legislation that would meaningful address many of the challenges faced by healthcare employers, providers, and importantly, patients. These included addressing Medicare reimbursement issues, investing in Graduate Medical Education (GME), exempting healthcare workers from the $100,000 H-1B fee, and reauthorizing the Conrad 30 program.
This was a great opportunity to raise awareness about physician recruitment and other provider issues, and to begin building relationships with offices where our members live and work. There will be more exciting opportunities like this in the future an we encourage you to get involved.
The bipartisan Patients First Act was introduced by Reps. John Joyce (R-OH), Greg Murphy (R-NC), and Kim Schrier (D-WA), the respective chairs of the Republican and Democratic Doctors Caucuses in Congress, as an effort to update Medicare physician payment policy and strengthen access to care. The bill is especially relevant because it addresses some of the financial and administrative pressures that can make it harder for physicians to remain in practice, particularly in independent, rural, and underserved settings.
The proposal would tie physician payment more closely to the cost of providing care, invest in primary care, simplify quality reporting, and support participation in value-based care models. AAPPR is closely reviewing the legislation and will follow up with more details and potential next steps.
The Trump Administration recently issued a final rule replacing the long-standing “duration of status” framework for certain visa holders, including J-1 exchange visitors, with fixed periods of admission and a formal extension process through federal immigration authorities. While the rule is framed by DHS as a way to increase oversight, medical and recruitment organizations have raised concerns about what it could mean for the physician workforce, especially for international medical graduates who train and practice in the United States.
From a recruitment and retention perspective, the concern is that new extension requirements during residency or fellowship could add uncertainty, paperwork, and possible interruptions in training or clinical service, making it harder for programs to attract and keep the physicians their patients rely on. AAPPR is reviewing the final rule and will follow up with additional information. Please reach out if you have any questions.
On June 25, 2026, 38 AAPPR member volunteers brought their expertise where it matters most – directly to Congress. In a series of meetings across House and Senate offices, physician and provider recruitment professionals made the case that workforce policy is patient access policy, and that AAPPR members are the experts policymakers need to know.
AAPPR members are directly involved in ensuring patients can access care by helping health care organizations recruit and retain the physicians and providers their communities need.
Advocacy Day was designed to elevate AAPPR’s voice at the federal level and to position our members as credible, on-the-ground resources for congressional offices navigating some of the most consequential health care workforce decisions in years.
Members didn’t just arrive with policy priorities. They arrived with stories: unfilled positions, recruitment pipelines that work, communities still waiting for the specialists they need. That specificity is what makes AAPPR’s voice distinct.
Across the day, members held 55 congressional meetings – a collective effort that put physician workforce issues in front of a broad cross-section of legislators.
Conversations were grounded in the real barriers members face every day:
By the end of each meeting, AAPPR’s goal was for congressional staff to leave knowing four things:
Advocacy Day is the beginning of an ongoing commitment. The relationships built on June 25 will be cultivated over time, and AAPPR will continue to serve as a resource to policymakers as they shape the future of health care delivery.
If you attended – thank you. If you didn’t, stay engaged. Follow AAPPR’s advocacy updates and look for future opportunities to add your voice to the issues that define this profession.
Stay connected with AAPPR’s advocacy efforts at aappr.org/government-affairs/.
The Association for Advancing Physician and Provider Recruitment (AAPPR) has released its 2026 Recruitment Team Professional Compensation Benchmarking Report, revealing significant gains in compensation and retention among physician and provider recruitment professionals, and making a compelling case for why hospital and health system leaders should be doubling down on their in-house recruitment teams, not replacing them with technology.
According to the report, median recruiter compensation increased 10.4% in 2025 to $100,420 – the highest level reported since AAPPR began tracking the data. Recruiter turnover also fell to an average of 12.1% in 2025, down from approximately 20% in recent years, suggesting that institutional knowledge is being built and retained inside organizations that are choosing to invest in their people. These findings are further supported by AAPPR’s The Heart Behind the Hire report, which found that 87% of in-house physician recruiters feel genuinely called to do this work. That statistic underscores that recruitment is not a transactional function technology can replicate, but a relationship-driven profession rooted in purpose.
“Physician and provider recruitment professionals play a vital role in helping healthcare organizations ensure patients have access to care,” said Carey Goryl, CEO of AAPPR. “As demand for physicians and advanced practice providers continues to outpace supply in many communities, recruitment teams are being asked to do increasingly complex and important work. AI can support a recruiter’s workflow, but it cannot replicate the trust a recruiter builds with a physician candidate over months, or the deep community knowledge that comes from years inside an organization. Health system leaders who want to win the physician recruitment challenge need to focus on building their teams, pouring into their teams, and giving them the right tools and compensation to succeed. This year’s findings suggest organizations are doing exactly that – and it’s working.
The report includes two chapters highlighting survey results related to physician recruitment profiles and compensation levels. The first chapter, “Recruitment Professional Profile,” provides data on demographic information, including recruitment professionals’ roles, education levels, years of experience, work arrangements and responsibilities. A total of 428 internal physician and provider recruitment professionals participated in this survey.
The second chapter, “Recruitment Professional Compensation,” examines compensation levels of recruitment professionals by their role, experience, education level, location desirability and remote work status. Of the 428 participants, 396 provided compensation data.
Some notable findings include:
The industry-level data in AAPPR’s benchmarking surveys helps recruitment professionals and departments establish target productivity levels, set goals and expectations, evaluate compensation competitiveness and grow their teams.
Organizations that participate in annual surveys gain free access to AAPPR’s Benchmarking Portal, where they can run custom benchmark comparisons to organizations and departments similar to their own. The Benchmarking Portal includes time to fill and compensation calculators and enables users to compare a range of data, including organizational profiles, search information, recruiter profile data and recruiter compensation figures, helping them make more informed decisions.
The complete 2026 AAPPR Recruitment Team Professional Compensation Benchmarking Report is available to organizations for sale online. To order, visit https://aappr.org/research/benchmarking/. The Heart Behind the Hire Report is also available online, free of charge at: https://aappr.org/research/surveys-reports/
The Association for Advancing Physician and Provider Recruitment (AAPPR) is the mission-aligned authority on addressing clinical workforce shortages and expanding access to care. For more than 30 years, AAPPR has connected and supported physician and provider recruitment professionals who serve as strategic partners within hospitals and health systems nationwide. Today, AAPPR represents over 2,700 members. Fully integrated into their organizations, AAPPR members lead the full recruitment continuum, designing hiring, onboarding, and retention strategies that mitigate vacancy impacts and strengthen care delivery. Guided by our RECRUIT values – Respect, Equity, Collaboration, Responsibility, Understanding, Inclusion, and Trust – AAPPR and its members cultivate a diverse, data-informed workforce dedicated to ensuring equitable access to care. To learn more or to become an organizational member of AAPPR, please visit https://aappr.org/join-now.
This month’s update highlights ongoing uncertainty around the $100,000 H-1B fee, which was struck down in court but remains temporarily in effect during appeal. It also covers potential changes to graduate loan caps, particularly for nursing programs, and new bipartisan legislation aimed at expanding physician placement in underserved areas. Additionally, Congress continues to support key workforce programs that strengthen healthcare access and provider training nationwide.
On June 8, a federal district court in Massachusetts vacated the federal policy implementing the $100,000 fee on certain new H-1B petitions, finding that the fee exceeded executive authority and was unlawful under the Administrative Procedure Act. The decision was a significant development for health care employers, physician and provider recruitment teams, and international medical graduates because the fee had created a major cost barrier for H-1B sponsorship in an already constrained workforce environment.
However, the practical effect of that ruling is now temporarily on hold. On June 12, the Massachusetts district court temporarily stayed its June 8 order while the First Circuit Court of Appeals considers the government’s expected request to keep the fee in place during the appeal.The government must file its stay request with the First Circuit by June 18 for the district court’s pause to remain in effect.
For now, USCIS may still require the $100,000 fee for approval of H-1B petitions that are filed. The next key milestone is the First Circuit’s decision on whether USCIS may continue collecting the fee while the government’s appeal proceeds.
AAPPR will continue to closely monitor this case and support efforts to permanently exempt health care professionals from the $100,000 H-1B fee so health care employers can recruit the physicians, IMGs, and other providers their communities need.
As you may know from last month’s update, the Education Department finalized a rule that caps most graduate borrowing at $20,500 annually and ends Grad PLUS in July. A recent House budget amendment could give advanced nursing programs a path back to higher federal borrowing limits by requiring the department to treat them as professional degree programs. If enacted, master’s- and doctoral-level nursing students could borrow up to $50,000 annually.
This would be a potential course correction for the nursing workforce, hospitals, and other organizations, but it is not final. The provision still must clear the House, Senate, and be signed into law, and it would not take effect until October 1 at the earliest. That means students and schools may still face several months of uncertainty, and financial aid offices could need to adjust midyear. Recruiters should stay engaged with nursing schools, especially in rural and underserved areas where workforce pipelines are already strained. AAPPR will continue tracking developments as the budget process moves forward.
AAPPR is supporting the bipartisan Physician Workforce Optimization Act, introduced by Sen. Kevin Cramer (R-ND) and Sen. Amy Klobuchar (D-MN), to strengthen the Conrad 30 J-1 Visa Waiver Program and help more communities access the physicians they need.
The bill would expand flex waivers from 10 to 15 per state and create a national secondary match portal to better connect J-1 physicians with states that have unused waiver slots. These updates would give states and healthcare organizations more flexibility to place physicians in rural and underserved communities where recruitment needs remain urgent.
For AAPPR members, this legislation is a practical step toward improving physician placement, supporting workforce planning, and strengthening access to care nationwide. AAPPR appreciates Sen. Cramer and Sen. Klobuchar’s bipartisan leadership and looks forward to continued work on policies that advance physician recruitment.
The House Appropriations Committee’s approval of the FY 2027 Labor, Health and Human Services, Education, and Related Agencies appropriations bill marks an important step in the annual federal funding process. Although the bill reduces overall HHS funding from last year’s enacted level, it continues to support key HRSA health workforce programs that help train clinicians and expand access to care. These include the Children’s Hospitals Graduate Medical Education (CHGME) program, the National Health Service Corps, and Title VII and Title VIII workforce programs.
At a high level, these programs help ensure that communities have access to the health professionals they need. CHGME supports the pediatric workforce by helping children’s hospitals train doctors and dentists. The National Health Service Corps helps bring primary care, dental, and behavioral health providers to communities with provider shortages. Together with Title VII and VIII programs, continued funding for these efforts would support the next generation of health professionals and help improve access to care nationwide, especially in rural and underserved areas.
The most important investment you can make in a rapidly changing healthcare landscape is in yourself. I’ve been thinking about that a lot lately—not as a tagline, but as something I’ve had to genuinely remind myself of throughout my career in physician and provider recruitment. Having spent years in HR, immigration, and healthcare management before stepping fully into Clinician Recruitment, I’ve experienced firsthand just how quickly this landscape can shift.
There have been moments when I felt completely on top of my game—clear on strategy, confident in the room, grounded in the data. And there have also been moments—usually when the industry moved faster than I expected or when a peer introduced an approach I’d never encountered—when I had to ask myself: am I keeping up?
That tension isn’t a weakness. It’s a signal that you care about doing this work well—and it’s exactly what makes professional development essential.
Recruitment has never been static, but the pace and complexity of change today are something else entirely.
We are facing intensified competition for physician and advanced practice clinician (APP) talent, persistent financial pressures, and leadership turnover that require us to constantly rebuild relationships and reestablish trust. Increasingly, the ability to effectively recruit and retain both physicians and APPs has become a true differentiator for health systems—impacting access, care delivery models, and long-term sustainability.
For those of us in academic healthcare, the environment is even more complex.
Shifts in clinical reimbursement, cost containment pressures, and ongoing uncertainty around clinical research funding are shaping how organizations make hiring decisions. Academic institutions, in particular, are navigating difficult tradeoffs—balancing clinical productivity with research missions, aligning recruitment with funding realities, and making strategic choices about where to invest.
For Clinician recruitment professionals, that means our work sits at the intersection of competing priorities:
– Clinical demand vs. research investment
– Physician hiring vs. APP workforce optimization
– Growth goals vs. financial constraints
These dynamics influence not just how we recruit, but how we position opportunities, advise leaders, and guide candidates through increasingly complex decisions. Add in the continued evolution of AI and technology, and it becomes even clearer: the recruiter role today is not transactional. It is strategic.
When we talk about professional development, it’s easy to think in terms of certifications or continuing education credits. Those matter—but the real value is deeper.
When I’ve invested intentionally in my own development. The biggest shift wasn’t just knowledge. It was how I showed up. I became:
– Less reactive and more strategic
– Better able to connect workforce data, funding realities, and clinician needs
– More confident advising leadership—not just executing requests
This is especially important as clinician recruitment becomes central to organizational strategy. How we recruit and deploy physicians and APPs directly impacts access to care, financial performance, and the patient experience.
That shift from execution to influence is where career acceleration happens. And it’s built over time through consistent investment.
In my experience, growth happens most effectively in three areas:
The strongest recruiters anticipate change. Developing skills in workforce planning, data interpretation, and care model strategy allows you to lead conversations rather than react to them.
The most effective recruiters remain deeply curious—about compensation trends, specialty shortages, APP utilization, and evolving healthcare funding. That curiosity is what keeps you relevant and informed.
Whether leadership roles, committee involvement, or strategic initiatives—tend to go to those who have already invested in their growth. Preparation creates visibility.
One of the reasons I pursued board service is that I strongly believe in AAPPR’s strategic goal for the Clinician Recruitment Industry. The resources are practical, relevant, and directly aligned to the skills needed in today’s clinician recruitment environment. The CPRP credential provides a comprehensive framework grounded in AAPPR’s competency model. It strengthens your ability to navigate the full recruitment lifecycle—from sourcing to onboarding to retention—while elevating your credibility and confidence.
For many, the challenge isn’t understanding the value of professional development—it’s making space for it.
One way to approach this is to align development with organizational priorities. A strong recruitment function directly impacts:
– Days-to-fill for critical physician and APP roles
– Access to care and patient outcomes
– Provider retention and engagement
– Financial performance tied to clinician productivity
And it doesn’t have to start big. A webinar. A conversation. A mentorship cohort. Small, consistent steps matter. The challenges we’re facing—financial pressures, evolving care models, shifting research funding, and the growing importance of team-based care—are reshaping our profession. Those who will lead in this environment are the ones who continue to learn, stay curious, and invest in their own development. APPR gives us the tools, the community, and the structure to do exactly that. The next step is deciding to take advantage of it.
I’m grateful for what this organization has given me as both a professional and a leader. I hope you’ll lean into everything it offers—and I’d love to hear how you’re investing in your own growth. Let’s keep learning together.
Last Updated: June 10, 2026
On June 8th, the U.S. District Court for the District of Massachusetts vacated the $100,000 fee on new H-1B petitions, ruling it exceeded executive authority and violated the Administrative Procedure Act. This is a welcome but potentially temporary development. As appeal is expected and recruitment teams should stand by and consult with your immigration counsel before changing filing strategies.
In September 2025, a presidential proclamation imposed a $100,000 payment requirement on new H-1B visa petitions filed on or after September 21, 2025. The fee was a one-time charge at filing for those not currently in country, with potential for exceptions if deemed in the national interest, which the Administration never exercised. It did not apply to renewals, previously filed petitions, or current H-1B holders. You can read previous updates on the H-1B policy here.
International medical graduates (IMGs) make up about one in four U.S. physicians and disproportionately serve underserved communities. The American Hospital Association found that more than 70% of hospitals expected the fee to impact patient care, 64% planned to pause or limit H-1B recruitment, and 57% of affected positions were clinical roles. For many rural and safety net facilities, H-1B sponsorship is essential for maintaining access to primary care and specialty services.
U.S. District Judge Leo Sorokin sided with 20 states, finding the fee constituted a tax on H-1B petitions not directed by Congress. The court vacated the policy as exceeding executive authority and violating the APA.
While the ruling is a significant development, the policy landscape remains unsettled. The federal government is expected to appeal the Massachusetts decision, and other litigation over the $100,000 H-1B fee remains pending in different federal courts.
AAPPR continues to support the bipartisan H-1Bs for Physicians and the Healthcare Workforce Act, which would exempt health care professionals from the $100,000 fee. Legislative action remains essential to provide meaningful relief regardless of litigation outcomes. Recruitment teams should continue to monitor this space closely, preserve documentation of any pending applications or fees paid, and monitor DHS/USCIS for guidance and court developments.
Please reach out if you have any questions.
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